Privacy Policy
SPARK Nation Network and Productions LLC (hereinafter referred to as "we" or "the Company") understands the importance of personal information to you and is committed to protecting your privacy and data security. This Privacy Policy is intended to clearly disclose our practices regarding the collection, use, storage, sharing, and other related information, to help you understand your rights, and how we protect your information. Before using our official website and related services, please be sure to carefully read and understand this Privacy Policy. Your access to, browsing of, or use of our services shall be deemed your acceptance and acknowledgment of the contents of this Policy. We reserve the right to update this Policy at any time. If there are material changes, we will notify you through prominent announcements on the official website or other reasonable means. We recommend that you review this Policy periodically.
Information Collection
The core purpose of our information collection is to provide you with personalized, high-quality official website services and related services, optimize the user experience, and meet business operation and compliance requirements. The types and contexts of information collected are specifically as follows:
1.1 Personal Identity Information
When you subscribe to services, participate in interactive activities, contact customer support, or perform other operations that require identity verification on the official website or application, we may collect personal identity information that you voluntarily provide, including but not limited to your name, email address, phone number, mailing address, company name (if applicable), etc. You have the right to choose whether to provide such information, but some services may not function properly.
1.2 Usage and Device Information
When you visit, browse, or use the official website, we automatically collect information related to your usage behavior and device, including but not limited to SDK/API/JS code version, browser type and version, Internet Service Provider (ISP), IP address, access platform (such as computer, mobile device), timestamp, application identifier, application version, application distribution channel, device model, device manufacturer, operating system version, session start/stop time, language settings, time zone, network status (such as WiFi, cellular network), hard disk, CPU and battery usage, network card (MAC) address, and unique advertising identifier (such as iOS Advertising Identifier IDFA, Android Advertising ID). This information will help us optimize official website performance, troubleshoot technical issues, and improve service stability.
1.3 App Activity
App interactions, installed apps, and other actions—including, but not limited to, data generated through your engagement with an app (such as game progress, unlocked achievements, strategic choices, saved or favorited content, categorized items, dialogue selections, etc.).
1.4 Approximate Location
To ensure legal compliance, maintain service security, or provide specific services, we may—with your consent—collect the physical location of a user or device, with a precision area of 3 square kilometers or greater. Examples include the city where a user is located, or location information provided via the ACCESS_COARSE_LOCATION Android permission as declared by the app package.
Information Use
We strictly use the collected information in accordance with this Privacy Policy and relevant legal requirements, mainly for the following purposes:
2.1 Provision and Maintenance of Services
Provide core official website services according to your requirements, including account management, service subscription, content push, activity participation, etc.; maintain the normal operation of the official website, and carry out technical support, troubleshooting, system updates, and other actions to ensure the stability and security of services.
2.2 Optimization and Improvement of Services
Analyze user usage behavior, device information, and feedback data to understand user needs and preferences, optimize functional design, website interface layout, and content presentation, develop new products or services, and improve the overall user experience. For example, recommend content or activity information that better matches your interests based on your browsing history.
2.3 Personalized Services and Advertising
With your explicit consent, we may use the collected information to provide you with personalized content recommendations, advertising displays, and other services. You can withdraw this authorization at any time through the official website settings. After withdrawal, we will not use the relevant information more broadly, but this will not affect the legality of information use based on lawful authorization before withdrawal.
2.4 Customer Support and Communication
Respond to your inquiries, complaints, feedback, and other requests, and handle your service needs; send you service-related notifications, updates, activity reminders, and other information (such as account security reminders, service term change notices, etc.). You may choose to unsubscribe from non-essential marketing information according to the prompts.
2.5 Compliance and Security Assurance
Comply with applicable laws and regulations, judicial procedures, court orders, or administrative supervision requirements; prevent, detect, and respond to fraud, abuse, security threats, technical failures, and other risks, protect your account security and personal information, safeguard our legitimate rights and interests, and maintain the normal order of the official website and related services.
2.6 Other Legal Purposes
Within the scope of your explicit consent or as permitted by law, use information for other purposes directly related to the above purposes, or for reasonable use based on legitimate interests (such as data analysis, market research, business planning, etc.). Such use does not constitute an infringement of your legitimate rights and interests.
Information Sharing
We attach great importance to the security of your information and will not arbitrarily share your personal information with third parties unless the following circumstances apply:
3.1 Obtaining Your Explicit Consent
Before sharing personal information with third parties, we will obtain your explicit authorization or consent and inform you of the sharing purpose, third-party identity, and the scope of relevant information.
