Privacy PolicyPocketSpark Studios

1. Scope and application

This policy applies to PocketSpark Studios games, applications and websites that link to it, as well as support communications related to those services, collectively referred to as the "Services".

Our practices depend on the features available in the Service you use. If a feature is not available in a game, this does not authorize the collection of data associated with that feature. Material differences will be identified in this policy or in an additional notice available within the relevant Service.

Third parties also explain their own practices in their policies. Those documents supplement the information about our integrations without replacing our responsibilities for processing under our control. The notices in sections 12 through 14 supplement the general provisions where the relevant laws apply. Rights provided in other jurisdictions remain available under applicable law.

2. Personal information we process

The categories of information processed vary depending on the game, its version, the features used and how you interact with our services. Not all categories described below apply to every game or use. Some information remains only on your device; other information is processed by the providers identified in this policy, depending on the feature used, permissions and applicable privacy choices.

2.1. Information you provide

• Profile and preferences: nickname, avatar, and language, sound and vibration settings, where these features are available. In games with local saving, this information is stored on your device.
• Contact and support: your email address, message content and any attachments you choose to send. We use this information to respond, investigate the issue reported and handle privacy requests.

Avoid sending passwords, identity documents or other information that is not necessary for support.

2.2. Information processed automatically

In games with advertising, the integration with Appodeal and enabled partners may process the following categories:

• Identifiers and connection information: IP address and advertising identifiers made available by the device, subject to the applicable settings.
• Device and application information: technical information such as the device model, operating system and application version.
• Advertising interactions: records of ad impressions and clicks, used for ad delivery and measurement.
• Diagnostics and performance: technical signals used to operate and analyze advertising services.

Processing depends on the components actually used and the applicable privacy choices. Listing a category in this policy does not mean that all partners receive all of that data in every game.

Information saved on your device

In games with local saving, progress, game sessions, results and achievements are stored on your device so that you can continue your experience.

This local storage is different from sending data to advertising services. A game may save your progress locally while also using advertising services that process data over the internet.

Backup and data transfer features provided by the operating system may also affect how this information is retained, depending on the device and application settings.

2.3. Third-party information and services

Third-party services may receive data directly from components integrated into the application, even when your progress remains saved only on your device. The purposes, information categories and links to providers' policies are set out in section 4.

3. Purposes of processing

The information described in section 2 is used for the following purposes, depending on the features available in the Service.

3.1. Operating the Services

Enabling games to function, allowing you to continue playing, saving progress and applying your chosen preferences.

3.2. User support

Answering questions, investigating reported problems and handling privacy requests. Information you provide voluntarily is used to address your request and any directly related follow-up matters.

3.3. Advertising and measurement

In games that include advertising, we use Appodeal to mediate ad delivery among enabled partners. Ad selection and measurement may involve the data processing described in this policy.

3.4. Security and fraud prevention

Protecting the operation of the Services, analyzing signs of failures and preventing abuse and fraud related to the Services and advertising.

3.5. Legal obligations and exercising rights

Complying with applicable obligations, privacy requests and valid orders from authorities. Where there is a lawful basis, retaining or using only the data needed to resolve disputes and exercise rights.

3.6. Activities requiring consent

Requesting a specific choice before activities that require consent, as explained in section 5. A new purpose is not authorized merely because it falls within a general description in this policy. The legal bases for processing subject to the GDPR or UK GDPR are detailed in section 14.2.

4. Sharing personal information

Sharing depends on the purpose of processing, the Service used and the applicable choices. The categories of recipients are described below.

4.1. Service providers

We use service providers to assist with support, hosting and the technical infrastructure of our services. Their processing of data relates to the activities they perform for the purposes described in this policy.

We use Google's Gmail to receive and respond to messages sent to pocketsparkstudios@gmail.com. The sender's address, message content and attachments are processed through that service. Please see the Google Privacy Policy.

Hosting and security services for the privacy page may process technical connection information, such as IP address, requested page and browser data, to make the page available, keep it running and prevent abuse. These technical records are separate from game progress stored on your device.

4.2. Advertising and mediation partners

The table identifies the ad mediation platform covered by this policy, its responsible company, purposes and data categories. Use of the services and processing of each category depend on the game, the features used and the applicable privacy choices.

Mediation allows different advertising networks to be used. A network's availability on the platform does not mean that it participates in every game or receives data in every situation.

Partners may receive data directly through components integrated into the application. Their policies supplement this explanation; they do not replace our responsibility to explain the processing carried out by our services.

4.3. Legal obligations and protection of rights

We may also provide information where necessary to comply with a legal obligation or valid order, within the limits of applicable law.

Where the law permits sharing that is necessary to protect rights or investigate fraud, it will be limited to the relevant purpose and data and will not authorize indiscriminate disclosure.

4.4. Sharing authorized by you

Where sharing requires your consent, you must be informed of the purposes and recipients before making your choice. Your authorization applies to the activities presented, not to any subsequent use of the data.

5. Your rights and choices

5.1. Privacy rights

Under applicable law, you may request confirmation of processing, access, correction and, where applicable, deletion, anonymization, blocking or portability of data. You may also obtain information about sharing, withdraw consent and exercise rights to object or restrict processing under the relevant law.

These rights are subject to the conditions and exceptions under applicable law. The regional notices in sections 12 through 14 provide additional information.

5.2. How to exercise your rights

To make a request, use the contact details in section 11 and identify the relevant Service and the nature of your request. We may request only the information necessary to verify your identity and locate the data. Do not send personal identification documents unless you receive a justified request.

We will respond within the time limits and under the conditions required by applicable law and explain any limitations or legally required retention. Where data is held only on your device, we will provide guidance on managing it locally without requesting unnecessary access to its contents.

5.3. Deleting data

You may submit a deletion request using the contact details in section 11. The absence of a remote account does not prevent requests concerning messages or data processed through integrations. For exclusively local data, we will provide guidance on managing it on your device without requesting unnecessary access to its contents. Retention, backups and the limits of deletion are described in section 8.

5.4. Consent and advertising preferences

For activities based on consent, we will request your choice before the corresponding processing, with information about the purposes and partners involved. You may refuse consent or withdraw it later. We will not share data for personalized advertising without your authorization for that purpose. Reading this policy or continuing to use a game does not replace that choice.

You may withdraw your consent at any time and request assistance with your choices by emailing pocketsparkstudios@gmail.com, identifying the game and the request you wish to make. Withdrawal does not affect the lawfulness of earlier processing based on consent.

Contacting us by email does not automatically change device or third-party service settings. Where a request involves a device setting or processing by a partner, we will provide guidance on the applicable procedure without requesting information that is unnecessary for support.

Operating system privacy settings may also allow you to limit the use of the advertising identifier, depending on the device and system version. Those controls do not, by themselves, withdraw all consent or delete data already processed.

Declining personalization does not necessarily mean that no ads will be shown or that no data will be processed. Delivery, security and measurement activities must be assessed in light of the service configuration and applicable law.

6. Security

Locally saved profile and progress data is held in the application's storage on your device. Not maintaining our own server database does not remove the need to protect application security, access to the support email account and advertising integrations.

Protecting data requires technical and organizational measures appropriate to the processing risks, including safeguards for access, communications and incident response. No storage system or internet transmission offers absolute security. This limitation does not remove our responsibilities to protect data and honor rights under applicable law.

If you suspect a security issue related to our services, contact us using the details in section 11 without sending passwords or other unnecessary information. We will review the report and take appropriate action, including notifying affected individuals and authorities where required by applicable law.

7. International transfers

Advertising, email and hosting providers may process data in countries other than the country where you are located. Those countries may have data protection rules that differ from those in your place of residence. This processing by providers is separate from game progress saved only on your device.

Transfers for which we are responsible must meet the requirements of applicable law. Where required, a transfer depends on a valid legal mechanism for the data flow, such as an adequacy decision or contractual clauses approved by the competent authority, depending on the region and the conditions of that mechanism. Reading this policy or using the Service does not, by itself, constitute consent to international transfers.

