1.1. This Privacy Policy ("Policy") explains the ways Spark X Games ("Spark X Games", "we", "us", or "our") collects, stores, uses, and otherwise processes the personal data of end users of our Services (referred to as "you" or "your"), 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 for, or otherwise accessing the Services, you agree to this Privacy Policy and give your explicit and informed consent to the processing of your personal data in accordance with this Policy. If you do not agree with this Privacy Policy, please do not install, use, register for, or otherwise access the Services.
1.4. Spark X Games reserves the right to modify and update this Privacy Policy periodically. We encourage you to check this page from time to time to review the latest version. Changes will come into effect immediately upon being posted on our Websites. Your continued use of the Services will signify your acceptance of the updated Privacy Policy. If material changes are made, we will notify you through the Services or by other appropriate means.
2.1. 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 is Spark X Games.
2.2. While operating the Services, we may share your data with partners we work with. Some of these partners are independent data controllers and, therefore, independently determine how and why they process your data. For more information on these partners and the ways in which they may process your data, please refer to Section 6 of this Policy.
3.1. When you access our products and Services, we will not collect your legally sensitive data (i.e., race, ethnicity, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sexuality, and/or criminal records) or other sensitive data (i.e., children's 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 the following categories of personal data:
| Category | Description | Examples |
|---|---|---|
| Account Information | Information you provide when registering | Name, email address, or other contact information |
| Online Identifiers | Identifiers used to recognize your device/account | In-game alias, IP address, internal account IDs, Advertising ID, device ID |
| Device Information | Technical details about your device | Device type, model, manufacturer, operating system, language, display, processor, memory |
| Location Data | Coarse location inferred from IP address | Country, state, or city |
| Usage Data | Information about your use of Services | Game progress, website visits, ad interactions |
| Ad Interaction Data | Data about interactions with our ads outside the Services | Referral source, ad engagement on third-party properties |
| Technical Data | Diagnostic and performance information | Crash logs, bug reports, error data |
| Communications | Messages you send to or through the Services | In-game chat messages, support emails, feedback |
| Third-Party Account Data | Data from linked third-party accounts (if you choose to connect) | Account name, identifier, email, profile picture, friends list |
| Purchase Data | Information from payment providers to validate purchases | Transaction ID, purchase amount (not actual payment details) |
| Survey/Research Data | Information you provide in surveys or research | Background, experience feedback, responses |
| Inferred Data | Inferences we make based on your activity | Preferences, behavior patterns |
3.3. With your consent, we may also collect other information explained to you at the time of asking for your consent.
We may collect and receive personal data through the following methods:
4.1. Directly from you when you submit it to us (e.g., when registering an account, subscribing to our communications, sending support inquiries, or responding to surveys).
4.2. Automatically from your device when you use our Services or interact with our ads outside of our Services (e.g., on third-party websites or applications), including through cookies or similar technologies, or software development kits (SDKs).
4.3. 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.
4.4. From third-party account providers if you choose to connect a third-party account (e.g., a social media account) with our Services.
4.5. From third-party payment service providers if you make purchases in our Services.
4.6. From other sources with your consent, as explained to you at the time of asking for your consent.
4.7. Providing data to us is not mandatory. However, we are unable to provide the Services, or certain parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this Policy, depending on the Services you decide to use and your choices when using them.
