Privacy Policy

Date of Effect: July 17, 2026

This Privacy Policy details how PT POLA PAPERINDO JAYATAMA ("we," "our," or "us") collects, uses, and protects your personal data while you engage with our mobile application, Mighty Mini: Adventure, available via the Google Play Store. We process your information strictly to deliver top-tier gaming experiences and maintain seamless interactivity.

1. How We Collect and Handle Personal Data

We obtain, utilize, and govern your personal information through multiple avenues, maintaining a steadfast commitment to data security at all times. Below are the specific categories of data we gather and our rationale for processing them.

1.1 Categories of Information Gathered Upon opening or playing Mighty Mini: Adventure, we routinely capture the following categories of user data:

• Server Log Information: Your IP address, hardware classification, and timestamps of your connection.
• Device Specifications: Manufacturer, exact model, operating system (Android/Google OS versions), local time zone, and language configurations.
• Unique Hardware Identifiers: Network tags linked to your gaming device, encompassing the Google Advertising ID (GAID), Android Device ID, Google Play Games profile ID, and your primary Google account identifier.
• In-Game Metrics: Your game progress, top scores, earned achievements, and logs of your multiplayer engagements.
• Purchase History: Records of bought items, consumption patterns, personalized game configurations, and histories of virtual goods or currency acquired.

1.2 Third-Party Information Sources If you elect to log in via external platforms such as Google Play Games Services, we will extract relevant profile details (like your username and public data) in strict compliance with their authorization procedures. This relies on your prior agreement to their specific data-sharing terms.

To understand how these external platforms manage your data, you can consult their privacy policies:

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

By utilizing a third-party service to access our application, you acknowledge that:

• Your usage of our game features complies with the active terms and conditions set by that third-party entity.
• You satisfy the minimum age criteria mandated by the third-party provider within your legal jurisdiction.

2. How We Use Your Information

We handle your personal data for the following purposes, verifying that every data type is supported by a valid legal justification:

• Delivering Services and Support: To process transactions, respond to your queries, and manage communications; to provide fundamental gameplay mechanics, personalize your experience, and send security alerts, technical patches, and customer service notifications.
• Legal Justification: This processing is grounded in Article 6(1)(b) of the General Data Protection Regulation (GDPR) (contractual necessity). It is essential for upholding our user agreement, operating our servers, and rolling out continuous updates.
• Optimization and Marketing: To send promotional materials about PT POLA PAPERINDO JAYATAMA or relevant third-party partners based on your preferences; to preserve your custom settings; to analyze player behavior, design new gameplay elements, and improve our software, customer support, and marketing strategies.
• Legal Justification: Based on Article 6(1)(f) of the GDPR (legitimate interests). We leverage this information to fulfill our legitimate interest in offering captivating content and enhancing operational standards.
• Tailored Advertising: To display personalized advertisements and promotional content to users who have agreed to share their device IDs with our ad partners.
• Legal Justification: Also supported by Article 6(1)(f) of the GDPR. This is motivated by our legitimate interest in presenting relevant advertising and optimizing our product offerings.

3. Data Retention Periods

We retain your personal data only as long as necessary to provide our gaming platform, comply with statutory requirements, and protect or establish our legal rights. For objectives like dispute resolution, enforcing terms of service, maintaining server architecture, fulfilling legal mandates, or ensuring security, we may store specific data points in our archives for a legally permitted timeframe.

Furthermore, Usage Data is kept for internal analytical purposes. This information is generally held for short durations, except when required to bolster system defenses, improve app functionality, or when regulations dictate a longer retention window.

4. Data Sharing and Disclosure

Honoring your legal rights and in accordance with GDPR Articles 6(1)(b), 6(1)(c), and 6(1)(f), we may transmit your collected data to external parties under these circumstances:

• Partner Organizations: For collaborative service delivery, legal compliance, business asset transfers, or other projects where you have given explicit permission.
• Law Enforcement and Regulators: If we suspect a breach of our policies, or if disclosure is legally mandated to protect the safety, rights, and intellectual property of PT POLA PAPERINDO JAYATAMA and the general public.
• Other Gamers: When you participate in multiplayer sessions, public chat forums, or when your gameplay stats are broadcasted on global leaderboards.

