Privacy Policy

PT BLUE INOVASI GLOBAL and its product Neo Party (hereinafter "we," "us," "our") deeply respect and are dedicated to safeguarding the privacy rights of our users (hereinafter "users," "you"). This commitment applies to users who visit our websites, access or utilize our games (whether played on mobile devices, personal computers, our websites, or any other applicable platforms and/or devices), and access or use any services offered by us, including but not limited to technology services, customer support, competitive gaming activities, marketing, and advertising (collectively, "our Services").
This Neo Party Privacy Policy (hereinafter "Policy") is designed to inform you about our practices concerning the collection, utilization, storage, and disclosure of information we obtain from or about you during your interactions with us. It also outlines your rights regarding the information you provide, and how we transfer and secure such information.
Please ensure you read this Policy thoroughly to comprehend our practices regarding your Personal Data (as defined below). We encourage you to access it periodically to stay informed of any updates. By downloading, accessing, using, and/or interacting with our Services, you acknowledge and expressly consent to our collection, use, and disclosure of your information as described herein. This Privacy Policy is incorporated by reference into our Terms of Service and is subject to its provisions. Should you have any concerns about providing information to us or its use as outlined in this Policy, you should refrain from using our Services.
Should we update this Policy, we will notify you via announcements within Neo Party, informing you of the changes made and seeking your consent again. Your continued access or use of our Services following such notice constitutes your acceptance of the revised Policy. You can determine when this Policy was last updated by checking the "last updated" date displayed at the top. Where mandated by applicable data protection laws, we will provide enhanced notice or seek your consent for specific changes. Any revised version of this Policy shall supersede all prior versions.
This Privacy Policy outlines the following sections for your understanding:
I. Key Definitions
II. Data We Collect and Utilize
III. Promotional Communications
III-A. Your Advertising and Data Sharing Choices
IV. How and Why We Use Your Personal Data
V. How We Store and Protect Your Personal Data
VI. How We Share, Transfer, and Disclose Your Personal Data
VII. How Your Data Is Transferred Across Borders
VIII. How We Handle Children's Data
IX. Your Data Protection Rights
X. How to Exercise Your Rights
XI. Cookies and Similar Technologies
XII. Third-Party Service Providers and Services
XIII. How to Contact Us
XIV. Extra Assistance

I. Key Definitions
"Personal Data" refers to any information relating to an identified or identifiable natural person, particularly through identifiers, location data, or factors specific to physical, physiological, genetic, economic, cultural, or social identity.
"Usage Data" means data collected automatically, generated either by the use of the Service or from the Service infrastructure itself.
"Cookies" are small data files placed on your hard drive or device memory that aid in improving our Services and your experience, identifying popular areas and features, and counting visits.
"Data Controller" denotes the natural or legal person who (alone, jointly, or in common with others) determines the purposes and means of processing Personal Data. For this Policy, we act as the Data Controller for your data.

