Privacy Policy

Effective Date: 2 December 2019

(Adjustments have been made since the enactment of Law of the Republic of Indonesia Number 27 of 2022 concerning Personal Data Protection.)

PT Bangun Digital Nusantara (hereinafter referred to as SLTR group) is fully aware that Personal Data is the most important asset for you, so SLTR group is committed to maintaining the confidentiality and protection of your Personal Data, related to the use of products and/or services offered by SLTR group.

SLTR group implements policies and best practices aimed at protecting and maintaining the privacy and security of your Personal Data in accordance with the Personal Data Protection Law, for data processing related to the use of SLTR group products and/or services (hereinafter referred to as the “Privacy Policy”).

Furthermore, this Privacy Policy applies to all owners of Personal Data (Personal Data Subjects), related to the use of products and/or services (hereinafter referred to as “you”).

1. Purpose and Scope of the Privacy Policy

This Privacy Policy regulates the policies and practices implemented by SLTR group as Controller of Personal Data in obtaining, correcting, updating, distributing, displaying, announcing, transferring, disclosing, deleting, and destroying (hereinafter referred to as “Processing”) your Personal Data, related to the use of products and/or services, includes:

a. Gamefinity (PT. Bangun Media Integra)

Game media and creative lab for the younger generation, committed to supporting the gaming and e-sports industry in Indonesia.

b. Pao Play

Online gaming platforms offer a diverse collection of mini casual games designed for players of all ages.

c. Solitaire Reward (PT. Bangun Digital Nusantara)

Aggregator of various digital products that provides consumers with safe and smooth transactions, consisting of:

E-Commerce;
Merchant;
H2H; and
Biller.
Harsa

lifestyle portfolio committed to providing an enjoyable sporting experience, currently focused on the billiards industry.

d. Obra (PT. Obra Kreasi Bersama)

A software development and digital marketing agency, experienced in varied projects that have pushed the boundaries of technology and innovation.

e. Horus (PT. Horus Solusi Teknologi)

A versatile payment gateway offering solutions for online transactions, including disbursement, QR code payments, virtual accounts (VA), and bank transfers.

All services hereinafter referred to as “Services”.

2. Rights of Personal Data Subjects

As a Personal Data Subject, you have the right to:

Obtain information regarding clarity of identity, basis of legal interest, purpose of requesting and using Personal Data, and accountability of the party requesting Personal Data.
Complete, update and/or correct errors and/or inaccuracies in Personal Data about yourself in accordance with the purpose of processing Personal Data.
Withdraw consent to the processing of Personal Data about yourself that has been given to the Personal Data Controller.
File an objection to decision-making actions that are based solely on automatic processing, including profiling, which give rise to legal consequences or have a significant impact on the Personal Data Subject.
Suspend or limit the processing of Personal Data proportionately according to the purposes for which the Personal Data is processed.
Other rights of Personal Data Subjects related to the processing of Personal Data refer to the applicable laws and regulations.

3. Purpose of Processing Personal Data

In processing Personal Data belonging to Personal Data Subjects, SLTR group has the following objectives:

To carry out Know Your Customer (KYC) principles and provide personalization to Personal Data Subjects regarding the use of services provided by SLTR group.
To carry out statutory regulations.
To carry out troubleshooting related to access to services.
For the marketing needs of the services and products offered by SLTR group, this includes sending promotions, new products, news, surveys and service-related updates.
To evaluate and update SLTR group service features on an ongoing basis.
For the needs of processing Personal Data to produce Personal Data Subject profile data.
To offer advertisements or promotions or offers from other parties who work with SLTR group.

4. Personal Data Processed by SLTR group

SLTR group obtains and collects information that identifies and/or can be identified separately or combined with other information either directly or indirectly through electronic and/or non-electronic systems related to that information which in this case is limited to Services.

Personal data collected by SLTR group can be provided by Personal Data Subjects directly or from third parties. SLTR group will collect Personal Data in various forms of purposes, including those permitted by the laws and regulations in force in the Republic of Indonesia.

