If you are a minor and are not sure you understand everything in this Policy, please review it with a parent or legal guardian before using SPARKS Apps and Games. SPARKS Apps and Games are not intended for users under 16 years of age. If local law requires a higher minimum age or parental or guardian authorization for specific processing activities, SPARKS may apply that higher standard for the relevant user, territory, feature, or processing activity.
Introduction
SPARKS INFORMATION (SINGAPORE) PTE. LTD. (hereinafter referred to as "SPARKS") is an international entertainment company that publishes and operates mobile games and related services, including official websites, account systems, customer support channels, community features, and official top-up or payment pages made available by or on behalf of SPARKS.
Purpose
The purpose of this Policy is to provide you with important information and explanations about how and why some of your data may be collected and processed by SPARKS when you use one of our applications, browse our websites, use our official top-up or payment center, contact customer support, participate in community features, or otherwise interact with SPARKS services.
This Privacy Policy governs and details the main principles that SPARKS applies to the data we collect and process to:
· develop, publish, operate, secure, support and monetize mobile games and applications ("SPARKS Apps and Games");
· run our corporate website, official top-up or payment center, and related web pages or portals operated by or for SPARKS; and
· manage user accounts, guest mode, third-party login, customer support, community and safety features, marketing communications, purchases, refunds, anti-fraud controls, compliance, and dispute handling.
Should you have any questions related to this Policy or our practices around privacy and data protection in general, please contact SPARKS as indicated in the Contact section of this Policy.
SPARKS Apps and Games
Why does SPARKS collect data from its apps and games?
When you use SPARKS Apps and Games, SPARKS may collect information about you, your device, your account, and your use of our services. Some information is provided directly by you, some is generated through your use of the service, and some may be received from third-party platforms, service providers, or payment and login partners when you choose to use those features.
Depending on the relevant feature and applicable law, SPARKS may process personal data on the basis of performance of a contract with you, SPARKS's legitimate interests, your consent, and or compliance with legal obligations. The legal basis may vary by jurisdiction, product configuration, feature, and processing activity.
SPARKS may collect and process data for the following purposes:
· To provide, operate, maintain and improve the services you request, including account registration, guest mode, third-party login, game progression, cross-device synchronization, social and community features, customer support, official top-up or payment functions, purchase fulfillment, virtual currency and virtual item delivery, and service administration.
· To secure SPARKS Apps and Games and users, including authentication, fraud prevention, abuse detection, account recovery, troubleshooting, moderation, handling user reports, investigating suspected violations, and reviewing suspension or ban appeals.
· To run first-party analytics and, where permitted or consented to as required by applicable law, third-party analytics, attribution and performance measurement, in order to understand how users interact with our products and services and to continuously improve them.
· To provide advertising, including contextual advertising and, where permitted or consented to as required by applicable law, personalized advertising, advertising frequency management, campaign measurement, and related monetization activities.
· To manage communications with you, including responding to support requests, sending service, security, account and transaction notices, and, where permitted or consented to, providing newsletters, updates, promotions or other marketing communications.
To comply with legal and regulatory obligations, protect SPARKS's rights and interests, establish, exercise or defend legal claims, maintain records, and support audits, corporate transactions, and internal governance.
What data does SPARKS collect from its apps and games?
Depending on the services, features and settings you use, SPARKS may collect personal data that identifies you directly, data that identifies you indirectly, and data that relates to your device, gameplay, communications, purchases, or interactions with our services.
· Account and identity information, such as account ID, user name, nickname, avatar, password or authentication credentials, age gate information, date of birth or age band, third-party platform identifiers, login tokens, and email address. Where technically appropriate, SPARKS may also store a hashed or otherwise pseudonymized version of your email address or identifier for account matching, security or recovery purposes.
· Gameplay and service usage information, such as your game progress, log-in history, friends or guild lists, interactions with other users, participation in events, feature usage, session duration, gameplay telemetry, and records relating to your use of virtual currency, virtual items, loot-box or probability-based features, offers, rewards, refunds, and chargebacks.
