1. Statement

The following statement explains our Privacy Policy (“Policy”) with respect to information including personally identifiable data (“Personal Data”) and other information that is collected by us when you access and/or use our Website. As you use our Website, we want you to be clear how we are using such Personal Data and the ways in which you can protect your privacy.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Policy. If you provide Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of TL.

All words and phrases used in this Policy shall have the same meaning given to them in our Website TOU & Notices. Specifically, the word “Authorised Third Party” shall mean the contractors, agents and/or third party suppliers/providers engaged by us from time to time for the purposes of providing certain services.

2. Changes

Our Policy may change from time to time. As a result, at times it may be necessary for us to make changes to this Policy. We reserve the right to update, revise or modify this Policy at any time and from time to time. Such update, revision or modification to the Policy shall be made known to you on the Website. Please review this Policy periodically, and especially before you provide us any of your Personal Data. This Policy was last updated on the date indicated above. Your continued use of the Website after any changes, revisions or modifications to this Policy shall indicate your agreement with the terms of such revised Policy.

3. Parental Advisory

One or more of our services are not catered to users under the age of 18 as our services may provide access to music or other content that contains explicit content including use of profane language and/or sexual references. If you are under 18, please obtain your parent/guardian’s permission before using and/or accessing the Website. Please do not provide us with your Personal Data unless you have obtained permission from your parent/guardian. Parental discretion is advised for all users below 18. We encourage parent/guardian to monitor their children’s internet usage and to help enforce our policy by instructing their children never to provide Personal Data through the Website without your permission. If you have reason to believe that a child under the age of 18 has provided Personal Data to us through the Website, please contact us and we will endeavour to delete that information from our database. Otherwise, all Personal Data provided by a user shall be deemed to have been submitted by a user above 18 or has obtained the relevant permission from their parent/guardian.

4. The Information We Collect

(a) Personal Data that you provide to us: We collect Personal Data (such as name, identity card number, gender, postal address, birthdate, telephone number, facsimile number, email address, credit/debit card information, photos etc.) when you voluntarily provide us with such information during the TL Membership registration process or as and when required by us.

(b) Information we get from your use of the Website: When you interact with us through the Website, we may collect or receive and store certain personally non-identifiable information. Such information is collected passively using various technologies and cannot presently be used to specifically identify you. This information includes without limitation:

(i) device-specific information such as hardware model, operating system version, unique device identifiers, mobile network information, memory, sound card data, IP address;

(ii) cookies that may uniquely identify your browser (this is described in detail below);

(iii) details of how you use our Website such as your search queries;

(iv) total number of visitors using our Website and the number of visitors to each page of our Website; and

(v) how our users use and interact with our Website.

As an on-going effort to better understand and serve the users of the Website, we may conduct research on customer demographics, interests and behaviour based on the Personal Data and other information provided to us. This research may be compiled and analysed on an aggregate basis. We may share this non-identifiable and aggregate data with our subsidiaries, affiliates, agents and business partners but this type of non-identifiable and aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.

5. Use of Your Personal Data and Information

5.1 We use the Personal Data you provide in a manner that is consistent with this Policy. If you provide Personal Data for certain reason, we may use the Personal Data in connection with the reason for which it was provided. Your Personal Data and information may also be used by us, our subsidiaries, affiliates or Authorised Third Parties for the following reasons:

(i) for the purposes of technical administration of the Website;

(ii) for research and development;

(iii) statistical analysis;

(iv) registering you as a customer and related customer administration matters;

(v) profiling services preferences;

(vi) finance and marketing operations and activities and/or as required in the provision of our Website including but not limited to credit control services;

(vii) in compliance with any regulatory, statutory or legal obligation imposed on us by any relevant authority;

(viii) to operate and provide the Website to you;

(ix) to support your questions about the use of the Website;

(x) to detect and prevent fraudulent activity;

(xi) to provide other goods and services by us or our designated representatives and/or business partners to you or parties designated by you and matters ancillary thereto;

(xii) to verify and process your order and payment transactions when you use the Website;

(xiii) to verify and record your personal particulars including comparing it with information from other sources and using the information to communicate with you;

(xiv) to conduct market research of the users of the Website including the number of users, the frequency of use, profile of users and using such analysis for our business plans, the enhancement of our products and services, targeted advertisements and conveying such information in broad aggregate terms to third parties who have or propose to have business dealings with TL; and/or

(xv) to send you information, promotions and updates including marketing and advertising materials in relation to our goods and services and those of third party organizations selected by us.

5.2 If we intend on using any Personal Data in any manner that is not consistent with this Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

6. Disclosure of Your Information (Within or Outside Indonesia)

6.1 We are not in the business of selling your information. We consider this information to be a vital part of our relationship with you. As such we will not sell or rent your Personal Data save and except as provided herein. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice, and hereby seek and retain your consent, to you, as set forth below:

Business Transfer

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

TL Group

We may also share your Personal Data with our affiliates and/or the TL Group for purposes consistent with this Policy.

