Latest Update: 24/08, 2023
If you accept SPARKGAME COMPANY LIMITED (“Company”, “we” or “us”) Spark Games Services versions other than the versions distributed in specific countries/regions includes Mainland China, Hong Kong, Macau, Taiwan, Japan and Korea, you acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy (“this policy”), you must not use Company Services. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.
This privacy policy is an inseparable part of our Terms and Service. This policy applies to all Company Services that directly reference or link to this policy but does not apply to Company Services that have separate privacy policies that do not incorporate this policy.
The minimum age to create a Spark Account ("Account") is 13. Insofar as certain countries or platforms apply a higher age of consent for the collection of personal data, parental or guardian consent is required before an Account is created and personal data associated with it is collected.
You agree that if you are under whatever is the age of legal majority where you access the services, you represent that your legal guardian has read, understood, and agreed to this policy.
This section describes the different types of personal information we collect and how we collect and use it. We will collect and use the following information about you:
1.1 Information You Provide Us
a) When you register for the Game (including your nickname, accounts and other information we import from your connected social media account (GooglePlay, Facebook, etc.) in order to set up your profile, including your name as it appears on your social media profile and your profile picture;
b) When you log-in as a ‘guest’ in order to use the Game (your nickname);
c) When you participate in a Survey in the Game (in which case we will process the information you provide to us as part of the Survey)
d) When you transact through our Services (if applicable) or with our third-party Service Providers authorized by us.
e) When you link your Account with Your Social Media Accounts (GooglePlay, Facebook, etc.) or other external accounts or use other social media functions in accordance with Service Provider's policies, and
f) When you use our Services or interact with other users and/or us through our Services. This includes, but is not limited to, the cookies that may be generated when you interact with us.
1.2 Information We Collect About You
a) Contact information (such as name and email address).
b) Player name or tag and password.
c) Profile information (such as profile photo).
d) Your messages to the Service (such as chat logs and player support tickets).
e) Other data you choose to give us (such as data to identify a lost account or data you provide to participate in survey or promotional programs).
1.3 Data we collect automatically.
a) Data about your account and game progress, including in most cases an automatically created internal account ID.
b) Your IP address and mobile device identifiers (such as your device or advertising ID).
c) Data about your device, such as device name and operating system, browser type and language, internet service provider, and mobile carrier.
d) Data we collect with cookies and similar technologies.
You also have the option to create a Spark Games ID using your email address or other social media accounts.
1.4 Data We Collect from Third Parties
We also use third-party partners, such as social networking sites, data analytics providers and advertising networks to supplement information we have about you, such as:
a) Data we receive if you link a third party tool with the Service (such as Facebook, Apple or Google).
b) Data to fight fraud (such as refund abuse in games or click fraud in advertising).
c) Data from platforms that the games run on (such as to verify payment).
d) Data for advertising and analytics purposes, so we can provide you a better Service.
e) Data that you have made available to us from a third party service (such as LINE, Apple, Google or Facebook) via your privacy settings.
1.5 Cookies.
We use cookies and other similar technologies (e.g., web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using our Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. You may permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the Game) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed.
We use your data for a variety of business purposes, such as:
a) To make the Service work.
b) Create accounts and allow you to play our games and use our Service.
c) Verify and confirm payments.
d) Provide and deliver products and services you request.
e) Send you Service-related communications.
f) To make the Service more suitable for our players.
g) Update and develop player profiles.
h) Develop and improve the Service and player experience.
i) Manage our relationship with you.
j) Customize your Service experience.
k) Respond to your comments and questions and provide player support.
l) To show personalized advertisements
m) To keep the Service safe and fair.
n) Take action against fraudulent or misbehaving players.
o) To analyze, profile, and segment.
In all of the above cases and purposes, we may analyze, profile and segment all collected data.
In order to combat fraud and illegal activity, we may process and disclose data with other companies and organizations and provide it to public authorities in response to lawful requests.
We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
If you request, we will provide you a copy of your personal data in an electronic format.
We rely on a number of legal grounds to process information about you. For example, we will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and where we have a legal obligation to process your information. For example, we rely on our legitimate interests to serve targeted marketing and on contractual necessity to process information when you create an account.