· Community, user-generated content and safety information, such as chat messages, voice communications or related metadata, friend requests, guild content, forum or community posts, images, text, recordings, reports, mute or block lists, moderation records, and ban or appeal submissions, where such features are available.
· Customer support and communications data, such as support tickets, emails, account recovery requests, attachments, diagnostic information, correspondence content, survey responses, complaints, and other materials you submit to SPARKS.
· Payment and transaction data, such as order number, transaction identifier, purchase history, purchased content, amount, currency, payment status, refund status, billing country or region, tax information where required, and payment provider references. Payment card numbers, bank account numbers and similar payment credentials are generally collected directly by the relevant payment service provider rather than by SPARKS, unless SPARKS must receive limited payment-related details for reconciliation, anti-fraud, customer support or legal compliance.
· Device, technical and network data, such as IP address, device model, operating system, language, app version, browser type, screen resolution, time zone, crash reports, error logs, timestamp, user agent, network type, device identifiers, and mobile advertising identifiers such as Apple IDFA, Google AAID, IDFV, Android ID or similar identifiers, subject to your settings and applicable law.
· Location, contact book and permission-based data, such as approximate or precise location, contact information, photo library content, microphone, camera, local storage, clipboard, notifications and other device permissions, but only when those permissions are made available by the product and authorized by you through your device or in-app settings, and only to the extent necessary for the relevant feature.
When you register an account, bind an account, recover an account, subscribe to email communications, use customer support, or log in through a third-party service such as Google, Apple, Facebook or another supported provider, SPARKS may collect your email address and related verification or login information. SPARKS may use that email address for account creation, login, identity verification, account recovery, customer support, service and security notifications, transaction-related notices, compliance, and, where permitted or consented to, marketing communications. You may unsubscribe from marketing emails at any time through the unsubscribe function in the relevant email or through available account settings.
If your email address is bound to an account and you wish to unbind or change it, you may do so through the in-app settings, the website account or deletion page where available, or by contacting SPARKS through the Contact section below. Subject to reasonable identity verification and account security checks, SPARKS will generally respond to email binding or unbinding requests within 15 business days and in any event within the time period required by applicable law.
With whom may your data be shared & why?
SPARKS does not sell your personal information for monetary consideration. However, depending on the jurisdiction and the way certain advertising or analytics technologies operate, some disclosures may be characterized under applicable law as a sale, sharing, cross-context behavioral advertising, or targeted advertising. Where required by applicable law, SPARKS will provide the relevant notice, consent or opt-out choices.
SPARKS may share personal data, as necessary and subject to applicable law, with the following categories of recipients:
· Affiliates and corporate group entities, to support internal administration, publishing operations, customer support, security, analytics, localization, finance, legal compliance, and other purposes consistent with this Policy.
· Service providers and processors acting on SPARKS's behalf, such as hosting and cloud providers, customer support tools, account and authentication providers, payment service providers, communication and email vendors, security vendors, moderation and trust and safety vendors, voice and chat infrastructure providers, crash reporting and analytics providers, attribution and anti-fraud providers, storage providers, and other vendors required to operate and improve the services.
· Advertising, attribution and analytics partners, to the extent enabled by SPARKS and permitted by applicable law and your choices, for advertising delivery, monetization, performance measurement, attribution, frequency management, fraud prevention, and analytics.Those partners usually collect data via their own tools (Software Development Kits or “SDK”). You will find a list of our partners implementing advertising SDKs through our applications and the privacy policies of their services that describe their practices and allow you to exercise your rights directly toward them hereafter:
Adcolony - https://www.adcolony.com/privacy-policy/
Applovin -https://www.applovin.com/privacy/
Facebook -https://www.facebook.com/about/privacy
Fyber - https://www.fyber.com/privacy-policy/
Google -https://policies.google.com/privacy
Inmobi -https://www.inmobi.com/privacy-policy/
Ironsource - https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Mintegral -https://www.mintegral.com/en/privacy/
Mopub -https://www.mopub.com/legal/privacy/
Oath -https://policies.oath.com/in/en/oath/privacy/
Ogury - https://ogury.com/privacy-policy/
Tapjoy - https://www.tapjoy.com/legal/tapjoy-users/#privacy-policy
Vungle - https://vungle.com/privacy/
· Third-party platforms and partners you choose to use, such as app stores, social login providers, game platforms, payment processors, or external community or sharing services, where sharing is necessary to enable the relevant function, complete a transaction, authenticate your account, or fulfill your request.
