Privacy Policy

Last updated: October 31, 2026
Effective from: October 31, 2026

1 About this notice and our games

PT ADINA MULTI WAHANA develops and publishes casual games. In this notice, “we,” “us,” and “our” refer to that company, and “you” refers to the person playing our games or otherwise using our services. We are responsible for the personal information processed as described here, subject to the roles of independent third parties explained below.

This notice covers App Sugar Paradise Match, together with the related websites, support functions, and other services that link to it (collectively, the “Services”). It explains what information we handle, why we need it, the circumstances in which others receive it, and the choices available to you.

“Personal information” and “personal data” mean information that identifies a person or can reasonably be connected to an identifiable person, either on its own or in combination with other information. Examples include an email address, age, gender, device identifiers, and records of how someone uses a service.

Please read this notice before using the Services and consult it when you have questions about your information. It describes our practices; it does not replace any separate permission or consent that the law requires us to obtain. Where consent is necessary, we request it through the relevant process rather than treating continued use alone as permission for every type of processing.

2 Information handled through the Services

The information involved depends on the app, the features you use, your device settings, and the permissions you provide. We may receive information directly from you, automatically through the Services, or through an integrated service provider acting in connection with your use of the app.

Device and connection details. Device model, operating system and version, screen dimensions, IP address, Mobile Country Code (MCC), and Mobile Network Code (MNC).

Device and advertising identifiers. Advertising ID, Android ID, device ID, and other identifiers made available by the device or an integrated service, subject to applicable restrictions and your settings.

Location-related information. Country, approximate location, and device-location information made available to the relevant feature. We do not collect precise real-time GPS location. Country and approximate region are derived from your IP address; where a feature relies on device-location information, you will be asked for the relevant permission and the information is used only for that feature.

Installed-application information. Information about applications installed on a device, to the extent actually accessed by the app or its SDKs and permitted by the operating system and applicable rules.

Gameplay and interaction records. Completed levels, progress, interactions with buttons or other controls, participation in game features, and related usage events.

Reliability and performance records. Crash reports, crash counts, information associated with a failure, battery-related performance measurements, loading times, latency, frame rates, and other technical diagnostic records.

Information you supply. Where the relevant feature requests it, a username, email address, age or age-related information, gender, and information included in support correspondence. These examples do not mean that every app requires every item.

App-specific information about permissions appears in Appendix C. A description in this notice is not itself an operating-system permission, and the availability of a device identifier does not remove any applicable consent requirement.

3 Purposes and grounds for processing

We use the information relevant to each activity for the following purposes:

• Running and developing the Services. Deliver gameplay and related features, maintain existing functions, investigate problems, evaluate performance, release improvements, and develop new products or features.
• Advertising and recommendations. Present advertisements and recommendations for games, features, or events that may interest you, taking account of availability in your country and your advertising choices.
• Leaderboards and game activities. Show your username, level, and progress to you and other players where a leaderboard feature is available, administer participation, and determine winners in the relevant activities.
• Support and service delivery. Deal with questions and service requests and coordinate the technical or customer-service assistance needed to resolve them.
• Protecting the gaming environment. Identify unusual activity, investigate suspected misuse or fraud, manage security risks, and help preserve fair play.
• Legal and rights-related matters. Meet applicable obligations, respond to lawful requests, and establish, exercise, or defend our rights and those of players, partners, or other affected parties.

Where the law requires a legal basis, we identify the basis appropriate to the particular purpose. This may be:

Your consent. Processing for a purpose that requires your permission, such as certain tracking or advertising activities. You can withdraw that permission as explained below.

Performance of a contract. Processing objectively necessary to provide the Services you request or to take steps you request before entering a contract.

Legitimate interests. Activities such as protecting the Services or understanding how to improve them, where permitted and after considering whether your rights and interests outweigh ours. This basis is not a substitute for consent where consent is required.

