This Privacy Policy (“Policy”) along with the Terms & Conditions of the VCGamers Platform as stated on the related page, sets out the basis for all acquisition, collection, processing, analysis, display, opening, storage, changes, deletion and/or any form of management related to data or information that identifies or can be used to identify Users that Users provide to VCGamers or VCGamers collects from Users (hereinafter referred to as “Personal Data”).
This Privacy Policy is published by PT Sotta Teknologi Indonesia, the owner and operator of the VCGamers Platform (vcgamers.com) and VCGamers Partner Platform (partners.vcgamers.com), as a Personal Data Controller as defined in Law No. 27 of 2022 concerning Personal Data Protection (PDP Law) which has been in full force since October 17, 2024.
This policy applies to all Platform Users, including visitors, buyers, sellers, partners (resellers), and other parties who interact with VCGamers services, whether through the website, mobile application, or other electronic means managed by PT Sotta Teknologi Indonesia.
By using the VCGamers Platform and services, the User declares that they have read, understood, and agreed to all applicable provisions, including the Terms & Conditions and this Privacy Policy, and agrees to all VCGamers activities in using, collecting, processing, displaying, storing, changing, deleting and/or utilizing such data as stated in this Policy. If the User does not agree to this Policy, the User is advised to immediately stop accessing or using the VCGamers Platform services.
This policy is an integral part of the Platform Terms & Conditions.
Applicable Regulatory Basis:
– Law No. 27 of 2022 concerning Personal Data Protection (PDP Law)
– Law No. 19 of 2016 concerning Electronic Information and Transactions (ITE Law)
– PP No. 71 of 2019 concerning the Implementation of Electronic Systems and Transactions
– Minister of Communication and Information Regulation No. 20 of 2016 concerning Protection of Personal Data in Electronic Systems
Definition
In this Policy, the following terms have the following meanings:
- Platform are all VCGamers services that can be accessed through vcgamers.com, partners.vcgamers.com, VCGamers mobile application, and other electronic means managed by PT Sotta Teknologi Indonesia.
- User / You is any person who accesses, registers, or uses the Platform services, including buyers, sellers, partners, and visitors.
- Personal data is any data about a person who is identified or can be identified, either directly or indirectly, in accordance with Article 1 number 1 of the PDP Law.
- Sensitive Personal Data is personal data that requires stricter protection, including health data, biometric data, financial data, child data, and other data as regulated in Article 4 paragraph (2) of the PDP Law.
- Data Controller is PT Sotta Teknologi Indonesia, as the party that determines the purpose and method of processing User Personal Data.
- Data Processor is a third party that processes Personal Data on the instructions of the Data Controller, based on a binding data processing agreement.
- Data Subject is the User as a person whose Personal Data is processed by VCGamers.
- Processing is any operation on Personal Data, including collection, storage, use, disclosure, deletion and destruction.
- Consent is a statement of consent given freely, specifically, informed and unambiguous by the Data Subject to the processing of his/her Personal Data.
Collection of Personal Data
VCGamers collects Personal Data based on the principle of data minimization, namely collecting only data strictly necessary for the stated purposes. Data collection is carried out for the purposes of processing transactions, monitoring User activity, and facilitating the use of the Platform. The following categories and details of the data collected:
A. Data Submitted Directly by Users
- Account Identity: username, full name according to official identity, active email address, contactable telephone number, profile photo, and other information entered by the User during the account registration process.
- Identity Verification (KYC) Data: Population Identification Number (NIK), photo of KTP/official identity card, selfie photo with KTP (for biometric verification), Taxpayer Identification Number (NPWP), Business Identification Number (NIB), and other supporting identity documents requested in the identity verification process.
- Financial Data: Bank account information includes the bank name, account number, and account holder name; registered digital wallet (e-wallet) information; and the payment method used in each transaction.
- Transaction Data: purchase and sales history, details of products or services transacted, transaction amount, transaction date and time, transaction status, and cancellation and refund history.
- Communication Data: all messages, reports, complaints and reviews submitted to the VCGamers Customer Service team, as well as communications that occur between Users on the Platform.
B. Automatically Collected Data
- Device Technical Data: the IP address of the device used, browser type and version, device operating system (OS) type and version, device serial number or unique identifier, screen resolution, and device language settings.
