Privacy Policy

Last Updated: Jan 12, 2026

1. INTRODUCTION

1.1. This Privacy Policy ("Policy") explains the ways Indotrax (referred to as "Indotrax", "we", "us", or "our" in this Policy) collects, stores, uses, or otherwise processes personal data of end users of our Services as defined below (referred to as "you" or "your" in this Policy), and why we collect it, how we use that information, and how you can exercise your privacy rights.

1.2. In this Policy, "Services" refers to our Games, Websites, and any related services or properties we directly control. "Games" refers to online games or applications that we own and operate.

1.3. BY INSTALLING, USING, REGISTERING TO, OR OTHERWISE ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT INSTALL, USE, REGISTER, OR OTHERWISE ACCESS THE SERVICES.

1.4. Indotrax Studio reserves the right to modify and update this Privacy Policy periodically, so please make sure to check back this page from time to time to review this Policy. Changes to this Privacy Policy will come into effect immediately upon such changes being uploaded on our websites. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.

2. DATA CONTROLLER

By "data controller", we mean an entity that determines how and why personal data is processed. Your personal data will be held by us in accordance with applicable data protection laws. For the purposes of data protection laws, the data controller will be Indotrax Studio.

While operating the Services, we may share your data with partners we work with. Some of these partners are data controllers independently of us and, therefore, independently determine how and why they process your data. For more information on these partners and how they may process your data, please refer to section 6 of this Policy.

3. WHAT DATA WE PROCESS

3.1. When you access our products and Services, we won't collect your legally sensitive data (i.e. race, ethnicity, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sexuality, and criminality) and other sensitive data (i.e. child data, social security numbers, bank account or payment card details). Please do not provide this kind of information to us or use the services to make it available to others.

3.2. We may collect user data from you, which includes:

- your name, email address, or other contact information if you have provided them to us (for example, when registering an account or subscribing to our communications);

- online identifiers such as your in-game alias, IP address, internal identifiers we assign to your account, or hardware or operating system-based identifiers including your Advertising ID or device ID;

- technical information about the device you use to play our Games or use our other Services (for example, information about its type, model, manufacturer, operating system, language, display, processor, or memory);

- your coarse location (for example, country, state, or city), inferred from your IP address;

- information about your use of the Services (for example, information about your progress in our Games, your visits to our Websites, or your interactions with ads in our Games);

- information about your interactions with our ads outside of the Services (for example, on third-party websites or applications);

- crash logs or other information related to bugs, errors, or other issues in our Services;

- inferences we make based on your activity in our Services;

- messages or other communications you send to us or through the Services (for example, your chat messages in our Games or emails you send to our support team);

- if you choose to connect a third-party account (for example, a social media account) with our Services, the information we receive from the third-party account provider;

- if you make purchases in our Games, the information we receive from third-party payment service providers to validate those purchases (but not your actual payment information such as credit card numbers);

- if you participate in our surveys or other research, any comments, feedback, responses, or other information you provide to us when doing so;

- any other information you choose to submit to us through our Services or otherwise; and

- with your consent, and other information explained to you when asking for your consent.

4. HOW WE COLLECT YOUR DATA

We may collect and receive information that may be considered personal data according to applicable laws in a variety of ways. More specifically:

- directly from you when you submit it to us (for example, when registering an account with us, subscribing to our communications, sending support inquiries to us, or responding to our surveys);

- directly from you and/or your device by automatic means when you use our Services or interact with our ads outside of our Services;

- from our advertising partners involved in the delivery and measurement of ads when you interact with third-party ads in our Games or our ads outside of our Services;

- if you choose to connect a third-party account with our Services, from the third-party account provider;

- if you make purchases in our Services, from the third-party payment service provider involved in those transactions; or

- with your consent, from other sources explained to you when asking for your consent.

Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. You have a number of options to limit or control the extent to which your data is processed.

5. WHY WE COLLECT YOUR DATA

5.1. GENERAL - When we process or collect your data, we ensure that we have a legal basis to do so. Below, you can find examples of the different purposes for which we process your data and the legal basis we have for each of those reasons:

- to carry out our obligations as a result of any contract entered into between you and us and to provide you with the information and services that you request from us;

- to notify you about changes to the products and services that we offer and (where you have indicated your consent) to directly market these products and services to you;

- to administer our websites for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

- to allow you to participate in interactive features of our products and services;

- as part of our efforts to keep our products and services safe and secure;

- to measure or understand the effectiveness of our advertising and marketing;

- to operate and improve our products and services;

- to set up and maintain your registration with the Service;

- to improve customer service;

- to provide features available in the Service;

- to audit and analyze the Service;

- to ensure the technical functionality and security of the Service;

- to inform you of promotions, rewards, upcoming events, and other news about products and services;

- to send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;

- for statistical and research purposes (including market research, marketing and data analysis purposes);

- to ensure the effective operation of software and IT services procured by us;

- to comply with licensing and regulatory requirements that are applicable to us; and

- for other reasons with your consent.