4.1 Sharing with Ad Networks Assuming you have provided consent under Article 6(1) of the GDPR, we will share your device identifiers with advertising partners to deliver tailored ad experiences. Our network of current and prospective ad partners includes:

• 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/

4.2 Third-Party Service Providers To run our backend infrastructure smoothly, we collaborate with specialized data processors. This includes analytics platforms, authentication services, and hosting providers:

• Firebase (Google LLC): https://firebase.google.com/support/privacy
• Adjust: https://www.adjust.com/terms/privacy-policy/

5. Policy on Children's Privacy

Mighty Mini: Adventure is not intended for, nor targeted at, users under the age of 13. We do not purposefully harvest identifiable information from individuals below this age threshold. If we discover that we have accidentally gathered such details, we will promptly purge them from our systems. If you are a parent or legal guardian and realize your child has submitted personal data to us, please contact us immediately to facilitate its removal.

6. Security Measures

We deeply value your trust and implement commercially reasonable security frameworks to protect your personal information. However, please be aware that no internet transmission or electronic storage solution is flawlessly secure. Consequently, we cannot guarantee the absolute invulnerability of your data.

7. Push Notifications

If you have opted in, we will send crucial updates, promotional offers, and game alerts directly to your Android/Google device. You retain the right to opt out of these push notifications at any point by adjusting your device's system preferences.

8. Your Privacy Rights

8.1 Rights for Residents of the EEA We strive to process privacy inquiries swiftly, typically responding within one month of receipt. For highly complex requests, we may extend this timeframe by a maximum of three additional months, as permitted by GDPR Article 12. In such instances, we will inform you of the delay and the reasons behind it.

1. Right to Access: Under GDPR Article 15, you can request full details regarding the personal data we hold about you, including the purposes of processing, data types, recipients, and expected storage periods. You may also ask for a digital copy, subject to restrictions involving intellectual property or trade secrets.
2. Right to Object: Per GDPR Article 21, you can oppose data processing based on the "legitimate interests" clause (Article 6(1)(f)). If you object, we will cease processing unless we can demonstrate compelling legal reasons that override your individual rights. You also have an unconditional right to opt out of direct marketing processing.
3. Right to Rectification: According to GDPR Article 16, you are entitled to have any inaccurate or incomplete personal records corrected.
4. Right to Restriction: Under GDPR Article 18, you may mandate that we limit the active processing of your data under specific conditions. When restricted, data is only processed with your consent, for legal claims, or for significant public interest reasons.
5. Right to Withdraw Consent: As stated in GDPR Article 7, if our processing operations rely on your explicit consent, you can revoke it at any moment. This stops future processing but does not retroactively invalidate the legality of processing carried out prior to the withdrawal.
6. Right to Data Portability: Per GDPR Article 20, you possess the right to receive your personal data in a structured, commonly used machine-readable format and to request its transfer to another data controller without interference.

8.2 Rights for California Consumers

1. Response Timeframe: We aim to fulfill verifiable consumer inquiries within 45 days. If a time extension is necessary (up to 90 days total), we will provide written notice explaining the justification and the new timeline.
2. Scope of Disclosure: Data disclosures will strictly cover information gathered within the 12-month period immediately preceding your request. We will supply this data in a readily accessible format to allow for seamless data portability.
3. Opt-Out of Data Sales: The California Consumer Privacy Act (CCPA) grants you the right to direct businesses to cease selling your personal information to external parties.
4. Right to Know: You are entitled to know the specific categories of data we collect and our motives for doing so. This is transparently outlined in this Privacy Policy, which is updated at least once a year.
5. Access to Records: You may request a detailed breakdown of the personal data we have collected about you over the past 12 months, including data sources, processing motives, and third-party sharing practices. You can exercise this right free of charge twice per calendar year.
6. Right to Deletion: You may petition for the permanent erasure of personal data collected over the preceding 12 months. Please note that certain legal exceptions—such as maintaining active services, fixing technical bugs, protecting free speech, or complying with statutory mandates—may require us to retain specific data points.

9. How to Request Data Deletion

Whenever it is no longer strictly necessary for us to retain your personal details, you may instruct us to securely eliminate them. To initiate a formal deletion request, please submit your inquiry to the contact email provided below.

10. Contact Us

For any questions, concerns, or privacy requests regarding this Privacy Policy, please reach out to us at: Contact Email: [email protected]