PRIVACY POLICY

PT. OCEANO GLOBAL MANDIRI MARITIM
Website: www.ogmmgroup.co.id
Effective Date: 7 September 2026
Last Updated: 3 September 2026

1. INTRODUCTION

PT. Oceano Global Mandiri Maritim (“OGMM”, “Company”, “we”, “us”, or “our”) is committed to protecting the privacy and personal information of our customers, business partners, vessel owners, ship managers, Masters, crew members, employees, contractors, suppliers, visitors, and other individuals who interact with us.

As a ship agency and maritime services company operating in Indonesia and internationally, we may process personal information as part of providing vessel agency, port, logistics, crew, documentation, and related maritime services.

This Privacy Policy explains how we collect, use, disclose, store, protect, and otherwise process Personal Data.

We aim to process Personal Data responsibly, transparently, and in accordance with applicable data protection and privacy laws, including Law of the Republic of Indonesia No. 27 of 2022 concerning Personal Data Protection (“PDP Law”), where applicable. The PDP Law establishes principles concerning lawful, limited, transparent, secure, and accountable processing of Personal Data.

2. WHO WE ARE

PT. Oceano Global Mandiri Maritim

Address:
Rukan Pesona View Blok A5
Depok, West Java, Indonesia

Email: agency@ogmmgroup.co.id

Website: www.ogmmgroup.co.id

For privacy-related questions or requests concerning your Personal Data, you may contact us using the email address above.

3. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to Personal Data processed by OGMM in connection with:

• Ship agency services;
• Vessel husbandry services;
• Port call coordination;
• Crew changes and crew-related services;
• Port clearance and documentation;
• Customs and immigration procedures;
• Transportation and accommodation arrangements;
• Medical assistance and emergency coordination;
• Cargo and logistics coordination;
• Communication with vessel owners and ship managers;
• Communication with Masters and crew;
• Communication with port and government authorities;
• Supplier and contractor management;
• Customer and business relationship management;
• Our website and online communications; and
• Other maritime and commercial activities conducted by OGMM.

4. PERSONAL DATA WE MAY COLLECT

Depending on the services provided and the circumstances, we may collect and process the following categories of Personal Data.

4.1 Identification Information

This may include:

• Full name;
• Date and place of birth, where required;
• Nationality;
• Gender;
• Passport details;
• Seafarer’s identification or seaman’s book details;
• Visa and immigration information;
• Identification document details; and
• Other information necessary for identification and regulatory purposes.

4.2 Contact Information

This may include:

• Email address;
• Telephone or mobile number;
• Business address;
• Residential address, where necessary;
• Emergency contact information; and
• Professional contact information.

4.3 Vessel and Crew Information

In connection with ship agency operations, we may process:

• Vessel name;
• IMO number;
• Vessel schedule;
• Port of arrival and departure;
• Crew list;
• Crew position/rank;
• Crew nationality;
• Passport and travel information;
• Sign-on and sign-off information;
• Flight and transportation details;
• Accommodation information;
• Shore leave information; and
• Other information necessary to facilitate vessel and crew operations.

4.4 Health and Medical Information

Where necessary for legitimate maritime, operational, emergency, insurance, immigration, or safety purposes, we may process limited health or medical information.

Because health information may constitute specific/sensitive Personal Data under applicable law, we will only process such information when there is an appropriate lawful basis and when reasonably necessary for the relevant purpose.

4.5 Financial and Transaction Information

We may process:

• Billing information;
• Invoice information;
• Payment records;
• Bank details where necessary;
• Purchase orders;
• Service orders;
• Contract information; and
• Other information related to commercial transactions.

4.6 Communication Information

We may retain records of communications with you, including:

• Emails;
• Letters;
• Telephone communications;
• Business correspondence;
• Service requests;
• Operational instructions; and
• Other communications related to our services.

5. HOW WE COLLECT PERSONAL DATA

We may obtain Personal Data directly or indirectly from:

• Vessel owners;
• Ship managers;
• Charterers;
• Masters;
• Crew members;
• Manning agencies;
• Customers;
• Business partners;
• Port authorities;
• Harbour Masters;
• Customs authorities;
• Immigration authorities;
• Quarantine and health authorities;
• Government agencies;
• Terminal operators;
• Pilots and tugboat providers;
• Transportation providers;
• Hotels and accommodation providers;
• Medical service providers;
• Suppliers and contractors;
• Our website;
• Email and other communication channels; and
• Other lawful sources.

In many ship agency situations, Personal Data may be provided to us by a vessel owner, ship manager, Master, crewing company, or another authorized representative rather than directly by the individual concerned.

6. PURPOSES OF PROCESSING PERSONAL DATA

OGMM may process Personal Data for purposes including, but not limited to:

6.1 Vessel Agency Operations

• Coordinating vessel arrival and departure;
• Preparing and processing port documentation;
• Arranging berthing and unberthing;
• Coordinating pilotage and tugboat services;
• Coordinating port services;
• Preparing port clearance documentation;
• Communicating with relevant maritime authorities;
• Supporting vessel turnaround operations; and
• Providing vessel husbandry services.