II. Data We Collect and Utilize
1. Overview
To enhance your experience with our Services, we may request that you supply specific Personal Data while using our Services.
We may gather your Personal Data through the following means:
1.	Information you provide directly (e.g., nickname, profile picture, phone number during account registration or login);
2.	Information automatically obtained during your use of our Services (e.g., Device Information and Usage Data); or
3.	Information acquired from other sources.
We will collect and use your Personal Data solely for the purposes described herein. The subsequent sections detail the types of Personal Data we collect and their respective uses.
2. Data Collection and Purposes
Based on legitimate interests, we may collect some or all of the following information when you use our Services:
(1) Login Information
When creating an account via email/mobile phone number, you consent to provide Personal Data such as email address, verification code (via email/SMS), and password.
When registering through Social Networks (e.g., Apple ID, Facebook, Google Play), we collect information you authorize them to share, typically including basic public profile details like nickname, username, and profile picture. Refusal to provide this information may prevent registration/login via Social Networks.
In certain regions, we may ask for your date of birth to verify your eligibility to access our Services.
(2) Account Information
You can choose what information to add to your Account profile, such as profile picture, nickname, gender, date of birth, and location. While optional, providing this information enhances your experience and helps others know you better. Please refrain from adding information you do not wish to be publicly available.
(3) Payment Information
For purchases of virtual currency or items, we process your purchase and transaction records, including device information (Open ID, IP address, OS version, device type, internet connection), transaction details (time, date, cost, product, currency, order ID), and transaction records (player ID, transaction time, country, email, phone number, purchase history, payment card details) to fulfill our contract, facilitate payment, and provide transaction details.
All financial transactions are handled by payment processors. We do not process payments nor access your full credit card or billing details.
(4) Information Submitted to Support
If you contact our support team, we may collect your inquiry content, device information, and contact details to assist you, record issues, and find solutions. Choosing not to provide this may limit support availability but won't affect other Service features.
(5) Advertising Information
We may store ad identifiers (e.g., Android ADID, Apple IDFA) and device information with your profile to track ad campaign success if you click ads within our Services.
Subject to your election and consent, for personalized ads, promotions, and marketing, we may process information like age, gender, email, geographical location, device type, in-game habits/preferences, and other details from surveys or inquiries.
We may use your information to send advertisements, market surveys, or research via email. You may opt-out of such communications (see "Promotional Communications").
Note that opting out of interest-based advertising means you will still see ads, but they will not be tailored using your Personal Data.
If we identify you as a minor according to applicable laws in your jurisdiction, we will not target you with ads or send promotional messages.
(6) Automatically Collected Data
To improve service quality and security, we automatically collect information about your device and service usage, including:
●	IP Address: Processed to manage access to our Services.
●	Device Information: Collected upon service use, based on your actions and granted permissions, to ensure security, manage registrations, and enhance Services. This may include UUID, IMEI, MAC address, IDFA, device model, OS and version, APK name, App version, display resolution, device settings, CPU info, storage data, battery status, time zone, and device location (IP address, GPS, WLAN, Bluetooth, cell site data).
●	Usage Data: Collected to perform our Terms of Service, includes login account, IP address, provider info, internet connection environment, WiFi status, and other usage data generated during service use.
Note: Some information alone may not identify an individual and isn't considered Personal Data. However, when combined with other data to identify a person, it is treated as Personal Data during that period. We will anonymize and de-identify such data unless consent is given or law requires otherwise. This information is essential for service provision; refusal may prevent us from providing the Services.
(7) Survey Information
We may collect other information reasonably needed to improve our products/services, including feedback from customer service interactions or survey responses. We may combine data from different services to enhance your experience.
(8) Other Collection Scenarios
Permitted by law, we may obtain your Personal Data from other individuals, entities, public sources, partners (for fraud prevention, information security), or other lawful channels. We will explain the context and seek consent at the time of collection.
We may employ other methods to collect information about you, your device, or service usage, which will be explained prior to obtaining your consent.
III. Promotional Communications
We may use your Personal Data to send you service updates, exclusive offers, promotions, or information about new services. We have a legitimate interest in processing your data for promotional purposes, typically not requiring consent. Where consent is necessary, we will seek it separately and explicitly. We will always handle your Personal Data respectfully and never sell it to third parties for marketing.
You can opt-out of promotional communications at any time by:
●	Contacting us (see "How to Contact Us"); or
●	Using the "unsubscribe" link in emails or the "STOP" instruction in texts.
We may ask you to confirm or update your marketing preferences if you request further services, or if laws, regulations, or our business structure change.

