Privacy Policy
Last Updated: September 27, 2024
[Preface]
What Does This Privacy Policy Cover
This privacy policy stipulates how we collect, use, protect, store, disclose, share, transfer or otherwise handle personal information from our users (“You”). We ask that you please read this policy carefully and confirm that you understand and agree to its contents, especially any bolded or underlined portions, before using our Services.
SparkWish (hereinafter referred to as “we”) is committed to maintaining your trust and upholding the fundamental principles of protecting the security of your personal information. We collect personal information during your use of the Services, but we only use it for the express purposes set forth in this Privacy Policy.
The “Privacy Protection for Minors” chapter of this Privacy Policy specifically stipulates the protection of personal information of minors in accordance with relevant national laws and regulations. Please note: If you are a minor under the law, please be sure to read this Privacy Policy accompanied by your parents or guardians. You can only use our services after they have agreed to this Privacy Policy.
The key points of this policy are set out below:
I. What Information We Collect
1. Information You Provide When Using Our Products
1.1 Registration and Login Information
1.1.1 You can enter our games directly as a visitor in order to complete a quick access.
1.1.2 When you choose to create an account to log in to our Games, you may register for an account to log in as required and we may collect your relevant registration information.
1.1.3 You may also log in to our products through a third party account (e.g. Facebook, Google, online, etc.), at which point we may collect publicly available information about your account on the third party platform (e.g. your avatar, username, account's identification ID).
1.2 Feedback Information
1.2.1 If you request information about our products, request technical support, or contact us through the in-product feedback function, we may ask you to provide personal information such as your login details, email address, phone number, device ID, system language, APP version, and other relevant information.
We collect this information to provide you with a prompt solution to your inquiry.
2. Other Information We Collect When You Use Our Products
2.1 Device Information
To ensure the normal operation of the basic functions of our products, optimize their performance, and protect the security of your account, we may collect relevant information about your device. This information may include your device ID, device name, device type and version, system version, IP address, application ID, application interactions, Google Advertising ID (GAID/AAID) or other identifiers, network connection status, and network access mode and type.
Please note that if your Android system is below version 6.0, it may collect your [IMEI, IMSI, MAC address]. Therefore, please ensure that you upgrade your system to version 6.0 or above to avoid sharing this sensitive information. But we do not collect any of your information in advance and advise you upgrade your system version to better protect your privacy.
2.2 Information Collected When Requesting Permissions from You
When we apply for or use the relevant permissions of your operating system, we will inform you of the purpose of the permissions and request your consent before opening them (except in cases where the operating system cannot support the mobile device you are using). The details are as follows:
2.2.1 In order to save some of your game data, pictures, and the function of uploading pictures for the feedback function, we may request your external device storage privileges (application access and writing to the external storage space of the app).
2.2.2 During your use of the services we provide, we need to check your network connection status which allows us to provide you with data usage alerts in order to avoid increasing your mobile data usage and to manage data retrieval and sending requests. In this scenario, we require permissions to allow the application to access network status information, allow the application to access Wi-Fi status information, and allow the application to access the internet.
2.2.3 In order to provide you with richer advertising information, we need to request permission for the application to access the advertising ID, allow the application to receive advertising attribution information, allow the application to access advertising topic information, and permit the application to access Google Play services ads. This involves obtaining your Google Advertising ID for the purposes of advertising attribution and analysis.
2.2.4 Request permission for the application to use Google Play Billing Service, which is used for purchasing in-app goods or subscription services.
2.2.5 Request permission for the application to create foreground services, in order to provide services to user programs.
2.2.6 Request permission for the application to publish notifications, used for alerting or informing the user.
2.2.7 Request permission for the application to receive messages from Google Cloud Messaging services, used to receive real-time messages and notifications.
2.2.8 Request permission for the application to control phone vibration, used to provide haptic feedback or alert the user; request permission for the application to keep the device awake, preventing the device from entering sleep mode.