Compliance with law. Processing necessary to meet an obligation that applies to us.

Where a jurisdiction uses a different legal framework, we apply the grounds and conditions recognized by that framework.

4 Advertising cookies and similar technology

Our websites and apps may use cookies, local storage, SDKs, identifiers, or comparable technologies. Their functions fall into three broad groups:

1. Operating the Services: supporting features that need those technologies to function.
2. Understanding performance: measuring usage, identifying technical issues, and improving the experience.
3. Supporting advertising: delivering and evaluating advertisements, including personalized advertising where permitted. Advertising helps fund the operation and development of our Services.

Where required, we explain these technologies and obtain permission before enabling non-essential uses. You can use the available privacy controls to give or withdraw consent or exercise an applicable opt-out right. Browser and device settings may offer additional controls, although their effect can differ between websites, apps, and devices.

Opting out of personalized advertising does not necessarily remove advertisements. You may continue to receive contextual or otherwise permitted ads. An opt-out submitted to us also does not automatically change a partner's separate activities outside our Services; that partner may provide its own controls.

Some advertising disclosures may qualify as a “sale,” “sharing,” or processing for “targeted advertising” under a particular US state's law, even when no money changes hands. Our applicable practices are described here: We do not sell your personal data in exchange for money. Some disclosures to advertising partners may qualify as “sharing” for cross-context behavioral advertising or as processing for “targeted advertising” under applicable US state laws. Where that is the case, you can opt out through the controls described in this Section and in Appendix A.

Our handling of these technologies is subject to applicable privacy requirements, including the GDPR and CCPA where they apply. Contact us if you need help understanding the controls or the information associated with them.

If you use the Services on an Apple device, the first time an advertising partner seeks to use the Apple Advertising Identifier (IDFA), you will see the App Tracking Transparency (ATT) prompt and can choose to allow or deny tracking. You can change this choice at any time in your device settings (Settings > Privacy & Security > Tracking). If you deny tracking, we will not link your activity across other companies’ apps and websites for advertising purposes, and you may continue to receive non-personalized or contextual advertisements.

5 When information is disclosed

We disclose information as needed for the purposes described in this notice and subject to applicable safeguards.

Service providers and integrated partners. Technical support, hosting and storage, customer support, marketing, analytics, and SDK providers may receive the information needed for their work. Depending on the service and its contractual arrangements, a provider may process information on our behalf or for its own disclosed purposes. Appendix B identifies third-party services that may be integrated into the Services. Their involvement depends on the app and its enabled features.

Companies in our group. Subsidiaries and other entities under common control may receive information for the activities explained here.

Business transactions. Information may be made available to relevant counterparties and advisers when considering or carrying out a financing, merger, acquisition, asset sale, or comparable transaction. Disclosure is limited to what is needed for the transaction and is subject to applicable legal and contractual restrictions.

Authorities and parties involved in protection or enforcement. We may provide information to courts, regulators, law-enforcement bodies, security service providers acting for us, or other relevant parties when required by law or reasonably necessary and legally permitted to address fraud, manage risks, protect rights, or respond to legal proceedings and investigations.

Other players. Where you participate in a public leaderboard, the username, level, and progress associated with that feature may be visible to other users, as described in Section 3.

We may also provide information that does not identify you to third parties for evaluation, analysis, and other business services. Information is not treated as non-personal merely because a direct identifier has been removed if it can still be linked to you.

Third-party privacy policies explain the practices for which those parties are independently responsible. Those policies do not replace our responsibilities for our own collection, use, or disclosure of your information.

6 Processing across borders

Operating the Services may require information to be stored or processed in countries other than the country where you live or where the information was originally collected. This can occur through our operations or through the providers we use.

We apply the protections required by the laws relevant to the transfer. Depending on the destination and applicable framework, these may include an officially recognized adequacy decision, contractual protections such as the European Commission's Standard Contractual Clauses, additional technical or organizational measures, or another legally permitted transfer mechanism. UK or Swiss transfers are subject to the corresponding requirements where applicable.

