Privacy Policy

1. Introduction and Scope

Welcome to SparkGaming Limited ("SparkGaming," "we," "us," or "our"). We are dedicated to providing exceptional gaming experiences while prioritizing the privacy and security of our users ("you," "your," or "players").

This Privacy Policy describes how SparkGaming collects, uses, stores, processes, and shares your personal information when you use our websites, mobile applications, PC games, console titles, and other online services (collectively, the "Services").

SparkGaming acts as the Data Controller for your personal information under applicable data protection laws, including the European Union's General Data Protection Regulation (GDPR), the Hong Kong Personal Data (Privacy) Ordinance (PDPO), and the Singapore Personal Data Protection Act (PDPA).

By accessing, downloading, or playing our games, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices as described herein, please discontinue the use of our Services immediately.

2. Information We Collect

We collect data to provide, improve, and protect our Services. The types of information we collect depend on how you interact with us and the specific games you play.

2.1 Information You Provide Directly

  • Account Registration: When you create a SparkGaming ID, we may collect your username, email address, password, date of birth, and region.
  • Customer Support: If you contact us via [email protected], we collect your contact details, message content, and any attachments (e.g., screenshots of game errors).
  • Purchases: If you make transactions within our Services, we (or our third-party payment processors) collect billing information, transaction history, and currency details. Note: We do not store your complete credit card numbers.
  • User-Generated Content: Any data you upload, such as profile photos, chat logs (text and voice), and forum posts.

2.2 Information Collected Automatically

  • Device Information: Device model, operating system (OS), unique device identifiers (e.g., IDFA, Android ID), IP address, MAC address, and mobile carrier.
  • Gameplay and Usage Data: We track your in-game actions, achievements, game progression, session duration, clickstreams, and crash reports.
  • Log Data: Server logs that record your browser type, language preference, referring/exit pages, and timestamps.
  • Location Data: General location derived from your IP address (e.g., country/city level). With your explicit consent on mobile devices, we may collect precise GPS data for location-based features.

2.3 Information from Third Parties

  • Connected Accounts: If you link your SparkGaming account with third-party platforms (e.g., Steam, Facebook, Google, Apple, PlayStation Network, Xbox Live), we receive information such as your user ID, profile name, and friends list, strictly in accordance with your privacy settings on those platforms.
  • Advertising Partners: We may receive data from marketing partners to attribute app installs or measure campaign performance.

3. How We Use Cookies and Tracking Technologies

We and our partners use Cookies, SDKs (Software Development Kits), and similar technologies (e.g., pixels, beacons) to enhance your experience.

  • Essential Cookies: Strictly necessary for the operation of the Service (e.g., keeping you logged in).
  • Performance & Analytics: Help us understand how the Service is being used (e.g., Google Analytics).
  • Functionality: Remember your preferences, such as language or region.
  • Advertising: Deliver personalized ads based on your behavior.

Your Control: You can manage or disable cookies through your browser settings. However, please note that disabling essential cookies may impact the functionality of our games.

4. Legal Basis and Use of Information

We process your data only where we have a legal basis to do so. The purposes and legal bases are as follows:

Purpose of Processing Legal Basis (GDPR/General)
Service Delivery: To create accounts, enable gameplay, process payments, and provide technical support. Contractual Necessity (Performance of the agreement between you and us).
Security & Fair Play: To detect fraud, prevent cheating/hacking, and ban toxic behavior. Legitimate Interests (Ensuring a fair gaming environment for all users).
Improvement & Analytics: To analyze trends, fix bugs, and develop new features. Legitimate Interests (Business intelligence).
Marketing: To send newsletters, promotional offers, and targeted ads. Consent (Where required by law) or Legitimate Interests.
Legal Compliance: To comply with tax laws, legal requests, or regulatory requirements. Legal Obligation.

