This document serves as a comprehensive guide to how PT.Mitra Niaga Berjaya, in conjunction with our external promotional and advertising affiliates, manages, treats, and distributes your personal information.
Our privacy protocols are applicable to all our services. This includes each App in our portfolio, our multi-channel marketing initiatives, and any additional support features we provide. Throughout this text, the collective term "Services" encompasses these Apps, our web platforms, and all associated advertising activities.
Your engagement with our Services—whether through installation, active use of our Apps, or browsing our web properties—functions as your formal acknowledgement of our data collection methods. Specifically, you are authorizing PT.Mitra Niaga Berjaya and our designated ad-tech partners to utilize your data for the delivery of tailored advertisements, the specifics of which are elaborated in our "Marketing and Advertising" chapter. Within those subsequent sections, you will find instructions on how to provide explicit consent, as well as the procedures for withholding or revoking your permission regarding data usage for personalized ad targeting. Should you find any part of these data processing terms disagreeable, we respectfully request that you refrain from using our Apps or accessing any of our Services.
1. Data Processing: Purposes and Legal Foundations
To facilitate the delivery of our Services when you download, access, or engage with PT.Mitra Niaga Berjaya's Apps and platforms, we must process certain personal information. While most of this data is voluntarily submitted by you, we specifically categorize the information collected through our Services as follows:
Identity & Locality Details: This encompasses your chosen username as well as your specific country or regional setting.
Contributed Media & Content: Any files, visual documents, videos, or other data you transmit or upload during your interactions with us or while using the features of our Services.
Feedback & Assessment Data: Information gathered from your participation in surveys, including the ratings and reviews you provide regarding our Apps and Services.
Analytical Profiles: Predictions and insights derived from your activity within our Services, which help us understand your interests and user behavior.
We utilize these datasets to maintain and improve our gaming environment. This includes refining service performance, tailoring in-app promotions to your preferences, and confirming the validity of your transactions. Additionally, your data may be utilized for other relevant objectives as detailed elsewhere in this Privacy Policy.
2. How we use your information
1. Operational Purposes and Service Improvement
We process your data (both individual and aggregated) to ensure the seamless delivery of [PRODUCT] and to refine your overall experience. This includes:
Maintaining the core functionality and technical stability of our services;
Implementing software patches and version updates;
Synchronizing your progress, achievements, and statistics across different platforms;
Identifying system vulnerabilities and performing real-time troubleshooting;
Upholding the integrity of our environment by preventing cheating, fraud, and unauthorized activities;
Meeting legal obligations and enforcing our internal policies or terms of service.
2. Social Features and Community Interaction
To make [PRODUCT] more engaging, we utilize information to:
Manage competitive rankings and public leaderboards;
Enable social connectivity, such as friend-finding features and content sharing on third-party networks;
Facilitate multi-device App usage and cloud-saving capabilities.
3. Assistance and User Engagement
We use your contact and account details to provide dedicated support, specifically to:
Resolve technical inquiries or account-related hurdles;
Distribute critical service notifications and transaction confirmations;
Gather feedback through voluntary user surveys to better understand your needs.
4. Marketing and Tailored Content
To provide a more relevant experience, we may use data to:
Deliver customized advertisements and measure their conversion rates;
Suggest new features or products that align with your interests;
Distribute promotional alerts and marketing updates based on your preferences.
5. Analytics and Behavioral Research
PT.Mitra Niaga Berjaya utilizes digital identifiers (such as Apple's IDFV or consistent device IDs) to analyze how users interact with our portfolio. If you have multiple apps from PT.Mitra Niaga Berjaya installed, we may link these identifiers to understand your cross-product behavior. Our research activities include:
Trend Analysis: Compiling anonymized datasets to study broad user behavior patterns.
Performance Monitoring: Assessing how [PRODUCT] functions on specific hardware to minimize crashes.
User Segmentation: Categorizing players into groups based on in-app activity or geography for better service targeting.
Experimental Testing: Conducting A/B tests—where different user groups experience slight variations of a feature—to determine which version provides the best user value.
6. European Economic Area (EEA) Supplemental Terms
In accordance with the GDPR, we maintain a secure log of your consent preferences. This compliance data is hosted on servers within the European Union.