These arrangements support compliance with relevant data-protection obligations, including those under the GDPR, CCPA, and VCDPA where applicable; these laws do not all impose identical transfer requirements.

Information is primarily stored and processed in Indonesia and in the countries where our service providers operate, including the United States and Singapore. For personal data transferred from the EEA, the United Kingdom, or Switzerland to countries not recognized as providing an adequate level of protection, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses and supplementary technical and organizational measures where required.

You can contact us for information about the safeguards applicable to your data and, where available, how to obtain a copy or description of them.

7 How long information is kept

Retention is determined by the purpose of processing and any applicable record-keeping requirement. Relevant factors include whether information is needed to deliver the Services or resolve a support request, establish or perform a contract, resolve a dispute, protect a legitimate interest recognized by law, or meet a statutory duty.

We review the need to retain information and delete it when the applicable retention period has ended and it is no longer needed for a permitted purpose. A withdrawal of consent, objection, or deletion request is assessed against any other lawful basis or obligation that requires continued retention; it does not automatically override a legal record-keeping duty.

We generally retain information as follows: device and advertising identifiers, gameplay and interaction records, and reliability and performance records are retained for up to 12 months after your last use of the Services; information you supply, such as support correspondence, is retained for up to 24 months after the related matter is closed; and records required for legal, accounting, or security purposes are retained for the period required by the applicable obligation. These periods are assessed against the criteria described above and may be shortened or extended where required by law.

You can request deletion at any time by emailing [email protected]. Where an exception applies, we will explain the relevant limitation as required by law.

8 Keeping information secure

We use administrative, technical, physical, and organizational safeguards appropriate to the information and the risks involved. These measures are intended to reduce unauthorized access, use, disclosure, alteration, loss, or destruction and to support the protection required in the place where the information was collected.

Our incident-response procedures address detection, containment, and investigation of suspected breaches. Where a breach triggers a legal notification requirement, we notify the relevant authority and/or affected individuals within the required period and provide the information the law requires.

Safeguards reduce risk but cannot make every system invulnerable. Internet transmissions and electronic storage cannot be guaranteed to remain completely secure in every circumstance.

9 Your choices and privacy requests

Depending on your location, the law that applies, and the type of processing, you may be entitled to:

• Ask whether we process your information, obtain access to it, and receive information about its collection, use, disclosure, sale, or sharing.
• Correct information that is inaccurate or incomplete.
• Request deletion, subject to applicable exceptions.
• Object to processing or ask for it to be restricted in circumstances recognized by law.
• Receive eligible information in a structured, commonly used, machine-readable form and, where applicable and technically feasible, have it transferred to another controller or provider.
• Withdraw permission for consent-based processing. Withdrawal does not invalidate processing carried out lawfully before the withdrawal. We stop the affected consent-based activity unless another lawful basis applies; if it is necessary for a requested feature, that feature may become unavailable.
• Opt out of targeted advertising, relevant content personalization, and any sale or sharing covered by applicable law.
• Exercise applicable rights relating to sensitive information, profiling, or decisions made solely by automated means.

To make a request, contact [email protected]. Describe the request and identify the relevant app. Including “Privacy Policy request” in the subject line helps us route your message, but is not a condition for exercising a statutory right.

Where verification is appropriate and legally permitted, we may ask for limited information, such as an account reference, where applicable, or device identifier, to locate the relevant records and protect them from disclosure to the wrong person. We will not impose identity verification on an opt-out request where the law prohibits doing so. An authorized agent may act for you where permitted, subject to the applicable authorization requirements.

We respond within the period required by the applicable law and explain any permitted extension. Some requests may be limited by legal obligations, the rights of others, or the need to complete a service request you already initiated. Where we cannot carry out a request, we provide the explanation and appeal or complaint information required by law.