2.2.9 Request permission for the application to bind to the Google Play store’s acquisition installer referral service, used to understand the channels through which users download and install applications.
2.2.10 Request permission for the application to trigger boot broadcasts, which enables the application to automatically start upon booting and provide services to users.
Note about specific feature permissions: If you need to turn off the feature permissions that are enabled for the use of the specific features mentioned above, most mobile devices support this requirement. You can refer to or contact your mobile device’s service provider or manufacturer for the specific method, or you can contact us for assistance.
It is important to note that device information, when collected alone, does not identify a specific natural person. If we combine such non-personal information with other information for the purpose of identifying a specific natural person or use the remaining personal information in combination, such non-personal information will be treated as personal information during the combination period. We will anonymize and de-identify such personal information unless we have obtained your authorization or are otherwise required by law or regulation.
3. Other Information We May Collect
3.1 Information Collected When You Make In-Game Purchases
When you make purchases on the Services, such as purchasing game props, removing advertisements from the game, auto-renewing subscriptions, etc. (subject to the availability of the product), please note that the payment service is provided by Google. We will only obtain payment result information from the payment service provider (Google) to validate that the payment has been made, and then provide you with the corresponding payment products and services. If you would like to know the specific rules for the collection of personal information by Google, please refer to the Google Privacy Policy of your choice.
II. How We May Use Your Personal Information What Information We Collect
When you use our products or services, we may collect and process your personal data for various purposes. To ensure the legality of this conduct, we will explain in detail the reasons for collecting this information and the legal regulations based on which we use this information legitimately and compliantly:
1.When it is necessary to perform a contractual obligation that we are about to enter into or have already entered into with you. For example, it is necessary to collect your related information when we use your personal information to provide services to you.
2.When it is necessary for our legitimate interests and/or the legitimate interests of a third party, provided that your interests and fundamental rights do not override those interests. For example, when we collect information about your device to ensure the security of our services, improve our services, and enforce our terms, conditions, and policies, it aligns with our legitimate interests.
3.When we need to comply with legal or regulatory obligations, for example, when we are legally required to provide your personal information to authorities to comply with lawful government or regulatory requests.
4.When we have obtained your explicit consent to process for specific purposes, for example, when we use your personal information to show you advertisements as required by law.
5.We will not combine stored information with personal identity information you provide. Meanwhile, we will analyze the operational status of our product based on information, including the frequency and circumstances of your use, fault information, and performance data, to ensure the safety of services, continually optimize our products, and improve our service quality.
6.We will strictly abide by the provisions of laws and regulations as well as the agreement we have with you to use collected information in accordance with this Privacy Policy and the User Agreement. We may analyze the operational status of our product based on information, including the frequency and circumstances of your use, fault information, and performance data, to ensure the safety of services, continually optimize our products, and improve our service quality.
We will use the collected information for the purposes covered by this policy. If we use your personal information beyond the scope described in this policy, we will revise the contents of this policy and obtain your express consent again before collecting your personal information.
III. Cookies or Similar Technologies
Cookies are a neutral technology that allows a web server to store data on or read data from a client. We may use cookies or similar technologies to optimize your experience, but we will not use them for any purpose other than those described in this policy. Please understand that certain services are only available through the use of such technologies.
You have the ability to turn off or delete these technologies by changing the settings of your device or related programs if permitted, or by visiting the provider’s web page. However, this action may affect your use of the products and/or services.
IV. Third-Party Services
To ensure the safe and stable operation of our games and to provide specific functions, we may use relevant third-party services in the game. We carefully select the third party and the third-party services, make reasonable efforts to urge the relevant third party to collect and use your personal information in accordance with this policy or as otherwise agreed with you, and take appropriate security technology and management measures to protect the security of your personal information.
However, please understand that we will not collect your personal information on behalf of third parties or share personal information we collect with them. Third parties collect your personal information for providing advertisements and analytic purposes separately. Third parties have their own privacy policies, and we have no control over the personal information collected by third parties or how they use that personal information. We recommend that you review the contents of their corresponding privacy policies on your own to learn more about their privacy data practices.