3.2 Service Providers and Partners
To implement service functions or optimize service quality, we may share necessary information with third-party suppliers, agents, or partners that provide services on our behalf, such as data analysis companies, server hosting service providers, payment processors, advertising service providers, etc. These third parties must comply with our data privacy and security requirements, use the information only within the authorized scope and not for other unrelated purposes, and bear corresponding information security responsibilities.
3.3 Legal Compliance Requirements
When we believe disclosure is necessary for compliance, we may disclose your personal information in accordance with applicable laws and regulations, in response to judicial procedures, court orders, or administrative supervision requirements, or to protect our legitimate rights and interests, the life and property safety of users or the public, or the public interest from infringement.
3.4 Business Mergers and Transfers
In the event of business changes such as mergers and acquisitions, bankruptcy liquidation, or asset transfers, your personal information may be transferred to relevant third parties as part of the enterprise assets. We will notify you before the transfer and ensure that the transferee continues to comply with the relevant provisions of this Privacy Policy to protect your information rights and interests.
3.5 Sharing of Anonymous or De-identified Information
We may share anonymous or de-identified information (information that cannot identify you personally) with third parties for purposes including market research, data analysis, and academic research. Such sharing does not require your separate consent.
4 Data Storage and Retention
4.1 Storage Method and Location
Your personal information will be stored in encrypted databases that meet industry security standards and transmitted through secure network connections. Because we are a U.S. company, the information collected may be stored in the United States or in countries/regions where we have third-party service providers. The data protection laws of these countries/regions may differ from those of your country/region, but we will take necessary protective measures to ensure that your information receives the same level of security protection as agreed in this Policy.
4.2 Retention Period
We will retain your personal information for the time necessary to fulfill this Privacy Policy or as required by applicable law (such as tax law, accounting law, data protection law, etc.). The specific retention rules are as follows:
When you request deletion of your account or related information, or after service termination, we will immediately delete or anonymize it, unless it is necessary to continue retaining it in accordance with relevant privacy regulations and internal guidelines for compliance or dispute resolution.
4.3 Storage Security Measures
We adopt reasonable and industry-standard physical, electronic, and administrative security measures to protect your information from unauthorized access, use, disclosure, modification, loss, or damage. Specific measures include but are not limited to: using firewalls, encryption technologies, and access control mechanisms to restrict information access rights; conducting regular security audits, vulnerability scans, and system updates; providing data security training for employees and clarifying information handling rights and confidentiality obligations.
Despite the above security measures, please note that no method of Internet transmission or electronic storage can guarantee 100% security. We are not responsible for information leakage risks caused by uncontrollable factors (such as force majeure, hacker attacks, or unauthorized third-party access). You should take reasonable measures to protect the security of personal information (for example, properly maintaining account passwords and avoiding access to sensitive information through public networks, etc.).
International Data Transfers
Due to the international scope of our business, your personal information may be transferred to servers or third-party service providers in the United States or other countries/regions in accordance with the purposes described in this Privacy Policy. The level of data protection in these countries/regions (including but not limited to the United States) may differ from that in your country/region, but we will ensure that data transfers comply with applicable legal requirements and take at least one of the following protective measures:
- Transfer to countries or regions recognized by the U.S. Department of Commerce as meeting data protection standards;
- Sign privacy protection contracts with recipients that meet internationally recognized standards (such as Standard Contractual Clauses approved by the European Commission);
- If the recipient is located in the EU/EEA, ensure that it complies with adequacy protective measures under the General Data Protection Regulation (GDPR);
- Other security measures comply with applicable legal requirements.
By using our services, you expressly consent to international data transfers in accordance with the above methods in order to provide corresponding services and fulfill related obligations.
Your Rights and How to Exercise Them
Under applicable U.S. federal and state data protection laws (such as the California Consumer Privacy Act (CCPA), the Virginia Consumer Data Protection Act (VCDPA), etc.) and other relevant laws and regulations, you have the following rights, and we will provide necessary assistance to help you exercise these rights:
5. Right to Know and Access
You have the right to request that we confirm whether we hold your personal information and obtain a copy of your personal information, including information such as collection sources, purposes of use, and sharing recipients.
6. Right to Correct and Update
If you find that the personal information we hold about you is incorrect, inaccurate, or incomplete, you have the right to request that we promptly correct, supplement, or update it.
6.1 Right to Deletion (Right to Be Forgotten)
Under circumstances provided by law, you have the right to request that we delete your personal information, including but not limited to situations where you withdraw consent, the information is no longer needed for retention, or our information processing activities violate legal provisions.
6.2 Right to Data Portability
You have the right to request that we provide your personal information in a structured, commonly used, and machine-readable portable format, and to transfer it to you or a third party designated by you to the extent technically feasible.
