This Privacy Policy reflect our respect to your privacy. This Privacy Policy will explain what information and how your personal data are processed by PT. Esports Star Indonesia (“ESI”), when you are using our games, mobile applications, services, features, products, customer support, social media channels, websites, questionnaires, or competitions (collectively referred to as our "Services") whether on mobile devices, PCs, or other platforms.

 

We are committed to protect and maintain the confidentiality of your personal data in accordance with applicable laws and regulations. In practice, what is meant by "Personal Data" is any personal identity data that is stored, maintained and kept accurate, about a person who can be identified from the information. We guarantee that we will not collect, use, disclose, transfer, store, and/or process Personal Data including your credentials to third parties, both commercial and non-commercial, for purposes other than as specified in this Privacy Policy. We guarantee that the processing of your Personal Data will be carried out in a professional and responsible manner and the results of such processing are sourced only from original and accurate Personal Data information as contained in your account.

 

If you do not agree to the processing of your Personal Data in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Services. By using any Services, you agree to all of the terms and conditions of this Privacy Policy and its changes and/or amendment in the future. If you do not consent to the collection and use of information from or about you and your Personal Data in accordance with this Privacy Policy, then you agree not to use the Services. We reserve the right to change this Privacy Policy at any time and you must check this Privacy Policy periodically. Your continued use of the Service following any changes to the Privacy Policy on this page, constitutes your acknowledgment of those changes and your agreement to comply with and be bound by the new Privacy Policy. If we make material changes to this Privacy Policy, we will notify you via the email address you provided, or by posting a prominent notice on our website/applications. We will make necessary changes to the Privacy Policy to comply with regulatory and business requirements from time to time.

 

 

1. COLLECTION OF INFORMATION

We ensure a reasonable and transparent processing in accordance with the rules on processing of Personal Data. Generally, we will collect or receive information in 3 (three) ways:

 

1. Information You Provide Us

We collect information you provide us, including:

• Contact and Profile Information;
• Age;
• Information you provide when seeking help from us, such as your name, email address, contact information, payment related information, and records of the issues you experience;
• Information you provide when completing a customer survey; and
• Information you provide to enter a contest or competition. If you win, we may need your social identity number, postal address and/or national identification for eligibility, prizes delivery, and tax purposes.
• We may use third party payment processors and they will use your payment information, such as credit card numbers, to process credit card transactions or other payment methods, to retrieve customer account information, to determine whether customers are eligible for certain promotions, and to detect against the Services.
• When you participate in social features or log in through third-party’s platform or a social media site, i.e. Facebook, Twitter, Google, Game Center, or other platform providers, you are acknowledging that the information you disclose is public information. We may store and access it, and it may be read, copied, collected, or used by other users without your consent. Please make sure your privacy setting through the third party’s platform reflect your preferences. You acknowledge that we are not liable when third party services use information you provide to them. We encourage you to be careful about the protection of your own personal information when using thirdparty services such as social media platforms.
• When you participate in online leaderboard components of our products, your in-game profile information, gameplay, and statistic may be visible to all.

 

2. Information Collected Automatically When You Use Our Services

We collect information automatically when you visit or use our Services. If a combination of information we collect does identify you as an individual, we will treat the combined information as personal information. We typically aggregate the data we collect automatically and use it in statistical form to determine trends among groups of users, rather than using it to identify individuals.

 

We may collect and store the information through technologies such as web browsers, cookies, log files, web beacons, and our back-end servers collect usage data transmitted from our Services, and other software. We use the information to modify or improve features, managing advertising, addressing technical issues, preventing fraud or misuses of our Services, and conduct data analytics.

 

We generally collect the information data as below:

• Technical information about your computer, device, hardware, or software you use to access our Services, such as IP address, or other transactional or identifier information for your device (such as device make and model, information about device operating systems and browsers, or other devices or system related specifications);
• Usage information and statistics about your interaction with our Services, which may include the URLs of our website/applications that you have visited, URLs of referring and existing pages, page views, time spent on a page, number of clicks, platform type, the application you used or the game you played, how long you used or played it and when, and other usage statistics;
• Crash reports, which may be automatically generated when a game or application crashes and includes information about your system and crash;
• Information that facilitate a safer and more personalized experience, such as your display name or other user identification provided in connection with your application use or game play, saved preferences, game progress, and device identifiers or usage information for authentication and fraud prevention purposes; and
• Location information of your device, such as may be derived from your device’s IP address.