We store your device identifier alongside your opt-in/opt-out status to respect your privacy choices.
If you authorize personalized ads, your advertising ID is retained specifically to facilitate "Data Portability" or "Right to Erasure" requests.
Users who decline personalized advertising will not have their advertising identifiers stored in our consent management database.
3. Advertise
1. Promotion and Third-Party Marketing
PT.Mitra Niaga Berjaya integrates marketing materials for external products and services within our App environment. To ensure these promotions are pertinent to you, we work alongside advertising affiliates to gather and analyze user data. This data processing is designed to optimize our targeting mechanisms and evaluate the effectiveness of the advertisements displayed.
2. Industry Compliance and Consent Protocols
Standards Participation: PT.Mitra Niaga Berjaya is a member of the IAB Europe Transparency and Consent Framework, adhering strictly to its guidelines. Our operations are supported by a Consent Management Platform (identified by ID 28).
Permission Management: We utilize specialized tools (CMPs) to obtain necessary authorizations for our marketing activities. Where local statutes permit, we may deliver personalized advertisements based on your inferred interests.
User Autonomy: You retain full authority over your data. Adjustments to your advertising preferences or the withdrawal of consent can be performed at any time through the in-App configuration menu.
3. Digital Identifiers and Tracking Tools
To maintain the functionality of our Apps and websites, as well as to facilitate tailored advertising, we employ advertising IDs, cookies, and equivalent tracking technologies. These tools are essential for recognizing your device and understanding your interactions with our services. Detailed instructions on how to regulate these technologies are provided in the following subsections.
4. Children
1. Age Requirements
You must be at least thirteen (13) years old to be eligible to utilize our Services and engage with our apps.
2. Minors' Data Handling
We maintain a strict policy against the willful or intentional collection of personal information from any user known to be under the age of 13.
3. Unauthorized Use and Data Acquisition
Despite our efforts to prevent it, should our Services be accessed and employed by an individual below the minimum eligible age in contravention of this policy, we may inadvertently acquire personal data associated with that unauthorized use.
4. Reporting Suspected Information
If you have reason to suspect that we may have received any data from or concerning a child under thirteen (13) years of age (or under sixteen (16) years of age in certain European Union countries or districts), we urge you to notify us immediately via our designated contact channels.
5. Data Retention and Management
Retention Period Criteria:
We maintain your personal information for the entire duration that your user account remains active, or for the necessary period required to successfully facilitate and provide you with the Service.
Proactive Data Minimization:
We routinely employ processes designed to manage and reduce our data holdings. For example, inactive accounts (such as those associated with the app) may undergo periodic de-identification. Furthermore, unnecessary or redundant data is regularly reviewed and anonymized.
Exceptions to Deletion Requests:
It is important to note that even when you submit a request for the erasure of your personal data, we may be obligated to retain certain elements. This retention is strictly for our legitimate business requirements, which encompass complying with legal mandates, resolving potential disputes, and enforcing the provisions of our user agreements.
6. How we protect your information
We have put in place reasonable controls designed to help safeguard the personal information we collect via our products. However, no security measures are perfect and we cannot assure you that personal information that we collect will never be accessed or used in an unauthorized way.
7. Your Rights & Regional Specific Information
1 General Rights Regardless of your location, we respect your privacy rights. You may contact us at any time to request:
Access to your personal data.
Correction of your personal data.
Deletion of your personal data (subject to legal or operational retention needs).
2 Notice to Users in Brazil (LGPD) If you are a resident of Brazil, the General Data Protection Law (Lei Geral de Proteção de Dados - LGPD) grants you specific rights.
Legal Basis for Processing: We process your data based on the execution of a contract (to provide the Service), legitimate interests (e.g., for security and fraud prevention), or consent (e.g., for personalized advertising).
Your Rights: Under Article 18 of the LGPD, you have the right to request: confirmation of the existence of processing; access to your data; correction of incomplete, inaccurate, or outdated data; anonymization, blocking, or deletion of unnecessary or excessive data; portability of your data; and information about public and private entities with which we have shared your data.
8. Contact Us & Exercise Your Rights
Please contact us via the email address provided below if you:
Have any questions regarding the content of this Policy; or
Wish to exercise any of your applicable data protection rights.
Email: smartsalestracker@gmail.com