Appendix A gives additional information for specific regions. You will not be subjected to unlawful discrimination for exercising an applicable privacy right.

10 Children and younger users

The Services are intended for users aged 13 or older. We do not knowingly collect personal information from children under 13. Users younger than 18 must have a parent or legal guardian review this notice and agree on their behalf where required by the applicable Terms or law.

Local law may set a higher age or impose additional conditions for consent and particular types of processing. A parent's review of this notice does not remove those requirements. If you believe that a child has provided information in circumstances that are not permitted, contact [email protected] so that we can investigate and take appropriate action, including deletion where required.

The Services are directed to a general audience aged 13 and older and are not directed to children under 13. Where the law of your country sets a higher age of consent for the processing of personal data, we apply that higher threshold and, where required, seek verifiable parental consent before processing such data.

11 Updates and contact details

We may revise this notice as our Services, information practices, or legal and operational requirements change. The current version will be posted on this page with an updated revision date. When a change requires an additional notice or renewed consent, we will provide it through an appropriate channel. Please check the notice periodically.

For privacy questions, concerns, deletion requests, or other rights requests, contact:

Responsible company: PT ADINA MULTI WAHANA

Email: [email protected]

Please use “Privacy Policy request” as the subject when practical so that we can direct the message to the appropriate team.

Appendix A Additional information for particular regions

These provisions supplement the main notice. Rights apply only to the extent provided by the relevant law, including its scope, eligibility rules, and exceptions. Mandatory local requirements take precedence over an inconsistent general description.

A1 European Economic Area United Kingdom and Switzerland

Where the relevant European, UK, or Swiss data-protection law applies, you may have rights to confirm processing and obtain a copy of your data; correct or complete it; request erasure; restrict processing; and obtain eligible data in a portable format or transmit it to another controller where feasible.

You may object, for reasons relating to your situation, to processing carried out on a legal basis that gives you that right. You may also object to the use of your information for direct marketing, including related profiling. Where we rely on consent, you can withdraw it without affecting earlier lawful processing.

Applicable law also protects you in relation to decisions based solely on automated processing, including profiling, that have legal or similarly significant effects. Where such processing is permitted, the relevant safeguards and rights apply, which may include human intervention and the ability to contest a decision.

Send a request to [email protected], explaining the right you wish to exercise and the information or processing concerned. We may seek proportionate identity verification where appropriate. Under the EU GDPR, the usual response period is one month from receipt; a permitted extension of up to two additional months may apply for complex or numerous requests, with reasons communicated within the initial month. UK and Swiss requests follow their applicable time-limit and verification rules.

You may complain to a competent supervisory authority, including the authority where you live or work or where an alleged infringement occurred, where the applicable law provides that option:

• EEA authorities: European Data Protection Board member directory
• United Kingdom: Information Commissioner's Office
• Switzerland: Federal Data Protection and Information Commissioner

A2 California

If the California Consumer Privacy Act, as amended, applies to our processing of your information, you may request information about our collection and handling of it. This includes the categories collected, the categories of sources, business or commercial purposes, categories of recipients, and categories of information sold, shared, or disclosed for a business purpose, together with the relevant recipient categories.

You may also request specific information held about you, deletion subject to statutory exceptions, and correction of inaccuracies. The required disclosure generally covers the preceding 12 months, with a longer period where the law requires or permits it.

California rights also include:

• Opting out of a covered sale of information or sharing for cross-context behavioral advertising.
• Limiting covered uses or disclosures of sensitive personal information where that right applies.
• Exercising these rights without unlawful discrimination.

Requests can be sent to [email protected] or submitted through our privacy email address. For a covered sale or sharing activity, use the in-app path Settings > Privacy > Do Not Sell or Share My Personal Information. Where required, we honor recognized opt-out preference signals, such as Global Privacy Control, for the relevant browser, device, or identified profile.