· Authorities, regulators, law enforcement agencies, courts, opposing parties, professional advisers, and other third parties where SPARKS reasonably believes disclosure is required or permitted by law, regulation, legal process, government request, industry rule, audit requirement, or to protect the rights, property, safety, users, systems, reputation or legal interests of SPARKS, its users, or the public.
· Counterparties and advisers involved in an actual or proposed merger, acquisition, asset sale, financing, reorganization, insolvency proceeding, or similar corporate transaction, subject to appropriate confidentiality and lawful handling requirements.
SPARKS may also disclose personal data without further notice to you where such disclosure is required or permitted by applicable law, is necessary to investigate fraud, abuse, illegal activity or security incidents, is necessary to enforce our terms, policies or game rules, or is otherwise necessary to establish, exercise or defend legal claims.
The current list of key third-party SDKs, cookies, processors or partners may change over time. Where required by applicable law, SPARKS will make the relevant vendor information, consent tools, or privacy choices available through the relevant in-app notice, consent manager, website cookie banner, account settings, or support channel. You will find a list of our partners implementing analytical SDKs through our applications hereafter:
·AppsFlyer - https://www.appsflyer.com/privacy-policy
·Adjust - https://www.adjust.com/terms/privacy-policy/
·Google Analytics - https://policies.google.com/privacy
SPARKS Website
SPARKS Website includes SPARKS's corporate website and any official top-up or payment center, account management page, support page, promotion page or other related web page that links to or incorporates this Policy. Use of the website and related services may also be governed by applicable terms and conditions, payment terms, campaign rules, or other notices made available on the relevant page.
Why does SPARKS collect data from its website?
Like most websites and online payment pages, when you browse SPARKS's website or use the official top-up or payment center, certain information about your device, browser, connection and activity may be collected automatically so that the website can operate properly, remember your preferences, secure transactions, diagnose issues, measure performance, process purchases, and, where permitted or consented to, support analytics, personalization and advertising.
SPARKS and its partners may also use cookies, software development kits, local storage, pixels, tags and similar technologies to administer the website, remember choices, authenticate users, prevent fraud, analyze traffic, measure campaigns, and operate account, support and payment features. You can control certain cookies and similar technologies through the available cookie banner, browser settings or other controls, although disabling some technologies may affect the functionality of the website or payment center.
What data does SPARKS collect from its website?
· Browsing events and interactions with the website, payment center, account pages, support pages, forms, banners, and related content and services.
· IP address, approximate location derived from IP, cookie identifiers, browser and device information, logs, referral source, user agent, session information and other technical information related to your browser and or device.
· Information you provide voluntarily when you contact SPARKS, create or bind an account, subscribe to updates, participate in promotions, submit a support request, complete a purchase, request a refund, or otherwise fill in a form on the website, such as email address, account identifier, order information, screenshots, written descriptions and other materials you choose to submit.
Transaction and payment-related information generated through the official top-up or payment center, such as selected goods or services, order value, currency, payment method, payment status, chargeback or refund status, tax or invoicing information where required, and related communications. Sensitive payment credentials are usually collected directly by the relevant payment service provider and processed under that provider's own privacy notice.