 

Please note that if certain features on our Services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of our Services or other’s Services over time. These features are subject to those third parties’ privacy policy. ESI Services are also available through internet websites or other platforms operated by other companies. Platforms such as these may be branded with our name and logo, but they will not be operated or maintained by us, and we are not responsible for the privacy practices of sites or platforms operated by third parties.

 

What is Cookies?

Cookies is a website technology to provide information on usage of service. A cookie is a small data file that is transferred to your computer's hard disk. We may use both session cookies and persistent cookies to better understand how you interact with our Services or the advertising published outside of the Services and to monitor aggregate usage by our users and web traffic routing on the Services. This allow us to improve our Services. Also, we may create a unique device or user ID for you and store it in a cookie so we can recognize you and customize your experience based on your preferences. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our services.

 

3. Information Provided By Third Parties

Third parties may provide or allow us to collect information about you if you play or purchase our products or in-app purchases on your devices. We receive the information from the app store or other platform providers. This information may include your username and/or device identification number and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of services also may send information that you authorized them to provide, through systems such as Google Play Services or Apple Game Center.

 

We may also receive information from third-party social network, like Facebook, Twitter, Google+, Game Center, or other platform providers when you use these services in connections with our Services. We may also receive information about you when other players choose to share their contact lists with us. We also may receive information from third parties to supplement the information we receive from you. We use information from these companies primarily to help us deliver relevant advertising to you. A representative list of these types of third parties can be found below. We also may use information from third parties, for instance, to help us understand your approximate geo location via your IP address for tax purposes, or to customize certain services to your location, and for fraud, and/or abuse prevention purposes.

 

2. USAGE OF INFORMATION

In general, we use your information to provide you the Services, experiences, merchandise, or information you requested.

 

We also use your information for the following purposes:

1. For our legitimate interest, consistent with your rights and preferences, we use Personal Data:
• to communicate with you, respond to your request, or provide you with updates and information, including advertising and marketing messages so that we can send you news regarding the Service, details about the latest videos, features and content available on the Service;
• to better understand our users, their interests, and their preferences;
• to personalize your experience, save your preferences, authenticate our users, and provide similar user-experience features;
• to measure, develop, deliver, and improve our Services, its features, and other offerings;
• to manage and customize advertisement or promotional offers;
• to facilitate sharing on social networks;
• to register your participation in a contest and contact you in case of prizes;
• to provide you with customer assistance (for example via electronic mail (email), notifications, and mobile phone short messages (SMS);
• to respond to inquiries and/or prevent illegal activities including fraud;
• for security purposes, including to protect your rights and ours;
• for internal purposes such as auditing and data analysis; and/or
• for other uses in accordance with the Terms and Conditions.

 

2. To provide Services that are subjected to the terms you have accepted and suitable to your age and compliant with the applicable laws of your country of residence.
3. To the extent you give consent, such as when we would like to process your personal information for a purpose that would otherwise be incompatible with this Privacy Policy.
4. To comply with legal obligations and requirements, and answer any request from Data Protection Authorities or any law enforcement.

 

We will normally collect personal information from you only:

• When we have your consent to do so;
• When we need the personal information to fulfil a contract with you and provide you with the Services, such as customer services, bugs and service error detection, and fraud prevention;
• When the processing is in our legitimate interest (when we serve and measure the effectiveness of advertising or marketing campaign, analyze your gaming activities, protect, and improve our Services) and not overridden by your rights; or
• When we have a legal obligation to collect personal information from you.

 

We may use analytics services to understand how you engage with our Services. Our analysis relies on your consistent device identifier, or identifier for vendor (IDFV) on Apple devices, so that we can track your behavior over time and develop an understanding of how you prefer to interact with our products. If you have more than one ESI’s product installed on your device, those products may share the same identifier value. This enables us to develop an understanding of how you engage with all of our products you have installed. The identifier value is provided to us through the operating system on your device.

 

In the course of processing your data, we may do any of the following:

• Analyze your behavior in our products over time;
• Analyze your behavior in aggregate;
• Combine your information with the information of other players to create anonymized aggregate reports that allow us to understand large-scale behavior trends;
• Analyze your information to understand how well our products perform on your device or to investigate bugs, crashes, and other technical issues;
• Combine your information with the information of other players to create customer segments based on behavior in our products or location-based behavior;
• Use analysis of your behavior in our products to provide you with customized gameplay experiences;
• Use your device identifier to enroll you in an A/B test. An A/B test is a type of simple behavioral experiment wherein groups of users are provided with slightly different experiences in our products so that we can research and analyze which of the experiences is the most compelling to users of our products; and
• Analyze your behavior in the context of an A/B test.

