Privacy Policy
Effective Date: January[6], 2022
Thank you for playing our app!
Please carefully read this privacy policy (“Privacy Policy”) when you use Spark Charge app of [ ChargeLabsy] Network Limited’s services(“Service”). This Privacy Policy will come into effect for all existing users on September [ 6 ], 2022. Your use of the Service from that day will be subject to this Privacy Policy.
This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with the Service, and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.
If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are accepting our rules regarding your personal information as described in this Privacy Policy.
This Service is operated by Spark Charge app of [ ChargeLabsy ] Network Limited ( “we”, “us”, “our”).
For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Spark Charge app of [ Snows Studio] Network Limited.
Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at [chargelabsy@gmail.com] .
1. The Types of Personal Information We Use
This section describes the different types of personal information we collect from you and how we collect it.
The following is a high level summary of the types of personal information we use:
1. Information you provide to us (either directly or through a third party).
•Account registration information: You give us your nickname when you log-in as a ‘guest’ in order to use the Service. If you login via your Google Play account, you give us your Google ID and Google display name. If you login via your Apple (iOS game centre) account, you give us your Apple ID, Apple display name and profile picture. If you login via your Facebook account, you give us your Facebook username and ID and you may choose to give us your email address and friends list as well. You may also choose to provide your gender during account registration.
•Marketing information: Advertising information about you that we collect directly from you and from third party ad partners (e.g. Facebook and Google) via a third party SDK (Appsflyer and AppLovin), such as your IP address, IDFA, Android advertising ID (AAID), which users click/view our campaign and creative materials, e.g. photos and videos that are advertised on the ad partner’s platform, your advertising ID and other user engagement data (purchase behaviour and in-app behaviour) (collectively, “advertising identifiers”), Facebook campaign ID, user search terms and Google Adwords campaign information and identifiers. We also collect certain advertising information about you which we share with third party ad partners (e.g. Facebook and Google) via a third party SDK (Appsflyer and AppLovin) to monitor the success of our advertising campaigns, such as your advertising identifiers, user in-game activities (including login, purchase activities, friends invited and user retention) and other tracking information (mobile device IDs, hashed email addresses, demographic or interest data, and content viewed or actions taken on a website / app).
2. Information about you generated as part of the Service
We automatically collect certain data from you when you use the Service, namely:
•game data and log information: open ID, IP address, device model and information regarding your use of the Service, such as gameplay statistics (e.g., level and scores);
•game analytics information: your user region and device information to enable us to perform overall game analytics, including error fixing, troubleshooting and debugging;
•for the purposes of providing customer support (in-app or via email): name, open ID, device ID, application version, battery level, Wi-Fi strength, free space on phone, network type, iOS version, platform and network type, carrier, country code and any photos that you may wish to upload to illustrate your problem;
•for the purposes of sending you push notifications while using the Service: your device model, device name, device manufacturer, running process information, SDK version, application package name, application version, operator name and network type; and
•security information: your device (iOS or Android)’s technical device information, for the purposes of detecting and preventing cheating and any domain name hijacking on the Service.
Cookies
We use cookies and other similar technologies (e.g., web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.
Children
Our Service is not intended for children. Children must not use the Service for any purpose.
By children, we mean users under the age of 13 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries, we have listed the relevant minimum age in the table below.
Country in which the user is locatedMinimum age of the user
Algeria19
Argentina13
Australia18
Brazil 18
Bangladesh18
Colombia18
Cambodia18
Canada13
Egypt18
European Economic Area/Switzerland16
Kingdom of Saudi Arabia15
Kuwait21
Mexico18
Morocco18
Myanmar18
New Zealand16
Nigeria13
Qatar18
Russia14
Serbia15
South Africa18
Sri Lanka18
Tunisia 18
Turkey 18
United Arab Emirates21
United Kingdom13
United States13
We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at [magicstudio556@gmail.com ] and we will delete such information.
2. How We Use Your Personal Information
This section provides more detail on the types of personal information we collect from you, and why.
Personal InformationUse
NicknameWe use this information to create your account for the Service in accordance with your request.
Google Play Login: Google ID and Google display nameWe use this information to create your account for the Service in accordance with your request.
Apple Login: Apple ID, Apple display name and profile pictureWe use this information to create your account for the Service in accordance with your request.
Facebook Login: Facebook username and ID. You may also choose to provide your Facebook friends list (name of friends who you have found and added) and email address (optional). We use this information to create your account for the Service in accordance with your request.
Gender (if you elect to provide this information)We only receive this information if you voluntarily provide it. It is used in order to customise gameplay.
Marketing data:
•data collected from you: IP address, IDFA and advertising ID;
•data collected from third party ad partners (Facebook, Google, Apple Search Ads, Twitter, Snapchat) via a third party SDK (Appsflyer and AppLovin):
o which users click/view campaign and creative materials (e.g. screenshots, videos) of our ads, such as photos and videos, that are advertised on the ad partner’s platform;
o device information (advertising ID, AAID) and other user engagement data (purchase behaviour, in-app behaviour));
o Facebook campaign ID (where data is collected from Facebook); and
o user search terms and Google Adwords campaign information and identifiers (where data is collected from Google).
•data collected by us and shared with third party ad partners via a third party SDK (Appsflyer and AppLovin):
o device information (advertising ID and Facebook ID);
o user in-game activities, including login, purchase activities, friends invited and user retention; and
o Appsflyer’s and AppLovin’s tracking information, such as, mobile device IDs, hashed email addresses, demographic or interest data, and content viewed or actions taken on a website / app. If you click on a link or interact with content that advertises the Service, we store this information and that advertisement and certain marketing analytics data with your profile in order to measure the performance of our advertisements.
IP address and open ID
We use this information to facilitate your account registration.
Game data and log information: open ID, IP address, device model and information regarding your use of the Service, such as gameplay statistics (e.g. level and scores)
We use this information to provide you with feedback and information about your gameplay and progress.
Game analytics information:
•User region information (country, province, city, carrier id, region, IP address)
•Device information (application version, application ID, battery information, WiFi strength, available space, network type, OS version, OS name, carrier, country code, IDFV, device language, device resolution, brand, manufacturer, device model, RAM, ROM and CPU information, GPU information, Google advertising ID, IDFA, Game Frame information, mobile signal strength, network round trip time, network bytes received/sent, login/pay step event information), XWID We use this information to:
•conduct general game analytics to improve our Service;
•reviewing game performance and payments;
•ensure smooth gameplay; and
•provide troubleshooting, such as addressing and remediating technical issues, error fixing and debugging.
Customer support information: name, open ID, device ID, application version, battery level, WiFi strength, free space on phone, network type, iOS version, platform and network type, carrier, country code and any photos that you may wish to upload to illustrate your problem. We use this information to provide you with customer service support, whether in-app or via email, in accordance with your request.
Push Notification information:
•device information (device model, device name, device manufacturer, running process information); and
•other information (SDK version, application package name, application version, operator name, network type) We use this information to send you push notifications about announcements, updates or information relating to the Service.
Security information:
•Android: device root status, list of installed hack software, list of running hack software, hash values of game files (encrypted), host file tampered, running in Android simulator, Android SDK API Level, equipment boot time, equipment brand and model, CPU structure and CPU model, resolution, Sensor status, device kernel version, country code, language, available memory and available space, internet type (WiFi/4G/3G)
•iOS: device jailbreaking status, hash values of game files (encrypted), host file tampered, IDFV, equipment brand and model, iOS version, Internet type (WiFi/4G/3G) We use this information to detect and prevent cheating and any domain name hijacking on the Service.
3. How We Store and Share Your Personal Information
Pursuant to our contract with you to provide you with the Service, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy.
Marketing data about you that is collected or shared with third party ad partners (e.g., Facebook and Google) may also be stored and processed on our third party SDK’s (Appsflyer and AppLovin) servers in the United States. Customer support information may also be stored in our third party partner’s servers in the United States.
In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world.
Only where necessary will we share your personal information with third parties. Situations where this occur are:
•Third parties that provide services in support of the Service, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Service, to allow you to login through an existing social network account (e.g. Google Play), and for the purpose of providing marketing and advertisements on ad partners’ platforms ( Facebook, Google, Apple, Twitter, Snapchat, Appsflyer and AppLovin) and monitor the success of our marketing and advertising programs on such platforms. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.
•Companies within our corporate group who process your personal information in order to operate the Service and conduct surveys for us. All related group companies may only use your personal information in accordance with this Privacy Policy.
•Regulators, judicial authorities and law enforcement agencies and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
•A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.
4. The Security of Your Personal Information
We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission of your information which you do at your own risk.
Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.
5. Your Rights
Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section.
This section entitled “Your Rights” applies to users that are located in a Relevant Jurisdiction. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.
The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada, Argentina and Russia.
You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at [magicstudio556@gmail.com ] .
Access
You have the right to access personal information we hold about you, 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 account. If you believe we hold any other personal information about you, please contact us at [magicstudio556@gmail.com ] .
Portability
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., game play statistics). You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
Correction
You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at [magicstudio556@gmail.com ].
Erasure
You can delete your account, or remove certain personal information, by logging into your account. If there is any other personal information you believe we process that you would like us to erase, please contact us at [chargelabsy@gmail.com ].
We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
Objection
You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at [chargelabsy@gmail.com ]
To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at [chargelabsy@gmail.com ]. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.
Announcements
We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend the Service’s access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
6. Contact & Complaints
Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to [chargelabsy@gmail.com ].
In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at [chargelabsy@gmail.com ] and we will endeavor to deal with your request as soon as possible.
7. Changes
If we make any changes to this Privacy Policy, we will post the updated policy here and notify our users within the Service. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.
California
This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).
Collection and Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:
•Identifiers, such as your name as it appears on your social media profile, open ID / user ID, IP address, phone number, mailing address, email address, and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.
•Internet or other electronic network activity information, such as your information regarding your use of the Service, including level, score, date and other device information as described in the main policy. This information is collected directly from you and your device.
•Commercial information about any transactions within the Service such as what products were purchased and how much they cost. This information is collected directly from you and your device and the Google Play or Apple iOS store.
•Other information described in subdivision (e) of Section 1798.80. This information is collected directly from you in the context of being our consumer.
We collect your personal information for the following purposes:
•To provide you the Service, including offering the Service, maintaining your account, and delivering audio and text messages;
•To process surveys;
•To improve our services, including the functionality of the Service;
•For security and verification purposes, including to prevent and detect fraudulent activity;
•To address and remediate technical issues and bugs.
We disclose personal information to the following types of entities:
•Other companies within our corporate group who process your personal information in order to operate the Service
•Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us
•Regulators and judicial authorities and law enforcement agencies
•Entities that acquire all or substantially all of our business
In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.
Rights under the CCPA
If you are a California resident, you have the right to:
•Request we disclose to you free of charge the following information covering the 12 months preceding your request:
o the categories of personal information about you that we collected;
o the categories of sources from which the personal information was collected;
o the purpose for collecting personal information about you;
o he categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
othe specific pieces of personal information we collected about you;
•Request we delete personal information we collected from you, unless CCPA recognizes an exception; and
•Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.
We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.
How to Exercise Your Rights
First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, regarding other data by contacting us at [chargelabsy@gmail.com ].
European Economic Area (EEA)
When you are located in the EEA, you will have following additional rights:
•To ask for a copy of your personal data to be provided to them, or a third party;
•To lodge a complaint about the processing of your personal data with your local data protection authority in the EEA.
When you are located in the EEA, your personal data will be transferred to recipients in countries located outside the EEA, which do not provide a similar or adequate level of protection to that provided by countries in the EEA.
You hereby expressly consent to the transfer of your personal data to recipients, as described in this Privacy Policy, which are located outside the EEA. You may withdraw your consent at any time.
You can use your accounts of the App to update and correct your personal data. You can also contact us and ask us to update or correct your data.
We do not knowingly collect personal data about children under the age of 13 (in EEA is under the age of 16). If a parent or guardian becomes aware that his or her child has provided us with data without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such data is deleted from our files.