We verify requests to access, correct, or delete information using information reasonably needed for that purpose. Opt-out requests follow the separate rules applicable to them. Where permitted, an authorized agent can submit a request; we may require proof of authorization and, where legally allowed, direct verification or confirmation from you. We may decline an agent request if the required authorization is not established.

We handle requests within the deadlines applicable to the particular right. Opting out does not guarantee an ad-free experience or change independent advertising activity outside our Services.

In the preceding 12 months, we have collected the categories of personal information described in Section 2, including identifiers (device and advertising identifiers), commercial information (gameplay and interaction records), internet or other electronic network activity information (usage and performance records), and inferences drawn from these categories for advertising and recommendations. We do not collect sensitive personal information as defined by the CPRA, we do not sell or share sensitive personal information, and we do not use sensitive personal information to infer characteristics about you.

A3 Other US state rights

This section provides additional information for residents of Illinois, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Tennessee, Texas, Utah, and Virginia. The laws in these states differ, and inclusion in this list does not mean that each state grants every right below or that every law applies to every business.

Where provided by applicable state law, you may request confirmation of processing and access, correction of inaccuracies, deletion, and a portable copy of eligible information. You may also have rights to object to or restrict particular processing, or seek review of certain automated decisions, where the relevant law provides them.

Relevant opt-out rights may cover targeted advertising, the sale of personal data, and profiling used to make decisions with legal or similarly significant effects. Applicable safeguards may allow you to challenge such a decision or obtain human review. We do not treat a general right to object or to restrict processing as available in every state.

Send requests to [email protected] or use our privacy email address. We may seek additional information where necessary and permitted to authenticate a request. If we cannot authenticate it, or another lawful exception applies, we explain the decision and available appeal route. We do not deny a request merely because a person has lawfully exercised a privacy choice.

To appeal a refusal where an appeal right applies, email [email protected] with the subject “Privacy request appeal,” identify the original request, and explain why you seek review. We provide the outcome and any further complaint route within the applicable period. For example, Virginia's law generally requires a response to a rights request within 45 days, permits a further 45 days where its conditions are met, and requires a written appeal outcome within 60 days. If a Virginia appeal is denied, we provide a means of contacting the Attorney General to complain.

These rights may be subject to statutory exceptions and must be exercised without unlawful discrimination. Applicable examples include the Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act.

A4 Brazil

Where Brazil's Lei Geral de Proteção de Dados Pessoais (LGPD) applies, you may request confirmation that we process your data and access to it, correction of incomplete, inaccurate, or outdated information, and information about public or private entities with which it has been shared.

You may also request anonymization, blocking, or deletion of unnecessary or excessive data, or data processed contrary to the LGPD; portability to another service provider under the applicable regulatory conditions and protections for trade secrets; and deletion of consent-based data subject to statutory retention exceptions. Consent can be revoked through an accessible procedure, without invalidating processing that was lawful before revocation. You may ask about the possibility and consequences of declining consent.

Direct requests to [email protected]. We may ask for proportionate information to verify that the request is yours before releasing information or taking an action that requires verification.

Rights are subject to the LGPD's conditions and exceptions. In permitted circumstances, information may need to remain available for legal or regulatory duties, lawful contractual purposes, or establishing, exercising, or defending rights, including in judicial, administrative, or arbitration proceedings. Such reasons do not create a blanket exemption from deletion or other rights.

If you believe your rights have not been respected, you may contact the Autoridade Nacional de Proteção de Dados (ANPD).

Appendix B Third party service directory

A provider's involvement can vary between apps and features. Review its own privacy information for details of its independent processing and available rights or choices. You can contact us to ask which providers are involved in a particular app.

Appendix C Device permissions

Permissions depend on the platform and feature you use. The table below describes the permissions requested by the covered apps, their purposes, and whether declining them affects the relevant feature.

Where the operating system provides a permission control, you can review or change it in the relevant device settings. The table explains the effect of declining a permission on the associated feature.