Analytics and third party cookies
SPARKS may use analytics technologies, including for example Google Analytics or similar tools where implemented, to understand website traffic, user behavior, campaign effectiveness, fraud risks, and the performance and proper functioning of the website and payment center. Where required by applicable law, SPARKS will request consent before placing or reading non-essential cookies or similar technologies and will honor applicable consent or opt-out signals.
For more information about the privacy practices of relevant analytics, advertising, social or payment providers, you can refer to Google specific policy accessible here: https://policies.google.com/privacy and opt-out from Google Analytics data collection here: https://tools.google.com/dlpage/gaoptout
Please refer to the notices made available through the relevant cookie banner, payment interface, privacy settings, or support channel, as those providers and integrations may change over time.
Social networks and other communication tools
SPARKS's website may offer social media widgets, sharing buttons, embedded content, external links, customer service tools or other communication tools. When you interact with those services, the relevant third-party provider may collect information about you, your device, your browser and your interactions, and your use of those services will be governed by that provider's own privacy notice and terms.
· Facebook:https://www.facebook.com/about/privacy
· Linkedin: https://www.linkedin.com/legal/privacy-policy
Security and other important information
How long does SPARKS keep your data?
SPARKS keeps personal data for no longer than is reasonably necessary for the purposes described in this Policy, unless a longer retention period is required or permitted by applicable law, needed to resolve disputes, enforce agreements, defend claims, maintain security, prevent fraud or abuse, complete audits, or comply with tax, accounting, payment, regulatory or recordkeeping obligations.
Retention periods may vary depending on the type of data and the relevant product, feature, country, and legal obligations. As a general rule:
· account data, game progression data and related profile information are generally kept for as long as your account remains active and for a limited period thereafter to allow account recovery, backup restoration, dispute handling and legal compliance;
· guest mode data is generally retained only for as long as necessary to support the guest account or device-based play and may be lost if you delete the app, reset your device, clear local storage, or replace the relevant device or identifier;
· advertising identifiers, attribution records and similar campaign data are generally not retained for more than 13 months, unless a shorter period applies under your settings or a longer period is required or permitted by applicable law;
· first-party analytics records may be retained for up to 25 months where such period is configured and permitted by applicable law;
· customer support records, moderation records, report handling records, ban and appeal records, and investigation materials are generally retained for the duration of the case and for up to 3 years thereafter, unless a longer period is necessary in light of repeated abuse, legal claims, or regulatory requirements;
· transaction, payment, tax, invoicing and anti-fraud records may be retained for up to 10 years or such longer period as is required or permitted by applicable law;
· marketing subscription records are generally retained until you unsubscribe, withdraw consent, or the relevant campaign ends, and suppression records may be retained thereafter to ensure your opt-out request is honored.
Children data
SPARKS does not knowingly collect or knowingly permit the continued use of SPARKS Apps and Games by children under 16 years of age. If you are under 16, please do not use SPARKS Apps and Games, create an account, make purchases, use community features, submit personal data to SPARKS, or otherwise access the services where prohibited.
If SPARKS becomes aware that personal data has been collected from a user under 16 in violation of this Policy or applicable law, SPARKS may take reasonable steps to verify age, suspend or terminate the relevant account, restrict access to certain features, cancel or reverse pending transactions where appropriate, and delete or anonymize the relevant data as required or appropriate. Where applicable law requires parental or guardian involvement for users above 16 or for specific processing activities, SPARKS may also require additional authorization, age verification or feature restrictions.
International transfers
SPARKS, its affiliates, processors and partners may process personal data in countries other than the country where you reside. Where required by applicable law, SPARKS will take appropriate steps to ensure that international transfers are made subject to adequate safeguards and lawful transfer mechanisms.
· the personal data may be transferred to countries or recipients recognized as providing an adequate level of protection under applicable law;
· for transfers that are not otherwise covered by an adequacy decision, SPARKS may rely on standard contractual clauses, data transfer agreements, certification frameworks, intra-group arrangements, derogations, or other transfer mechanisms recognized under applicable law; and
SPARKS may implement supplementary contractual, technical and organizational measures where appropriate, taking into account the nature of the data and the relevant transfer scenario.
