1. Introduction

We recognize that Personal Data is an important matter that must be properly protected. Accordingly, through this Privacy Notice, PT Malindo Feedmill Tbk together with all of its subsidiaries and affiliates (“Malindo Group”, “We”, “Us”) is committed to protecting the privacy and security of the Personal Data of every individual who interacts with us, including employees, job applicants, customers, suppliers, contractors, and other business partners (“You”).

As part of our responsibility to implement transparent and ethical business practices, Malindo Group ensures that all processing of Personal Data is carried out in compliance with Law No. 27 of 2022 on Personal Data Protection (“PDP Law”) and its implementing regulations applicable in Indonesia.

This Privacy Notice aims to clearly explain how We collect, use, store, protect, and delete Your Personal Data, as well as to inform You of the rights You have in relation to the management of such Personal Data.

This Privacy Notice is provided solely for informational purposes and is not intended to constitute an agreement or contract that creates additional legal obligations beyond those stipulated under applicable laws and regulations.

2. Scope and Application

This Notice applies to all Personal Data processing activities carried out by Malindo Group, including but not limited to business activities in the following fields:

• Animal Feed Industry (Feedmill)
• Poultry Breeding
• Poultry Broiler Farming
• Poultry Slaughtering and Meat Processing
• Wholesale Trade of Live Animals
• Wholesale Trade of Chicken Meat and Processed Chicken Products
• Corn Milling, Drying, and Cleaning
• Other Business Activities Conducted by Entities within the Malindo Group in Indonesia

This policy also covers all divisions or functions that process Personal Data, including but not limited to Human Resources & General Affairs (HRGA), Legal, Marketing, Purchasing, Information Technology (IT), Credit Control, and other authorized units.

3. Types of Personal Data We Collect

“Personal Data” refers to information relating to an identified or identifiable individual, whether obtained through electronic or non-electronic systems.

• Identity Data: full name, place/date of birth, gender, identification numbers (KTP, NPWP, passport), nationality.
• Contact Data: residential address, phone number, email address.
• Employment Data: employment history, position, attendance records, training records, performance evaluations, compensation data.
• Financial Data: bank account information, payment details, transaction records.
• Legal and Contractual Data: agreements, legal correspondence, supporting documents.
• Access and Technology Data: IP addresses, login data, device information, network activity, CCTV recordings.

Provision of Personal Data is voluntary. However, failure to provide required Personal Data may limit the services We provide.

4. How We Collect Personal Data

1. Personal Data provided directly by You;
2. Personal Data collected automatically through systems, networks, applications, or websites;
3. Personal Data obtained from authorized third parties.

All collection processes are conducted lawfully, transparently, and solely for legitimate operational purposes.

5. Purposes of Personal Data Processing

1. Employment administration and labor relations;
2. Execution of business contracts and commercial relationships;
3. Legal and regulatory compliance;
4. Security and internal control;
5. Business communication and marketing activities.

6. Legal Basis for Processing Personal Data

• Your consent;
• Performance of contracts or legal relationships;
• Compliance with legal obligations; or
• Legitimate interests of the Company.

7. Data Storage and Security

We implement reasonable technical and organizational measures to protect Personal Data from unauthorized access, use, or disclosure.

8. Data Retention, Deletion, and Destruction

Personal Data will be retained only as long as necessary and will be securely deleted, destroyed, or anonymized after the retention period expires.

9. Disclosure and Transfer of Personal Data

• Entities within the Malindo Group;
• Third-party service providers;
• Government authorities as required by law;
• Parent companies or international affiliates with adequate safeguards.

10. Cross-Border Transfer of Personal Data

Personal Data may be transferred outside Indonesia in compliance with applicable laws and with appropriate safeguards.

11. Your Rights

1. Access and information;
2. Correction and deletion;
3. Withdrawal of consent;
4. Objection or restriction of processing;
5. Complaint submission;
6. Data portability.

12. How to Contact Us

PT Malindo Feedmill Tbk
Komplek Golden Plaza Blok G No. 17–22 Jl. R.S. Fatmawati No. 15 Jakarta Selatan 12420, Indonesia
Email: legal@malindofeedmill.com
Phone: 021 766 1727

13. Updates to This Notice

This Privacy Notice may be updated from time to time. The latest version published on the official website shall prevail.