Policy on the Processing of Personal Data
1. General Provisions
This Personal Data Processing Policy is prepared in accordance with applicable requirements and defines the procedure for processing personal data, as well as measures undertaken by PT. LOYO DEVELOPMENT BALI (hereinafter referred to as the "Operator") to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family confidentiality, to be one of its most important objectives and conditions for conducting its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://lb-club.com/.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, that ensure their availability on the Internet at the network address https://lb-club.com/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that render it impossible, without the use of additional information, to determine the ownership of personal data by a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or 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), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a public authority, municipal authority, legal or natural person, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://lb-club.com/.
2.9. Personal data allowed by the subject for distribution — personal data to which an unlimited number of persons are granted access by the personal data subject by giving consent for the processing of personal data allowed for distribution in the prescribed manner (hereinafter referred to as "personal data allowed for distribution").
2.10. User — any visitor of the website https://lb-club.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data known to an indefinite group of persons, including the publication of personal data in mass media, placement in information and telecommunication networks, or granting access to personal data by any other means.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with no possibility of further restoration of the content of personal data in the personal data information system and/or the destruction of tangible media containing personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject accurate information and/or documents containing personal data;
— continue processing personal data without the consent of the personal data subject in cases where the subject withdraws consent or submits a request to terminate the processing of personal data, provided there are legal grounds for such processing;
— independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations related to the processing of personal data.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with applicable legislation;
— respond to inquiries and requests from personal data subjects and their legal representatives;
— provide the authorized body for the protection of the rights of personal data subjects, upon request, with the required information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— implement legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as other unlawful actions in relation to personal data;
— cease the transfer (distribution, provision, access) of personal data, terminate processing, and destroy personal data when required;
— fulfill other obligations as established by applicable data protection laws.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data. Such information shall be provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except in cases where there are grounds for disclosing such personal data;
— request the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose;
— impose the condition of prior consent for the processing of personal data for the purpose of promoting goods, works, or services in the market;
— withdraw consent to the processing of personal data, as well as submit a request to cease the processing of their personal data;
— appeal to the authorized body for the protection of personal data subjects’ rights or through the court against unlawful actions or inaction by the Operator regarding the processing of their personal data.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any updates, changes, or corrections to their personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without their consent shall bear responsibility.
5. Principles of Personal Data Processing
5.1. Personal data processing shall be carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of data collection is not permitted.
5.3. The merging of databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data that meet the purposes of their processing shall be subject to processing.
5.5. The content and volume of processed personal data shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed.
5.6. Personal data processing shall ensure the accuracy, sufficiency, and, when necessary, relevance of personal data in relation to the purposes of processing. The Operator shall take or ensure the taking of necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that permits identification of the personal data subject no longer than required by the purposes of personal data processing, unless otherwise established by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or loss of necessity to achieve those purposes, unless otherwise provided by law.
6. Purposes of Personal Data Processing
Purpose of Processing:
To provide the User with access to services, information, and/or materials contained on the website.
Personal Data:
Transfer of personal data
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. Personal data processing is necessary to achieve the objectives provided by an international treaty for the fulfillment of the functions, powers, and duties assigned to the Operator.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a court decision, act of another authority, or official.
7.4. Personal data processing is necessary for the performance of a contract, where the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to protect the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data processing is performed for personal data that the personal data subject has made publicly available or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is performed for personal data subject to publication or mandatory disclosure in accordance with applicable law.
8. Procedure for Collecting, Storing, Transmitting, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable data protection laws.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable laws or if the personal data subject has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil law contract.
8.3. If inaccuracies in personal data are detected, the User may update them independently by sending a notification to the Operator’s email address info@loyo-development.com with the subject line "Personal Data Update."
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is specified by contract or applicable law.