5. Sharing and Disclosure of Information

SparkGaming does not sell your personal information. We only share data under the following circumstances:

  • Service Providers: We engage trusted third-party companies to perform services on our behalf, such as cloud hosting (e.g., AWS, Azure), payment processing, customer support ticketing, and data analytics. These providers are contractually bound to protect your data.
  • Affiliates and Subsidiaries: We may share information within the SparkGaming corporate family for operational purposes.
  • Legal Requirements: We may disclose information if required by law enforcement, courts, or government regulators in Hong Kong, Singapore, the US, or other jurisdictions where we operate.
  • Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your user data may be transferred as part of the transaction. We will notify you of any such change in ownership.
  • With Your Consent: We may share information with third parties if you explicitly authorize us to do so.

6. International Data Transfers

As a global company, SparkGaming Limited may process and store your information on servers located outside your country of residence, including in Singapore, the United States, and Hong Kong.

  • For European Users: When transferring data outside the EEA/UK, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission or ensure the destination country has an adequacy decision.
  • For Chinese Users: Your personal information will generally be stored on servers in the People's Republic of China if legally required. If transferred outbound, we comply with the Measures for the Security Assessment of Outbound Data Transfers.

7. Data Security and Retention

7.1 Security Measures

We employ industry-standard physical, technical, and administrative security measures to protect your data, including SSL/TLS encryption for data in transit, access controls, and firewalls. While we strive for absolute security, no system is impenetrable. In the event of a data breach, we will notify affected users and relevant authorities as required by law.

7.2 Data Retention

We retain your personal information only as long as necessary to fulfill the purposes outlined in this policy, or as required by law (e.g., for tax and accounting records). When data is no longer needed, we securely delete or anonymize it.

8. Your Rights and Choices

Depending on your location, you have specific rights regarding your personal information:

  • Right to Access: Request a copy of the personal data we hold about you.
  • Right to Correction: Request that we fix inaccurate or incomplete data.
  • Right to Deletion (Right to be Forgotten): Request deletion of your account and data, subject to legal retention obligations.
  • Right to Restrict Processing: Ask us to limit how we use your data in certain contexts.
  • Right to Data Portability: Receive your data in a structured, commonly used format.
  • Right to Object: Object to our processing of your data for direct marketing purposes.
  • Withdraw Consent: Where processing is based on consent, you may withdraw it at any time.

To exercise these rights, please contact our Data Protection Officer at: We will respond to your request within the timeframe mandated by local laws (usually 30 days).

9. Specific Regional Disclosures

9.1 California Residents (CCPA/CPRA)

This section applies to residents of California.

  • Categories Collected: Identifiers, Commercial Information, Internet Activity, Geolocation.
  • Rights: You have the right to know what personal info is sold or shared and to opt-out of the sale/sharing of personal info. SparkGaming does not "sell" personal information in the traditional sense.
  • Shine the Light: You may request a list of third parties to whom we have disclosed personal information for their direct marketing purposes.

9.2 Children's Privacy

Our Services are not intended for children under the age of 13 (or the age of digital consent in your region, e.g., 16 in parts of the EU). We do not knowingly collect personal information from children without verifiable parental consent. If we discover that we have collected data from a child without consent, we will take steps to delete it immediately.

10. Third-Party Links

Our Services may contain links to third-party websites or services (e.g., Discord, Twitch, YouTube). This Privacy Policy does not apply to those external sites. We encourage you to review the privacy policies of any third-party sites you interact with.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in technology, law, or our business operations.

  • Notification: Material changes will be communicated via in-game notifications, website banners, or email.
  • Continued Use: Your continued use of the Services after the effective date of the revised policy constitutes your acceptance of the changes.

12. Contact Us and Dispute Resolution

If you have questions, concerns, or complaints regarding this Privacy Policy or our data practices, please contact us:

SparkGaming Limited

Email: [email protected]

Attention: Privacy Team / Data Protection Officer

Governing Law and Jurisdiction:
Except where prohibited by local law, this Privacy Policy shall be governed by and construed in accordance with the laws of Hong Kong. Any dispute arising out of or in connection with this Policy shall be referred to and finally resolved by arbitration in Hong Kong, or submitted to the exclusive jurisdiction of the courts of Hong Kong.