You may consult the providers' policies listed in section 4 and use the contact details in section 11 to request information about destination countries and the safeguards applicable to the processing of your data, subject to legal limits on access. Partners' policies do not replace our transparency and protection obligations.

Additional rules for the regions identified in section 14 are also addressed in section 14.5.

8. Retention of personal information

We retain personal data for which we are responsible only for as long as necessary for the purposes described in this policy. This period takes into account the nature of the data, the need to provide the Service or complete support, and applicable legal obligations. Retention to resolve disputes or exercise rights is limited to circumstances permitted by law and to the data necessary for that purpose.

We do not maintain our own server database to store players' profiles and local progress. This does not mean that no data processing takes place: the application stores information on the device, partners process advertising data, and voluntary communications are received through Gmail.

Local data remains available for as long as it is retained by the application and device. Clearing application data may erase local progress. System backups may require separate management. Uninstalling a game is not the same as requesting deletion of data processed by partners.

Messages received at our support email address are retained for as long as necessary to review and respond to the request and handle directly related follow-up matters. Privacy request records and technical logs for which we are responsible follow the same necessity-based approach, according to their purpose and applicable obligations.

When there is no longer a purpose or lawful basis for retention, we will arrange for data under our control to be deleted. You may also request deletion using the contact details in section 11. If there is a legal reason to retain certain information, we will explain the limitation applicable to your request. Receiving or replying to a message does not mean that Gmail automatically deletes it.

Retention by advertising partners and other providers depends on their activities and the applicable rules, as explained in the policies listed in section 4. A request to PocketSpark does not automatically delete data held by third parties; we will take the steps for which we are responsible and provide guidance on directing the request where necessary.

9. Children and teenagers

Audience and age limits

Our games are not directed at children. We apply the following age restrictions for access to the games covered by this policy:

• European Union and United Kingdom: you must be at least 16 years old.
• United States: you must be at least 13 years old.
• Other jurisdictions: you must meet the minimum age required under local law to consent to the data processing applicable to the Service.

If you are below the applicable age limit, you must not download, access or play our games or provide us with personal data. These limits are access rules adopted by PocketSpark Studios; they do not replace store age ratings or the legal protections applicable to children and teenagers.

Requests from parents or guardians

If you are responsible for a child or teenager and believe that our services have improperly processed their data, please email pocketsparkstudios@gmail.com, identifying the game and describing the situation. Do not send identity documents or other sensitive information without a justified request.

Where necessary to handle the request securely, we may ask for information strictly necessary to confirm your identity and your responsibility for the child or teenager, explaining the purpose of that verification.

We will review the request and take appropriate action, including deleting data under our control where applicable. For information saved only on the device, we will provide guidance on local removal. Where processing involves a partner, we will provide contact guidance or forward the request where appropriate; we cannot guarantee deletion of data outside our control.

10. Updates to this policy

We will update this policy when there are material changes to our services or data practices. The published version takes effect on the last-updated date shown at the beginning of the document and remains in effect until replaced by a new version, without a fixed expiration date. Where necessary, we will provide an additional notice and request a new choice before starting processing that requires consent.

11. Contact

PocketSpark Studios.

For questions about this policy, our privacy practices or the exercise of your rights, please email pocketsparkstudios@gmail.com.

12. Additional notice for individuals in the United States

This notice supplements the other sections for individuals in the United States to the extent that the privacy law applicable to the processing grants the rights described. Requirements vary by state.

12.1. Rights under applicable laws

Depending on applicable law, your rights may include:

• Knowing whether data is processed, accessing information and obtaining a copy of the data.
• Correcting inaccurate information and requesting deletion.
• Receiving data in a format that allows it to be transferred.
• Opting out of the sale of data, targeted advertising or certain uses of profiling, where provided by law.
• Not being discriminated against for exercising your rights.
• Challenging a denial and seeking recourse from the competent authority where that procedure is provided by law.

12.2. Requests and appeals

Use the contact details in section 11, identifying the Service and the right you wish to exercise. Verification will reflect the need to protect your data and applicable legal requirements. If a request is denied, we will explain the reason and the available options for challenging the decision. Where a right to appeal applies, you may use the same contact details to submit an appeal, identifying the response you are challenging.

