📕Privacy Policy (Indonesia)
Sportoner Decentralized Apps Privacy and Security Policy
1. General provisions
1.1. This Privacy and Security Policy posted on the Sportoner Platform (hereinafter referred to as the "Policy", "Privacy Policy") has been developed in accordance with the provisions of law of the Republic of Indonesia and the General Data Protection Regulation (GDPR), in order to ensure proper protection of information about Users, including their personal data, from unauthorized access and disclosure. By performing any actions related to the use of the Site, the User agrees to the terms of this Policy. If the User does not agree with the terms of this Policy, the use of the Site must be immediately terminated.
1.2. The following terms are used in this Privacy Policy:
Company - Sportoner Decentralized Apps, registered under the laws of Indonesia at the address: JALAN RATNA NOMOR 80, Desa/Kelurahan Tonja, Kec. Denpasar Utara, Kota Denpasar, Provinci Bali, 80239, Indonesia, NIB 0707230260239.
Website - an Internet resource that represents a set of information and intellectual property objects contained in an information system (including a computer program, database, graphical interface design, etc.), which is accessed from various user devices connected to the Internet by means of special web browsing software-pages (browser) by address https://sportoner.com.
Site administration - employees authorized to manage the Site who organize and (or) process personal data, as well as determine the composition of personal data of Site Users to be processed, the purpose of processing and collection of personal data.
User - an individual, a user of the site's services, a personal data subject who provided personal data.
Terms of Use of the Payment Service – an agreement in the form of a public offer that regulates relations between the Company and the Site User (hereinafter referred to as the "Agreement").
Personal data - any information related directly or indirectly to a specific or identifiable individual (subject of personal data), which alone or in combination with other information available to the site, allows identifying the user's identity.
Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.
1.3. This Privacy Policy sets out the procedure for receiving, protecting, storing, processing and transmitting Users' personal data, and applies to all information that the Site Administration can receive about Users during their use of the Site.
1.4. This Privacy Policy does not apply to other sites and does not apply to third-party sites. The site administration is not responsible for third-party sites that Users can click on the links available on the Site.
1.5. The User's personal data authorized for processing under this Privacy Policy is provided by the User by filling out the feedback form on the Site, etc. and includes:
* First And Last Name Of The User.
* The User's contact phone number.
* e-mail address (e-mail);
* location address,
* gender, date of birth,
* history of financial transactions.
1.6. Any other personal information not specified above (browsers and operating systems used, etc.) is subject to secure storage and non-distribution, except for the cases provided for in clauses 5.2. and 5.3.of this Privacy Policy.
Other User information processed by the Company includes:
standard data automatically received by the http-server when accessing the Site and subsequent User actions (IP address of the host, type of operating system, visited Site pages), information containing the history of Site visits;
information automatically obtained when accessing the Site using bookmarks (cookies);
information provided or created by Users on the Site: comments, etc. ("Content");
location coordinates (geolocation data).
The Site Administration can receive all personal data about Users only from them and only with their consent. The User's consent to the use of personal data is stored electronically on the servers used by the Company.
Personal data is confidential information and cannot be used by the Site Administration or any other person for personal purposes.
1.7. Purposes of processing personal data of Site Users:
the Company fulfills its obligations to the Site User;
providing information of a notification or marketing nature;
collect statistical data necessary to improve the Site and its services, anonymously and in a generalized form;
compliance with legal requirements;
processing User requests/complaints.
1.8. The Site administration provides Users with free access to their personal data, including the right to receive copies of any record containing their personal data, except in cases stipulated by law.
The site administration develops measures to protect the personal data of Site Users.
2. Collection, storage, processing and transfer of personal data of Site Users
2.1. The processing of personal data of Site Users is carried out exclusively for the purposes specified in clause 1.7. of this Policy. Personal data is provided by the User voluntarily and independently. The User's personal data and other information is collected on the Site when using the Site and its services, as well as in the future when the User enters additional information about himself / herself on his / her own initiative.
2.2. The User understands and agrees that the information posted on the Site about themselves may become available to other Users of the Site and Internet users, may be copied and distributed by such users.