Your Personal Data that will be collected in the implementation of this Service include:

Personal Data required by SLTR group to provide Services, includes general and specific Personal Data as follows:
1. General data:

1. - Full name.
  - Address.
  - Place and date of birth.
  - Gender.
  - Citizenship.
  - Work.
  - Education.
  - Position.
  - National Identity Number / Passport / Child Parent Card / Student Card,
  - Mobile phone number,
  - Office/home phone number,
  - Personal Data combined to identify an individual.
2. Custom Data
  - Biometric data that can uniquely identify individuals but not limited to facial images, fingerprints, speech recordings.
  - Personal financial data but not limited to income and Taxpayer Identification Number.
  - Other data in accordance with the provisions of the applicable laws and regulations.
3. In addition, to the extent that other information, including personal profiles and/or identification, is associated with or incorporated in Personal Data, then that information is also Personal Data.

5. Storage of Personal Data

SLTR group is committed to keeping your Personal Data with the best protection as long as necessary to provide the Service. Some Personal Data can also be managed, processed and stored by third parties who work with SLTR group to maintain Service performance while still complying with obligations for effectiveness of supervision in accordance with applicable laws and regulations.

SLTR group will store Personal Data as mentioned above as long as it is needed to achieve the purpose why the Personal Data was collected, while you are still using the Service, or as long as the storage is required or permitted in accordance with SLTR group data retention policy and applicable laws and regulations in the Republic of Indonesia.

SLTR group will stop storing your Personal Data, or eliminate the ways in which Personal Data can be associated with you, immediately after reviewing the reasons or assumptions that the collection of Personal Data is no longer fulfilled by storing related Personal Data, and storage is no longer required for legal and business purposes.

6. Processing of Personal Data

Personal Data Subjects are responsible for maintaining the confidentiality of details of their Personal Data and must always maintain and be responsible for the security of the devices used to access SLTR group Services.

Personal Data Subjects, hereby acknowledges and if required by applicable Personal Data Protection regulations, expressly agrees that the Personal Data obtained and collected by SLTR group together with information related to relevant transactions, can be disclosed to authorized government agencies or other authorized parties based on laws or cooperation agreements, in terms of:

For the purposes of applicable law and/or in response to ongoing legal processes.
To protect the safety of SLTR group, the safety of Personal Data Subjects or the safety of other people or for legitimate interests in the context of:
- Law enforcement process.
- State administration.
- The interest in overseeing the financial services sector, monetary, payment systems, and financial system stability.
- Aggregate data and its processing are intended for the purposes of statistics and scientific research in the framework of state administration.
For the purposes of internal audit and/or digital forensics for criminal acts or violations of regulations or policies within SLTR group and affiliated companies.
If necessary in connection with legal proceedings filed against the Bank, officials, employees, affiliates or other related third parties.
To establish, implement, protect, maintain and enforce the legal rights of SLTR group.
In the context of processing personal data with SLTR group affiliated companies, SLTR group will only provide it in good faith in the form of a summary on the basis of legitimate interest before the law. In the event that SLTR group processes Personal Data that opens your personal profile, SLTR group will make the best efforts to protect the privacy of Personal Data, which is carried out after signing a confidentiality agreement, or additional approval by giving notice to you before your Personal Data is disclosed to affiliate of SLTR group and comply with the Privacy Policy and applicable laws and regulations, so that you can still ensure the confidentiality of your Personal Data.
To disclose your Personal Data to third parties, in order to ensure that SLTR group can provide services to you and assist the government of the Republic of Indonesia and its supporting institutions for the implementation of state functions.
For certain services, SLTR group needs to process sensitive Personal Data, such as information related to health, genetics, biometric identifiers, sexual orientation, and so on. To the extent that SLTR group requires your explicit consent to process this kind of data, SLTR group will provide details about the processing of Personal Data at the time of data collection and seek consent from you.

This disclosure is carried out by considering the security aspects so as to ensure that in the disclosure process no data is misused.

7. Correction and Updating of Personal Data

If you find an error in your Personal Data caused by inaccuracies or you need to update your Personal Data, then you can ask SLTR group to correct, complete and/or update your Personal Data which is in the management of the SLTR group, by contacting the communication channel set by the SLTR group.

In the event that there is an inaccuracy in providing your Personal Data, SLTR group has the right to stop services and/or transactions based on the knowledge and considerations of SLTR group.

SLTR group urges you to play an active role in ensuring the accuracy and updating of your Personal Data.

8. Deletion and Destruction of Personal Data

In accordance with applicable laws and regulations or SLTR group data retention policy or at your request / request, SLTR group can delete and/or destroy your Personal Data from the system so that the data no longer identifies you, except in the case of:

If it is necessary to retain Personal Data to fulfill legal obligations, the need for proof at a later date, tax, audit and accounting.
Personal Data is still in the retention period based on the applicable laws and regulations.

Regarding the need to destroy your Personal Data from the system (right to erase), a written application is required to be submitted to the SLTR group so that the Personal Data can be destroyed from the SLTR group system.

9. Personal Data Security

Confidentiality of your Personal Data is a priority for the SLTR group. SLTR group is committed to implementing the best efforts in order to protect and secure Personal Data to collection, processing, analysis, storage, disclosure, repair and deletion by unauthorized parties.

In the event of illegal activities on the confidentiality of Personal Data that are beyond the control of the SLTR group, SLTR group will immediately notify you at the first opportunity so as to reduce the risks arising from these incidents.

You are responsible for maintaining the confidentiality of your Personal Data information, including maintaining your username, password, email or OTP from anyone and for always maintaining and being responsible for the security of the device you use.

10. Acknowledgment and Approval

This Privacy Policy can be changed and/or updated as needed SLTR group urges you to always read carefully and check this page regularly to find out about changes to this policy.

In terms of using User Personal Data, you have the right to:

Request a copy of Personal Data (SLTR group reserves the right to charge a reasonable fee to complete this request).
Request SLTR group to correct incorrect data, or complete incomplete Personal Data.
Submit a complaint to a data protection authority or other independent regulator about the use of Personal Data.

Depending on the circumstances and nature of the consent being withdrawn, you must understand and acknowledge that the SLTR group has the authority to fulfill or not comply with the request for withdrawal of the approval. Once you withdraw the consent, you cannot use the Service. Withdrawal of consent can result in termination of your account or contractual relationship with SLTR group, where all rights and obligations of each party are still fully protected.

11. Service Settings

You can choose not to receive marketing services, advertising, or other activities related to the processing of Personal Data, by contacting the SLTR group through the communication channels set by the SLTR group, or through other mechanisms prepared by each SLTR group Service.

If you choose not to receive one service, SLTR group still has the right to send messages regarding other SLTR group services.

12. Cookie Use Policy

Web applications use cookies to differentiate you from other users of the application. This is to assist SLTR group in providing a good experience when you use web applications and also allows SLTR group to improve service quality through web applications.

You have the ability to accept or decline cookies by modifying the settings in your browser.

13. Amendment of Privacy Policy

We may update this privacy policy from time to time in accordance with changes in applicable laws or our internal policies. Any changes made will be announced through our website or other available communication channels. Users are encouraged to periodically review this privacy policy to stay informed about how we protect your personal information.

14. Governing Law and Dispute

This Policy shall be governed by and enforced in accordance with the laws of the Republic of Indonesia. We will try to resolve amicably any dispute arising out of or in connection with the provisions of this Policy (including any question of its existence or validity), but if such efforts fail, the Dispute shall be adjusted by agreement of each party using the Law of the Republic of Indonesia.

15. Contact Us

If you have questions or complaints regarding this Privacy Notice or if you wish to access and/or correct your personal information, please contact SLTR group via:

Email : [email protected]
Office Phone Number : (021) 50882957

16. References

Law of the Republic of Indonesia Number 27 of 2022 concerning Personal Data Protection.