6.2 Crew Services

We may process crew information for:

• Crew sign-on and sign-off;
• Crew changes;
• Immigration and visa processing;
• Customs and port formalities;
• Airport and transportation arrangements;
• Hotel accommodation;
• Medical assistance;
• Emergency response;
• Shore leave arrangements; and
• Other services requested by the vessel owner, ship manager, or authorized representative.

6.3 Regulatory Compliance

Personal Data may be processed to comply with:

• Maritime regulations;
• Port regulations;
• Immigration requirements;
• Customs requirements;
• Quarantine and health requirements;
• Security requirements;
• Government reporting obligations; and
• Other applicable laws and regulations.

6.4 Commercial and Administrative Purposes

We may also process Personal Data for:

• Preparing quotations;
• Issuing invoices;
• Processing payments;
• Managing contracts;
• Maintaining customer records;
• Managing suppliers;
• Responding to inquiries;
• Managing claims and disputes;
• Accounting and auditing;
• Risk management; and
• Maintaining business records.

7. LEGAL BASIS FOR PROCESSING

Where applicable, OGMM will process Personal Data based on an appropriate lawful basis.

Depending on the circumstances, this may include:

1. Consent provided by the Data Subject;
2. Performance of a contract or taking steps at the request of the Data Subject before entering into a contract;
3. Compliance with legal obligations;
4. Protection of vital interests, including situations involving health, safety, or emergencies;
5. Performance of a task in the public interest or exercise of official authority, where applicable; or
6. Legitimate interests, provided that such interests do not override the rights and interests of the Data Subject.

These bases are consistent with the lawful processing grounds recognized under Article 20 of Indonesia’s PDP Law.

8. PROCESSING OF CREW AND SEAFARER DATA

Due to the nature of our business, OGMM may be required to process Personal Data belonging to Masters, officers, crew members, seafarers, and other vessel personnel.

Such information may be necessary to facilitate:

• Port entry and clearance;
• Immigration procedures;
• Crew changes;
• Visa processing;
• Transportation;
• Accommodation;
• Medical assistance;
• Emergency response;
• Security procedures;
• Government reporting; and
• Other vessel-related operational requirements.

Where Personal Data is provided to OGMM by a vessel owner, ship manager, crewing agency, or other organization, that organization should ensure that it has an appropriate legal basis and authority to provide the information to OGMM.

9. DISCLOSURE OF PERSONAL DATA

OGMM may disclose Personal Data where reasonably necessary for the purposes described in this Privacy Policy.

Recipients may include:

• Vessel owners;
• Ship managers;
• Charterers;
• Masters;
• Manning agencies;
• Port authorities;
• Harbour Masters;
• Customs authorities;
• Immigration authorities;
• Quarantine and health authorities;
• Maritime authorities;
• Terminal operators;
• Pilotage companies;
• Tugboat operators;
• Transportation providers;
• Airlines;
• Hotels;
• Medical providers;
• Security service providers;
• Insurance companies;
• Banks and payment providers;
• Professional advisers;
• IT and technology service providers;
• Government authorities; and
• Other authorized service providers.

We will not sell Personal Data to third parties.

10. INTERNATIONAL DATA TRANSFERS

As OGMM provides maritime services in Indonesia and internationally, Personal Data may be transferred to, stored in, or accessed from jurisdictions outside Indonesia.

Such transfers may be necessary to:

• Coordinate international vessel operations;
• Facilitate crew travel;
• Communicate with overseas ship owners or managers;
• Coordinate international port calls;
• Process immigration or travel requirements;
• Engage overseas service providers; or
• Fulfil contractual or operational requirements.

Where required by applicable law, OGMM will implement appropriate safeguards for international transfers of Personal Data.

Under Indonesia’s PDP Law, transfers of Personal Data outside Indonesia are subject to requirements concerning the adequacy of protection in the destination country and, where applicable, appropriate safeguards or consent.

11. DATA SECURITY

OGMM takes reasonable technical and organizational measures to protect Personal Data against:

• Unauthorized access;
• Unauthorized disclosure;
• Loss;
• Destruction;
• Alteration;
• Misuse;
• Unauthorized processing; and
• Other security risks.

We limit access to Personal Data to personnel and authorized parties who reasonably require such information to perform their duties or provide services.

However, no electronic communication, storage system, or transmission over the internet can be guaranteed to be completely secure.

12. DATA BREACH AND SECURITY INCIDENTS

In the event of a Personal Data security incident, OGMM will take reasonable steps to:

1. Identify and assess the incident;
2. Contain and mitigate its impact;
3. Investigate the circumstances;
4. Take appropriate corrective measures; and
5. Provide notifications where required by applicable law.

Under Indonesia’s PDP Law, where a Personal Data protection failure occurs, the Data Controller is required to provide written notification within 3 × 24 hours to the affected Data Subject and the relevant institution, subject to the requirements of the law.

