Sparkle Games Limited
32 Nassau Street, Dublin D02 YE06, Ireland[email protected]
Privacy Policy
Version 3.0 (20190722)Introduction
Effective date: 22 July 2019
This sets out the privacy policy applicable to your use of any of the applications (“App” or “Apps”) or websites from Sparkle Games. This privacy policy explains what is being done with your personal data. Personal data is anything that can be linked to you. As we transfer your personal data through our business in Ireland we ensure that we are compliant with European data protection law contained within the General Data Protection Regulation 2016/679 and Irish law. If you have any questions about this privacy policy please contact us at [email protected].
All references to “you” or “your” mean you, the user of our Apps, and all references to “we”, “us” or “our” refer to Sparkle Games.
This policy contains the following information:
- Why we collect data, what data we collect and what we do with it
- What if you do not wish to provide your data
- Your Rights
- Retention
- Security
- Tailored Experience
- Who has access to my information
- Changes to this Policy
- Contact Details
1. Why we collect data, what data we collect and what we do with it
We collect data in order for the Apps to function, as well as for performance monitoring and marketing purposes. The following is a breakdown of the data we collect and why:
1. Player Profile
When you use one of our Apps, we automatically create a Player Profile for you based on a unique identifier. This enables us to keep track of your activities so you can pick up where you left off, and if you use our App across multiple devices, or delete and re-install the App, you can continue with the same game experience. Furthermore, if you are having issues with the App, we can better assist you. The Player Profile keeps track of your progress in the App, such as which puzzles you’ve downloaded or purchased, which ones you’ve completed, any achievements earned, competitions entered, how many puzzles you’ve done, and what settings you’ve chosen (for sounds, music, colors and so on). We also record if you’ve opted-in to communications via push notifications, so that we know if we have permission to send you messages or not. Push notifications can be switched off at any time by changing the notification settings on your device. For statistical purposes, we record the App version, device model, language and iOS version you are using. This allows us to focus our development on supporting the most popular devices and languages. To track crash reporting and in App messaging, instance IDs are also collected. If you installed our App by following an advertisement, then we record the name of the advertising campaign through which you discovered the App. Sparkle Games does not collect your credit card, billing or any other financial information since any purchases you may make in our App take place via the iTunes App Store.
2. Linking to Social Accounts
One or more of our Apps may offer the ability to log-in via Apple, a social media account (like Facebook) or an email account for social sharing. If you log in with one of these services, then we may collect further information such as your name and email address to provide a more personalised App experience. There is also the capability to share your achievements on our App via social media, in this instance we take note that you have shared such content. Our Apps do not have access to your social media account and never automatically post anything on your social media.
3. Facebook
When using one of our Apps and you log in with your Facebook account, Facebook may share extra information about you with us. The information that Facebook shares depends on your privacy settings in your Facebook account. For example, Facebook may tell us your name, email, Facebook ID, and which of your friends also has our App installed. We use this information so we can personalise the App experience for you, and so that you can share and play our game with your friends. Depending on your Facebook settings, we may use Facebook Advertising to find people similar to you on Facebook who would also like our Apps.
4. Log Data
When you use our Apps our servers automatically record information, including information that your device sends when you are using the App. This log data may include the date and time of your use of the App, IP address, information about your browser configuration and plug-ins, language preferences, and cookie data. This data is collected for the functioning of the App, as well as for statistical and analytical purposes.
5. Device Information
We may collect information about the device you are using our Apps on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data. This data is collected for the functioning of the App, as well as for statistical and analytical purposes.
6. Analytics and Further Processing
We may use some or all of your data for statistical purposes. This data will be aggregated. This information is used to support our business and track the success of our Apps. We may use the analytical information, to improve your experience in the App and to test new App functions on you, including sending you in-App messages. For example, if our analytics shows that people in a certain country like a certain type of puzzle, we may feature that type of puzzle more often in that country or send people in that country an in-App message telling them about the puzzle.
7. Customer Support
When you get in touch with Sparkle Games Customer Support we shall gather any data that you have provided to us in order to solve your issue and or query. We will also keep track of your interaction with Customer Support i.e. when a query is received, when a message is responded to. It is necessary for us to collect this information to deal with your query.
2. What if you do not wish to provide your data
You do not need to share your name, email or Facebook, or use any social media to enjoy our Apps.
If you do not want us to record any of the information that is necessary for the functioning of the App, as listed in Section 1 (including the Player Profile and log data), then you should not use our Apps.
All other information to which you need to opt in to or consent to (for example sharing on Facebook, or subscribing to our mailing list) is not required for the functioning of the App. As such, if you do not wish to enjoy these extra features, it shall in no way impact your ability to use and enjoy our Apps.
3. Your Rights
Any personal data we collect relating to you shall be processed in accordance with the relevant data protection requirements contained within the General Data Protection Regulation and applicable national law.
a. Right to access your data and the right to data portability
As data subjects, you have the right to request access to your data. Where you request access to your data, you have the right to data portability, meaning that you have the right to receive the data in an accessible format. Where you would like to request access, please contact [email protected].
b. Right to rectify your data
If you notice that some of the data stored about you is wrong, you have the right to rectify your data. If you would like to rectify your data, please contact us at [email protected].
c. Right to erase your data
If you no longer want us to store information about you, you have the right to erase your data. To learn how to exercise this right, please refer to part 4 on retention. In certain circumstances, where it is more appropriate, you can restrict data processing.
d. Right to object to data processing
You have the right to object to data processing in certain instances; in particular if direct marketing is taking place and if your personal data is being processed on the basis of public interest or the exercise of official authority. If you wish to exercise this right, please contact us at [email protected].
e. Right to withdraw consent
Where your consent is obtained to collect and or process your data (for example, to receive push notifications), you may withdraw your consent at any time.
f. Right to lodge a complaint
If any issues arise, you have the right to lodge a complaint with the relevant supervisory authority.
4. Retention
We shall maintain your Player Profile and all associated data for as long as you are an active user of the App. If you have not used our App for 12 months, we will consider that you are not an active user and we will delete your Player Profile and all associated data. Alternatively, if you wish to proactively delete some or all of your data prior to this 12 month period, please contact [email protected]. Once we are informed of your request for deletion, we will delete such information from our databases within 1 week.
5. Security
Data gathered or received via our App shall be stored in a secure manner and via secure processes.
6. Tailored Experience
We may tailor your App experience (including communications such as push notifications) based on how you use our Apps, where you have provided consent for us to do so.
7. Who has access to my information
We, Sparkle Games, will have access to the data. We use third party’s to aid with customer support, data storage, analytics, statistics, iCloud features, crash reporting and marketing; as such some data may be stored on other databases. Some of these third parties store data outside of the EU; however, we have taken steps to ensure your data is protected to the same standard as required in the EU. If you have configured iCloud on your devices, our Apps will use iCloud to keep track of what puzzles you are working on or have downloaded so that we can offer a better experience across all your devices. If you use iCloud backup, your saved games and puzzles you create will be backed up to iCloud so that you can restore them if required. Any purchases from our Apps takes place via the iTunes App Store. Thus, Apple Inc will have access to data on your purchases. We may also need to transfer your data to comply with a legal obligation or as a result of a merger, acquisition, liquidation, dissolution or sale of the Apps. If you post anything from our Apps publicly on social media, please note that other people may view it.
8. Changes to this policy
If we make changes to this privacy policy, we shall inform you immediately via a message in the App, on our mailing list or on our website as applicable.
9. Contact details
If you have any queries about our data policy or your rights as a user, or if you have any concerns with how we are handling your information please contact us via [email protected]