- Activity Log Data: server logs that include the date and time of access, pages and features visited, duration of visit on each page, links clicked, User navigation patterns within the Platform, and errors or technical problems that occur during the usage session.
- Location Data: general device location information based on IP address, or more precise location data (GPS) if the User explicitly grants location access permission to the Platform.
- Cookies and Similar Tracking Technologies: Data collected through cookies, web beacons, pixel tracking, local storage, and other client-side tracking technologies. More information is available in the Cookie Policy.
C. Data from Third Parties
- Business Partners and Payment Gateways: data obtained from official business partners, payment service providers (payment gateways), and financial institutions that collaborate with VCGamers, according to the scope of cooperation that has been agreed upon and permitted by applicable regulations.
- Verification Service Provider: identity verification data from a third-party KYC (Know Your Customer) service provider appointed by VCGamers.
- Public Authorities: data obtained from authorized government agencies or authorities, if required for verification purposes or to fulfill applicable legal obligations.
Important Notes regarding Sensitive Personal Data: VCGamers collects several categories of Sensitive Personal Data during the KYC process, including biometric photos (selfies with ID cards) and financial data (bank account information). Sensitive Personal Data is processed only with the User's explicit consent, for specifically stated purposes, and with stricter security standards, including advanced encryption and strict access restrictions.
Legal Basis for Personal Data Processing
In accordance with Article 20 of the PDP Law, all processing of Personal Data by VCGamers is based on one or more of the following legal bases. VCGamers does not process Personal Data without a clear and accountable legal basis.
- Implementation of Agreements (Contracts) — Article 20 letter b of the PDP Law: This legal basis applies to the processing necessary to carry out the agreement between VCGamers and the User, including the creation and management of User accounts, processing of buying and selling transactions on the Platform, handling complaints and Customer Service services, and sending operational notifications regarding transactions and account security.
- Legal Obligations — Article 20 letter c of the PDP Law: This legal basis applies if processing is necessary to fulfill legal obligations imposed on VCGamers, including carrying out identity verification (KYC) in accordance with anti-money laundering provisions, reporting to PPATK (Financial Transaction Reports and Analysis Center), OJK (Financial Services Authority), Directorate General of Taxes, Ministry of Communication and Digital (Komdigi), and fulfilling official requests from law enforcement officials.
- Legitimate Interest — Article 20 letter f of the PDP Law: This legal basis applies to processing necessary to fulfill the legitimate interests of VCGamers or third parties, as long as it does not override the rights and interests of Users, including prevention and investigation of fraud or suspicious transactions, enhancement of system and Platform security, performance analysis and service development, and transfer of data to VCGamers Asia Pte. Ltd affiliates within the framework of the group's business operations.
- Consent — Article 20 letter a of the PDP Law: This legal basis applies to optional processing that requires explicit consent from the User, particularly for sending promotional information, product offers, and marketing communications. This consent is voluntary and can be withdrawn at any time by the User without any consequences for the primary service received.
Use of Personal Data
VCGamers uses User Personal Data responsibly, solely for the purposes stated in this policy, and will not use Personal Data for any other purpose without prior notification to the User. The detailed purposes for using Personal Data are as follows:
- Platform Service Operations: processing all requests, activities and transactions made by Users, including managing accounts, activating Platform features, completing orders, processing payments, verifying payments, processing withdrawals, and providing a smooth and secure shopping experience.
- Customer Support and Service: handle all complaints, questions, reports, and requests submitted to the Customer Service team; examine and resolve User issues; provide responses and solutions to problems experienced; and contact Users via email, telephone, WhatsApp, or other means of communication for the purposes of problem solving and information confirmation.
- Platform Security and Fraud Prevention: detect, investigate, and prevent all forms of fraud, cheating, money laundering, misuse of the Platform, violations of Terms & Conditions, and other illegal activities; monitor suspicious transactions; and take necessary preventive and enforcement actions to protect the Platform ecosystem and all its Users.
- Fulfillment of Legal and Regulatory Obligations: comply with applicable regulatory requirements, including reporting suspicious transactions to the PPATK, reporting tax obligations to the Directorate General of Taxes, fulfilling supervisory requirements from the OJK and Komdigi, and complying with court orders or official requests from other competent authorities.