3.1 Share. We value the protection of your personal information, which is an important basis and part of the products and services we provide to you. We will only collect and use your personal information for the purposes and within the scope of this Policy or as required by law and regulations and will keep it strictly confidential. In general, we will not share your personal information with any company, organization or individual, except in the following cases:
a) with your prior consent;
b) where the sharing of your personal information is required by applicable law, regulation, legal process, governmental compulsion or judicial decision;
c) to the extent required or permitted by law, it is necessary to provide your personal information to third parties in order to protect us, its users or the public from harm to their interests, property or safety;
d) your personal information may be shared among our affiliated companies. We will only share personal information that is necessary and such sharing is subject to the stated purposes of this Policy. If an affiliate wishes to change the purpose of processing personal information, it will again seek your authorized consent;
e) in order to provide you with improved, quality products and services, some of our Services will be provided by authorized partners. We may share some of your personal information with our partners in order to provide better customer service and user experience. We will only share your personal information for purposes that are legal, legitimate, necessary, specific, and explicit, and only as much personal information as is necessary to provide the services. We also require our partners to handle your personal information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures. Our partners are not authorized to use the personal information shared for any other purpose. If you refuse to allow our partners to collect the personal information necessary to provide the service, you may not be able to use that third party service on our platform.
3.2 Transfer. We will not transfer your personal information to any company, organization or individual, except for the following:
a) Transferring with obtaining explicit consent: after obtaining your explicit consent, we will transfer your personal information to other parties;
b) Provision in accordance with applicable laws and regulations, requirements of legal proceedings, and mandatory administrative or judicial requirements as may be necessary;
c) In the event of a merger, acquisition, transfer of assets, bankruptcy and liquidation or similar transaction involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this Policy before we require the company or organization to seek your authorized consent again.
3.3 Disclosure. We will only disclose your personal information publicly when:
a) After obtaining your express consent;
b) Disclosure based on law: We may disclose your personal information publicly if compelled to do so by law, legal process, litigation or governmental authority.
3.4 Without Your Prior Consent. In accordance with relevant laws and regulations and national standards, we may share, transfer, and publicly disclose personal information without obtaining your prior authorized consent in the following cases:
a) In connection with the performance of our obligations under laws and regulations;
b) Directly related to national security and national defense security;
c) Directly related to public safety, public health, and significant public interests;
d) Directly related to crime investigation, prosecution, trial and execution of judgments, etc.;
e) For the purpose of safeguarding the life, property and other significant legitimate rights and interests of the subject of personal information or other individuals but where it is difficult to obtain his or her consent;
f) Personal information disclosed to the public by the subject of the personal information himself/herself;
g) Personal information collected from information that is legally and publicly disclosed, such as legal news reports, government information disclosure and other channels.
In accordance with the law, sharing, transferring or publicly disclosing personal information that has been de-identified to the extent that the data recipient is unable to recover and re-identify the information subject shall not be deemed as sharing, transferring or publicly disclosing personal information, and such data shall be stored and processed without notice to or consent from you.
We will keep your data only for as long as your account is active or only for as needed to provide you the game services unless deleted in accordance with your request or as otherwise required by any applicable laws.
You acknowledge and agree that your data will be processed on our servers which may not be located in your country of residence and can be accessed by our support, engineering and/or our affiliates around the world. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable law.
In the case you request to remove or delete your personal data, we will retain your data as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable services.
We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where the applicable law provides for longer storage and retention period. Upon the expiration of such period, your personal data will be deleted, blocked or anonymized, as provided by applicable law.
5. If you request in writing, we will provide you a copy of your personal data in an electronic format after passing our verification process. You also have the right to correct or modify your data, have your data deleted, object to how we use or share your data, restrict how we use or share your data, and make any other request as provided herein or regulated by the applicable regulations of the relevant authorities (including but not limited to the GDPR and the CCPA) through sending an email to our Data Protection Officer (referred as DPO) at services@raindewstudio.com. Upon receiving your request via email, we will promptly conduct a verification process including but not limited to instructing you to provide information to confirm that you are the user from whom we have collected information, subject to the specific instructions of our DPO.
5.1 Right to Know About Your Personal Information
You have the right to access your personal data we hold about you, including but not limited to how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your Game account and by contacting our DPO. If you believe we hold any other personal information about you, please email us as well. You have the right to require us to provide a duplicate of your personal data undergoing processing, subject to submitting a verifiable request in the form of an email to our DPO’s email address According to our reasonable and unilateral judgement, if your verifiable request affects or will affect the rights or freedom of other users or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs arising therefrom) or refuse to act on the request.
5.2 Right to Rectify
If we process your personal data, we shall endeavor to ensure, by implementing suitable measures, that your personal data is accurate and up-to-date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate personal data without undue delay according to Article 16 of the GDPR (if applicable) and you can modify the information you provided via Account Management on our websites.
