ACE ARENA: PRIVACY POLICY
Last Updated: April 30, 2025
INTRODUCTION
SparkGame Interactive Entertainment Co., Limited ("SparkGame," "we," "us," or "our") is dedicated to protecting the privacy rights of our online users ("users" or "you"). This Privacy Policy explains how we collect, store, process, use, and manage information you provide in connection with Ace Arena (the "Game" or "Services"), whether accessed through our direct channels or through third-party platforms like Discord where our game is available.
This Privacy Policy applies only to information collected by SparkGame and does not apply to information collected by third parties on other websites or platforms where SparkGame is not the owner or responsible party.
By using the Service, you agree to the collection and use of your personal information as outlined in this Privacy Policy. We may amend the Privacy Policy from time to time, and we encourage you to consult it regularly for changes.
CONTROLLER AND CONTACT INFORMATION
SparkGame Interactive Entertainment Co., Limited, a company registered in the United States with headquarters at 110 16th Street Suite 1400, Denver CO 80202, USA, acts as the data controller as defined in this Privacy Policy.
For questions about this Privacy Policy or any other matter regarding personal data, please contact our Data Protection Officer at legal@spark-game.com or through our dedicated privacy request form available on our website.
LEGAL FRAMEWORK AND DEFINITIONS
Your data will be processed according to all applicable privacy and data protection laws, including but not limited to the General Data Protection Regulation (EU) 2016/679 ("GDPR"), California Consumer Privacy Act ("CCPA"), California Privacy Rights Act ("CPRA"), and other relevant local privacy regulations.
For better understanding, we provide the following definitions:
- "Personal data": Any information relating to an identified or identifiable natural person, directly or indirectly, such as a name, electronic identifiers, or email.
- "Processing": Operations performed on personal data, whether by automated or non-automated means, including collection, organization, storage, adaptation, retrieval, consultation, use, disclosure, or erasure.
- "User" or "Data subject": A natural person who uses our Services whose personal data is processed.
- "Data controller": Entity that determines the purposes and means of processing personal data (SparkGame in this case).
- "Data processor": Entity that processes personal data on behalf of and according to instructions from SparkGame.
- "Personal data recipient": Entity that receives personal data provided by SparkGame.
- "Supervisory Authority": Independent public authority established to oversee the application of privacy laws.
GENERAL PRINCIPLES
Regarding personal data processing, SparkGame ensures that data is:
- Subject to lawful, fair, and transparent processing
- Collected for specific, explicit, and legitimate purposes, not later processed in incompatible ways
- Adequate, relevant, and limited to what is necessary for the purposes processed
- Accurate and, where necessary, updated, with measures taken to delete or rectify inaccurate data
- Stored in a form allowing identification of users only for as long as necessary for the processing purposes
- Processed in a manner ensuring appropriate security, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage
PERSONAL DATA WE COLLECT
Types of Data
We may collect, process, store, and transfer different types of data grouped by the following categories:
- Account Information: When you register or use our Services through Discord, we may collect information such as your Discord username, user ID, and email address (if provided).
- Device and Technical Information: We may collect information about your device and how you access our Services, including your IP address, browser type, operating system, device type, and mobile device identifiers.
- Game Play Information: We collect information about your interactions with the Game, such as game progress, scores, achievements, and gameplay statistics.
- Transaction Information: If you make purchases within the Game, we may collect information about those transactions, including purchase history and payment method information (but not your full payment details).
Data Sources
SparkGame collects two types of data: passive data and active data.
Passive Source Data
Passive collection is data collected when users play games. This data may include:
- City/region based on your IP address
- Session duration
- Operating system version
- Device model
- Game events (in-game actions, progression)
- App crashes and technical performance data
- Browser type (for web-based gaming)
- Screen resolution
- Language preferences
- Referral information
Active Source Data
We may also collect data based on direct interactions you have with us, such as:
- Contact inquiries: When you send us an email with an inquiry about the Game or other questions, we may process your contact details, such as your email.
- Customer support: When you contact our support team, we may collect additional information to assist you.
- Surveys and feedback: When you participate in surveys or provide feedback, we may collect your responses and opinions about our Services.
- Contest or promotion participation: If you participate in competitions or promotions, we may collect information required for your participation.