 

 

3. STORAGE OF INFORMATION

We will store your Personal Data for as long as necessary in order to provide you with the Services or otherwise fulfil the purposes as described above, unless further storage is required in order to establish, exercise, or defend a legal claim or to comply with applicable law. We periodically review the personal information we retain to determine whether continued storage is proper.

 

Your Personal Data are deleted or anonymized as soon as it no longer serves one of the above mentioned purpose and in any event no later than 3 (three) years after your interaction with ESI has ceased.

 

4. SHARING INFORMATION

We may share, or provide you with opportunities to share, information about you with other users of our Services. We also provide services that allow our users to communicate with us and each other, in which case personal information may be shared and account IDs may be displayed.

 

We may share personal information we collect within ESI’s affiliates and/or any company within the scope of the MNC group including but not limited to PT Media Nusantara Citra, Tbk., PT Global Mediacom, Tbk., PT MNC Studios International, Tbk., and/or PT Multi Vision Network, Tbk., (“MNC Group”). We also will share information with service providers that perform services on our behalf and under our instructions. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share certain limited information, such as device identifiers, with advertisers and other marketing partners for purposes of gauging the effectiveness of advertising and other marketing strategies. We use third-party services.

 

We may share information about you with your social network contacts when you and they use the same social features of our Services. If you decide, while using our Services, to use social sharing features such as “Share” or “Like” on Facebook or other third-party social network sites, this may allow the sharing and collection of personal and non-personal information both to and from such third-party social networks. You should visit the policies of such third parties for more information about their information-collection practices.

 

We may also disclose information about you: (i) if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity, or (iii) if necessary to protect the vital interests of another party (such as to prevent death, bodily harm, or serious damage to property). We reserve the right to transfer information about our users in the event we sell or transfer all or substantially all our business or assets.

 

5. CHILDREN’S PRIVACY

We encourage parents to instruct their children about privacy and the way they use their information on the Internet. Children should never disclose their name, address, phone number, or any personal information, without their parents’ prior permission.

 

If you are under the age of 13, you must not use our Services. If you are between the ages of 13 and 18 (or the relevant age in your jurisdiction where you are considered a minor), your parent or guardian must agree to this Terms (both for themselves and on your behalf) before you can use our Services. In some cases we may ask the user to provide us with their birth date. If such information indicates the user is under the age stipulated by the applicable laws and deemed as child under such laws, we will not collect further personal information from the child until a parent/guardian’s verifiable consent is obtained. Please ask your legal guardian’s permission to use or access our Services. If you believe ESI has inadvertently have personal information of a child without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please inform us in Contact section below, so we can promptly remove the information from our records.

 

 

6. INTERNATIONAL OPERATIONS AND TRANSFERS OF YOUR INFORMATION

We may collect the personal information and processed for the purposes as set out above in Indonesia or any other country which ESI, its business partners, or third party agents operate. By using our Services, you consent that your personal information may be transferred to the recipients in the Indonesia and/or other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

 

7. PROTECTION

We take reasonable controls designed to help safeguard the personal information we collect through our Services. However, no security measures are perfect and we cannot assure you that personal information that we collect will never be accessed or used in an authorized way.

 

We use reasonable physical, technical and administrative measures to safeguard the information in our possession from loss, theft and misuse, disclosure and modification. For example, passwords and other sensitive information are encrypted in transit. We also take steps to ensure that only ESI’s employees, agents and contractors are granted access and have a valid business reason to gain access to sensitive information from or about you.

 

When you enter payment information (such as credit card information on our order forms), we encrypt that information using secure industry standard protocols for payment transmission to help protect the payment information you submit to us.

 

Despite these efforts, please note that there is always a possibility that a breach in the transmission or storage of data may occur. We want you to feel confident in our security when using the Services, as we strive to use commercially acceptable means to protect your information, but we cannot guarantee the complete security of any information from or about you.

 

8. LEGAL BASIS FOR PROCESSING

Our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where:

• we have your consent to do so;
• where we need the personal information to perform a contract with you (e.g. to deliver a service you have requested); or
• where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).

 

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another party. If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests which are not already described in this Privacy Policy, we will make clear to you at the relevant time what those legitimate interests are.

 

9. YOUR CHOICES

We provide you with choices about whether to provide us with personal information and whether it is shared. For example, we may seek your prior consent for certain processing. We are required to seek your consent before we use your personal information for any purpose incompatible with the purposes identified in this Privacy Policy. You may withdraw your consent at any time by sending an email as specified in the Contact section below. Any withdrawal of consent is only effective on a going-forward basis and will not impact processing we undertook while relying on your consent.