What rights do you have?
Your personal information belongs to you, and SPARKS will respect the rights available to you under applicable law. Depending on your jurisdiction, those rights may include the right to access, know, correct, update, delete, port, restrict, object to, or withdraw consent to certain processing; the right to opt out of certain advertising or data-sharing practices; the right to limit certain uses of sensitive personal information where applicable; and the right not to be discriminated against for exercising your privacy rights.
You may contact SPARKS at the email address listed in the Contact section below at any time to exercise your rights, subject to reasonable identity verification, legal exceptions and technical feasibility. SPARKS may ask you for additional information reasonably necessary to verify your identity, confirm your request, protect account security or prevent unauthorized access to another person's data.
Consent withdrawal and opt-out of sale of information
You can change certain consent or privacy settings at any time through the Privacy Settings made available in SPARKS Apps and Games, the website cookie banner, your device settings, or other controls made available by SPARKS or the relevant platform. Please note that if you refuse or withdraw consent for personalized advertising or certain analytics technologies, you may still receive advertising, but it may be less relevant to your interests and certain features may function differently.
Although SPARKS does not sell personal information for money, certain advertising or analytics disclosures may be regarded under some laws as a sale, sharing, or targeted advertising. Where those laws apply, SPARKS will provide the required opt-out tools and will process qualifying requests in accordance with applicable law.
Access right
Upon request and subject to applicable law, SPARKS will provide you with information about whether SPARKS holds personal data about you and, where required, access to such data and related information. Requests may be submitted through available in-app tools, account settings, website tools, the account deletion page, customer support, or the contact information below. SPARKS will respond within the time period required by applicable law and, where permitted, may extend that period where the request is complex or numerous.
Rectification and erasure
You may request that SPARKS correct inaccurate or incomplete personal data and, where applicable law provides, erase personal data that is no longer necessary, that is processed unlawfully, or that must otherwise be deleted. These rights are subject to applicable exceptions, including where SPARKS must retain data for legal compliance, account security, fraud prevention, dispute handling, tax, accounting, payment reconciliation, legal claims, or other lawful purposes.
Depending on the relevant service and your jurisdiction, you may be able to manage or erase certain data by resetting your advertising identifier, changing device permissions, adjusting privacy settings, unbinding or changing your email address, deleting your account through the account deletion page, or contacting SPARKS directly. Where identity verification or security checks are necessary, SPARKS may ask for additional information before acting on the request.
Portability
Where the right to data portability applies and where technically feasible, SPARKS will provide you, upon request, with the personal data that you provided to SPARKS in a structured, commonly used and machine-readable format, or will transmit that data to another controller where applicable law so requires and the transmission is technically feasible and secure.
Right to lodge a complaint
If you believe that SPARKS has not handled your personal data in accordance with applicable law, you may lodge a complaint with the competent data protection, privacy or other supervisory authority in your place of residence, place of work, place where the alleged infringement occurred, or other competent jurisdiction. If you are located in Singapore, you may also contact the Personal Data Protection Commission of Singapore.
Delete Account Data
In addition to contacting SPARKS through the Contact section below, you may also follow the instructions on SPARKS's data deletion website or any in-app deletion function made available by SPARKS to request deletion of your account data. Please note that account deletion may cause you to lose access to your account, game progression, virtual items, virtual currency, purchases, community content, and other service features associated with the deleted account, except to the extent retention, restoration or continued access is required or permitted by applicable law or SPARKS's contractual obligations.
Contact
SPARKS INFORMATION (SINGAPORE) PTE. LTD. is the data controller for the processing described in this Policy, except where a third-party payment service provider, platform provider, login provider or other partner acts as an independent controller for its own processing activities under its own privacy notice.
You can contact SPARKS or its data protection contact point at:
· dpo@huntingsniper.games
18 Kaki Bukit Road 3, #05-18, Entrepreneur Business Centre, Singapore