INTRODUCTION

References to vocagame.com in this Privacy Policy may mean PT BERMAIN BERSAMA INDONESIA, affiliates of PT BERMAIN BERSAMA INDONESIA, group companies, and subsidiaries of PT BERMAIN BERSAMA INDONESIA, including Representatives of PT BERMAIN BERSAMA INDONESIA, namely financial, insurance, legal, accounting, or other advisors of vocagame.com who provide professional services to vocagame.com and third parties who cooperate with PT BERMAIN BERSAMA INDONESIA, namely partners, vendors, and subcontractors.
This Privacy Policy is an integral part and is an integral part of the Terms and Conditions of vocagame.com. Capitalized terms used in this Privacy Policy have the same meaning as stated in the Terms and Conditions of vocagame.com.
vocagame.com reserves the right to update this Privacy Policy from time to time to keep it relevant and up to date with changing technology, applicable laws, vocagame.com's evolving business practices and the needs of vocagame.com users. If there are changes made to this Privacy Policy, vocagame.com will provide a “Last Updated Date” statement. vocagame.com encourages vocagame.com Users to periodically review this Privacy Policy to stay informed about how vocagame.com manages your personal data and information. By using the Service, Users are deemed to have given explicit consent to the Privacy Policy and by continuing to use the Service after the Privacy Policy, Users are deemed to have read, understood and agreed to the updated Privacy Policy.
THIS PRIVACY POLICY IS A FORM OF AGREEMENT THAT IS A BINDING AGREEMENT BETWEEN THE USER AND VOCAGAME.COM THE USER CONSCIOUSLY AND VOLUNTARILY AGREES TO THESE TERMS TO USE THE SERVICES ON THE VOCAGAME.COM PLATFORM

APPLICABLE LAWS AND REGULATIONS

Vocagame.com is subject to all applicable laws and government policies of the Republic of Indonesia, including those governing electronic information and transactions, the implementation of electronic systems, and the protection of Users' personal data; including all implementing regulations and amendments to these regulations that govern and protect the use of Users' important data and information.

DATA ACQUISITION AND PROTECTION

Vocagame.com has the right to request User data and information, including the following:

Information related to Vocagame.com accounts

Name
Username
E-mail
Telephone Number
Address and/or location
Profile, including Date of Birth, Gender
Transaction, financial, and/or banking information

User behavior on Vocagame.com and/or while using the Service Information on product choices, features, and services

Information on User preferences and interests
User experience information
Information on photos and media on the User's device
QR Code scanning information
Real-time geolocation information
Survey result information sent by vocagame.com or on behalf of vocagame.com
User track record (log) including but not limited to device IP address, date and time of access, application features, website pages viewed, application work processes and other system activities, type of web browser, and/or site or service site from a third party used before interacting with the site
Other User information including but not limited to registration activities, logins, transactions, and others

Information from third parties

Personal Information from third parties who work with vocagame.com such as vendors, agents, professional advisors, consultants, and others may be collected by us in connection with the purpose of the third party's engagement.
Vocagame.com may receive information about Users from Third Parties as long as the Third Party has obtained the User's consent to provide the necessary (relevant) information, for example shipping and address information from Vocagame.com's operators, which Vocagame.com uses to correct Vocagame.com's records and send subsequent purchases more easily.

By providing information in letters a to c above, the User waives the right to claims, losses, demands, and lawsuits that may occur due to the acquisition, storage, use, utilization, and/or disclosure of information, including personal information, in the Vocagame.com System.

