Last Updated: October 2024

This Privacy Notice applies to PT Golf Entertainment Indonesia and its affiliates (“Topgolf Jakarta” or “we” or “our” or “us“) responsible for the operation of Topgolf Venues located in Jakarta – Indonesia or other location (“Location(s)”).

This Privacy Notice only applies to processing your personal information collected during registration and payment of a Day Pass or Membership. This Privacy Notice DOES NOT apply to personal information collected as a result of your purchases of food/beverage through any in-bay ordering app, retail, gift cards, Fastrack Passes, golf coaching/lessons, mini/adventure golf, participating in holiday clubs, hosting an event, social media posts, participating in contests/sweepstakes or when you access any of our products or services online or through mobile/cell apps.

You can find more information on how we process personal information at privacy notice by contacting us at onestopservice@topgolfindonesia.co.id.

Please review this Privacy Notice carefully. When you hit “I ACCEPT” during the sign-up process, you confirm that you have read, understood, and agreed to us processing your personal information as set out in this Privacy Notice.

(1) CONTROLLERS. Topgolf Jakarta and Topgolf Limited and its affiliates (“Topgolf International”) are joint or separate controllers of the processing of your Personal Information described in this Privacy Notice. This means that Topgolf Jakarta and Topgolf International work together to decide why and how your Personal Information is processed. Such joint management of your personal information will be subject to the Personal Data Regulation under provision 15 of this Privacy Notice.

We do not perform all processing of your personal information as joint controllers. Each of Topgolf Jakarta and Topgolf International may also be controllers in their own right when processing your Personal Information independently. You can find more information on how Topgolf International processes your personal information at https://topgolf.com/us/company/privacy-policy/

(2) PERSONAL INFORMATION WE COLLECT. We collect your title, name or alias (including full name and Identification Card Number or similar), date of birth, address and/or zip/postcode, email and phone number, gameplay and purchase history, payment methods and other information you provide to us when you register to use or purchase our products or services, respond to surveys, or otherwise communicate with us.
We collect your mobile number, carrier’s name, date, time, and content of messages to update you on your bay allocation or provide your game scores. We may collect medical information if you have been involved in an incident or injured at our Location. CCTV in operation in our Locations may capture your images and movements.

Personal information collected is combined with other information collected about you and is used and disclosed in several ways to help us better understand and serve our guests and customers.

You do not have to provide all personal information identified in this Privacy Notice to use our products or services, but certain functionality will not be available, and we may not be able to provide you with certain products or services. You do not have to have a membership to play at our Locations.

You can find more information on the personal information we collect on our website or by contacting us at the contact details in this Privacy Notice.

(3) USAGE OF YOUR PERSONAL INFORMATION. We use your personal information to respond to your requests for information, administer your membership, facilitate gameplay, provide our products and services, provide updates on your bay allocation, game scores or statistics, display game scores and statistics on leaderboards and analyse guest behaviours and trends to enhance your experiences.
Our collection and processing of your personal information are based on different contexts, including your consent, to perform the contract between you and us, to comply with our legal obligations, and/or in our legitimate interest in conducting our business.

Our third parties and us will use aggregated and anonymised information about guests, customers, or visitors collected in connection with research, benchmarking, and analytics. Aggregated and anonymised information that cannot identify an individual is not personal information.

You can find more information on the uses of your personal information on our website or by contacting us at the contact details in this Privacy Notice.

(4) CHILDREN’S PRIVACY. We collect personal information from children under the age of 16 if they have been registered by their parent/guardian as a junior member or, if necessary, to comply with our legal obligations.

(5) MOBILE TEXT PROGRAMME. We collect your mobile phone number, your carrier’s name, the date, time, content of your messages, and other information you provide to us to send marketing by Whatsapp or other types of short messaging media if you have opted-in to our mobile Text Programme.

You must be 16 or older to participate in our direct marketing mobile Text Program. . By providing your mobile phone number and opting-in, you consent to receive future recurring automated marketing text/SMS messages to the mobile number provided from us or on our behalf. You also acknowledge that your agreement to receive these messages isn’t required as a condition of purchase.

Message & data rates may apply. All charges are billed and payable to your mobile service provider. We do not charge you for sending or receiving Whatsapp messages or other types of short messaging media to or from the number provided. We are not liable for any delays in receiving text messages or undelivered messages.

(6) FINANCIAL INCENTIVES. If offered, you may be able to join our loyalty or rewards program (“Rewards Programs”). Rewards Programs provide certain perks, such as rewards, promotions, and exclusive offers. When you sign up for the Rewards Programs, we will ask you to provide your name and email address. The value of your personal information to us is related to the value of the free or discounted products or services that you obtain when you redeem points. This value is based on the expense of offering those free or discounted products or services. You may withdraw from participating in the Rewards Programs at any time by contacting us at the contact details in this Privacy Notice.

(7) PARTICIPATING LOCATIONS. You may play Topgolf at any Participating Locations worldwide as part of a lifetime membership? See the Location Terms and Membership Agreement for more information on how the benefits are provided as part of your lifetime membership. Participating Locations are independently owned or operated by Topgolf International or other Topgolf system franchisees or licensees (“Independent Franchisees”). Not all Independent Franchisees are Participating Locations.

Participating Locations process your personal information for their own purposes. Each Participating Location will be a controller of your personal information in its own right.