V. How We Share, Transfer and Publicly Disclose Your Personal Information
You have the right to know if your personal information is shared or sold. We do not share, transfer or disclose your personal information to third parties except as provided in this Privacy Policy and the User Agreement. If there are other instances of sharing, transferring or disclosing your personal information or if you request us to share, transfer or disclose your personal information to a third party other than us, we will confirm this directly with you and obtain your express consent. We will not sell the information you provide to us or the information we collect from you to any other company for their free use, and will strictly abide by relevant laws and regulations to keep the above information confidential.
We will only share your de-identified, anonymized personal information for legal, legitimate, necessary, specific, and explicit purposes. According to legal and regulatory requirements, sharing, transferring, or disclosing personal information that has been de-identified—and ensuring that the recipient of the data cannot restore and re-identify the data subjects—does not constitute the act of external sharing, transferring, or public disclosure of personal information. Therefore, we do not need to notify you or obtain your consent separately for the storage and processing of such data.
VI. How We Retain and Protect Your Personal Information
1. Information Retention
We do not retain personal information collected, received and processed for the purposes described in this policy for longer than necessary. To ensure that your personal information is protected in accordance with the law, the information we collect from you will be stored in accordance with the relevant laws and regulations governing privacy data protection in the country concerned. To the extent not prohibited by local laws and regulations, we may also store personal information collected in countries or regions other than those in which we operate.
If we terminate our services or operations, we and the third-party platforms we work with will promptly stop the activities of continuing to collect your personal information and will comply with the requirements of relevant laws and regulations to notify you in advance and delete or anonymize your personal information after the termination of the services or operations, unless otherwise provided by laws, regulations or regulatory authorities.
2. Information Security Protection
The security of your information is very important to us, and we will use reasonable security measures to ensure that your personal information is not lost, disclosed, destroyed or abused. For example, we use measures like encryption technology (such as SSL) and anonymization to protect your personal information. However, please understand that no method of Internet transmission or electronic storage is 100% safe and reliable, and we cannot guarantee its absolute security. We recommend that you pay due attention to the protection of your personal information when using our products and services, and we provide a variety of security features to assist you in protecting the security of your personal information.
VII. Privacy Protection for Minors
In compliance with relevant policy requirements and legal provisions, we may verify your age through pop-up window prompts to provide you with advertising services that are more in line with your rights and interests. However, please note that we will only obtain verification information on whether you are a child user, and we will not use this information for any other purposes, nor will we use it in combination with other personal information.
We do not knowingly collect or solicit personal data about minors or knowingly allow such persons to use our Services directly. If you are a minor, please do not send us any personal data; if we become aware that we have collected personal data about minors or if you believe that we may have data from or about minors, please contact us immediately so that we may delete the data as soon as possible.
Please note that different countries have varying definitions of minors, and to ensure greater security and protection of minors’ information, we limit the age of minors to less than 13 years old (including 13 years old) or the age of minors as limited by relevant national regulations in accordance with the laws and regulations of the relevant countries. We will strictly abide by the relevant laws and regulations and adopt reasonable and necessary measures to protect the privacy and security of minors. If you have any questions, please contact us promptly.
VIII. What Rights Do You Have with Respect to Your Personal Data?
Subject to any limitations and exceptions under applicable laws, you have the right to request access to your personal data and exercise the following rights, which we will adhere to in accordance with applicable laws and your requests. Please contact us using the information provided, where we will verify your identity and understand your specific requirements before proceeding with reasonable actions.
1.The Rights You Have
You have the right to access or inquire about certain personal information of yours, asking how we use this information, and to whom we disclose or share it. However, please understand that we may only be able to provide the information we retain according to the relevant legal requirements.
If you believe that there are errors in the personal information we process about you or if there is other information that needs modification, you have the right to correct or update this personal data to ensure its timeliness and accuracy.