- Marketing Communications and Promotion: Informing Users who have given their explicit consent about products, services, new features, loyalty programs, promotions, discounts, and Platform updates. All marketing communications include the option for Users to unsubscribe at any time via the unsubscribe link provided in each message or through the account settings menu.
- Product Development and Improvement: analyze aggregate and anonymous Platform usage pattern data to identify areas for improvement, develop new, more relevant features and services, improve user experience, and conduct comprehensive system performance testing and monitoring.
- Identity and Eligibility Verification: carry out Know Your Customer (KYC) processes to verify the User's identity, ensure the User's eligibility to use certain features (such as large withdrawals), and comply with applicable anti-money laundering and anti-terrorism financing regulations.
Protection and Disclosure of Personal Data
VCGamers is committed to maintaining the confidentiality of User Personal Data under its control. VCGamers will not sell, rent, trade, distribute, or lend User Personal Data to third parties for their commercial interests. Personal Data will only be disclosed under the following circumstances, while prioritizing the protection of User rights:
- VCGamers Designated Data Processors: VCGamers collaborates with selected third parties acting as Data Processors, namely parties that process Personal Data solely on VCGamers' instructions and for the purposes specified. Each Data Processor is bound by a legally binding Data Processing Agreement, containing strict confidentiality obligations, technical and organizational security standards equivalent to those implemented by VCGamers, a strict prohibition on processing or using Personal Data outside of VCGamers' instructions, and an obligation to report any security incidents that occur. The categories of Data Processors that collaborate with VCGamers include: cloud infrastructure and hosting service providers; payment gateways and payment service providers licensed and supervised by Bank Indonesia or the OJK; certified identity verification service providers (KYC providers); platform performance measurement and analytics service providers; and communication service providers (transactional email, SMS, push notifications).
- Government Authorities and Law Enforcement Officials: VCGamers may disclose Personal Data to government agencies, regulators, or law enforcement officials under the following conditions: (a) upon a valid official request with a clear legal basis in accordance with applicable laws and regulations; (b) in order to fulfill VCGamers' legal obligations, including mandatory reporting to the Financial Transaction Reports and Analysis Center (PPATK), Financial Services Authority (OJK), Directorate General of Taxes, or Komdigi; (c) to protect the safety of a person's life or in an emergency that threatens public safety. Disclosure to law enforcement officials may be made without prior notification to the User if it is prohibited by applicable laws or orders.
- Affiliated Companies in the VCGamers Group: Personal Data may be shared with VCGamers' parent company, VCGamers Asia Pte. Ltd., domiciled in Singapore, and other affiliated entities within the VCGamers group, for integrated business operations, consolidated reporting, joint product development, and other group business purposes. Any affiliated entity receiving Personal Data is bound by privacy policies and data security standards that are equivalent to or stricter than this Policy. Data transfers to affiliated entities outside Indonesia are subject to cross-border data transfer provisions as set out in the Cross-Border Data Transfers section.
- Data Transfer in Corporate Transactions: In the event of a merger, acquisition, consolidation, restructuring, or transfer of all or part of VCGamers' business to another party, User Personal Data may be part of the assets transferred to the successor or acquiring entity. In such circumstances, VCGamers will notify Users via registered email and/or an official announcement on the Platform no later than 14 calendar days before the data transfer takes effect. The successor entity must be bound by this Privacy Policy or implement a privacy policy that provides no less protection than this Policy.
VCGamers stores Personal Data on servers located in Indonesia and/or Singapore, with the implementation of comprehensive technical and organizational security measures, including encryption of data-at-rest and data-in-transit using the latest industry standards; role-based access control that ensures only authorized personnel can access Personal Data; continuous 24-hour system security monitoring; periodic security audits by internal parties and independent external auditors; and documented data backup and recovery procedures (disaster recovery).
Data Retention Period
VCGamers retains Personal Data only for as long as necessary to fulfill the stated processing purposes, or as required by applicable laws and regulations. Once it is no longer needed, Personal Data will be securely deleted or destroyed using methods that prevent data recovery. The minimum retention periods for each category of data are as follows:
- Active account data: stored as long as the User's account is active and in use. This data is necessary for the execution of the service agreement between VCGamers and the User.