2.3. Personal data of Site Users is stored electronically in the Site's personal data information system, as well as in archived copies of the site's databases in an impersonal form.
2.4. The User is aware that certain types of information transmitted by them to other Users cannot be deleted by the User themselves.
2.5. When storing personal data of Site Users, organizational and technical measures are taken to ensure its safety and exclude unauthorized access to it.
2.6. The Site Administration may transfer Users' personal data to third parties in order to fulfill the User Agreement and its obligations, as well as at the request of the competent state authorities in order to comply with the current legislation.
2.7. When transmitting personal data of Site Users, the Site Administration warns the persons receiving this information that this data can only be used for the purposes for which it is reported.
2.8. The transfer (distribution, provision, access) of personal data authorized for distribution by the personal data subject must be terminated at any time upon their request. The personal data specified in this request can only be processed by the operator.
2.9. All information about the transfer of personal data of Site Users is taken into account to control the legality of the use of this information by the persons who received it.
2.10. In order to improve the quality of the service and ensure the possibility of legal protection, the Site Administration has the right to store log files about actions performed by Users during the use of the site.
3. Transfer of data to partners and interaction with third parties
3.1. In the framework of cooperation with project partners (including LLC "FOR GOOD SOLUTIONS", the Association of Football Clubs "Russian Premier League" and its affiliated football Clubs), the Site Administration provides these partners with the data of platform users necessary to fulfill the terms of contractual obligations. This data includes:
personal data of users provided during registration and use of the platform;
information about user actions on the platform;
confirmation of users' consent to receive advertising and informational messages from the League and Clubs.
3.2. The League and Clubs have the opportunity to create personal accounts on the platform, where user data can be stored and processed, including:
history of interactions with content.
activity statistics.
other information required for service personalization and communication.
3.3. Data transfer to partners is carried out exclusively for the following purposes:
fulfillment of contractual obligations of the Site Administration;
informing users about events, promotions and services of the League and Clubs;
analyze user activity to improve the platform's functionality.
3.4. The Site guarantees that the transfer of data to partners takes place only if there are legal grounds, including obtaining the user's explicit consent in accordance with the requirements of current legislation.
3.5.The respective partner is responsible for the use of data transmitted to partners (League and Clubs), including their processing in personal accounts. The Site is not responsible for the actions of third parties related to user data after their transfer.
3.6. Users have the right to withdraw their consent to data processing for the purposes specified in clause 3.3 at any time through the settings of their personal account or by contacting the Site's support service.
At the same time, the withdrawal of consent to provide data to partners (League and Clubs) may lead to the inability to continue using the Site's functionality, since data transfer is an integral part of providing the platform's services. In this case, the user's access to the Site will be terminated and their account will be deactivated.
3.7. Notification of the consequences of revocation of consent. Before confirming the withdrawal of consent, the user will be informed that this action will lead to the loss of access to the Site. The Site reserves the right to restrict or terminate the provision of services if its implementation is technically or legally impossible without processing the relevant data.
4. Rights and obligations of the Site Administration
4.1. The Site Administration has the right to set requirements for the composition of Users' personal data, which must be provided for the use of the site, while the Site Administration is guided by this Policy, the User Agreement, and relevant laws.
4.2. The Site Administration does not verify the accuracy of the personal data provided by Users, believing that users act in good faith and maintain information about their personal data up-to-date, except in cases when such verification is necessary in order for the Company to fulfill its obligations to the User.
4.3. The site Administration is not responsible for the voluntary transfer of Users' contact information, password or login to third parties.
4.4. The site Administration does not collect and process Users' personal data about their political, religious and other beliefs and private life.
4.5. The Site Administration takes measures to ensure the protection of personal data of Site Users from misuse or loss in accordance with the procedure established by law.