III-A. Your Advertising and Data Sharing Choices
We may share specific Personal Data (e.g., device identifiers, usage data) with advertising partners to deliver personalized or interest-based ads on our Services and across the internet. This might be considered a "sale" or "share" under some privacy laws.
You have the right to opt-out of your Personal Data being used for targeted advertising. Methods to exercise this right include:
●	Through our Services: Contact us directly at support@blueinovasiglobal.com to submit an opt-out request.
●	Device Settings: Opt-out on mobile devices by enabling "Limit Ad Tracking" (iOS) or "Opt-out of Ads Personalization" (Android). This applies to all apps on the device.
Opting out doesn't eliminate ads; it makes them less relevant to your interests.
IV. How and Why We Use Your Personal Data
Under data protection law, we process your Personal Data based on proper reasons, such as:
●	Compliance with legal obligations;
●	Performance of our contract with you or steps at your request pre-contract;
●	Our or a third party's legitimate interests; or
●	Your consent.
A legitimate interest represents a business/commercial reason for using your data, provided it doesn't override your rights.
We use your Personal Data for:
●	Service Provision: To perform our contract or take pre-contract steps.
●	Fraud Prevention: For our/third party legitimate interests (minimizing damaging fraud).
●	Customer Verification: To comply with legal obligations.
●	Confidentiality: For our/third party legitimate interests (protecting trade secrets, valuable information) and legal compliance.
●	Statistical Analysis: For our/third party legitimate interests (efficient business management, enhancing service).
●	System Security: For our/third party legitimate interests (preventing damaging criminal activity) and legal compliance.
●	Record Maintenance: For contract performance, legal compliance, and our/third party legitimate interests (e.g., communication regarding orders/products).
●	Marketing: To promote our Services and selected third parties' services to existing/former customers, interested parties, and new contacts for our/third party legitimate interests (business promotion).
We do not engage in automated decision-making using your Personal Data.
V. How We Store and Protect Your Personal Data
Personal Data may be stored at our offices and those of our third-party service providers, representatives, or agents (see Section VI). Data storage complies with relevant national personal data protection laws. You acknowledge that, where not prohibited by local law, your data may be processed on servers located outside your country of residence and accessed by our support, engineering teams, and affiliates globally. Information we collect may be stored/processed in Indonesia or any other country where we, our subsidiaries, or third-party agents operate, for the purposes outlined herein. Regardless of server location, we implement appropriate safeguards to protect your rights per this Policy and applicable laws.
We retain your Personal Data while your account exists or we provide services. Afterwards, we keep it as necessary to:
●	Address questions, complaints, or claims;
●	Demonstrate fair treatment; or
●	Maintain legally required records.
Retention periods vary by data type, but we won't retain data longer than necessary for stated purposes:
●	Login Information: Retained as needed for Services or by law.
●	Account Information: Retained as needed for Services or by law.
●	Payment Information: Retained as needed for Services or by law.
●	Support Information: Retained as needed for Services or by law.
●	Advertising Information: Retained as needed for Services or by law.
●	Automatically Collected Information: Retained as needed for Services or by law.
●	Survey Information: Retained as needed for Services or by law.
●	Other Information: Retained as needed for Services or by law.
If your account is canceled/terminated per the Terms of Service, we will delete or anonymize your Personal Data.
We prioritize the security of your Personal Data, implementing safeguards and regularly monitoring for vulnerabilities and attacks. We continuously work to enhance these protections.
However, no internet transmission or electronic storage method is 100% secure. While we use commercially acceptable means to protect your data, we cannot guarantee absolute security.

VI. How We Share, Transfer and Disclose Your Personal Data
We adhere to principles of minimization, necessity, and legality when sharing, transferring, or disclosing your Personal Data. Except as described, we do not externally share, transfer, or disclose your data.
(1) Sharing Your Personal Data
WE DO NOT SELL PERSONAL DATA TO THIRD PARTIES. Sharing occurs only where necessary:
●	Service Support Providers: Third parties providing cloud/network services, user authentication, customer support, crash analysis, performance improvement, marketing/advertising (including monitoring success), service updates, translations, content moderation, payment processing (fraud detection), and refund process improvement. These providers are prohibited from using/disclosing your data beyond providing services to us.
●	Corporate Group: Affiliated companies processing your data to operate the Services, adhering to this Policy.
We ensure service providers implement appropriate measures and impose contractual obligations limiting data use to service provision. Their processing is governed by their privacy policies; this Policy does not apply to their independent offerings. We are not responsible for their data practices.
(2) Transferring Your Personal Data
We will not transfer your data except:
●	With your explicit consent;
●	During a merger, acquisition, or asset sale affecting your Personal Data, where we will notify you via email/website about ownership changes and your rights; or
●	As explained in this Policy or via other notified means.
(3) Disclosing Your Personal Data
We may disclose your data when required by law, subpoena, legal process, or when we believe in good faith it's necessary to: (1) investigate/prevent/take action regarding suspected illegal activities or assist government agencies; (2) enforce agreements with you; (3) defend against third-party claims; (4) protect our Services' security/integrity; or (5) protect the rights/safety of our Services, users, personnel, or others. We may notify users of legal demands when appropriate, unless prohibited. We may challenge demands we deem overbroad, vague, or unauthorized.
Additionally, we may share data with:
●	Professional advisors (lawyers, accountants, auditors) when seeking advice.
●	Investors/relevant third parties during potential/actual company transactions related to our group.
●	Other third parties with your authorization.

