Privacy Policy

Effective Date: August 25, 2026

This Global Privacy and Compliance Directive dictates the regulations PT POLA PAPERINDO JAYATAMA (herein "we," "us," or "our") adheres to when obtaining, processing, and shielding your personal information during your use of Milk Tea Sort: Color Puzzle on the Google Play distribution platform. Our sole mandate in governing this information is to render exceptional digital entertainment while remaining strictly compliant with global data protection standards.

1. Data Acquisition Directives

We employ multi-layered methodologies to collect and oversee your personal data, governed by an absolute commitment to information security. The following stipulations define the categories of data collected and our standard operating procedures.

1.1 Classifications of Data Collected Upon the initialization of Milk Tea Sort: Color Puzzle, our infrastructure is mandated to record the following classifications of user information:

Network Logs: IP addresses, exact timestamps of server connections, and fundamental hardware categorizations.

Hardware Specifications: Device manufacturer, hardware model variant, operating system environment (Android/Google OS), localized time settings, and system language parameters.

Unique Tracking Parameters: Identifiers inextricably linked to your device, specifically the Google Advertising ID (GAID), Android Device ID, Google Play Games ID, and your primary Google Account identifier.

Performance Metrics: Player progression timelines, maximum scores, unlocked milestones, and transactional data from multiplayer engagements.

Financial Ledgers: Histories of virtual purchases, depletion of in-game resources, tailored account configurations, and records of digital currency acquisition.

1.2 Integrated External Platforms Should you opt to authenticate your identity via external gateways like Google Play Games Services, we shall import the approved profile data (e.g., public display names) in strict accordance with their API authorization rules. This is fundamentally contingent on your prior ratification of the third party's privacy policies. Users are legally advised to scrutinize the compliance frameworks of these external entities:

Google Play Games / Google Services: https://policies.google.com/privacy

By authenticating via a third party, you formally stipulate that:

Your usage is in complete harmony with the prevailing Terms of Service of that external platform.

You satisfy the legal age of consent mandated by the third party within your specific legal jurisdiction.

2. Legal Basis for Data Utilization

We process your personal data exclusively to fulfill the operational mandates listed below, ensuring every action is supported by a codified lawful basis:

Service Fulfillment and User Support: To clear commercial transactions, resolve helpdesk tickets, and maintain communication channels; to execute core game mechanics, apply custom user settings, and distribute software patches, security warnings, and administrative notifications.

Lawful Basis: Anchored in GDPR Article 6(1)(b) (contractual necessity). This processing is a mandatory requirement to uphold our Terms of Service and maintain software viability.

Product Enhancement and Promotional Strategy: To dispatch curated marketing materials concerning PT POLA PAPERINDO JAYATAMA or authorized partners; to archive user preferences; and to conduct analytical research aimed at feature development, software refinement, and optimization of our marketing apparatus.

Lawful Basis: Authorized by GDPR Article 6(1)(f) (legitimate interests). We utilize this provision to fulfill our legitimate corporate interest in refining our product and elevating consumer satisfaction.

Targeted Commercial Advertising: To present customized marketing content to users who have explicitly permitted our advertising affiliates to access their device identifiers.

Lawful Basis: Equally supported by GDPR Article 6(1)(f). This serves our legitimate commercial necessity to monetize the platform effectively through relevant ad placements.

3. Statutory Retention Guidelines

Your personal information is retained strictly for the duration necessary to provision our software, comply with legislative mandates, and manage legal liabilities. For scenarios encompassing arbitration, contract enforcement, infrastructural auditing, or regulatory compliance, we retain the right to archive specific data segments for the legally mandated period. Additionally, anonymized Usage Data is retained for internal auditing. Such aggregated data is typically purged rapidly unless an extended retention period is compelled by law or is necessary to secure our network infrastructure.

4. Authorized External Disclosures

In strict observance of user privacy entitlements and governed by GDPR Articles 6(1)(b), 6(1)(c), and 6(1)(f), we may facilitate the transfer of your data to authorized external parties under the following conditions:

Strategic Partners: For the delivery of integrated services, legal compliance, corporate acquisitions, or any initiative demanding your explicit consent.

Law Enforcement and Regulatory Bodies: In the event of a verified breach of our policies, or if statutory obligations necessitate disclosure to protect the physical safety, legal rights, or intellectual property of PT POLA PAPERINDO JAYATAMA and the general public.

Public Player Communities: As a result of your engagement in networked multiplayer environments, message boards, or global leaderboards.