4.6. The site Administration is obliged to take measures necessary and sufficient to ensure the fulfillment of its obligations. The site Administration independently determines the composition and list of measures necessary and sufficient to ensure the fulfillment of these duties. These measures include:
publication of documents defining its policy regarding the processing of personal data, local acts on the processing of personal data, as well as local acts establishing procedures aimed at preventing and detecting violations of the law, and eliminating the consequences of such violations;
application of legal, organizational and technical measures to ensure the security of personal data;
implementation of internal control and (or) audit of the compliance of personal data processing with the requirements for personal data protection, the site's policy on personal data processing, and local acts of the site;
assessment of the harm that may be caused to the subjects of personal data in the event of a violation, the ratio of this harm and the measures taken by the site aimed at ensuring the fulfillment of its duties.
5. User' rights to protect their personal data
5.1. In order to ensure the protection of their personal data stored on the site, Users have the right to:
receive full information about the personal data, its processing, storage and transfer;
identify their representatives to protect their personal data;
request the deletion or correction of incorrect or incomplete personal data, as well as data processed in violation of this Policy and applicable laws;
require the Site Administration to notify all persons who were previously informed of incorrect or incomplete personal data of Users, about all exceptions, corrections or additions made to it.
5.2. Users have the right to independently restrict the collection of information by third parties, as well as to change, delete or supplement the personal data provided by them at any time.
5.3. If Users believe that the processing of their personal data is carried out in violation of legal requirements or otherwise violates their rights and freedoms, they have the right to appeal against the actions or omissions of the Site Administration to the authorized body for the protection of the rights of personal data subjects or to the court.
5.4. Users may at any time independently edit the personal data provided by them during registration or authorization in their personal account.
5.5. Users can send their questions to the Company, including those related to the use of their personal data, by e-mail specified on the Site.
5.6. The User is obliged to independently take measures to ensure the confidentiality of credentials (login and password), and may not transfer them to third parties, with the exception of persons acting in the interests of the User in cases stipulated by law.
6. Procedure for destruction or blocking of personal data
6.1. In case of detection of illegal processing of personal data when contacting Users, the Site Administration is obliged to block the unlawfully processed personal data related to these Users from the moment of such request for the period of verification.
6.2. In case of detection of inaccurate personal data when contacting Users, the Site Administration is obliged to block personal data related to these Users from the moment of such request for the period of verification, if blocking personal data does not violate the rights and legitimate interests of users or third parties.
6.3. If the fact of inaccuracy of personal data is confirmed, the Site Administration, based on the information provided by Users, or other necessary documents, is obliged to clarify the personal data within 3 working days from the date of submission of such information and remove the blocking of personal data.
6.4. In case of detection of illegal processing of personal data carried out by the site, the Site Administration is obliged to stop illegal processing of personal data within a period not exceeding 3 business days from the date of this detection.
6.5. The Site Administration is obliged to notify Users about the elimination of violations or the destruction of personal data.
6.6. If Users withdraw their consent to the processing of their personal data, the Site Administration is obliged to stop processing it and, if the storage of personal data is no longer required for the purposes of processing personal data, to delete personal data within a period not exceeding 30 days from the date of receipt of the specified withdrawal.
7. Liability for violation of the rules governing the processing and protection of personal data of Site Users обработку и защиту персональных данных Пользователей сайта
7.1. Persons guilty of violating the rules governing the receipt, processing and protection of personal data of Users of the Site are brought to disciplinary, material, civil, administrative and criminal liability in accordance with the procedure established by the current legislation.
8. Term of storage and processing of User information
8.1. User Information is subject to storage and processing by the Company:
during the entire term of the Agreement between the Company and the User;
within 5 (five) years after the end of the year in which the Agreement between the Parties ended for any reason.
8.2. The Company draws the attention of Users, as well as persons who were previously denied access to the Site and services due to their violation of the terms of the Agreement, that they have the right to delete their account on the Site. If the account is deleted, the personal data of such persons is removed from public access, no longer available to other Users, as well as when search engines issue search queries, but remains in the Company's database for the period specified in this clause
9. Change of the Personal Data Processing Policy
9.1. This Policy may be changed or terminated by the Site Administration unilaterally without prior notice to the User. The new version of the Policy comes into force from the moment it is posted on the site, unless otherwise provided.
9.2. The current version of the Privacy Policy is available on the Website.
9.3. The rules provided for in this Policy come into force for the User from the moment of concluding the Agreement and are valid for an indefinite period.
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