The User hereby gives explicit consent to vocagame.com to obtain, collect, process, analyze, store, display, use, utilize, publish, send, disclose, disseminate, delete and destroy personal data and information that the User submits (input) into the vocagame.com System, including the User's personal data, Product photos, chats and conversations in the vocagame.com system and the User hereby declares that the granting of consent to such personal data and information is done without coercion, in a competent condition, and in a conscious state, where the User grants such consent when creating a vocagame.com account ("User Consent").
With the User's Consent, the User hereby declares that all such data and information belongs to vocagame.com. For the avoidance of doubt, the User's personal data, whether entered into the vocagame.com Platform or not entered into the vocagame.com Platform, belongs to the User as part of his/her complete personal rights.
The User hereby declares that the personal data that the User submits (inputs) into the vocagame.com System (including documents uploaded and/or provided to vocagame.com) is original, authentic, true, accurate, complete, not misleading, up-to-date, and is the User's personal right and/or he/she is authorized to submit the User's personal data to submit it into the vocagame.com System.
vocagame.com protects all information provided by the User when the User uses all vocagame.com services, including maintaining the confidentiality, integrity, and availability of the personal data it manages.
Vocagame.com has the right from time to time to request authentication and updating of User's personal data, so that User's data and information are accurate, complete, and up-to-date, including temporarily stopping the Service and/or stopping the Service permanently, if the User has not authenticated and updated the User's personal data.
The User has the right from time to time to update the User's personal data.
The User hereby understands that the use of certain features in Vocagame.com requires a further personal data authentication process and is subject to the Vocagame.com Usage Rules and the terms and conditions of certain features in Vocagame.com. The User hereby confirms that the User's Consent is an explicit consent to the acquisition, storage, use, utilization, and/or disclosure of personal data that the User submits (inputs) into the Vocagame.com System and certain features in Vocagame.com, and states that the provision of use of such personal data is done without coercion, in a capable condition, and in a conscious state.
The User releases Vocagame.com from all claims, lawsuits, losses and/or demands in connection with the failure of transaction processing on the Vocagame.com application caused by inaccuracy/insufficiency of the Personal Data information that the User provides to Vocagame.com.

USE, STORAGE, UTILIZATION, AND PROCESSING OF DATA

Vocagame.com will collect, use, store, utilize, process, analyze, transmit and disclose User's personal data for the following purposes and other purposes permitted by applicable laws and regulations:

Service Process and Product transactions. For the purposes of, among others, (i) receiving, processing and verifying the selection, ordering, purchasing, payment, return, transfer, exchange of Products, (ii) know-your-customer (“KYC”) purposes, (iii) internal data processing (iv) communicating with Users regarding orders, data verification, products and services, and promotional offers, (v) monitoring and knowing User transaction patterns, (vi) billing, activation, provision, maintenance, support, troubleshooting, deactivation, replacement, improvement or renewal of Services (vii) administrative purposes (viii) processing all forms of User activities including but not limited to processing transactions, payment verification, product delivery, use of services, (ix) managing or responding to User inquiries, (x) using bank name information including name and account number to ensure payment/receipt by Users, (xi) to fulfill or enforce applicable notices for the Services.
Provide, troubleshoot, and improve Vocagame.com Services. Vocagame.com uses User Personal Data to (i) provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of the Services, (ii) to ensure the Services are technically functioning as intended and to help identify and troubleshoot problems.
Recommendations and personalization. Vocagame.com uses User Personal Data to recommend features, products and services that may be of interest to Users, to better understand, analyze and predict User preferences and interests, combine such information with other information to customize User experience, and personalize User experience with the Services.
Provide image and camera services. When Users use User image and camera services, Vocagame.com uses images, videos and other personal data to respond to User requests, provide requested services to Users, and improve Vocagame.com services.
Comply with legal obligations. In certain cases, Vocagame.com collects and uses User Personal Data to comply with laws, regulations and respond to emergency situations. For example (i) Vocagame.com collects from Users information regarding bank account information for identity verification and other purposes, (ii) to respond to court orders, summonses or legitimate requests or other legal or law enforcement processes, (iii) official requests or orders from authorities, officers or institutions authorized under applicable legal provisions, including but not limited to disputes, investigations, inquiries, legal processes and dispute resolution processes between Vocagame.com and Users, Users with other Users, and Users with other parties and other illegal activities, (iv) requests from authorized banking institutions, financial institutions or non-financial institutions, and/or third parties based on official requests and applicable legal provisions, (v) to provide emergency assistance, emergencies, in situations that may threaten the life, health or physical safety of Users or others.
Communication with Users. Vocagame.com uses User Personal Data to communicate with Users in connection with the Services through different channels (e.g., via phone, email, chat).
Advertising, promotions and personalization. Vocagame.com uses User Personal Data to (i) display or conduct promotional activities and interest-based advertisements for features, products and services that may be of interest to Users including but not limited to advertising identifiers, including those provided by other software platforms, or similar identifiers, to facilitate Vocagame.com in conducting analytics or providing promotional content or other information that may be relevant and interesting to Users, (ii) to facilitate User access to and use of the Services and/or third party offerings; (iii) to send subscription offers, messages, news and posts within the Services on behalf of Vocagame.com.
Fraud and money laundering prevention and credit risk. Vocagame.com uses User Personal Data to prevent and detect fraud and money laundering and abuse to protect the security of Users, Vocagame.com and others. Vocagame.com may also use scoring methods to assess and manage credit risk.
Developing the Services. Vocagame.com uses User Personal Data to develop new services and improve existing Services and provide Users with information about third party content or related products, services and software including to communicate with Users about the various ways they use, for example to provide or send to Users: (i) improvements or updates, or notices about improvements or updates to the Services or third party content or related products, services and software; (ii) notifications of promotions, contests, offers, and upcoming events; (iii) personal information, surveys, marketing materials, advertisements or customized content. Also for the purposes of (i) detecting, monitoring, investigating, reducing or preventing fraud and technical or security issues or to protect the property of Vocagame.com; (ii) enabling business continuity and disaster recovery operations; (iii) obtaining legal services, to seek legal advice and/or to enforce the legal rights of Vocagame.com or the legal rights of other members of Vocagame.com; (iv) for statistical purposes; (v) business, product, quality, and service development including promotional activities, studies, research, and cooperation of Vocagame.com with other third parties. When necessary for a clear purpose in the interests of the User and User Consent cannot be obtained in a timely manner.
Other purposes conveyed from time to time by Vocagame.com to the User, and required, permitted or required by applicable laws and regulations.

Vocagame.com may cooperate with companies and other third parties who facilitate or provide assistance in the development of certain services for and/or on behalf of Vocagame.com, including:

Provide User assistance;
Perform services related to the Platform (including but not limited to maintenance services, database management, analysis and improvement of Platform features;
To assist Vocagame.com's professional advisors and external auditors, including legal advisors, financial advisors, and consultants. These third parties only have access to User Data to perform such tasks for and/or on behalf of Vocagame.com and are contractually bound not to disclose or use such Personal Information for any other purpose.

In disclosing information, Vocagame.com can inform some of the User Data so that the information becomes information that cannot identify the User as a whole (aggregate data/anonymous data) which is intended for third parties used for Platform development, database management, analysis or improvement of Services, promotion and advertising.
Vocagame.com can also combine User Data with other information in such a way that the information is no longer associated with the User, then disclose the combined information to third parties, for purposes such as in point 3.
For the purpose of developing, improving, perfecting, protecting, and maintaining Platform products and/or Services, Vocagame.com is sometimes required to process, utilize, display, disclose, publish, send, transfer, and/or disseminate Personal Data to third parties. For the avoidance of doubt, the third parties referred to in this paragraph may include but are not limited to:

Third Parties within the Vocagame.com group of companies, subsidiaries, affiliates, partners, partners and vendors for or in connection with purposes related to the provision of the Platform, business management, provision of Services, data management and other activities;
The interests of Vocagame.com, Vocagame.com affiliates, Vocagame.com group companies and subsidiaries, for the development of business, products, quality and services including promotional activities, studies, research and cooperation of Vocagame.com with other third parties;
The interests of Vocagame.com to fulfill the purpose of the transaction, including in the case of the sale of all or part of Vocagame.com assets including any purchase, sale, lease, merger or amalgamation or acquisition, disposal or financing of Vocagame.com, Vocagame.com affiliates, Vocagame.com subsidiaries and group companies;
Third Parties if there is a corporate transaction, such as: formation of a joint venture, restructuring, reorganization, sale of subsidiaries or divisions, merger, acquisition, consolidation, takeover, sale of assets, or liquidation;
Third Parties in relation to service providers engaged by Vocagame.com to perform functions on Vocagame.com’s behalf. Examples include removing repetitive information from User lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing payments, delivering content, scoring, assessing and managing credit risk, and providing User services, if applicable. These third party service providers have access to Personal Data as needed to perform their functions, but may not use it for any other purpose;
Other Third Parties (including agents, vendors, suppliers, contractors, third parties providing services to Vocagame.com or Users, performing tasks on behalf of Vocagame.com that enter into a commercial relationship with Vocagame.com) for or in connection with the purposes of Vocagame.com involving the third party or the purposes of Vocagame.com’s relationship with the third party (as the case may be), which may include allowing the third party to introduce or offer products or services to Users or conducting other activities including marketing, research, analysis and product development of such third party (as the case may be).

In connection with the implementation of widgets or content from within the Vocagame.com application and/or Platform, Vocagame.com hereby declares that third parties will and may send, submit and/or provide User Personal Data to other parties who cooperate with third parties (relevant). In this case, other parties who receive User Personal Data will be subject to obligations related to the sending and use of the same data that apply to the third party Vocagame.com.
Vocagame.com has the right to store User personal data and information to fulfill the purposes of the Service, the purposes of this Privacy Policy, the purposes of applicable laws and regulations, including processing, transferring, and/or storing User data and information, both within the territory of the Republic of Indonesia and outside the territory of the Republic of Indonesia, by considering regulations, including laws and regulations and privacy policies in the country where the User data and information are processed, transferred, and/or stored.
Vocagame.com strives to protect the security of User Personal Data during transmission by using encryption protocols and software and Vocagame.com ensures that Personal Data collected and/or collected by Vocagame.com will be stored securely in accordance with applicable laws and regulations in the Republic of Indonesia. Users understand and agree that Vocagame.com will maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of User Personal Data. Users agree that Vocagame.com will store Personal Data for as long as necessary to fulfill the purposes described in this Privacy Policy.
The Platform may contain links to third-party sites. Vocagame.com is not responsible for the acquisition, collection, processing, analysis, use, storage, display, announcement, transmission, dissemination, deletion, and destruction of User Personal Data by such third parties. If the User provides information directly to the site, then the privacy policy and terms of service on the site will apply, so that all consequences of such actions are entirely the responsibility of the User.
Vocagame.com, affiliates, group companies, and subsidiaries, including representatives of Vocagame.com, and third parties cooperating with Vocagame.com, in providing the Service have the right to utilize and process the User's personal data and information to fulfill the purposes of the Service, the purposes of this Privacy Policy, the purposes of applicable laws and regulations. The utilization and processing of such data is covered by an agreement and contains a confidentiality clause that binds the parties. In this case, including representatives of Vocagame.com.
Vocagame.com may transfer the User's Personal Data information to the affiliate platform or Vocagame.com service provider or to a third party recipient. Therefore, by agreeing to this Privacy Policy, the User also gives consent to transfer the Personal Data information to the affiliate platform or Vocagame.com service provider or to a third party data recipient for the development of services, whether technical, commercial and others. Wherever the User's Personal Data information is transferred, stored or processed by Vocagame.com or an affiliate platform or third party, or other Vocagame.com service provider, Vocagame.com will take reasonable steps to protect the privacy of the User's Personal Data Information.

DATA STORAGE

User data and information on the Platform will be stored as long as it is still used for the purposes as referred to in this Privacy Policy and as required by applicable laws. Vocagame.com will stop storing User data and information immediately if Vocagame.com considers that the data that Vocagame.com collects is no longer in accordance with the purpose of data collection, storage of the data is no longer necessary, is not permitted to be stored or is required to be deleted by applicable laws.

DELETION OF DATA

For various information on the latest promos and exclusive offers, Users can:

unsubscribe if they do not wish to receive such information by clicking the "unsubscribe" link via e-mail sent by Vocagame.com to Users; or
set up "Promo" notifications on the Vocagame.com application.

Users can withdraw the User Consent provided regarding the use of User data and personal information, including stopping using, accessing the Services, and/or closing accounts by considering the provisions of applicable laws and regulations (including retention provisions required by applicable laws). The User hereby declares that the User understands the consequences of withdrawing the User Consent, including but not limited to no longer being able to enjoy the Services.
Subject to applicable laws and regulations, the User may submit a data deletion request to Vocagame.com through Vocagame.com Customer Service by attaching:

a data deletion request form provided by Vocagame.com;
valid proof of identity (KTP/SIM/PASSPORT) in accordance with his/her personal identity on the Vocagame.com Account page; and
the reason for the deletion request.

The User must first study and agree to the Account Deletion Terms and Conditions.
Vocagame.com approves the deletion of data submitted by the User if it has fulfilled the provisions in number 3 above and has fulfilled its rights and obligations at Vocagame.com within a reasonable time.
Vocagame.com, upon the User's request, may collect User data and information that is made unrecognizable.
Vocagame.com has the right to continue to store User data during the retention period set by Vocagame.com on the Vocagame.com system in accordance with the laws and regulations.
Vocagame.com has the right to reject User requests to access and/or change or delete User Personal Data for reasons justified under applicable laws and regulations.
Data deletion and data storage will be carried out by Vocagame.com in accordance with the provisions of applicable laws and regulations.

LIMITATION OF VOCAGAME.COM LIABILITY

Users are responsible for the security and mitigation of violations of their own Vovagame.com Account, such as maintaining the confidentiality of User's Personal Data, implementing appropriate security, limiting access, creating strong passwords and/or PINs (personal identification numbers), maintaining passwords and/or PINs that Users create and use to access User's Personal Data wherever Users store Personal Data, maintaining one time passwords ("OTP").
Users are responsible for all misuse of passwords and/or PINs (whether by Users and/or third parties) or misuse of the Platform, created and used by Users or third parties who obtain the word on the Platform and/or third party platforms affiliated with Users to access User's Personal Data including Accounts, passwords and/or PINs to access or login to User's applications carried out by parties other than Users and such misuse is not the responsibility of Vocagame.com.
Users are required to immediately notify Vocagame.com if the User believes that the password and/or PIN of the Vocagame.com Platform and/or third party platforms affiliated with Vocagame.com to access the Platform is being misused by other irresponsible and/or authorized parties.
Vocagame.com is not responsible for the exchange and provision of User data and personal information carried out by the User himself, including those carried out between Users. Included in this provision are any and all User errors that result in User data leakage.
Vocagame.com is responsible for the Vocagame.com Platform, including the protection and security of personal data confidentiality, including notifying Users in the event of a failure in protecting personal data through at least the User's e-mail registered on the Vocagame.com Platform and reporting to law enforcement or relevant authorities. In the event of a data leak, the party responsible for informing Users regarding the failure in data protection is the party or institution where the data is processed based on this Privacy Policy.
Vocagame.com is not responsible for the authenticity, truth, accuracy, completeness of personal data entered by the User into the Vocagame.com Platform.
By providing User Consent, the User waives the right to claims, losses, demands and lawsuits that may occur due to the acquisition, storage, use, utilization and/or disclosure of data, including personal data, on the Vocagame.com Platform.
In the event that the User is a minor, Vocagame.com is not responsible for the input of the User's personal data and recommends that parents/guardians of children monitor their child's internet usage, so that the provision of the User's personal data is given and/or under the supervision of parents/guardians as authorized parties.
Vocagame.com cannot be held responsible for data leaks caused by a cause beyond the ability or control of Vocagame.com (Force Majeure). What is meant by Force Majeure includes but is not limited to (i) mass strikes, company closures, and other industrial actions; (ii) riots, demonstrations, unrest, invasion, seizure of power, sabotage, embargo, drastic political/economic changes, terrorist attacks or threats, war (whether declared or not) or threats of preparation for war; (iii) earthquakes, tornadoes, landslides, floods, fires, explosions, storms, other natural disasters, epidemics or pandemics whether or not confirmed by statements from the authorities in that regard, and the enactment of new laws and regulations that directly or indirectly affect the implementation of the Privacy Policy, resulting in the inability to carry out the obligations of a party in this Privacy Policy; (iv) unavailability or disruption of the use of the goods delivery network (including transportation routes); (v) unavailability or disruption of telecommunications networks, information systems and technology, widespread internet network outages or unavailability, or lightning strikes; (vi) system failures caused by third parties that occur outside the authority of Vocagame.com (example: hacking of the system by third parties and/or viruses); (vii) banking systems and/or networks not functioning; (viii) actions, decisions, laws, regulations or restrictions issued by the government regarding the implementation of the Privacy Policy; and (ix) changes in economic and financial conditions, as well as restrictions imposed by regulatory authorities regarding the use of the Privacy Policy.

COOKIES

Cookies are small data storage places on computers or other devices such as smartphones or tablets, when Users browse and/or visit Vocagame.com.
User's computer or other device will automatically receive Cookies when Users browse and/or visit the Vocagame.com Platform and when Users use Vocagame.com services (Use of Cookies). However, Users can choose to modify or choose to reject the Use of Cookies through the User's web browser settings preferences.
Vocagame.com uses Google Analytics (Feature), where data obtained from the use of the Feature includes the User's IP address, User's device type, and others (Data). The data is used by Vocagame.com for the development of the Vocagame.com Platform and Content as well as advertising. Users can choose not to be accessed by the Feature by downloading the Google Analytics Opt-Out Add-on on the User's web browser.
Vocagame.com may provide User data and information derived from the Use of Cookies to third parties, such as location data, advertising identifiers, or email addresses used for advertising segmentation, including but not limited to marketing and advertising purposes, where such data and information cannot be personally identified.
Users can control the Use of Cookies through the User's web browser settings preferences, namely by modifying or choosing to reject the Use of Cookies. However, by making these settings, the performance of services when accessing the Vocagame.com Platform may be affected, such as certain functions and pages on the Vocagame.com Platform cannot work optimally for services to Users.

INTELLECTUAL PROPERTY RIGHTS

All works contained in the Services or Platform and its supporting systems including but not limited to: (a) layout, design and appearance of the Services or Platform contained or displayed on Vocagame.com media; (b) logos, photos, images, names, brands, words, letters, numbers, writings, and color arrangements contained in the Services or Platform; and (c) the combination of elements as referred to in letters (a) and (b), are entirely the Intellectual Property Rights of Vocagame.com and no other party also has rights to the Vocagame.com Services or Platform.
Users are not permitted from time to time to:

copy, modify, adapt, translate, create derivative works from, distribute, sell, transfer, display to the public, reproduce, transmit, transfer, broadcast, describe, or disassemble any part of or otherwise exploit the Platform (including the supporting systems and facilities therein) licensed to Users, except as permitted in this Privacy Policy; license, sublicense, sell, resell, transfer, assign, distribute or commercially exploit or otherwise provide the software and/or software to any third party in any way;
publish, distribute or reproduce in any way any copyrighted material, trademarks or other information from Vocagame.com without obtaining prior consent from the proprietary rights of Vocagame.com or the rights owner who licensed the rights to Vocagame.com;
remove any copyright, trademark or other proprietary notices contained in the Vocagame.com service;
reverse engineer the Vocagame.com application or access and/or supporting system to (i) build a counter product or service, (ii) build a product or service using similar ideas, features, functions or graphics, or (iii) copy ideas, features, functions or graphics; launch automated programs or scripts, including, but not limited to, web crawlers, web robots, web indexers, bots, viruses, worms, or other similar applications and any program that may make multiple server requests per second, create a heavy load, or hinder the operation and/or performance of the Platform;
use robots, spiders, site search/retrieval applications, or other manual or automatic processes or processes to retrieve, index, "data mine", or in any way reproduce or circumvent the navigational structure or presentation of the Vocagame.com application and its contents.

CHANGES TO THE PRIVACY POLICY

Vocagame.com has the right to make updates and/or changes to the Privacy Policy from time to time if necessary for the security and convenience of User transactions on the Vocagame.com Platform without prior notice. The User hereby agrees that the User is responsible for reading carefully and checking this Privacy Policy from time to time to find out about any updates and/or changes. By continuing to access and use the services on the Vocagame.com Platform, the User is deemed to agree to the updates and/or changes to this Privacy Policy.

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