5.3 Right to Request Deletion of Personal Information
You have the right to obtain deletion of your personal data if the reason as stated in this Privacy Policy does not exist anymore, or if there is another legal ground for its deletion, subject to submitting a verifiable request in the form of sending an email to our DPO’s email address.
You acknowledge and agree that as a result of deleting your Account, you will lose access to our Services, including but not limited to the Account statistics, subscriptions game-related information linked to such Account, and lose the possibility to access other services through such Account.
5.4 Right to Object
When our processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR (if applicable) and/or this Privacy Policy or any other applicable law in your country/region of residence, you have the right to object to our processing. If you object, we will no longer process your personal data unless there are compelling and prevailing on legitimate grounds of processing as described in Article 21 of the GDPR or any other applicable laws in your country/region of residence; in particular, if the data is necessary for the establishment, exercise, or defense of legal claims. You also have the right to lodge a complaint with a supervisory authority.
5. 5 Right to Restrict Processing
You have the right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR (if applicable) or any other applicable law in your country/region of residence.
5.6 Right to Personal Data Portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format and have the right to transmit that data to another controller under the conditions set out in Article 20 of the GDPR (if applicable) or any other applicable law in your country/region of residence.
5.7 Right to Opt-Out of the Sale of Personal Information (if applicable)
You have the right to opt-out of the sale of your personal data (if any) and require us to make a statement regarding whether or not we sell your personal data and provide an opt-out mechanism or link to it except as otherwise stipulated in the CCPA.
5.8 Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You have the right not to receive discriminatory treatment by us for the privacy rights conferred by the CCPA, namely that we shall not offer financial incentive or a price or service difference due to your exercise of any of your rights under the CCPA unless such difference is reasonably related to the value of your personal data. Notwithstanding the foregoing, we have the right to deny your request to know, request to delete, or request to opt-out for reasons permitted by the CCPA (if applicable) or those regulations thereof, and such denial shall not be considered discriminatory.
5.9 Right to Authorize an Agent to Make a Request on Your Behalf
You have the right to authorize an agent on your behalf to make a request to know, delete, or opt-out under the CCPA (if applicable). When you use an authorized agent to submit any request provided above, we may require you to provide signed permission to authorize your agent to do so for the purpose of verifying your own identity, and the official permission by your agent to submit this request. In the case of failure to provide any of the requested materials, to protect the user’s information and data security, we are entitled to denying such request.
Notwithstanding the foregoing, if the applicable law in your country/region of residence provide otherwise, such laws shall govern.
Pertaining to your use of our services, we have endeavored to take reasonable measures to prevent unauthorized access to or improper use of your personal data, such as organizational controls, technical protection, and other protection measures.
However, the transmission of information via the internet is not completely secure. While we strive to protect your personal data, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet. Therefore, we strongly urge you to take every possible precaution to protect your personal data when using our services, including but not limited to changing your passwords from time to time, not reflecting other unnecessary personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser, and/or taking other possible security measures. Please note that for security reasons, we store passwords in encrypted form.
Please be aware that advertisers or websites with links to and/or from our websites may collect personal data about you and this Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or websites. We highly recommend that you read the privacy policy of such third party websites which you may be directed to before providing any personal data.
We may update this privacy policy from time to time. If we make material changes in the way we collect, use, retain or share your personal information, we will notify you by posting notice of the changes on the services covered by this privacy policy. By continuing to access or use our Services after we have posted a modification to this policy or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified terms. If the modified terms are not acceptable to you, your are free to cease using our Services.
We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information and the use and disclosure of information about you, including personal information, as described in this Policy.
You represent that you are an adult in your country/region of residence (or at another age in your jurisdiction where you are classified as a majority) when using our Services. If you are a minor or under the legal age of majority (“Minor” or “Children”), please do not send any personal data about yourself to us, including but not limited to your name, address, telephone number, or email address.
Notwithstanding the foregoing, we recognize that we have a special obligation to protect children in regards to the collection and processing of personal data, and we do not and will not knowingly collect personal data from children without consent from their parents or guardians. We strongly urge guardians to instruct their children not to disclose any of their personal data when using our Services without the prior permission of their parents or guardians. If we learn that we have collected a child’s personal data, we will delete such data as quickly as possible. Also, if you believe that we might have any data from or about a child, please contact us at our DPO’s email.
Questions, comments and requests regarding this policy are welcomed. Also, in the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance via email at services@raindewstudio.com. We will endeavor to deal with your request as soon as possible.