4.1 Disclosures to Advertising Coalitions Subject to the receipt of your explicit consent as dictated by GDPR Article 6(1), we shall transfer your device identifiers to advertising coalitions to power targeted ad campaigns. Our authorized roster of advertising affiliates encompasses:

Applovin Corporation: https://www.applovin.com/privacy/

AdColony: https://yandex.com/legal/international_ads_privacy_policy

Amazon Publisher Services: https://www.amazon.com/privacyprefs

Meta (Facebook, Inc.): https://www.facebook.com/about/privacy/

Google LLC: https://policies.google.com/privacy

Google Admob: https://support.google.com/admob/

Unity Technologies: https://unity3d.com/legal/privacy-policy

IronSource: http://www.ironsrc.com/wp-content/uploads/2019/03/ironSource-Privacy-Policy.pdf

Vungle, Inc.: https://vungle.com/privacy/

Fyber: https://www.fyber.com/privacy-policy/

InMobi: https://www.inmobi.com/privacy-policy/

Disclaimer: This Directive does not govern the independent data processing policies of these external corporations. Users must consult the respective privacy notices of these organizations to understand their data stewardship.

4.2 Infrastructure Sub-processors To maintain backend operations, we engage specialized data sub-processors, including hosting facilities and analytical engines:

Firebase (Google LLC): https://firebase.google.com/support/privacy

Adjust: https://www.adjust.com/terms/privacy-policy/

5. Child Privacy Mandates

The Milk Tea Sort: Color Puzzle application is strictly not designed for, nor commercially marketed to, individuals under the age of 13. We maintain a strict prohibition against the intentional collection of personally identifiable information from this age bracket. Upon confirmation that such data has been inadvertently collected, permanent erasure protocols will be executed immediately. Legal guardians identifying unauthorized data submissions by minors are instructed to contact us forthwith to initiate remediation.

6. Cybersecurity Obligations

We acknowledge the sensitivity of your data and deploy commercially robust cryptographic and operational safeguards to defend your personal information. Notwithstanding these protocols, users must concede that no digital transmission or data storage network can ensure absolute invulnerability. We therefore cannot offer an absolute legal warranty against unauthorized data breaches.

7. Mobile Alert Authorizations

Conditioned upon your explicit opt-in, we may transmit system alerts, promotional notifications, and critical update logs directly to your Android/Google operating system. Users possess the absolute right to rescind this authorization and disable such push communications globally via their device’s native notification settings.

8. Jurisdictional Privacy Privileges

8.1 European Economic Area (EEA) Stipulations We are bound to process valid privacy inquiries within a standard operational window of one month. For submissions of significant complexity, GDPR Article 12 permits an extension of an additional two months. We shall proactively issue written notification detailing the rationale for any such extension.

(1) Right of Access: Under GDPR Article 15, you may formally request granular disclosures concerning your retained data, including processing motives, data classifications, recipients, and retention limits. A digital copy may be requested, provided it does not infringe upon trade secrets.

(2) Right to Object: Pursuant to GDPR Article 21, you may formally contest data processing activities justified by "legitimate interests" (Article 6(1)(f)). We shall suspend operations unless we demonstrate overriding legal justifications. The right to object to direct marketing is absolute.

(3) Right to Rectification: Mandated by GDPR Article 16, you hold the legal right to compel the correction of inaccurate or incomplete profile records.

(4) Right to Restriction: Under GDPR Article 18, you may compel our organization to restrict the active processing of your data under stringently defined legal conditions.

(5) Right to Withdraw Consent: Dictated by GDPR Article 7, if processing hinges upon your consent, you may nullify said consent at any time. This revocation is prospective and does not invalidate prior processing.

(6) Right to Data Portability: Authorized by GDPR Article 20, you possess the entitlement to extract your personal data in a standardized, machine-readable format and transfer it to an alternate data controller without systemic interference.

8.2 California Resident Stipulations (CCPA)

(1) Execution Timeline: We adhere to a 45-day statutory turnaround for verifiable consumer inquiries. Should constraints necessitate a prolongation (up to a 90-day maximum), formal written notification shall be dispatched.

(2) Disclosure Scope: Evidentiary data disclosures are strictly limited to information aggregated within the 12-month trailing window preceding your formal request.

(3) Right to Opt-Out: The CCPA guarantees your right to explicitly instruct our organization to cease the commercial sale of your personal information.

(4) Right to Know: You are empowered to comprehend the exact data categories we harvest and our operational motives, as codified in this annually reviewed Directive.

(5) Access Petitions: You may demand a comprehensive audit of the personal information logged over the trailing 12 months (executable twice per calendar year without penalty).

(6) Right to Erasure: You may instigate the permanent deletion of personal data gathered over the preceding 12 months, subject strictly to statutory exemptions (e.g., legal compliance, security auditing).

9. Execution of Data Erasure

Upon the cessation of the operational necessity for your personal data, you are authorized to mandate its secure destruction. To formally trigger these erasure protocols, submit your explicit directive to the compliance contact email designated below.

10. Corporate Communication Hub

For regulatory inquiries, compliance clarifications, or the execution of formal privacy rights, direct all communications to: Contact Email: [email protected]