Legal Requirements

To comply with any order of court or directive from authorities investigating any alleged offence, misdeed and/or abuse or to enforce any of the terms in the Website TOU & Notices, this Policy, and the Privacy Notice or, where such action is necessary to protect and defend the rights or property of TL.

Authorised Third Party

Where services from such Authorised Third Party are required, we will share your Personal Data on a strictly confidential basis. The Authorised Third Party will not be allowed to use your personal information disclosed to them except for the limited purpose of providing the particular service.

6.2 It may be necessary for us to transfer your personal information to other group companies or services providers located in countries outside Indonesia. This may happen where the Authorised Third Parties are based outside Indonesia or where you use our Website from countries outside Indonesia. By accessing and continuing usage of our Website, you hereby give your consent to such transfer.

7. Third Party Services

Our Website may provide a link or platform to third party applications, websites and/or services to make available certain services to you (“Third Party Services”). This Third Party Services may contain, from time to time, links to other web sites. You should review the privacy policies of such Third Party Services. This Policy applies solely to information collected by our Website.

8. Cookies

What is a cookie?

When you use or access our Website, your device will automatically be issued with a cookie. Cookies are text files that are placed in your device's hard drive to identify your device to our server. Generally, cookies themselves only record those areas of the site that have been visited by the device in question, and the duration. Many websites and/or software applications do this whenever a user visits their site in order to track traffic flow.

Depending upon the type of device you are using, you may set your device to accept all cookies, to notify you when a cookie is issued, or not to receive cookies at any time. The last of these, of course, means that certain personalised services cannot then be provided to you.


We use "cookies" to store and track information about you and your use of the Website. Our cookie and information retrieved from our cookie is used in line with the uses set out in in this Policy and more specifically to:

(i) help save and retrieve passwords used on our Website. This way, you will not have to re-enter information upon every new visit to our Website;

(ii) track information such as the frequency and duration of your use or visit to our Website, your click-stream as you go through our Website, your preferred websites and to help us determine whether you came to our Website from a particular Internet link or banner advertisement;

(iii) analyse the profile of visitors and users to helps us in providing you with better services and to enhance our Website;

(iv) personalize the content, banners and promotions that you will see on our Website.

Most cookies are "session cookies," meaning that they are automatically deleted from your device at the end of a session. You are always free to decline cookies if your device permits, although in that case you may not be able to use certain features of our Website and you may be required to re-enter your password more frequently during a session.

Third Party Cookies:

We may use other third-party advertising companies to serve ads when you access and/or use our Website. In the course of serving advertisements, our third-party advertisers may place or recognize a unique cookie in your device. These companies may use information retrieved from their cookies to provide advertisements on our Website and other services about goods and services that may be of interest to you.

We have no access or control over third party cookies and they are not subject to our Policy. Please review the privacy policy of these third party websites respectively for details. If you want to prevent one of these third-party companies from sending and reading cookies on your device, you will need to visit each of their websites individually to request that you be removed from that system.

9. Opting-Out, Change, Update of and Access to Your Information

9.1 You may be able to access and/or use the Website without providing us with any Personal Data. If you choose not to provide any Personal Data, you may not be able to access and/or use certain services.

9.2 However, when you choose to provide us with such Personal Data, we may also use your Personal Data and information to contact you in the future to tell you about our services we believe will be of interest to you.

10. Security

10.1 The internet is not a secure medium, and communications over the internet may be subject to third-party interception.

10.2 We have implemented security policies, rules and technical measures to protect your Personal Data from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss. All our employees and data processors who have access to and are associated with the processing of Personal Data, are obliged to respect the confidentiality of your information.

10.3 While we cannot guarantee that loss, misuse or alteration of data will not occur; we make reasonable efforts to prevent such unfortunate occurrences. TL shall immediately make notification to you should there be any misuse or alteration of data. Personal Data that we collect from you will be stored and backed up securely in an environmentally-controlled location. Only authorized people with user ID and password from our company have access to the information.

10.4 You must remember to log off after accessing and/or using our Website and/or close the browser window after use so that no unauthorized party can have access. You must not, at any time, divulge your Personal Data to any third party.

11. Transferring Your Information Outside of Indonesia

The internet is not a secure medium, and communications over the internet may be subject to third-party interception.

It may be necessary to transfer your personal information to other group companies or service providers located in countries outside Indonesia. This may happen where the Authorised Third Parties are based outside Indonesia or where you use our Website and/or services from countries outside Indonesia. By continuing usage of our Website and access to our Website, you hereby consented to such transfer.

12. Contacting the Website.

If you have any questions about this Policy or your dealings with the Website, please write to

13. In the event of any inconsistency or different interpretation between the Indonesian and English versions of this Privacy Policy, the English version will prevail and the Indonesian version is deemed to be automatically amended to conform to the relevant English version.