VII. How Your Data Is Transferred Across Borders
For the purposes stated herein, and as permitted by law with your consent, we may transfer your Personal Data to servers specified in Section V for storage/processing. Transfers may also occur to third-party service providers and partners in other countries/regions.
When transferring data outside your jurisdiction, we comply with applicable laws, implementing appropriate security measures to ensure transfers meet local data protection requirements.

VIII. How We Handle Children's Data
Our Services are not intended for children under 14 (or the higher minimum age in your territory) ("Child"/"Children"). We do not knowingly collect personal information from Children. Children should not use our Services or provide any personal information.
If we discover we have inadvertently collected a Child's information, we will take reasonable steps to delete it. Parents/guardians believing we might have collected a Child's information can request deletion via the email in Section XIII.
IX. Your Data Protection Rights
You possess specific rights regarding your personal information, outlined below. You or an authorized agent may exercise these rights by submitting a verifiable request or via our platform (see Section X). For agent-submitted requests, we require:
●	Signed permission from you authorizing the agent;
●	Direct identity verification from you; and
●	Direct confirmation from you about the agent's permission.
Your rights include:
●	Access/Deletion: You can request access to your Personal Data. Upon verification, we will provide an electronic copy. Subject to legal exceptions, upon verifiable request, we will delete your Personal Data from our records and instruct our service providers/affiliates to do the same, unless they have separate consent. Deletion may affect feature availability. We may retain data as necessary for legitimate interests (legal compliance, dispute resolution, agreement enforcement).
●	Rectification: You have the right to request correction of inaccurate/incomplete Personal Data without undue delay.
●	Objection/Restriction: You can object to processing (e.g., direct marketing) or request restriction of processing. You can ask us to stop or limit using your data (e.g., if inaccurate or unlawfully held).
●	Data Portability: You can request a copy of your data in a structured, machine-readable, commonly used format.
●	Withdraw Consent: You can withdraw consent for processing based on your consent at any time by deleting data, disabling device features, or contacting us. Withdrawal may affect your ability to use certain Services and does not affect the lawfulness of prior processing.
●	Control Privacy Settings: You can control privacy settings to restrict our collection, use, disclosure, or processing (e.g., manage "Location Access" or "Storage" permissions; adjust "Privacy Settings" on your device).
●	Know About Sharing: You have the right to know if we share your Personal Data with third parties, the categories involved, and the data shared. This Policy provides this information; contact us for further details.
●	Close Account: You can close your account via in-Service instructions or by contacting us. For security, closure must follow our instructions. Closure may prevent Service use and is irreversible. Upon closure, we delete or anonymize relevant data. For third-party logins (e.g., Apple ID, Facebook), account closure must be requested from the respective third party.
Depending on applicable laws in your jurisdiction, additional rights may apply. Refer to Jurisdiction-Specific Disclosures at the end.
X. How To Exercise Your Rights
To access, view, update, correct, delete, or port your Personal Data, or update preferences, sign in to your "Account Settings" or contact customer service. Where we rely on consent, you can withdraw it anytime. Requests to delete data necessary for purchased services will be honored only to the extent it's no longer necessary for services, legitimate business purposes, or legal/contractual requirements.
To exercise access, portability, correction, or deletion rights, submit a verifiable request to support@blueinovasiglobal.com.
Only you, or a legally authorized agent, may make a verifiable request. You may also make a request for your minor child.
You can make two verifiable access/portability requests within 12 months. The request must:
●	Provide sufficient information (account name, passwords, email, other reasonable details) for us to verify your identity or authority;
●	Describe your request with enough detail for us to understand, evaluate, and respond.
We cannot respond if we cannot verify your identity/authority and confirm the data relates to you.
If you lose account access, verify via SMS, email, or customer service to reset your password, which may require providing Personal Data for identity verification (e.g., frequent login location/device, registration details).
Creating an account is not required for verifiable requests. We only use Personal Data from such requests for verification.
We endeavor to respond within one month of receipt. If more time is needed, we will inform you in writing. We send confirmation of receipt within ten business days.
For account holders, responses are delivered to the account. For non-account holders, responses are sent via the submission method.
If we cannot comply, we will explain in writing. For portability requests, we provide data in a readily usable format.
Generally, no fee is charged for exercising rights. However, for clearly unfounded, repetitive, or excessive requests (excluding consent withdrawal), we may charge a reasonable fee. We will explain the decision and provide an estimate beforehand. We may refuse such requests.
We may decline requests in accordance with law, including where related to:
●	Legal/regulatory obligations;
●	National security/defense;
●	Public safety, health, major public interests;
●	Criminal investigation, prosecution, trial;
●	Subjective malice or rights abuse;
●	Serious harm to legitimate rights of others/organizations;
●	Trade secrets; or
●	Other legally stipulated conditions.