13. DATA RETENTION

OGMM will retain Personal Data only for as long as reasonably necessary to fulfil the purposes for which it was collected, including:

• Providing maritime and ship agency services;
• Maintaining operational records;
• Complying with legal and regulatory obligations;
• Maintaining accounting and financial records;
• Resolving disputes;
• Protecting our legal rights;
• Meeting contractual requirements; and
• Maintaining appropriate business records.

When Personal Data is no longer required, we will take reasonable measures to delete, destroy, anonymize, or otherwise dispose of it in accordance with applicable law and our internal retention procedures.

14. YOUR RIGHTS AS A DATA SUBJECT

Subject to applicable law, you may have the right to:

• Obtain information regarding the processing of your Personal Data;
• Access your Personal Data;
• Obtain a copy of your Personal Data;
• Correct or update inaccurate or incomplete Personal Data;
• Request deletion or destruction of Personal Data where legally permitted;
• Withdraw consent where processing is based on consent;
• Request restriction or suspension of processing in applicable circumstances;
• Object to certain processing activities;
• Request transfer of Personal Data in circumstances provided by applicable law; and
• Submit a complaint regarding the processing of your Personal Data.

Indonesia’s PDP Law expressly recognizes rights including access, correction, deletion/destruction, withdrawal of consent, restriction of processing, and data portability, subject to applicable legal limitations.

15. WITHDRAWAL OF CONSENT

Where OGMM processes Personal Data based on your consent, you may withdraw that consent by contacting us at:

Email: agency@ogmmgroup.co.id

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Please note that certain Personal Data may need to continue to be processed where processing is required by law, necessary to perform a contract, necessary to protect vital interests, or otherwise permitted under applicable law.

16. ACCURACY OF PERSONAL DATA

We expect Personal Data provided to OGMM to be accurate, complete, and up to date.

If you become aware that Personal Data held by us is inaccurate or incomplete, please contact us so that appropriate corrections can be made.

17. CHILDREN’S PERSONAL DATA

Our services are primarily directed toward businesses, maritime professionals, vessel personnel, and other adults.

We do not intentionally collect children’s Personal Data unless it is legitimately required for a specific operational or legal purpose.

Where the processing of children’s Personal Data is required, we will apply appropriate safeguards and comply with applicable legal requirements.

18. THIRD-PARTY WEBSITES AND SERVICES

Our website may contain links to third-party websites or services.

OGMM is not responsible for the privacy practices, security, or content of third-party websites.

We recommend that users review the privacy policies of third-party websites before providing Personal Data.

19. COOKIES

Our website may use cookies and similar technologies for purposes such as:

• Website functionality;
• Security;
• Performance monitoring;
• Website analytics;
• Improving user experience; and
• Understanding website traffic.

You may configure your browser to block or delete cookies. Certain website features may not function properly if cookies are disabled.

20. CONFIDENTIALITY OF MARITIME AND COMMERCIAL INFORMATION

In addition to Personal Data, OGMM recognizes that ship agency operations involve confidential commercial and operational information.

We will take reasonable measures to maintain the confidentiality of information relating to:

• Vessel operations;
• Port calls;
• Crew;
• Cargo;
• Customers;
• Commercial arrangements;
• Operational instructions;
• Security-related information; and
• Other confidential business information.

Such information will only be disclosed where authorized, necessary for the provision of services, required by applicable law, or otherwise permitted by contract.

21. CHANGES TO THIS PRIVACY POLICY

OGMM may update this Privacy Policy periodically to reflect:

• Changes in applicable laws;
• Changes in our services;
• Changes in our business operations;
• Changes in technology; or
• Changes in our data processing practices.

The updated Privacy Policy will be published on our website, and the “Last Updated” date will be revised accordingly.

22. CONTACT US

If you have questions, concerns, complaints, or requests regarding this Privacy Policy or the processing of your Personal Data, please contact:

PT. OCEANO GLOBAL MANDIRI MARITIM

Address:
Rukan Pesona View Blok A5
Depok, West Java, Indonesia

Email:
agency@ogmmgroup.co.id

Website:
www.ogmmgroup.co.id

Subject: Privacy / Personal Data Request

We will review and respond to privacy requests in accordance with applicable laws and regulations.

23. GOVERNING LAW

This Privacy Policy shall be interpreted and applied in accordance with the laws and regulations applicable to OGMM and its processing activities.

For processing activities conducted in Indonesia, this includes, where applicable, Law of the Republic of Indonesia No. 27 of 2022 concerning Personal Data Protection, together with other applicable Indonesian laws and regulations.

For international operations, additional privacy and data protection laws may apply depending on the jurisdiction, location of the Data Subject, nature of the services, and applicable contractual or regulatory requirements. The Indonesian PDP Law itself has provisions concerning certain processing outside Indonesia where it has legal consequences in Indonesia or for Indonesian citizens abroad.