Neither Topgolf Jakarta nor Topgolf International is responsible for the compliance of the Participating Location with privacy laws. However, if you believe a Participating Location is violating the applicable privacy laws where the Participating Location is located, you may report this to Topgolf Jakarta or Topgolf International at the contact details provided in this Privacy Notice.

(8) SHARING YOUR PERSONAL INFORMATION. We share your personal information within the Topgolf Jakarta group of companies. We also share your personal information with Topgolf International, Participating Locations, service providers, sub-processors, suppliers, and partners. We share your personal information to perform the purposes for which the personal information is collected, complete transactions, respond to requests and fulfil other business and compliance purposes.

In case of a transfer or sale of some or all our business or assets, we will disclose your personal information to those involved in such a transfer or sale of business or assets, including at the negotiation stage. We may share your Personal Information with governmental or public bodies (“Government Agencies”), our insurers, and professional advisors. We will only share your personal information if we have a lawful basis to do so. We may share data in other unanticipated circumstances but will only do so with your consent.

We do not sell or rent to third parties any personal information you provide to us at our Locations or authorise our third parties to sell or rent your personal information. We do not authorise our third parties to make independent use of your personal information for their own purposes, including (but not limited to) marketing, except if you have opted-in to receive marketing. This Privacy Notice does not apply to processing your personal information by third parties who are a controller in their own right. You should carefully read any privacy notices provided by the third party before providing any personal information.

You can find more information on the third parties with whom and why we share your personal information on our website.

(9) INTERNATIONAL TRANSFERS. We transfer your personal information internationally within the Topgolf Jakarta group of companies. We transfer your personal information internationally to Topgolf International (based in the UK and USA) and to our and Topgolf International service providers, sub-processors, suppliers, or partners to provide membership benefits and/or facilitate gameplay at the Location and Participating Locations.

The countries to which we transfer your personal information may not provide you with the same protection afforded under applicable law. We will only transfer your personal information internationally based on an adequacy decision, standard contractual clauses, derogation, or another lawful basis.

You can find more information on international transfers of your personal information on our website or by contacting us at the contact details in this Privacy Notice.

(10) SECURITY. We cannot guarantee that there will never be a security problem, but we put in place and require that our third parties put in place technical and organisational security measures to keep your personal information secure. You can find more information on our security measures on our website. or by contacting us at the contact details in this Privacy Notice.

(11) RETENTION AND DESTRUCTION. We do not keep your personal information for longer than is necessary to carry out the functions for which you provided the personal information, to comply with our statutory obligations, or in our legitimate interests (such as defending legal claims and disputes), whichever is the longer. We do not retain any personal information collected when you purchase a Day Pass except if you have been involved in an incident or injured at our Location. We securely destroy personal information that is no longer required.

Information that has been anonymised and aggregated and cannot be used to identify an individual is not personal information. We will keep such information following our retention policy. You can find more information on our retention policies on our website or by contacting us at the contact details in this Privacy Notice.

(12) YOUR CHOICES AND RIGHTS. Depending on the applicable law, you may be entitled to certain rights regarding your Personal Information, e.g., request updates, access, rectify, delete, and revoke consent. You can exercise any of your rights by contacting us as set out in this Privacy Notice. If you elect to exercise any of your choices listed below, you will not receive discriminatory treatment by us for exercising your privacy rights conferred upon you by law.

If you don’t want to receive promotional and marketing post, emails, and text messages from our third parties and us, You can withdraw your consent to marketing by contacting us at the contact details in this Privacy Notice.

(13) CHANGES TO THIS PRIVACY NOTICE. We reserve the right to change our Privacy Notice from time to time. You can always find our current Privacy Notice on our website. Be sure to check our website periodically for updates. We will ask for your consent to the updates if required by applicable law. If you hold a membership or account with us, we will send out an updated Privacy Notice to your last known email that we have on record.

(14) APPLICABLE LAW AND DISPUTE SETTLEMENT. The applicable law in this Privacy Notice is the applicable law in the Republic of Indonesia, i.e. Law No. 27 of 2022 on Personal Data Protection; Law No. 11 of 2008 on Electronic Information and Transactions; Government Regulation No. 71 of 2019 on the Operation of Electronic Systems and Transactions; and Minister of Communication and Information Technology Regulation No. 20 of 2016 on the Protection of Personal Data in Electronic Systems (“Personal Data Regulation“) as partially revoked, amended or updated from time to time including any regulations made under or separate from such Personal Data Regulation or other laws relating to the protection of personal data. Personal information that is jointly managed and transferred to Topgolf Affiliates or other parties permitted under this Privacy Notice will be conducted by Topgolf Jakarta under the applicable Personal Data Regulations.

Any disputes, conflicts and differences of opinion that occur between us and you relating to this Terms shall be as long as possible resolved by deliberation and consensus no later than 30 days from the first deliberation.

When deliberate resolution is unsuccessful, you agree with us to choose a legal domicile and remain at the South Jakarta District Court Registrar’s office.

(15) LANGUAGE
These Privacy Notice are made in two language versions, namely Indonesian and English. In the event of any differences in interpretation or inconsistencies between the Indonesian and English versions, the Indonesian version shall prevail and be used as the reference.

(16) QUESTIONS AND MORE INFORMATION. If you have questions about this Privacy Notice, please contact us at onestopservice@topgolfindonesia.co.id. You can find more information on how we process personal information on our website at privacy notice