- Account data after deactivation or deletion: stored for 5 (five) years after the account is deactivated or deleted, based on the obligations of the PDP Law and VCGamers' internal policies for the purposes of resolving claims or disputes that may arise after the relationship ends.
- Financial transaction data: stored for 10 (ten) years from the date of the transaction, in accordance with legal obligations under the Banking Law, Taxation Law, and other related regulations that require the storage of financial records for that period.
- KYC data and identity verification: stored for 5 (five) years after the business relationship between VCGamers and the User ends, in accordance with the obligations under Law No. 8 of 2010 concerning the Prevention and Eradication of Money Laundering Crimes (TPPU Law) Article 25.
- Activity logs and security logs: stored for 2 (two) years, in accordance with PP No. 71 of 2019 concerning the Implementation of Electronic Systems and Transactions which regulates the obligation to store system logs.
- Communication recording with Customer Service: stored for 3 (three) years, based on Law No. 8 of 1999 concerning Consumer Protection, for the purposes of dispute resolution and proof of service.
- Data relating to disputes or litigation: stored until the dispute, mediation or litigation process in question is legally completed, plus 1 (one) year thereafter, to ensure the availability of the necessary evidence during the legal process.
VCGamers periodically reviews the Personal Data stored to ensure that no data is stored beyond the required time limit. If Personal Data is no longer needed and there is no legal obligation to store it, VCGamers will securely delete or destroy it, or anonymize the data so that it can no longer be linked to the User's identity.
Cross-Border Transfer of Personal Data
In carrying out its business operations, User Personal Data may be transferred to and processed outside the territory of the Republic of Indonesia, specifically to servers and data processing facilities located in Singapore for the operational purposes of VCGamers Asia Pte. Ltd as the parent company, as well as to other locations made possible by cooperation with international Data Processors.
VCGamers ensures that any cross-border data transfer is carried out in full compliance with the provisions of Article 56 of the PDP Law, with the following protection guarantees:
- Assessment of the Protection Level of the Destination Country: VCGamers ensures that the destination country of the transfer (specifically Singapore) has a legal framework for personal data protection that is equivalent to or higher than the standards set by the Indonesian PDP Law, based on VCGamers' internal assessment and/or recommendations from the competent supervisory authority.
- Additional Protections for Countries with Lower Standards: If data transfers are made to countries or jurisdictions where the level of personal data protection has not been assessed as equivalent, VCGamers must ensure that there are adequate additional safeguards, in the form of: (a) internationally recognized standard data protection clauses (SCCs); or (b) binding corporate rules (BCRs) within the scope of the VCGamers business group that have been approved by a supervisory authority.
- User Agreement: By using the VCGamers Platform, Users knowingly consent to the data transfer as referred to in this section. This consent is part of the general consent to the Privacy Policy provided when Users register or use the Platform.
- Right to Information: Users have the right to obtain further and more detailed information regarding the mechanisms, purposes, and security guarantees applied in every cross-border data transfer carried out by VCGamers, by contacting the VCGamers privacy team via the contact listed in the Contact Us section.
Cookie Policy and Tracking Technologies
Cookies are small data files that are automatically stored on a User's device when they visit the VCGamers Platform. Cookies work by storing certain information on the User's device, which is then read back by the VCGamers server on subsequent visits, allowing the Platform to recognize the User, remember preferences, and provide a more personalized and efficient experience. Cookies are not used to access or read other data stored on the User's device beyond what has been authorized.
The following are the types of cookies used by VCGamers and their respective functions:
- Essential Cookies (Strictly Necessary Cookies): These are cookies that are absolutely necessary for the Platform's basic functions to function properly. These cookies manage the User's login session (so that the User doesn't have to re-login every time they change pages), store items in the shopping cart, maintain session security, and prevent security attacks such as cross-site request forgery (CSRF). Essential cookies cannot be disabled by the User, as this would prevent the Platform from functioning properly. These cookies do not collect information that can be used for marketing purposes.
- Preference Cookies (Preference/Functionality Cookies): These cookies enable the Platform to remember choices and settings made by Users, such as display language preferences, interface settings, time zone, and other personalized feature configurations. Without these cookies, Users may need to reset their preferences each time they visit the Platform.