 

We generally only ask you for personal information that is necessary to provide the services you request. You can choose not to give us the personal information we request, as described in the “Information You Provide Us” section of this Privacy Policy. However, in some cases, if you decide not to provide the personal information we request, we will not be able to provide the Services you requested.

 

Other examples of your choices include:

• You can browse our website without providing any personal information. We may collect some limited information automatically.
• You may opt out of receiving our messages at any time by using the opt out mechanism provided in the message.
• You can change your privacy settings on other parties’ websites/applications, such as social networks, which will stop or limit our receipt of information from those other websites/applications. You also may choose not to use social features we make available. If you choose to use these features, you should refrain from posting personal information that will be visible to others, such as including your email address in a forum or during a chat.
• You may change your browser settings or take other steps to block, manage, or delete cookies. Not all of our websites/applications and online services currently respond to browser “do not track” signals, so you will need to use your browser settings to effectively manage cookies. In some cases, blocking or disabling cookies may cause the Services not working as intended and some features may not be available.
• If you are under the age of 13 years old and have an account for our Services, you may request that we remove certain content that you provided, such as deleting or editing comments you have posted. You also may ask us to assist you in removing or anonymizing content you have posted by contacting us as described in the Contact section of this Privacy Policy. Please be aware that taking these steps may not ensure complete or comprehensive removal of the content or information posted on our Services. We also may not be able to remove content you post if applicable law requires us to maintain the posting or if another party has re-posted the content to a website, app, game or other online service that we do not own or control.

 

You may also exercise and amend your choices by sending an email to us as detailed in the Contact section below.

 

10. ACCESS AND CORRECTION

We provide you with the ability to request access to, correction, or deletion of your personal information. You can update or request for deletion of your account information any time through our Services. If you would like to request access to or correction or request for deletion of your personal information, please submit your request by sending an email to the address specified in the Contact section below. Please include your name, email address, and postal address in your request and describe specifically the information that you would like to access or correct or delete so that we may respond appropriately and promptly.

 

11. THIRD PARTIES’ SERVICES

Our Services may link to external sites that are beyond our control. This Privacy Policy only covers the way we treat personal information and non-personal information we collect on the Services. By accessing any external sites, you agree to the privacy policies of those sites. Please understand that external sites may have different policies with respect to the collection, use, and disclosure of your personal information. We have no control over, and are not responsible for, the privacy practices of such third parties. Therefore, you are encouraged to review the privacy policies of all third parties' services. Without limiting anything in the following section, we are not liable in any way for the actions, inactions, or policies of any external services.

 

12. UPDATES TO OUR PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect changes in our personal information practices or relevant laws. We will indicate at the top of this Privacy Policy when this Privacy Policy was last updated. Please review this policy every time you access or use our Services in order to stay informed about how we process your Personal Data and information.

 

13. LEGAL DISCLAIMER AND INDEMNIFICATION

Our Services operate AS IS, and we do not represent or warrant that our Services will be available at all times, or that your use of the Services will be uninterrupted or error-free. We are not responsible for your ability to access the Services or for matters beyond our control. This Privacy Policy is governed by the laws of Indonesia. Any dispute arising from the use of the Services shall be submitted to the competent courts of West Jakarta District Court. You agree to waive any and all objections to the exercise of jurisdiction over you by such courts and to venue in such courts.

 

You agree to defend, indemnify, and hold harmless ESI, MNC Group, its affiliates, and licensors, and their respective officers, directors, employees, contractors, agents, licensors, and suppliers from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys’ fees) resulting from your contributions or violation of this Privacy Policy. To the extent permissible under applicable laws, in no event shall ESI, MNC Group, our subsidiaries, affiliates, successors, and assigns or any of our shareholders, directors, officers, employees, or licensors be liable (jointly or severally) to you for personal loss, injury or any special, incidental, indirect or consequential damages of any kind, or any damages whatsoever.

 

You agree to indemnify and hold harmless ESI, MNC Group, their subsidiaries and/or their affiliates, as well as directors, commissioners, officials, employees, agents, and their representatives from any claims or demands, including reasonable attorneys' fees, performed by a third party on or arising from use of the Services by your violation of this Privacy Policy, or falsification of an intellectual property rights by you of intellectual property rights or other right possessed by any other person or entity.

 

14. CONTACT

Esports Star Indonesia has the following contact information:
MNC STUDIOS INTERNATIONAL. QQ. PT. ESPORTS STAR INDONESIA
MNC Studios Tower 2, 7th Floor
Jalan Raya Pejuangan No. 1 Jakarta Barat 11530
Indonesia
E-mail: [email protected]