6.3 Right to Object and Restrict Processing
You have the right to object to our processing of your personal information based on legitimate interests or for marketing purposes; under specific circumstances, you have the right to request that we restrict the processing of your personal information (for example, when there is a dispute regarding the accuracy of the information or the processing activity is unlawful).
6.4 Right to Withdraw Consent
If you previously consented to our processing of your personal information, you have the right to withdraw that consent at any time, but this will not affect the legality of information processing based on lawful authorization.
6.5 How to Exercise Rights
If you wish to exercise the above rights or have questions about personal information processing, you may contact us through the contact information set out in Section 14 of this Policy. We will verify and respond within 7-21 business days after receiving the request. If necessary, we may ask you to provide identity verification information to ensure the security of exercising your rights. If you are dissatisfied with our response, you may file a complaint with the relevant regulatory authority.
Children's Information Protection
Our official website and related services are not intended for children under the age of 13 (as required by the United States). In accordance with the Children's Online Privacy Protection Act (COPPA), we do not knowingly collect, use, or store personal information from children under 13.
If you are a parent or legal guardian of a child and discover that the child has provided personal information to us without authorization, please immediately contact us through the contact information provided in Section 14 of this Policy and provide relevant supporting documents. After verification, we will delete the relevant personal information as soon as possible and will not disclose it to third parties. If you are under 13, please do not use our official website or provide us with any personal information.
Legal Basis for Processing
Under applicable U.S. and relevant national/regional data protection laws, our legal bases for processing your personal information include:
- Performance of contractual obligations: necessary to provide the services you requested and perform agreements signed with you (such as Terms of Service);
- Compliance with legal requirements: to comply with applicable laws and regulations, judicial procedures, court orders, or administrative supervision requirements;
- Legitimate interests: necessary to protect our legitimate business interests without infringing your legitimate rights and interests, such as ensuring service security, managing customer relationships, conducting data analysis and business optimization, and preventing fraud;
- Your consent: processing relevant information based on your explicit consent (such as personalized advertising, third-party information sharing, etc.), which you may withdraw at any time.
In some cases, your provision of necessary personal information is a prerequisite for using specific services. If you refuse to provide information, you may not be able to enjoy these services.
Legal Disclaimer
Notwithstanding anything else in this Policy, we reserve the right to disclose your personal information in the following circumstances:
- To comply with applicable laws and regulations, judicial procedures, court orders, administrative subpoenas, or other legal requirements;
- To protect our legitimate rights and interests, trade secrets, intellectual property, website operation security, and other property rights;
- To protect the personal and property safety of users, the public, or other legitimate rights and interests, and prevent infringement, such as preventing or responding to fraud, abuse, security threats, and other acts;
- To investigate or take corresponding measures against violations of our Terms of Service, this Privacy Policy, or other rules.
Changes to the Privacy Policy
We may revise this Privacy Policy from time to time based on business development, legal and regulatory updates, or technological progress. Any changes to this Policy will be notified to you after modification through prominent positions on the official website (such as homepage announcements, pop-up prompts, etc.) or through the contact information you have retained (such as email, SMS, etc.). These changes will take effect from the effective date stated in the announcement or notice.
If changes involve your core rights (such as the scope of information collection, purposes of use, sharing rules, etc.), we will provide you with a reasonable preparation period, and the changes will take effect after you confirm your consent (unless otherwise provided by law). Your continued access to, browsing of, or use of our official website and services will be deemed your acceptance of the revised Privacy Policy. We recommend that you review this Policy periodically to stay informed of the latest content.
Supplementary Notes on Information Security
We continuously improve our information security management system, regularly assess security risks, and update security protection technologies and measures to ensure the security of personal information. However, due to the complexity of the network environment, limitations of technological development, and other uncontrollable factors, we cannot absolutely guarantee that information will not be leaked, lost, misused, or tampered with.
If a personal information security incident occurs, we will promptly take remedial measures in accordance with applicable legal requirements, assess the impact of the incident, and notify you through official website announcements, emails, phone calls, and other means within the prescribed time, explaining the relevant circumstances of the incident, potential impacts, and the response measures we have taken.
You should properly keep account information (such as username, password) and other sensitive information, avoid disclosing it to others, change passwords regularly, access the official website through a secure network environment, and contact us immediately if you discover account abnormalities or information leakage.
Contact Us
If you have any questions, complaints, or suggestions about this Privacy Policy, or wish to exercise relevant rights, you may choose to contact us through the following methods:
Company Name: SPARK Nation Network and Productions LLC
Contact Email: [email protected]