You have the right to request the deletion of your personal data, which we will carry out after verifying your identity and understanding your specific needs. Please be aware that some functions requiring this information may no longer be available if you choose to delete it. If relevant data protection regulations stipulate that we have a justified reason to keep your personal data, we may retain it but will inform you in advance if this is the case.
In certain circumstances, you have the right to request that we cease processing your personal data (except for storage purposes). However, we may reuse this information again if justified reasons exist under data protection laws.
You have the right to obtain a copy of your personal data that we collect and process based on your consent or the contract signed between us, in a structured, commonly used, and machine-readable format. You also have the right to request that we transfer such information within reasonable limits to a third party. If exercising this right infringes on the rights and freedoms of others, we will not support the exercise of this right.
You have the right to object to the processing of your personal information, which you can communicate to us through the contact information in this policy.
You can contact us to withdraw the consent you previously provided. However, please be aware that if you withdraw your consent, some service features may no longer be usable.
You have the right to complain to the relevant data protection authorities about our handling of your personal data, but if you have any dissatisfaction with our processing of your personal information, we recommend contacting us first so that we can address your concerns promptly.
2. Cancellation of Account:
If you want to cancel your account and delete the information related to the account, you can contact us directly through the contact information provided by us. Please note that once you have canceled your account, you will not be able to recover it, so please be careful. When you cancel your account, we will stop providing services to you and will delete or anonymize your personal information in accordance with the requirements of applicable laws and regulations, unless otherwise provided by laws and regulations.
9. Special Notice for Other Regions
Special Notice for California Resident (as per the “California Consumer Privacy Act of 2018” amended by the “California Privacy Rights Act of 2020” (“CCPA”))
If you are a California resident, your personal data is protected under the provisions of the CCPA. The terms “personal information” and “sensitive personal information” carry the meanings given in the CCPA and do not include information outside the scope of the CCPA.
1.Collection and Disclosure of Personal Information
We fully ensure that you are informed about whether your personal information is shared with third parties or sold.
Over the past 12 months, you can review our purposes, methods, and scope of collecting and using your personal information in the first part “What Information We Collect” and the second part “How We May Use Your Personal Information” of this policy. We have not shared, sold, or disclosed your personal information to any third parties.
In the last 12 months, we have not sold or shared personal information of California residents as defined under “sell” and “share” in the CCPA, nor have we conducted such activities concerning personal information of users under the age of 16.
2.Collection and Use of Sensitive Personal Information
In the past 12 months, we have not collected your sensitive personal information. Apart from providing services reasonably expected by typical consumers requesting services, we will not use sensitive personal information for other purposes.
3.Retention of Personal Information
As stipulated by the CCPA, we retain personal information for a reasonable and necessary period to achieve the purposes described in this policy, including but not limited to fulfilling our legal obligations, managing internal records, enforcing our terms, and resolving disputes. We will not extend the retention period of information unnecessarily unless required or authorized by relevant laws.
4. CCPA-Specified Privacy Rights on Personal Information
If you are a California resident and CCPA does not recognize exceptions applicable to you or your personal information, you have the right to:
4.1 Request that we disclose to you, free of charge, the following information from the 12 months preceding your request;
4.2 The categories of personal information about you that we collect;
4.3 The categories of sources from which we collect personal information;
4.4 The purposes for collecting your personal information;
4.5 The categories of third parties to whom we disclose your personal information, the categories of personal information disclosed (if applicable), and the purposes for disclosing your personal information; and
4.6 The specific personal information about you that we collect;
4.7 Request us to delete personal information collected from you, unless an exception under CCPA is recognized;
4.8 Request us to correct inaccurate personal information we hold about you; and
4.9 When you exercise rights granted by the CCPA, protection against unlawful discrimination for exercising such rights, including receiving different levels or quality of services, or refusal to provide goods or services to you;
4.10 In some cases, you have the right to limit the use of any sensitive categories of personal information. As stated above, we do not collect or attempt to collect sensitive categories of personal information;
4.11 In certain situations, you have the right to opt out of automated decision-making related to your personal information.