- Analytics Cookies (Analytics/Performance Cookies): These cookies are used to collect information about how Users interact with the Platform, including the most frequently visited pages, duration of visits, navigation flow, most frequently used features, and any error messages. The collected data is aggregated and anonymous, and therefore cannot be used to identify individual Users. This information is used solely for the purposes of improving service quality and developing the Platform.
- Marketing/Targeting Cookies: These cookies are used to serve advertisements and promotional content relevant to User interests and behavior on the Platform and on third-party websites partnering with VCGamers. Marketing cookies will only be activated if the User explicitly consents via the cookie consent banner. Users can revoke this consent at any time.
Users can manage and control the use of cookies in several ways: (a) using browser settings to disable or delete cookies, with the note that disabling essential cookies will affect the functionality of the Platform; (b) selecting cookie preferences via the cookie consent banner displayed when first accessing the Platform; or (c) setting cookie preferences via the privacy settings menu available in the registered User account.
User Rights as Data Subjects
In accordance with Articles 5 to 16 of the PDP Law, VCGamers recognizes and respects the rights of Users as Data Subjects over their Personal Data. VCGamers is committed to fulfilling every request submitted within 14 (fourteen) Business Days of receiving a complete and qualified request. The following details User rights and how to exercise them:
- Right to Obtain Information (Article 5 of the PDP Law): Users have the right to obtain clear, transparent, and easy-to-understand information regarding the identity and contact of VCGamers as the Data Controller, the legal basis and purpose of processing Personal Data, the types of Personal Data collected and processed, the data retention period, the identity and categories of third parties who receive Personal Data, as well as the rights of Users and how to exercise them.
- Right of Access (Article 6 of the PDP Law): Users have the right to obtain confirmation of whether VCGamers processes their Personal Data, as well as to obtain a copy of the Personal Data held and processed by VCGamers in a structured, human-readable format. VCGamers reserves the right to charge a reasonable fee for excessive or repeated requests for data copies.
- Right to Correction (Article 7 of the PDP Law): Users have the right to request corrections, updates, or supplements to inaccurate, incomplete, irrelevant, or outdated Personal Data. For some data, Users can make corrections independently through the account settings menu on the Platform without the need for a formal request.
- Right of Deletion (Article 8 of the PDP Law): Users have the right to request the deletion of their Personal Data if the data is no longer necessary for the original processing purposes, the User withdraws consent and there is no other legal basis for the processing, or the processing is unlawful. This right does not apply if the processing is still necessary for fulfilling a legal obligation, in the public interest, or defending VCGamers' legal rights.
- Right to Restrict Processing (Article 9 of the PDP Law): Users have the right to request that VCGamers restrict the processing of their Personal Data under certain conditions, such as when the User disputes the accuracy of the data (restrictions apply during the verification process), when the processing is unlawful but the User desires restriction rather than deletion, or when VCGamers no longer requires the data but the User requires it for legal purposes.
- Right to Data Portability (Article 10 of the PDP Law): Users have the right to receive their Personal Data provided to VCGamers in a structured, commonly used, and machine-readable format (such as JSON or CSV), and to transfer such data to another data controller without hindrance from VCGamers. This right applies to data processed based on consent or the execution of an agreement and carried out automatically.
- Right to Object (Article 11 of the PDP Law): Users have the right to object to processing of Personal Data based on legitimate interests, including for profiling or direct marketing purposes. If an objection is raised regarding direct marketing, VCGamers must immediately cease processing for that purpose. For objections to processing based on other legitimate interests, VCGamers will conduct an assessment and provide an adequate response.
- Right to Withdraw Consent: Users have the right to withdraw consent previously granted for the processing of Personal Data at any time without providing a reason. Withdrawal of consent will not affect the lawfulness of processing carried out prior to the withdrawal. Withdrawals can be made through the account settings menu or by contacting Customer Service. Please note that withdrawing consent for data that is a prerequisite for the service may result in limited access to certain features or account deactivation.
- Right to Automated Decision Making (Article 13 of the PDP Law): If VCGamers uses an automated system to make decisions that have a legal or significant impact on Users (such as decisions about creditworthiness or account restrictions), Users have the right to request that such decisions be reviewed with the involvement of human judgement, and have the right to receive an explanation of the logic and impact of such automated decisions.