4.8. You have a number of options to limit or control the extent to which your data is processed:
When we process or collect your data, we ensure that we have a legal basis to do so. Below is a summary of the purposes for which we process your data and the corresponding legal basis:
| Purpose | Legal Basis |
|---|---|
| To set up, manage, and administer your account and provide the Services you request | Performance of a contract |
| To operate, maintain, and improve our products and Services | Legitimate interests |
| To ensure the technical functionality and security of the Service | Legitimate interests |
| To provide features available in the Service | Performance of a contract |
| To improve customer service and respond to your inquiries | Legitimate interests |
| To troubleshoot, analyze, test, and conduct research and statistics | Legitimate interests |
| To keep our products and services safe and secure, including fraud prevention | Legitimate interests |
| To measure and understand the effectiveness of our advertising and marketing | Consent / Legitimate interests |
| To send you service-related communications (confirmations, technical notices, updates, security alerts) | Performance of a contract / Legitimate interests |
| To inform you of promotions, rewards, upcoming events, and other news about products and services offered by Spark X Games | Consent |
| For statistical and research purposes (including market research, marketing, and data analysis) | Legitimate interests |
| To identify your gameplay behavior, habits, and preferences | Consent / Legitimate interests |
| To handle payment and collection processes | Performance of a contract |
| To comply with legal, regulatory, and licensing requirements applicable to us | Legal obligation |
| For other purposes with your consent | Consent |
Marketing refers to advertising, one of the tools that helps fund our Services and enables us to make our Games available free of charge. In some of our Games, we may show our own ads as well as ads from third parties. We also advertise our Games outside of our Services on third-party properties such as websites or applications.
Mobile advertising identifiers. Mobile advertising relies on the use of certain online identifiers, in particular Advertising IDs but also IP addresses or other identifiers. An "Advertising ID" is an alphanumeric string provided by the operating system of your mobile device. It is consistent across applications from different publishers. The Advertising ID is known as the Identifier for Advertisers ("IDFA") on iOS devices and the Google Advertising Identifier ("GAID") on Android devices.
Controlling advertising personalization. You can control the extent to which your Advertising ID is used for interest-based advertising:
How we use advertising data:
We may share your data with third parties to achieve the purposes described in this Policy. This may include sharing data with the following categories of recipients:
Your personal data may be used by us and disclosed to our group companies, including Spark X Games Co., Ltd. and all of its subsidiaries.
Your personal data may be disclosed to the partners we work with while providing the Services (who may process your data independently of us), including advertising partners, IP licensors, and others, such as:
| Partner | Privacy Policy |
|---|---|
| Adjust | adjust.com/legal/privacy/privacy-policy |
| AppLovin | applovin.com/privacy |
| Facebook (Meta) | facebook.com/privacy/policy |
| policies.google.com/privacy | |
| ironSource | developers.ironsrc.com |
| Pangle | csjplatform.com/privacy |
| Unity Ads | unity.com/legal/privacy-policy |
| Vungle | vungle.com/privacy |
We may disclose your personal data to regulators and law enforcement agencies, or in response to a lawful request from a government agency, where required by applicable law.
We may disclose your personal data to third-party service providers (including our professional advisors, data analysis processors, and data storage service providers) who require access to such information to provide specific services to us. These third parties are bound by contractual obligations to only access your data for the purpose of providing us their services and will not use it for their own purposes.
Your personal data and in-game behavior data may be stored on servers hosted by Amazon Web Services (AWS) located in the United States.
If the management and operation of Spark X Games and its affiliates are transferred to another company, we may disclose your personal data to the successor entity so that the products and services can continue to be provided to you. In the event that we sell or buy any business assets, or if Spark X Games or substantially all of its assets are acquired by a third party, personal data held by us about our customers will be one of the transferred assets.
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.
| Data Category | Retention Period |
|---|---|
| Account information | For the duration of your account, plus a reasonable period after deletion for legal compliance |
| Usage and gameplay data | For the duration of your active use, then deleted or de-identified |
| Purchase/transaction data | As required by applicable tax and financial laws (typically 5–7 years) |
| Technical/crash logs | Typically 90 days, then deleted |
| Marketing data | Until you withdraw consent or opt out |
| Communications (support tickets) | Typically 2 years after resolution |
We may periodically delete or de-identify inactive accounts or other data in our Games or other Services. After the applicable retention period, we will either delete or de-identify your data or, if neither is immediately possible (e.g., due to data stored on backup servers), isolate your data from further processing until deletion or de-identification is possible. We may continue to use data that is not identifiable to you (e.g., aggregate data).