12.3. Sale, sharing and targeted advertising

The advertising-related processing described in sections 2 and 4 may fall within legal definitions of sale or sharing, even without direct payment for data. The classification depends on the law and the actual activity involved.

You may submit requests about these practices using the contact details in section 11 and consult the choices described in section 5.4. Sending an email does not automatically change device or partner settings.

12.4. Authorized agents

Where permitted by law, an agent may submit a request on your behalf. We may verify the authorization and identities involved according to the nature of the request, without requiring unnecessary information.

13. Additional notice for California consumers

This notice applies to California consumers where processing is subject to the California Consumer Privacy Act, as amended (CCPA). It supplements sections 2, 3, 4, 5, 8 and 12.

13.1. Categories, sources, purposes and recipients

The table describes the categories relevant to the Services covered by this policy. Their application depends on the features used; exclusively local data is not, by virtue of being listed here, received by PocketSpark servers.

The sources and examples above do not authorize indiscriminate collection. Retention follows the criteria in section 8. Recipients and their policies are described in section 4; lawful grounds for disclosure also apply.

13.2. Rights and choices

Where applicable, you may exercise the rights to know, correct, delete and opt out of sale or sharing, as well as to limit certain uses of sensitive personal information and not be discriminated against, under the CCPA. Contact details and procedures are provided in sections 11 and 12.

Advertising use must be assessed against the legal definition of sale or sharing, not solely by whether payment is involved. The information in section 12.3 supplements this notice.

14. Additional notice for individuals in the European Economic Area, United Kingdom and Switzerland

This notice supplements the policy for individuals in the European Economic Area, United Kingdom and Switzerland, depending on the law applicable to the processing. Grouping these regions in this section does not mean that their rules are identical.

14.1. Responsibility for processing

PocketSpark is responsible for the processing decisions it makes regarding its Services. Providers that process data under our instructions and partners that determine their own purposes may have different roles. Information about the services involved is provided in section 4.

14.2. Legal bases

Where applicable law requires a legal basis for processing, the basis depends on the activity performed. For processing subject to the GDPR or UK GDPR, we distinguish the following purposes and bases:

You may withdraw consent without affecting the lawfulness of earlier processing and exercise the rights described in section 5. Refusal or withdrawal does not allow consent to be automatically replaced by legitimate interest to continue the same activity.

Legitimate interest is not a general authorization to use data: it requires a specific purpose, necessary processing and an assessment of the effects on you. Using providers does not remove the need for the basis applicable to the purpose, nor does it mean that all partners act under the same basis or responsibility. Additional regional rules continue to apply, including those concerning access to information on the device and international transfers.

For processing subject to Swiss law, the principles and conditions of that law apply; the table does not automatically apply the GDPR framework to all processing carried out in Switzerland.

14.3. Individual rights

For processing subject to the GDPR or UK GDPR, you may exercise, subject to the legal conditions, rights to information, access, rectification, erasure, restriction, portability, objection and withdrawal of consent, as well as protections relating to solely automated decisions that produce legal or similarly significant effects.

In Switzerland, applicable rights may include information about processing, access, correction and, subject to legal conditions, deletion or restriction of processing. To make a request, use the procedure in section 5.2 and the contact details in section 11.

You may also contact the competent authority: your country's data protection authority in the European Economic Area, the Information Commissioner's Office (ICO) in the United Kingdom or the Federal Data Protection and Information Commissioner (FDPIC) in Switzerland. Contacting us is not a condition for contacting the authority.

14.4. Marketing and choices

Personalized advertising and sharing that require consent follow the specific choice described in section 5.4. You may withdraw that consent without affecting the lawfulness of earlier processing. Sending a message to support does not constitute general authorization to receive marketing.

14.5. International transfers

In addition to section 7, where a transfer is subject to the rules of these regions, the mechanism used must be valid for the origin, destination and data flow involved. This may require an adequacy decision, contractual safeguards or another permitted ground, with the relevant local conditions and adaptations.

You may request information about destinations and safeguards using the contact details in section 11, subject to legal limits on access.