Privacy Policy

1. SCOPE

This Privacy Policy applies to personal information processed by us when you install, download, subscribe to, access, use the features and/or interact with the content of the Game. PinSight Media Inc. is the primary operator of the Game and has taken the position of a controller for the personal information we process, unless otherwise stated. For information on how to contact us, please refer to "Contact Us" below.

2. PERSONAL INFORMATION WE COLLECT

We keep data collection to a minimum. We do not ask user to provide any information to us. The information we automatically collect is your:

• Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, mobile carrier, mobile advertising, e.g. persistent identifiers, iOS Identifier for Vendors (IDFV); Google Advertising ID (GAID), or Android ID for Android devices, other unique identifiers, device information, Internet service provider, language settings, time zone, and version of the Application you are using. We may also automatically collect information regarding your interaction with: 1) the Application, such as pages that you visit during use of our Services, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services; 2) the ads presented on your device, such as content type of the ad (the advertiser and category, e.g., games, finance, entertainment, news), ad type (e.g., whether the ad is a text, image, video or other format based), platform displaying the ad (e.g., the site, digital media or app on which the ad appears), and other information about your interaction with the ads.
• Tracking Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use SDKs, application program interfaces, a resettable device identifier from your device, and other similar technologies ("Technologies"), to automatically collect information through your use of our Services.

• Resettable Device Identifiers. Resettable Device Identifiers (also known as advertising identifiers) are similar to cookies and are found on many mobile devices and tablets (e.g., the "Identifier for Advertisers" (or IDFA) on Apple iOS devices and the "Google Advertising ID" on Android devices), and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant and for analytics and optimization purposes.

Our uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular application behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.

See "Your Privacy Choices and Rights" below to understand your choices regarding these Technologies.

• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. These technologies allow us to process usage data to better understand how our website and web-related Services are used, and/or to continually improve and personalize our Services.

3. HOW WE USE YOUR PERSONAL INFORMATION

We use your GAID for two purposes:

1. Provide Our Games - We use your information to fulfil our contract with you and/or provide you with our Game, such as:
   • Managing your information and account;
   • Providing access to certain areas, functionalities, and features of our Game;
   • Notifying you of any relevant available Game updates or upgrades;
   • Answering requests for customer or technical support;
   • Communicating with you about your account, activities on our application, and policy changes;
2. Administrative Purposes - We use your information in our legitimate interest, such as:
   • Pursuing our lawful business purposes such as research and development (including marketing research), network and information security, and fraud prevention;
   • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
   • Measuring interest and engagement in our Games;
   • Improving, upgrading, or enhancing our Games;
   • Developing new products and services;
   • Ensuring internal quality control and safety;
   • Authenticating and verifying individual identities, such as requests to exercise your rights under this policy;
   • Debugging to identify and repair errors with our Games;
   • Auditing relating to interactions, transactions, and other compliance activities;
   • Sharing information with third parties as needed to provide the services;
   • Enforcing our agreements and policies; and
   • Other uses as required to comply with our legal obligations.
3. Marketing, Advertising and improving our services

   We may use personal information to tailor and provide you with interest-based advertisements and/or content personalization. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include custom audiences advertising, and "interest-based" or "personalized advertising," including through cross-device tracking. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in "Contact Us" below.

4. With your Consent

   We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent, where required.

5. Other Purposes

   We also use your information for other purposes as requested by you or as permitted by applicable law.

   • Automated Decision Making. We may engage in automated decision making, including for profiling and cross-platform advertising. Our processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in "Contact Us" below.
   • De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about how you use the Games, information about the device from which you access our Games, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.

4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your information to the third parties (as set out below) for a variety of business purposes, as described above, in accordance with applicable privacy laws and regulatory requirements:

1. Disclosures to Provide our services

   The categories of third parties with whom we may share your information are described below.

   • The Group. We may share your personal information with the Group for purposes as described above in " How We Use Your Personal Information", such as targeted advertising data analytics, profiling and/ or content personalization in their business context.

     "Group" as used in this policy, means, with respect to InMobi, its affiliates and group entities listed here.

   • Advertising Partners. We may share your personal information with advertising partners which may be the Group or third parties. These advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as "interest-based advertising", "targeted advertising", or "personalized advertising". If you have questions or concerns about this, please contact us as set forth in "Contact Us" below.
2. Disclosures to Protect Us or Others

   We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

3. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

   If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

Control your advertising ID. You can reset your GAID or opt out of personalized advertising at any time in your device settings:

• On Android: Settings → Privacy → Ads (options may include Delete advertising ID or Opt out of Ads personalization).

• Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

  Automated Decision Making. We may engage in automated decision making, including for profiling and cross-platform advertising. Our processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision making. If you have questions about our automated decision making, you may contact us as set forth in "Contact Us" below.

• De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about how you use the application, information about the device from which you access our application, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.
• Mobile Devices. With your consent, we may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.
• "Do Not Track." Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Tracking Technologies and Interest-Based Advertising. You may opt-out of personalized advertisements by following the instructions on Android and iOS devices to limit ad tracking. Please note that limiting advertising tracking will not eliminate advertisements but may make them less relevant to you.

  The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

  Please note you must separately opt out on each device.