We take the security of your personal data very seriously. We implement appropriate technical, organizational, and physical safeguards to ensure that your personal data is protected against accidental or unlawful loss, destruction, alteration, unauthorized access, disclosure, or any other unlawful processing. Our security measures include, but are not limited to:
Please keep in mind that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security.
You have various rights in relation to the personal data we hold about you. To exercise any of these rights, please contact us using the details in Section 14. We will seek to deal with your request without undue delay and in accordance with applicable law. We may request reasonable evidence to verify your identity before processing your request.
| Right | Description |
|---|---|
| 9.1. Right of Access | You have the right to know what personal data we hold about you, how and why we process it, and to request a copy of your personal data. |
| 9.2. Right to Rectification | You have the right to request the correction or update of any personal data that is inaccurate, incomplete, or out of date. |
| 9.3. Right to Erasure | In certain circumstances, you have the right to request that we delete the personal data we hold about you. Please note that deleting your account may result in permanent loss of game progress, virtual currency, and virtual goods without the right to recovery or refund. Some data may be retained for legal compliance, fraud prevention, or technical integrity purposes. |
| 9.4. Right to Restrict Processing | In certain circumstances, you have the right to restrict the processing of your personal data. |
| 9.5. Right to Object | You have the right to object at any time to the processing of your personal data that is based on legitimate interests, unless our interests are overridden by your rights and freedoms. |
| 9.6. Right to Opt Out of Targeted Advertising | You can opt out of personalized advertising through your device settings. iOS: Settings > Privacy & Security > Apple Advertising > turn on "Limit Ad Tracking." Android: Settings > Google > Ads > turn on "Opt out of Ads Personalization." Note: you will still see ads, but they will not be personalized. |
| 9.7. Right to Data Portability | In some circumstances, you have the right to receive the personal data you have provided to us in a structured, machine-readable format and to transmit it to another controller. |
| 9.8. Right to Withdraw Consent | You have the right to withdraw your consent at any time where we process your personal data based on consent. Withdrawal does not affect the lawfulness of processing before withdrawal. |
| 9.9. Right to Lodge a Complaint | You have the right to lodge a complaint with your local data protection authority if you believe we have infringed your privacy rights. |
| 9.10. Right to Object to Automated Decision-Making | In some instances, our use of your personal data may result in automated decisions (including profiling). For example, we use automated decisions to deliver targeted interest-based advertising. You can opt out of targeted advertising as described in Section 9.6. |
| 9.11. Right to Opt Out of Sale (California, USA) | California residents have the right to opt out of the "sale" of personal data, which may include the transfer of data to third parties for ad personalization. If you opt out, we will not sell your data, but you may still see ads in the game. |
For EU/EEA residents: The EU General Data Protection Regulation ("GDPR") grants you the above rights. While we will usually not do so, we reserve the right to charge a reasonable fee for the exercise of your rights where permitted by applicable law.
Our Services are global by nature, and your data may be transferred to and processed in countries outside your country of residence, which may have different data protection laws.
To ensure adequate protection of your data during such transfers, we implement appropriate safeguards, including:
You have the authority to manage, use, and delete the data generated in the application. If you no longer need your account data, you can delete or remove it.
Data that can be deleted:
For detailed step-by-step instructions, please see our User Data Deletion Guide.
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, or if you are between 13 and the age of majority in your jurisdiction, that you have obtained parental or guardian consent.
We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not use the Service and do not send any information about yourself to us.
If you are a parent or guardian and believe that your child under 13 has provided us with personal information, please contact us using the details in Section 14, and we will take steps to delete such information.
We may update this Policy from time to time, for example, due to changes in our operations, services, or applicable legal obligations. Updates will be posted on this page, and we encourage you to check it periodically.
If we make material changes to this Policy, we will notify you through the Services or by other appropriate means (e.g., email or in-app notification) before the changes take effect.
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us:
We are committed to resolving your questions and concerns in a timely manner and in accordance with applicable data protection laws.