HOW WE USE YOUR INFORMATION
We use the information we collect for the following purposes:
- To provide, maintain, and improve our Services
- To personalize your experience and deliver content and product features relevant to your interests
- To process transactions and provide customer support
- To send you important information about the Services, including technical notices, updates, security alerts, and administrative messages
- To monitor and analyze trends, usage, and activities in connection with our Services
- To detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of SparkGame and others
- To comply with legal obligations
- To respond to your comments and questions and provide customer service
Legal Basis for Processing
For users in the European Economic Area (EEA), United Kingdom, or where GDPR applies, we rely on the following legal bases to process your personal data:
- Contractual Necessity: Processing necessary for the performance of our contract with you (such as providing access to the Game).
- Legitimate Interests: Processing necessary for our legitimate interests, provided these interests do not override your fundamental rights and freedoms (such as improving and personalizing our services, conducting analytics, and preventing fraud).
- Consent: Processing based on your specific, informed, and unambiguous consent (such as for certain marketing communications or cookies).
- Legal Obligation: Processing necessary to comply with our legal obligations.
For each processing activity, we ensure that we have an appropriate legal basis. Where consent is the legal basis, you have the right to withdraw that consent at any time.
DATA SHARING AND DISCLOSURE
Third-Party Service Providers
We may share your information with third-party vendors, service providers, contractors, or agents who perform services on our behalf, such as:
- Hosting and infrastructure providers that help us deliver our Services
- Analytics providers who help us understand user behavior and optimize our Services
- Payment processors who handle transactions (we do not store full payment information)
- Customer support services that help us respond to your inquiries
We require these third parties to maintain the confidentiality of the information we share with them and to use it only for the purpose of providing their services to us. We have executed appropriate Data Processing Agreements with all processors as required by applicable data protection laws.
Aggregated and Anonymized Data
We communicate data to third parties in an aggregated and anonymized form, which these third parties cannot use to identify you personally:
- Analytics Partners: They help us better understand how users interact with our Services and help us improve them.
- Advertising Partners: We provide them with advertising space, and these partners are solely responsible for the content they show to users. We do not share your personal data with these entities.
If you engage with third-party features integrated into our Game (including third-party SDKs or cookies), you may be subject to those third parties' privacy practices. We recommend reviewing their privacy policies before engaging with these features.
Legal Requirements
We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).
Business Transfers
If SparkGame is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
INTERNATIONAL DATA TRANSFERS
Your personal data may be transferred to, and processed in, countries other than the country where you reside. These countries may have data protection laws that are different from the laws of your country.
When we transfer your personal data from the EEA, UK, or other regions with data protection laws to countries that have not received an adequacy decision from the European Commission or equivalent authority, we implement appropriate safeguards to ensure that your personal data remains protected according to applicable law. These safeguards include:
- European Commission approved Standard Contractual Clauses (SCCs)
- Conducting transfer impact assessments
- Implementing supplementary measures as needed
- Binding Corporate Rules (where applicable)
You can request more information about these safeguards by contacting us using the details provided in the "Contact Us" section.
DATA RETENTION
We retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider:
- The amount, nature, and sensitivity of the personal data
- The potential risk of harm from unauthorized use or disclosure
- The purposes for which we process the data and whether we can achieve those purposes through other means
- Applicable legal, regulatory, or business requirements
Specific retention periods include:
- Account data: While your account is active plus 2 years after account closure/inactivity
- Transaction data: 7 years for tax and accounting purposes
- Communications with customer support: 2 years after resolution of your inquiry
- Game analytics data: In anonymized form for up to 5 years
CHILDREN'S PRIVACY
Our Services are not directed to children under the age of 13 (or the applicable minimum age in your jurisdiction, which may be 16 in some EU countries). We do not knowingly collect personal information from children under these age thresholds. If we learn that we have collected personal information of a child without verification of parental consent, we will take steps to delete such information as soon as possible.
For users between 13 and 18 years old (or the age of majority in their jurisdiction), we recommend parental supervision when using our Services, especially when making in-game purchases.
If you believe we might have collected information from children under the applicable minimum age, please contact us immediately.
YOUR PRIVACY RIGHTS
Depending on your location and applicable laws, you may have the following rights regarding your personal data:
- Right to Access: Right to be informed about and request access to the personal data we process about you.
- Right to Rectification: Right to request that we amend or update your personal data where it is inaccurate or incomplete.
