PRIVACY POLICY

Orangetopia

Effective 15 May, 2023

This Privacy Policy (or “Policy”) explains how PT Hanwha Life Insurance Indonesia (“we” or “us” in this Policy) uses, collects, or otherwise processes the personal data of the end users (“you” in this Policy) in our Services, which is our compliance with the laws of the Republic of Indonesia, especially in Law no. 27 of 2022 concerning Protection of Personal Data and its implementing regulations and their amendments from time to time. This policy also explains what rights you have related to our processing of your personal data.

In this policy the term “Services” refers to our games, websites, and any other services offered by us, unless a separate notice is supplied with a particular service.

Please note that some parts of our Services may link to properties controlled by third parties. Such properties are not governed by this policy and the operators of those properties may process your personal data in accordance with their own .

This policy includes information pertaining to your rights and is supplement to our Terms of Service, which govern your use of the Services. Please note that we may from time to time update this policy by posting a new version on https://hanwhalife.co.id/. If we make any material changes, we will notify you by posting a notice in the Services prior to the change becoming effective. Your continued use of the Services after the effective date will be subject to the updated policy.

Data controller

In this policy the term “Data Controller” means an entity that decides how and why personal data is processed. The Data Controller for our Services is PT Hanwha Life Insurance Indonesia, having its address at World Trade Center 1, 12th Floor, Jl. Jenderal Sudirman Kav.29, Kuningan, Karet, Kecamatan Setiabudi, Jakarta 12920.

With your consent some personal data may be shared with our partners, Luxrobo providing the application base and Aldmic Coopn providing e-voucher rewards. These partners are individual data controllers independently determining how they process your personal data. For more information on how our partners process your personal data please review our list of .

How to contact us

If you have questions about data protection or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through our games so we can reply to you more quickly.

You can also reach us and our designated by email at Orangetopia@hanwhalife.co.id

We use your personal data for various purposes in connection with your use of the Services. The purpose and types of personal data are listed by their basis below.

 

Performance of contract. In order to provide you with the Services we process personal data necessary to:

  • create accounts and allow you to play our games and use our Services;
  • operate the Services;
  • verify and confirm payments;
  • provide and deliver products and services you request; and
  • send you communication related to the Services.

Legitimate Interests. In order to make our Services more enjoyable we process your personal data in order to:

  • update and develop player profiles;
  • develop and improve the Services and player experience;
  • manage our relationship with you;
  • provide social features as part of the Services;
  • customize your Service experience;
  • respond to your comments and questions and provide player support;
  • provide you offers in the Services related to other Hanwha Life Insurance Indonesia products and services;
  • send you related information, such as updates, security alerts, and support messages; and
  • enable you to communicate with other players.

Legitimate Interests. In order to keep the Services safe and fair we process your personal data to:

  • analyze and monitor use of the Services and their social features;
  • moderate chats either automatically or manually;
  • take action against fraudulent or misbehaving players; and
  • prevent harassment and cyber-bullying.

Legitimate Interests. In order to promote and monetize our Services to you, we may process your personal data to:

  • show non-targeted ads to you in our Services, either from us or our advertising partners;
  • keep track of your activity in our Services to learn about your interests;
  • keep track of installations and installation source of our games;
  • measure, analyze and improve the effectiveness of our advertising both in and outside of the Services; and
  • send you communications about offers, rewards, events, or other news related to the Services.

 

Consent. With your separate consent we may process your personal data in order to:

  • share it with our advertising partners for their independent use. These uses may include creating a personalized ad profile about you, selecting personalized ads for you, measuring ad performance, generating audience insights, and other uses:
  • to send you newsletters or other similar communication if you have subscribed to them; and
  • any other purposes as described in the relevant consent screen in the applicable Services.

Your personal data is being processed and collected throughout your use of the Services, such as technical data related to your device or internet connection. Some personal data is processed automatically where some require your input, such as providing a user name to be used in the Services.

 

We process data you provide in the Services, such as:

  • player nickname entered in-game;
  • in-game chat messages; and
  • other data you choose to give us (such as your email address and information in player support tickets)

 

We process personal data automatically as part of delivering the Services, such as:

  • your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address and IMEI);
  • data about your device, such as device name and operating system, browser type and language;
  • data we collect with cookies and similar technologies (see more below);
  • coarse location data (country or city-specific); and
  • we also may create a Hanwha Life and/or game-specific ID for you when you use the Services.

We process personal collected or enriched with data from our partners:

  • data we receive if you link a third-party tool with the Services (such as login using your WhatsApp, Facebook or Google );
  • demographic data (such as to determine the coarse location of your IP address);
  • data to fight fraud (such as refund abuse in games);
  • data from platforms that the games run on (such as to verify payment); and
  • data for advertising and analytics purposes, so we can keep improving our games.

 

 

Apart from Hanwha Life Insurance Indonesia, your personal data can be accessed by others in the following situations:

Other players and users

Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

Partners working for Hanwha Life Insurance Indonesia

Hanwha Life Insurance Indonesia has partners to perform certain services on our behalf. These partners process your data only at and according to Hanwha Life Insurance Indonesia’s instructions to provide the Service, such as hosting, player support, advertising, analytics, and fraud prevention.

Hanwha Life Insurance Indonesia’s development partners

Hanwha Life Insurance Indonesia may publish games developed or maintained by other game development companies. These development partners may process your personal data for the purposes described herein and where applicable, working as joint controllers of the processed data together with Hanwha Life Insurance Indonesia. These partners are listed at  Hanwha Life Insurance Indonesia Partners.

Other companies and public authorities

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.

We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

Advertising and social media partners

The Services include features from our partners, such as social media interaction tools and in-game advertising. A list of these partners is available at  Hanwha Life Insurance Indonesia Partners. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

International data transfers

Our Services are global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy.

We will keep your personal data for as long as necessary to achieve the purposes for which it was collected, including to provide you with the Services or to comply with any legal, accounting, or reporting requirements. We periodically delete or de-identify inactive accounts or other data in our Services.

After the applicable retention period, we will either delete or de-identify your personal data or, if neither deletion or de-identification is possible (for example, due to data being stored on a backup server), isolate your data from further processing until deletion or de-identification is possible. We may continue to use any data that is not identifiable to you (for example, aggregated data).

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

All data security measures are adopted in order to provide a level of security appropriate for the degree of risk involved. These measures are designed to protect your data against accidental or unlawful destruction, loss, or alteration as well as unauthorized disclosure or access. The specific measures typically include, encryption in transit, pseudonymization of identifying data where feasible, controls to limit access to services or systems that contain personal data, and maintaining procedures to handle any suspected security incidents. Please consider that the internet is an inherently insecure environment and we cannot guarantee absolute security for your data.

Your rights regarding your personal data

You have the right to a access and obtain a copy of your personal information to be supplied to you in an electronic format upon request.

You also have the right to obtain information regarding clarity of identity, basis of legal interest, purpose of requesting and using your personal data and the accountability of party requesting your personal data, to complete, update and/or correct your data, have your data deleted, object to how we use or share your data, and the right to restrict how we use or share your data. If certain personal data is processed based on consent given by you, such consent can also be withdrawn by you at any time, for example in the applicable game’s settings.

We will respond to all requests within a reasonable time frame.

Request for access, correction or other queries relating to your personal data should be address to:

 

PT HANWHA LIFE INSURANCE INDONESIA

World Trade Center 1, Lantai 12

Jl. Jenderal Sudirman Kav.29, Kuningan, Karet, Kecamatan Setiabudi

Jakarta 12920

Phone: (021) 50816100

Email:

or by using the “Contact Support” feature available in some of our Services

 

Hanwha Life Insurance Indonesia has the right to charge costs that are directly related to and necessary for the processing of any personal data access request.

Opt-out of targeted advertising

You can always opt-out of directed advertising in our games by checking the privacy settings of your device or by using the applicable opt-out function provided by Hanwha Life Insurance Indonesia’s Partners. Please review your device’s user manual or the applicable Partner privacy policy on how to do so.

 

Nearly all websites today use cookies or similar technologies (such as local shared objects or web beacons). A “cookie” is a small file your browser stores when told to do so by a website. Cookies can be set by either the website you visit or a third party involved in providing content, functionality, or services such as analytics or advertising for the website. Cookies are typically used to identify or “remember” your device, for example to enable functionality, facilitate audience measurement, improve performance, or remember your online shopping cart contents.

When you visit our website(s) you may be prompted to make a choice regarding cookies. Some cookies may be strictly necessary for the operation of the websites, where some may be optional. All cookies will be used and stored on your device independent of your choices regarding other types of cookies. You can also control the use of cookies using your browser or device settings for example by disabling some or all cookies or configuring your browser or device to notify you when cookies are being set. Please note that disabling cookies may affect your ability to use the Services.

Our Services are intended and designed for adults. As such when you access and use our Services we may ask you to confirm your age. If we discover that you are a minor or do not meet another age threshold we have applied we may take steps to limit, suspend, or terminate your access to the Services where we believe that to be necessary due to applicable regulatory or platform requirements or to provide you with an appropriate experience. If your access to the Services is not suspended or terminated, we alter or remove access to some parts of the Services in order to comply with applicable laws, regulations, and platform policies.

If you are a parent or guardian and You are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from child without verification of parental consent, we take steps to remove that information from our servers.