The User may withdraw consent to personal data processing at any time by sending a notification to the Operator via email at info@loyo-development.com with the subject line "Withdrawal of Consent to Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is advised to familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except granting access), as well as on the processing or conditions of processing (except obtaining access) of personal data allowed for distribution, do not apply when processing personal data in the interests of the state, society, or other public interests.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject no longer than required by the purposes of processing, unless the storage period is established by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The conditions for termination of personal data processing may include achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the personal data subject, a request to cease processing, or detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Collected Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without such transmission.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator is required to notify the authorized body responsible for protecting the rights of personal data subjects about its intention to carry out such cross-border transfer (this notification is sent separately from the notification of the intention to process personal data).
10.2. Prior to submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by applicable law.
12. Final Provisions
12.1. The User may obtain any clarifications on questions concerning the processing of their personal data by contacting the Operator via email at info@loyo-development.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://lb-club.com/.
This Personal Data Processing Policy is prepared in accordance with applicable requirements and defines the procedure for processing personal data, as well as measures undertaken by PT. LOYO DEVELOPMENT BALI (hereinafter referred to as the "Operator") to ensure the security of personal data.
1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the right to privacy, personal and family confidentiality, to be one of its most important objectives and conditions for conducting its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the "Policy") applies to all information that the Operator may obtain about visitors to the website https://lb-club.com/.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data — processing of personal data using computing technology.
2.2. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
2.3. Website — a collection of graphic and informational materials, as well as computer programs and databases, that ensure their availability on the Internet at the network address https://lb-club.com/.
2.4. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Depersonalization of personal data — actions that render it impossible, without the use of additional information, to determine the ownership of personal data by a specific User or another personal data subject.
2.6. Processing of personal data — any action (operation) or 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), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a public authority, municipal authority, legal or natural person, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data — any information relating directly or indirectly to an identified or identifiable User of the website https://lb-club.com/.
2.9. Personal data allowed by the subject for distribution — personal data to which an unlimited number of persons are granted access by the personal data subject by giving consent for the processing of personal data allowed for distribution in the prescribed manner (hereinafter referred to as "personal data allowed for distribution").
2.10. User — any visitor of the website https://lb-club.com/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data — any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data known to an indefinite group of persons, including the publication of personal data in mass media, placement in information and telecommunication networks, or granting access to personal data by any other means.
2.13. Cross-border transfer of personal data — the transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data — any actions resulting in the irreversible destruction of personal data with no possibility of further restoration of the content of personal data in the personal data information system and/or the destruction of tangible media containing personal data.
3. Main Rights and Obligations of the Operator
3.1. The Operator has the right to:
— receive from the personal data subject accurate information and/or documents containing personal data;
— continue processing personal data without the consent of the personal data subject in cases where the subject withdraws consent or submits a request to terminate the processing of personal data, provided there are legal grounds for such processing;
— independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations related to the processing of personal data.
3.2. The Operator is obliged to:
— provide the personal data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with applicable legislation;
— respond to inquiries and requests from personal data subjects and their legal representatives;
— provide the authorized body for the protection of the rights of personal data subjects, upon request, with the required information within 10 days from the date of receipt of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— implement legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, distribution, as well as other unlawful actions in relation to personal data;
— cease the transfer (distribution, provision, access) of personal data, terminate processing, and destroy personal data when required;
— fulfill other obligations as established by applicable data protection laws.
4. Main Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— receive information regarding the processing of their personal data. Such information shall be provided by the Operator in an accessible form and must not contain personal data relating to other personal data subjects, except in cases where there are grounds for disclosing such personal data;
— request the Operator to clarify, block, or destroy their personal data if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose;
— impose the condition of prior consent for the processing of personal data for the purpose of promoting goods, works, or services in the market;
— withdraw consent to the processing of personal data, as well as submit a request to cease the processing of their personal data;
— appeal to the authorized body for the protection of personal data subjects’ rights or through the court against unlawful actions or inaction by the Operator regarding the processing of their personal data.
4.2. Personal data subjects are obliged to:
— provide the Operator with accurate information about themselves;
— notify the Operator of any updates, changes, or corrections to their personal data.
4.3. Persons who provide the Operator with false information about themselves or information about another personal data subject without their consent shall bear responsibility.
5. Principles of Personal Data Processing
5.1. Personal data processing shall be carried out on a lawful and fair basis.
5.2. Personal data processing is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of data collection is not permitted.
5.3. The merging of databases containing personal data processed for incompatible purposes is prohibited.
5.4. Only personal data that meet the purposes of their processing shall be subject to processing.
5.5. The content and volume of processed personal data shall correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not allowed.
5.6. Personal data processing shall ensure the accuracy, sufficiency, and, when necessary, relevance of personal data in relation to the purposes of processing. The Operator shall take or ensure the taking of necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that permits identification of the personal data subject no longer than required by the purposes of personal data processing, unless otherwise established by a contract to which the personal data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or loss of necessity to achieve those purposes, unless otherwise provided by law.
6. Purposes of Personal Data Processing
Purpose of Processing:
To provide the User with access to services, information, and/or materials contained on the website.
Personal Data:
- Last name, first name, patronymic
- Email address
- Phone numbers
Transfer of personal data
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the personal data subject for the processing of their personal data.
7.2. Personal data processing is necessary to achieve the objectives provided by an international treaty for the fulfillment of the functions, powers, and duties assigned to the Operator.
7.3. Personal data processing is necessary for the administration of justice, enforcement of a court decision, act of another authority, or official.
7.4. Personal data processing is necessary for the performance of a contract, where the personal data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract under which the personal data subject will be a beneficiary or guarantor.
7.5. Personal data processing is necessary to protect the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.
7.6. Personal data processing is performed for personal data that the personal data subject has made publicly available or at their request (hereinafter referred to as publicly available personal data).
7.7. Personal data processing is performed for personal data subject to publication or mandatory disclosure in accordance with applicable law.
8. Procedure for Collecting, Storing, Transmitting, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of applicable data protection laws.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access to personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with applicable laws or if the personal data subject has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil law contract.
8.3. If inaccuracies in personal data are detected, the User may update them independently by sending a notification to the Operator’s email address info@loyo-development.com with the subject line "Personal Data Update."
8.4. The period of personal data processing is determined by the achievement of the purposes for which the personal data were collected, unless another period is specified by contract or applicable law.
The User may withdraw consent to personal data processing at any time by sending a notification to the Operator via email at info@loyo-development.com with the subject line "Withdrawal of Consent to Personal Data Processing."
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreements and Privacy Policies. The personal data subject is advised to familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.
8.6. Restrictions established by the personal data subject on the transfer (except granting access), as well as on the processing or conditions of processing (except obtaining access) of personal data allowed for distribution, do not apply when processing personal data in the interests of the state, society, or other public interests.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows identification of the personal data subject no longer than required by the purposes of processing, unless the storage period is established by a contract to which the personal data subject is a party, beneficiary, or guarantor.
8.9. The conditions for termination of personal data processing may include achievement of the processing purposes, expiration of the consent period, withdrawal of consent by the personal data subject, a request to cease processing, or detection of unlawful processing of personal data.
9. List of Actions Performed by the Operator with the Collected Personal Data
9.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the obtained information via information and telecommunication networks or without such transmission.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing activities involving the cross-border transfer of personal data, the Operator is required to notify the authorized body responsible for protecting the rights of personal data subjects about its intention to carry out such cross-border transfer (this notification is sent separately from the notification of the intention to process personal data).
10.2. Prior to submitting the above-mentioned notification, the Operator must obtain relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the personal data subject, unless otherwise provided by applicable law.
12. Final Provisions
12.1. The User may obtain any clarifications on questions concerning the processing of their personal data by contacting the Operator via email at info@loyo-development.com.
12.2. Any changes to the Operator’s personal data processing policy will be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://lb-club.com/.