5. Right to Opt-Out of “Selling” or “Sharing” Your Personal Information
If there is a situation involving “sharing” or “selling” your personal information, you have the right to direct us not to engage in such activities. If you choose to opt-out of sharing or selling your personal data, you can contact us using the methods described in this policy to exercise your rights.
As a California resident covered by CCPA, you can contact us through the contact methods specified in this policy to exercise your rights concerning other data (if any). Please note that to protect your privacy and security, we may implement verification measures before processing your request. Should verification fail, we may deny your request.
Additionally, the CCPA grants you choices which you can exercise on your own or you can designate an authorized agent to make requests on your behalf. To ensure the validity of requests from an authorized agent, you must provide formal written authorization to them. We reserve the right to require the agent to verify their identity and to confirm directly with you the authenticity of the authorization to ensure the security and legality of the process. Under the provisions of the CCPA, we are committed to completing all actions related to your verified request within 45 days after receipt. If there are special reasons necessitating an extension of the processing time, we will extend it by an additional 45 days and provide a detailed explanation of the reasons for the delay.
Special Notice for Residents of Virginia (“Virginia Consumer Data Protection Act” - “VCDPA”)
If you are a resident in the state of Virginia, your “personal data” and “sensitive personal data” have specific meanings as defined under the VCDPA and do not include information that falls outside the scope of this act. Below are the rights granted to you under the VCDPA:
1.If you are a resident of Virginia and there are no recognized legal exceptions applicable to you or your personal data, you have the right to:
1.1 Request that we disclose the personal data we collect, use, or disclose about you, as well as information about our data practices.
1.2 Request that we delete the personal data collected from you, unless an exception recognized by law applies;
1.3 Request corrections to inaccurate personal data that we hold about you;
1.4 Be free from unlawful discrimination when exercising your rights under the law, including receiving different levels or quality of services, or denial of goods or services.
If you are a Virginia resident to whom VCDPA applies and wish to exercise the above rights, you may contact us using the contact methods provided in this policy. Please be assured that we do not collect any sensitive personal information.
2.Appeals and Complaints
If you wish to appeal any decision regarding your request to exercise any rights under the VCDPA, you can contact us.
Special Notice for Residents of the European Economic Area, Switzerland, and the United Kingdom
If you are a resident of the European Economic Area, Switzerland, or the United Kingdom, the provisions of the General Data Protection Regulation (GDPR) will apply to your personal information.
1.Access to Personal Information
You have the right to access certain personal information about you, inquire how we use this information, and to whom it has been disclosed or shared. However, please understand that we can only provide the information we retain according to relevant legal requirements.
2.Correction of Personal Information
If you believe that the personal information we process about you is incorrect or needs modification, you have the right to correct or update this data to ensure its timeliness and accuracy.
3.Restriction of Processing Personal Information
You have the right to request that we anonymize or de-identify your non-essential personal information, or address any processing not in compliance with GDPR regulations. Please contact us using the provided contact methods.
4.Portability of Personal Information
You have the right to request us to transfer your related personal information and data to a third party under conditions of confidentiality and as further stipulated by the GDPR.
5.Objection to Processing Personal Information
You may notify us through the contact method provided at the end of this policy if you oppose our processing of your personal information. It is your right to refuse such processing.
6.Withdrawal of Consent to Personal Information
You can contact us to withdraw the consent you previously provided. However, please be aware that if you withdraw your consent, some service functions may no longer be usable.
7.Feedback and Complaints
You have the right to object to our processing of personal data, including for marketing purposes based on profiling and/or automated decision making. Within the limits allowed by GDPR, we may continue to process your information despite your disagreement. You can also inform us of your issues, opinions, or complaints through the provided contact methods.
8.Transferring Personal Information Outside the EU
If there are situations that involve transferring personal information outside the EU, we will use technological and physical safeguards to protect your personal information and strictly comply with the relevant EU laws and regulations. If you have any questions about the mechanisms related to the transfer of your personal information, please contact us.
We will only collect, use, or store your personal information under the following circumstances:
8.1 Information you voluntarily provide to us.
8.2 To provide you with the services you requested.
8.3 To protect your vital interests or those of others.
9.Deletion of Personal Information
If you are a resident of the aforementioned countries/regions, you can contact us regarding our collection and use of your user information via the contact methods outlined in this privacy policy. Please provide sufficient information to enable us to identify the content or information to be deleted. However, we don’t need to delete your personal information if we have valid reasons to retain it, such as preventing fraud.
Please note, in some cases, the law prohibits us from fulfilling your request, including when:
9.1 We cannot confirm your identity;
9.2 The request is deemed excessive;
9.3 Doing so would adversely affect the rights or freedoms of others.
Special Notice for Residents of Brazil (Regions subjected to LGPD)
If you are a resident of Brazil, your personal information will be subject to the provisions of the LGPD.
1.Access Personal Information
You have the right to access or inquire about certain personal information we hold about you. You can ask how we use this information and to whom we disclose or share it. However, please understand that we may only provide the information that we are required to retain by law.
2.Correction of Personal Information
If you believe that the personal information we process about you is incorrect or needs updating, you have the right to correct or update this information to ensure it is timely and accurate.
3.Deletion of Personal Information
You have the right to request the deletion of your personal information. After verifying your identity and clearly understanding your request, we will delete your personal information. Please be aware that if you choose to delete this information, some features that require this information may no longer be available. If data protection law prohibits the deletion under certain circumstances, we will continue to retain the information.
4.Restriction of Processing Personal Information
In some cases, you have the right to ask us to stop processing your personal information (except for storage purposes). However, we may use the information again if there are legitimate reasons under data protection law.
5.Data Portability
You have the right to obtain a copy of the personal information we collect and process based on your consent or contracts signed by both parties in a structured, commonly used, and machine-readable format. You also have the right to ask us to transfer this information to a third party within reasonable limits. If exercising this right infringes on the rights and freedoms of others, we will not support the exercise of this right.
6.Objecting to Processing Personal Information
You can use the contact information provided at the end of this policy to inform us that you object to our processing of your personal information. This is your right to refuse the processing of your personal information.
7.Withdrawal of Consent
When we use your personal information based on your consent, you can withdraw your previously given consent for the collection, use, and disclosure of your personal information within the scope agreed upon in the contract and as permitted by law. To withdraw consent, you can contact us through the contact information in this policy. However, please note that this may affect the services we provide to you.
8.Protection of Minors
If you have not reached the legal age of majority (under 18), you must obtain the explicit permission of your parents or legal guardians before using this service to ensure they have read and agreed to the terms of this policy. We promise not to intentionally collect any information about minors without the necessary consent. If you suspect that we may hold personal information about a minor without the necessary consent, please contact us immediately. We will verify and delete such information.
9.Information Transfer
By agreeing to this privacy policy, you consent to us collecting, using, and processing your personal information within the scope specified in this policy, including disclosing and transferring to third parties outside Brazil when necessary.
X. How We Will Update This Privacy Policy
We reserve the right to change this Policy from time to time in accordance with applicable law. When we update our Privacy Policy, we will post the new Privacy Policy by updating the “Update Date” at the top of this Policy, and your continued access to or use of the Platform after the date of the updated Policy will mean that you accept the updated Privacy Policy. If you do not agree to the updated Policy, please stop accessing or using the Platform immediately. Please note that if we need to adapt the Policy to legal requirements, the new Policy will be effective immediately or as needed.
XI. Contact Us
SparkWish is your data controler. If you have any questions or requests regarding this Privacy Policy, you may contact us by sending an email to sparkwishstudios@hotmail.com. Generally, we will accept and process your request for personal information within fifteen business days after verifying the relevant information.
Data Protection Officer (DPO): SparkWish
Email Address: sparkwishstudios@hotmail.com