To apply for the above rights, Users can send an email to [email protected] with subject: [DATA SUBJECT RIGHTS] – Request Type, along with the full name, email address registered on the Platform, the type of rights requested, and a brief explanation of the request. VCGamers reserves the right to verify the applicant's identity before processing the request. For complex requests or those requiring more in-depth review, the response time may be extended to 30 (thirty) days upon notification to the User. If VCGamers is unable to fulfill the request, the User will be provided with a clear explanation along with information on further steps that can be taken.
Policy Regarding Children
The VCGamers platform is designed and intended for use by individuals aged 18 (eighteen) years and over, in accordance with the age limits set out in the PDP Law and Law No. 35 of 2014 concerning Child Protection. VCGamers recognizes the importance of protecting children's personal data and is committed to not collecting, storing, or processing Personal Data from children without adequate supervision.
- VCGamers does not knowingly collect, solicit, or store Personal Data from anyone under the age of 18 (eighteen). If a User is under the age of 18, VCGamers strongly recommends that parents or guardians provide full supervision of their children's online activities.
- If a User is under 18 years of age and wishes to use the Platform, such use may only be made with the written consent and under the direct supervision of a parent or legal guardian. Parents or guardians are fully responsible for all activities and transactions conducted by children under their supervision.
- Parents or guardians who provide consent for the use of the Platform by children under their supervision are deemed to have read, understood, and agreed to all provisions of this Privacy Policy on behalf of the child, and are fully responsible for the child's use of the Platform.
- If VCGamers learns or discovers that Personal Data from a child under the age of 18 has been collected without the consent of a parent or legal guardian, VCGamers will immediately take the necessary steps, including deleting the child's Personal Data from the system and closing the relevant account, and if necessary, informing the parent or guardian of the incident if their identity and contact information can be identified.
- Parents or guardians who suspect or become aware that the Personal Data of a child under their care has been collected by VCGamers without valid consent, can immediately contact the VCGamers team via the contact listed in the Contact Us section to request deletion of the data.
Data Security Incident Handling
VCGamers has a dedicated team and procedures designed to respond to data security incidents (data breaches) quickly, in a coordinated, and responsible manner, in accordance with Article 46 of the PDP Law. VCGamers' incident handling procedures include the following steps:
- Early Detection and Initial Assessment: As soon as a security incident is detected or reported, the VCGamers security team will immediately activate the incident response protocol. The team will conduct an initial assessment, including identifying the source and cause of the incident, determining the scope of the affected data, assessing the severity and risk, and implementing containment measures to prevent further spread of the incident.
- Mandatory Reporting to Competent Authorities: Within a maximum of 14 (fourteen) calendar days of the incident being confirmed, VCGamers are required to submit an official report to the Ministry of Communication and Digital (Komdigi) and/or the National Cyber and Crypto Agency (BSSN), in accordance with the reporting mechanisms established by each agency. The report includes: a complete description of the nature and chronology of the incident; the categories and estimated amount of Personal Data affected; the estimated number of Data Subjects affected; the potential consequences of the incident; and the mitigation measures that have been, are being, and will be taken by VCGamers.
- Immediate Notification to Affected Data Subjects: VCGamers will directly contact any User whose Personal Data is affected by the incident, via the email address registered on the Platform. Notification will be delivered in clear and easy-to-understand language, containing: a detailed explanation of what happened and when the incident occurred; the specific categories of Personal Data affected and the estimated amount of data exposed; the potential risks and consequences that the User may face as a result of the incident; concrete steps that VCGamers has taken to address the incident and protect User data; and recommendations for practical actions that Users can take to protect themselves, such as changing passwords, monitoring account activity, or other relevant security measures.
- System Recovery and Corrective Action: Once the incident has been successfully brought under control, VCGamers will perform a full system recovery to ensure the Platform returns to normal and secure operation, and implement any necessary corrective actions to close the exploited security gap.
- Post-Incident Evaluation and System Improvement: VCGamers will conduct a thorough post-incident review of the incident to identify the root cause, assess the effectiveness of the response, and formulate systematic corrective measures to prevent similar incidents from occurring in the future. The results of this evaluation will be used as a basis for continuous improvement of VCGamers' security systems and operational procedures.
Cancellation of Consent
- Users have the full right to withdraw their consent to the processing of certain Personal Data at any time without needing to provide justification or reasons to VCGamers. Withdrawing consent is a User right guaranteed by the PDP Law and cannot be restricted or complicated by VCGamers.
- Withdrawal of consent by a User will not affect the validity or legality of all processing of Personal Data carried out by VCGamers prior to the date of such withdrawal. This means that all data processing occurring during the period while consent was still valid remains legally valid.
- VCGamers is committed to processing and following up on any request for withdrawal of consent within 14 (fourteen) Business Days of receiving a complete request. During the processing period, VCGamers will temporarily suspend processing of the Personal Data covered by the request for withdrawal of consent.
- Users should understand that not all processing of Personal Data is based on their consent. Some processing is based on other legal grounds, such as legal obligations or the performance of an agreement. Therefore, withdrawing consent will not stop processing based on that legal ground. VCGamers will clearly inform Users of the specific impact of any withdrawal of consent.
- If withdrawing consent is a prerequisite for the provision of certain services or the entire Platform service, the User needs to understand that such withdrawal may result in: (a) limiting the User's access to certain features that require the processing of such data; or (b) deactivation of the account if the data for which consent is withdrawn is a fundamental prerequisite for the use of the Platform. In such circumstances, VCGamers will inform the User of the consequences that will occur before proceeding with the deactivation process.
- If a User has any concerns, questions, or complaints regarding VCGamers' handling of their Personal Data, or if they feel their privacy and rights to their Personal Data have been violated, they are encouraged to contact VCGamers immediately through the official communication channels listed in the Contact Us section. VCGamers is committed to investigating every complaint seriously and providing an adequate response and appropriate solution within a reasonable timeframe.
Contact us
VCGamers is committed to handling all questions, requests, and complaints regarding this Privacy Policy or User Personal Data seriously and responsively. Users can contact us through the following channels:
- Email Privacy: [email protected] — use the subject line: [PRIVACY] followed by a brief description of your needs. Our team will respond within 14 business days.
- Customer Service: through the “Contact Us” feature available on the Platform vcgamers.com or partners.vcgamers.com, for faster handling during working days and hours.
- Correspondence Address: PT Sotta Teknologi Indonesia, Jl. Kemang Pratama Raya Block A No. 6, RT 001/RW 011, Rawalumbu District, Bekasi City, West Java 17114, Indonesia.
If the User feels that his/her privacy rights and protection of Personal Data are not being adequately fulfilled by VCGamers after going through the internal complaint procedure, the User has the right to submit an official complaint to the competent data protection supervisory authority in Indonesia:
- Ministry of Communication and Digital (Komdigi) as a supervisory body for the implementation of the PDP Law: www.komdigi.go.id
- National Cyber and Crypto Agency (BSSN) for complaints regarding cybersecurity incidents and data leaks: www.bssn.go.id
- Financial Services Authority (OJK) specifically for complaints related to financial data processing: www.ojk.go.id
Privacy Policy Changes
- VCGamers reserves the right to update, revise, or change this Privacy Policy from time to time, in line with developments in business activities, changes in the technology used, or if required by changes in laws and regulations and provisions from authorized government institutions.
- For any material changes — that is, changes that significantly and directly affect User rights, the way Personal Data is collected or used, or the parties with whom Personal Data is shared — VCGamers commits to providing adequate notice to Users at least 14 (fourteen) calendar days before the changes become effective. Notification will be provided via the email registered on the Platform and/or through a prominent announcement on the Platform's homepage.
- For minor or immaterial changes — such as editorial corrections, language clarifications, updates to contact information, or adjustments that do not substantially change the User's rights and obligations — VCGamers may directly update the Privacy Policy text on this page without the need to provide separate notification to Users.
- The most recent version and effective date of the Privacy Policy will always be prominently displayed at the top of this page. VCGamers strongly encourages Users to regularly review this Privacy Policy page to ensure they are up-to-date with VCGamers' privacy practices.
- By continuing to use the VCGamers Platform after the effective date of the Privacy Policy changes, Users are deemed to have read, understood, and agreed to the updated Privacy Policy. If Users do not agree to the changes, they are advised to immediately discontinue use of the Platform and may request account deletion from VCGamers.
In the event of any conflict, discrepancy or difference in interpretation between the Indonesian language version of this Policy and its translation in another language, the Indonesian language version shall prevail and be deemed the official binding version.
June 2, 2026