5.2. MARKETING - Marketing refers to advertising, one of the tools that helps fund our Services and enables us to make our Games available free of charge. Mobile advertising relies on the use of certain online identifiers, in particular Advertising IDs but also IP addresses or other identifiers. You can control the extent to which your Advertising ID is used for these purposes using the privacy settings on your device.

6. WHO WE SHARE YOUR DATA WITH

We may share your data with third parties to achieve the purposes described in this Policy. This may include sharing data with the following types of recipients:

6.1. Related entities - Your personal data will be used by us and disclosed to our group companies, including Indotrax Studio and all of its subsidiaries.

6.2. Selected business partners and advertising partners:

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

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

- Facebook: https://www.facebook.com/policy.php

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

- ironSource: https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

- Pangle: https://www.csjplatform.com/privacy

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

- Vungle: https://vungle.com/privacy/

6.3. Public authorities/regulatory bodies/industry bodies - We may disclose your personal data to regulators and law enforcement agencies in response to an enquiry from a government agency.

6.4. Service providers - We may disclose your personal data to third party service providers who require access to such information for the purpose of providing specific services to us.

6.5. Replacement providers - If the management and operation of Indotrax Studio and its affiliates are transferred to another company, we may disclose your personal data to the other company so the products and services can continue to be provided to you.

7. HOW LONG DO WE KEEP YOUR DATA?

We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including to provide you with the Services or to comply with any legal, accounting, or reporting requirements. We may periodically delete or de-identify inactive accounts or other data. After the applicable retention period, we will either delete or de-identify your data or, if neither is possible, isolate your data from further processing until deletion or de-identification is possible.

8. HOW DO WE KEEP YOUR DATA SECURE?

We take the security of your Personal Data very seriously. We implement the appropriate technical and physical safeguards to ensure that your Personal Data is protected against accidental or unlawful loss, destruction, alteration, unauthorized access or disclosure, or any other unlawful processing. Please keep in mind, though, that the Internet is not 100% secure.

9. YOUR RIGHTS

You have various rights in relation to the data which we hold about you:

9.1. Right to access your Personal Data - You have a right to know what Personal Data we hold about you, how and why we handle your Personal Data.

9.2. Right to correct or update your Personal Data.

9.3. Right to delete your Personal Data - In certain specific circumstances, you have a right to ask us to delete your Personal Data which we are holding about you.

9.4. Right to restriction of processing your personal data.

9.5. Right to object at any time to processing of your personal data when processing is necessary for the purposes of the legitimate interests.

9.6. Right to opt-out of direct or target interest advertising on mobile applications by checking the privacy settings on your device settings menu.

9.7. Right to portability of your personal data.

9.8. Right to withdraw your consent at any time if we are processing your personal data with your consent.

9.9. Right to complain to a data protection authority about our collection and use of your personal information.

9.10. Right to opt-out (California, USA) - California residents have the right to opt out of the sale of personal data.

The EU General Data Protection Regulation ("GDPR") gives you the above rights in relation to your personal data. If you believe that we have infringed your privacy rights, please contact us so we can try to resolve the issue.

10. INTERNATIONAL TRANSFER

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. These include implementing the European Commission's Standard Contractual Clauses for transfers of personal data between our group companies and third party service providers and partners.

11. USER DATA DELETION

The user has the authority to manage, use and delete the data generated in the application. Data range that can be deleted: 1) The basic information of the user's Facebook account obtained by the application; 2) User account login record; 3) All user operation records in the app, such as level records, purchase records, etc.

Steps to delete the data in the app: 1) Go to your Facebook profile, and find Apps and Websites page at the Facebook Settings; 2) Remove our app; 3) Click the Removed sub-tab, find our app, and Send Request to delete data.

12. CHILDREN'S POLICY

This Service is not directed to children younger than thirteen (13) years of age. By accepting our Terms of Service and using our Services, you represent that you are at least 13 years of age. We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to use our Services.

13. CHANGES

We may update this Policy from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. Therefore, we encourage you to check this page periodically. We may also inform you of any changes by other means that are appropriate to the significance of the changes.