XI. Cookies and Similar Technologies
Cookies are small text files ensuring normal software operation and convenient access. They typically contain identifiers, site names, numbers, and characters. We may use Cookies and similar technologies (e.g., Pixel Tags, Web Beacons). Information from these is generally treated as non-Personal Data unless it contains personally identifiable information. If IP addresses or similar identifiers are considered Personal Data by local law, we treat them accordingly.
We and partners may use cookies/similar technologies to collect data (e.g., device IDs) to recognize you/your devices across different services/devices where you've engaged with our Services. You can manage/delete Cookies based on your preferences.
As Do Not Track (DNT) signals may not reflect user preferences accurately, we do not respond to them. You can opt-out of certain tracking (analytics, tailored advertising) via cookie settings.

XII. Third-Party Service Providers and Services
To provide specific functionalities and enhance your experience, we integrate third-party SDKs and services. These may collect and process information as described. We select partners carefully and require them to protect your information consistent with this Policy and law. However, their data practices are governed by their own privacy policies, which we encourage you to review.
Key third-party SDKs currently used:
1.	Firebase Analytics (Google LLC)
○	Purpose: Analytics, Crash Reporting, Performance Monitoring
○	Data: Device identifiers (Android ADID, Apple IDFA), Device info (model, OS), Usage data, IP address
○	Policy: https://policies.google.com/privacy
2.	Facebook Login (Meta Platforms, Inc.)
○	Purpose: User Authentication, Social Features
○	Data: Public profile (name, picture), Email (if authorized)
○	Policy: https://www.facebook.com/policy.php
3.	Adjust (Adjust GmbH)
○	Purpose: Attribution Analytics, Marketing Measurement
○	Data: Device identifiers (Android ADID, Apple IDFA), Installation/event data, IP address
○	Policy: https://www.adjust.com/terms/privacy-policy/
4.	AppsFlyer (AppsFlyer Ltd)
○	Purpose: Attribution Analytics, Marketing Measurement
○	Data: Device identifiers (Android ADID, Apple IDFA), Installation/event data, IP address
○	Policy: https://www.appsflyer.com/legal/privacy-policy/
You may encounter links to third-party websites/content. Your interactions are governed by their terms/privacy policies. We recommend reviewing their privacy statements. We are not responsible for their data practices.

XIII. How to Contact Us
As the Data Controller, we have designated a Data Protection Officer ("DPO") responsible for overseeing and implementing our Personal Data protection strategy and ensuring compliance with applicable laws. For comments, questions, or concerns regarding this Policy or our data practices, please contact our DPO, Stevie, at support@blueinovasiglobal.com (Please label email subject "Privacy Policy request" for efficient handling). Postal mail: Gedung Menara Dea Tower 1 lantai 8, Desa/Kelurahan Kuningan Timur, Kec. Setiabudi, Kota Adm. Jakarta Selatan, Provinsi DKI Jakarta.
We will review and respond to your requests after verifying your identity. Complex requests may require additional information.

XIV. Extra Assistance
If you require this Policy in an alternative format (e.g., audio, large print, braille), please contact us.
XV. Jurisdiction-Specific Disclosures
Our Services are primarily intended for users in Indonesia, and this Policy is structured to comply with Indonesia's Personal Data Protection Act 2010 (PDPA).
We acknowledge that privacy laws in other jurisdictions (e.g., CCPA/CPRA in California, VCDPA in Virginia) grant specific rights to residents.
Please note our Services are not specifically targeted at, nor do we intend to offer goods/services to, individuals in California, Virginia, or similar jurisdictions. Consequently, we do not represent being subject to or fully compliant with CCPA/VCDPA.
Notwithstanding this, we are committed to respecting all users' privacy. Therefore, we extend the core data subject rights described in Section IX (e.g., know, access, rectify, delete, object) to all users, where practicable and consistent with the PDPA.
If you are a resident of California, Virginia, or similar jurisdiction and believe your local rights should apply to your use of our Services, please contact us per Section XIII. We will review requests case-by-case.