- Right to Erasure: Right to request that we delete your personal data, subject to certain exceptions where we have legitimate grounds to retain it.
- Right to Restrict Processing: Right to request that we temporarily or permanently stop processing all or some of your personal data.
- Right to Object: Right to object, at any time, to the processing of your personal data on grounds relating to your particular situation.
- Right to Data Portability: Right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party's service.
- Right not to be Subject to Automated Decision-making: Right not to be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
- Right to Withdraw Consent: Where processing is based on consent, the right to withdraw that consent at any time.
Additional CCPA/CPRA Rights (California Residents)
- Right to Know/Access: What personal information we collect, use, disclose, and sell.
- Right to Delete: Request deletion of personal information we have collected.
- Right to Correct: Request correction of inaccurate personal information.
- Right to Opt-Out: Opt-out of the "sale" or "sharing" of personal information for cross-context behavioral advertising.
- Right to Limit: Limit the use and disclosure of sensitive personal information.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of these rights.
To exercise these rights, please contact us using the contact information provided at the end of this policy. We will respond to your request within the timeframe required by applicable law (30 days for GDPR requests, 45 days for CCPA requests, with possible extensions as allowed by law).
We may need to verify your identity before fulfilling your request. In certain cases, we may deny your request if we have a lawful reason to do so.
Personal Data Request Process
To submit a personal data request:
- Email us at legal@spark-game.com with the subject line "Privacy Rights Request"
- Use our dedicated privacy rights request form on our website
- Provide sufficient information for us to verify your identity
DATA SECURITY
We implement appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:
- Encryption of personal data where appropriate
- Regular security assessments and testing
- Access controls and authentication procedures
- Staff training on data protection
- Incident response plans
- Physical security measures for our facilities
However, please note that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
DATA BREACH NOTIFICATION
In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority without undue delay, and no later than 72 hours after becoming aware of the breach, when required by applicable law.
This notification will include:
- The nature of the breach
- Categories and approximate number of data subjects affected
- Likely consequences of the breach
- Measures taken or proposed to address the breach
- Contact information for our Data Protection Officer
COOKIE POLICY
SparkGame's websites and games use cookies and similar technologies that collect and store information as you interact with them.
What Are Cookies?
A cookie is a small data file that we transfer to your computer's hard disk to quickly identify a user's computer and "remember" things about your visit, such as your preferences. Information contained in a cookie may be linked to your personal information for purposes such as improving our services and customizing content.
Types of Cookies
Based on their origin, cookies can be classified as:
- First-party Cookies: Cookies managed and stored by SparkGame.
- Third-party Cookies: Cookies managed and stored by entities with content or systems integrated into SparkGame's website or applications.
Based on their purpose, cookies can be classified as:
- Necessary Cookies: Technical cookies that allow basic functions like page navigation and access to secure areas. These are essential for the website or services to function properly. We do not request consent for these cookies as they are strictly necessary.
- Preference Cookies: Allow you to use the service with certain features that personalize your experience, such as recognizing your language preference. We use these based on your consent.
- Statistical (Analytical) Cookies: Allow for monitoring and analysis of user behavior to measure activity and make improvements. We use these based on your consent.
- Marketing or Advertisement Cookies: Allow us to know your browsing habits and show relevant advertising. We use these based on your consent.
Based on duration, cookies can be classified as:
- Session Cookies: Stored temporarily during a browsing session and deleted when you close the browser.
- Persistent Cookies: Stored for a specified length of time and used to remember settings or preferences. SparkGame does not store cookies for more than 2 years.
Cookie Management
We have implemented a cookie consent management platform on our website and within our game where applicable. This allows you to:
- View a comprehensive list of the cookies we use
- Choose which categories of non-essential cookies to accept
- Change your preferences at any time
- Exercise your right to withdraw consent for non-essential cookies
You can also configure your browser to allow, block, or delete cookies. Please note that if you disable cookies, you may not be able to access all features of our Services. Each browser has different procedures for managing cookies.
To learn more about cookie management in different browsers, please visit the help pages of your browser:
CHANGES TO THE PRIVACY POLICY
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.
For material changes to this Privacy Policy, we will make reasonable efforts to provide notification via email (if we have your email address) or through a prominent notice on our website or within the Game, at least 30 days before the changes take effect.
We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted.