PT Bangun Digital Nusantara (hereinafter referred to as Solitaire) is fully aware that Personal Data is the most important asset for you, so Solitaire is committed to maintaining the confidentiality and protection of your Personal Data, related to the use of products and/or services offered by Solitaire.
Solitaire 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 Solitaire 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 Solitaire 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. Instn (PT. Artha Mandala 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, Solitaire 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 Solitaire.
- 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 Solitaire, this includes sending promotions, new products, news, surveys and service-related updates.
- To evaluate and update Solitaire 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 Solitaire.
4. Personal Data Processed by Solitaire
Solitaire 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 Solitaire can be provided by Personal Data Subjects directly or from third parties. Solitaire 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 Solitaire to provide Services, includes general and specific Personal Data as follows:
- General data:
- 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.
- 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.
- General data:
- 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
Solitaire 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 Solitaire to maintain Service performance while still complying with obligations for effectiveness of supervision in accordance with applicable laws and regulations.
Solitaire 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 Solitaire data retention policy and applicable laws and regulations in the Republic of Indonesia.
Solitaire 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 Solitaire 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 Solitaire 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 Solitaire, 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 Solitaire 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 Solitaire.
- In the context of processing personal data with Solitaire affiliated companies, Solitaire 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 Solitaire processes Personal Data that opens your personal profile, Solitaire 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 Solitaire 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 Solitaire 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, Solitaire needs to process sensitive Personal Data, such as information related to health, genetics, biometric identifiers, sexual orientation, and so on. To the extent that Solitaire requires your explicit consent to process this kind of data, Solitaire 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 Solitaire to correct, complete and/or update your Personal Data which is in the management of the Solitaire, by contacting the communication channel set by the Solitaire.
In the event that there is an inaccuracy in providing your Personal Data, Solitaire has the right to stop services and/or transactions based on the knowledge and considerations of Solitaire.
Solitaire 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 Solitaire data retention policy or at your request / request, Solitaire 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 Solitaire so that the Personal Data can be destroyed from the Solitaire system.
9. Personal Data Security
Confidentiality of your Personal Data is a priority for the Solitaire. Solitaire 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 Solitaire, Solitaire 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 Solitaire 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 (Solitaire reserves the right to charge a reasonable fee to complete this request).
- Request Solitaire 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 Solitaire 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 Solitaire, 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 Solitaire through the communication channels set by the Solitaire, or through other mechanisms prepared by each Solitaire Service.
If you choose not to receive one service, Solitaire still has the right to send messages regarding other Solitaire services.
12. Cookie Use Policy
Web applications use cookies to differentiate you from other users of the application. This is to assist Solitaire in providing a good experience when you use web applications and also allows Solitaire 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 Solitaire via:
- Email: marketing@sltr.id
- Office Phone Number: (021) 50882957
16. References
Law of the Republic of Indonesia Number 27 of 2022 concerning Personal Data Protection.