• Opt-out of all information collection. You may stop all collection of information by the Application by uninstalling the Application.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (the "right of data portability");
• Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
• Request Deletion, Anonymization or Blocking of your personal information;
• Right not to be subject to automated decision making and profiling and request the review of such decisions.
• Request to Opt-Out of Certain Processing Activities including, as applicable, if we process your personal information for "targeted advertising" (as "targeted advertising" is defined by applicable privacy laws), if we "sell" your personal information (as "sell" is defined by applicable privacy laws), or if we engage in "profiling" in furtherance of certain "decisions that produce legal or similarly significant effects" concerning you (as such terms are defined by applicable privacy laws);
• Request Restriction of or Object to our processing of your personal information, including where the processing of your personal information is based on our legitimate interest or for direct marketing purposes. In the event you have uninstalled the application and want us to stop using your personal information, please click here or contact us as set forth in "Contact Us" below;
• Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing and will not affect the lawfulness of processing before the withdrawal. Some features of our Service may not be available; and
• Appeal our Decision to decline to process your request. Please contact us as set forth in "Contact Us" below.

How to exercise your rights
To submit a request, please click here or contact us as set forth in "Contact Us" below. As the primary information we hold is your GAID, we may ask you to provide that identifier so we can locate and verify your information before responding. You may also use an authorized agent to submit a request on your behalf, in which case we may require proof of the agent's authorization.

We will respond to your request within the timeframe required by applicable law.

6. SUPPLEMENTAL STATE-SPECIFIC PRIVACY NOTICE

This Supplemental State-Specific Privacy Notice supplements our Privacy Policy and is required by the California Consumer Privacy Act, as amended (CCPA), Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act. To the extent there are further U.S. State laws mandate similar requirements, this paragraph shall apply to the such applicable users.

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in "Personal Information We Collect", " How We Use Your Personal Information", and "How We Disclose Your Personal Information" above, respectively. We will retain personal information in accordance with the time periods set forth in "Retention of Personal Information."

Authorized Agent. If you are a consumer in a jurisdiction that recognizes the ability to use a legally authorized agent to act on your behalf, your authorized agent may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize an agent, provide written authorization signed by you and your designated agent using the information found in "Contact Us" below and ask us for additional instructions.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include, but not limited to, asking you to answer questions regarding your account and use of our Services.

Additional Privacy Rights for Residents of certain countries or states which provide such rights

California residents have the right to know what categories of personal information the Application has collected about them, whether Pinsight Media disclosed that personal information to a service provider or a contractor for a business purpose in the preceding 12 months, whether Pinsight Media "sold" that personal information, and whether Pinsight Media "shared" that personal information for "cross-context behavioural advertising" in the preceding 12 months. You can find this information below:

We "share" your personal information to provide you with "cross-context behavioural advertising."

We do not "sell" personal information in exchange for money. However, there are a number of US state privacy laws that define "sale" broadly such that it may include routine website activities like disclosures of personal information to advertising partners for "targeted advertising" and/or "cross-context behavioural activities". If these laws apply to our processing of your personal information, we may "sell" your personal information to provide you with "targeted advertising" and/or "cross-context behavioural advertising".

Opting Out of "Sales" of Personal Information and/or "Sharing" for Cross-Context Behavioral Advertising under the CCPA. California residents have the right to opt out of the "sale" of personal information and the "sharing" of personal information for "cross-context behavioural advertising." California residents may exercise these rights by clicking the "Do Not Sell or Share My Personal Information" link clicking here, or contacting us as set forth in "Contact Us" below.

Disclosure Regarding Individuals Under the Age of 18. Sparks is not directed to children under the age of 13, and we do not knowingly collect personal information from any individual under 13. If we become aware that a child under 13 has provided us with personal information, we will promptly delete it. Users between the ages of 13 and 17 may access Sparks only upon providing explicit consent to the collection and processing of their personal information as described in this Privacy Policy. Parents or guardians who wish to review, correct, or delete their child's personal information may contact us via Email mentioned in the "Contact Us" section.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA. If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in "Contact Us" below. We will process such requests in accordance with applicable laws wherever applicable and not just limited to California.

Refer-a-Friend and Similar Incentive Programs. We may offer referral programs or other incentivized data collection programs. For example, we may offer incentives to you such as SPARKS coins in connection with these programs, wherein you provide your personal information in exchange for a reward or share our link with your friends or colleagues and receive rewards when they sign up to use our Services. (The referred party may also receive rewards for signing up via your referral.) These programs are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of your data to us depends on how you ultimately use our Services, whereas the value of the referred party's data to us depends on whether the referred party ultimately becomes a User and uses our Services. Said value will be reflected in the incentive offered in connection with each program.

Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium's Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

California Shine the Light. The California "Shine the Light" law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

Additional Privacy Rights for Residents of Colorado, Connecticut, Virginia and Utah

• Pinsight Media does not "sell" your personal information. We process your personal information for the purposes of "targeted advertising" as that term is defined under the Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act and Utah Consumer Privacy Act.
• Residents of Colorado, Connecticut, and Virginia can opt out of targeted advertising under Privacy Settings section of the Game.
• Pinsight Media does not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under the Colorado Privacy Act.

7. CHILDREN'S PRIVACY

The Games are not directed to children under the age of 13, and we do not knowingly collect, use, or disclose personal information from children under 13 years of age. Data of Users between the ages of 13 and 17 may be processed only upon providing explicit consent to the collection and processing of their personal information as described in this Privacy Policy. If you are a parent or guardian and believe that your child under 13 years of age has provided us with personal information without your consent, please contact us as set forth in the "Contact Us" section below. Upon becoming aware that a child under 13 has provided personal information in violation of applicable law, we will promptly delete such information from our systems, unless we are legally obligated to retain it.

8. RETENTION OF PERSONAL INFORMATION

We retain your GAID only for as long as needed to provide the Games and for the purposes described above, or as required by law. If you delete or reset your advertising ID, we will no longer be able to associate prior activity with your new identifier.

9. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date above. Your continued use of the Games after any change means you accept the updated Policy.

10. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy or your rights as detailed in this Privacy Policy, please contact us at: support@sparksgames.io