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NOTICE OF FINANCIAL INCENTIVE

Sparks Rewards Program

1. Name of Financial Incentive Program

Sparks Rewards Program, operated by Pinsight Media, Inc. on behalf of its affiliates and group companies (collectively, "InMobi", "We", "Us", "Our"). The Sparks Reward Program is governed by the Sparks End User License Agreement ("Sparks EULA"). If this Notice of Financial Incentive conflicts with the Sparks EULA, the Sparks EULA will control.

Participation in the Sparks Rewards Program is required to use Sparks. Tap "No Thanks" to decline. Please note that if you decline, you will not earn Coins and will not be able to access Activities on the Sparks platform. Your choice is voluntary.

2. Description of Financial Incentive

The Sparks Rewards Program constitutes a "financial incentive" as defined under the California Consumer Privacy Act (as amended by the California Privacy Rights Act) ("CCPA") because InMobi offers virtual Sparks Coins to users in exchange for their engagement with rewarded Activities, which involves the collection, use, and sharing of personal information for targeted advertising purposes.

Specifically, users who opt into the Sparks Rewards Program will:

  • Earn Sparks Coins upon verified completion of Activities;
  • Accumulate Coins toward milestone redemption thresholds; and
  • Have their personal information including device identifiers, advertising IDs, behavioural and engagement data, and ad interaction history collected, used, and shared with advertising partners for the purpose of serving targeted advertisements within Sparks and on other digital properties.

3. Material Terms of the Financial Incentive

i. Earn Rate: The number of Coins awarded per ad completion is dynamic and varies based on the real-time effective cost per mille (eCPM) of the ad served, as determined by the Agentic Game Economics Engine (AGEE).

ii. Redemption Thresholds: As per the FAQ

iii. Payout Cap: As per the FAQ

iv. Coin Expiry: Coins that remain unredeemed for 12 months following the date of earning, or upon account inactivity for 12 months will expire and be forfeited without compensation.

v. Coin Value Outside Platform: Sparks Coins have no cash value outside the Sparks platform, cannot be transferred between users, and are purely a promotional reward mechanism.

vi. No Guaranteed Earnings: InMobi does not guarantee any specific level of Coin earnings, payout amounts, or reward availability. Coin and reward calculations depend on real-time ad market conditions and are awarded at InMobi's sole discretion.

vii. Changes to Terms: InMobi reserves the right to modify the earn rate, redemption thresholds, payout caps, or any other material term of the Sparks Rewards Program. Material changes will be notified via in-app notice before taking effect.

4. Categories of Personal Information Collected

In connection with the Sparks Rewards Program, InMobi collects, uses, and shares the following categories of personal information:

  • Device identifiers and advertising IDs;
  • IP address and approximate location data;
  • Ad engagement and interaction data (ads viewed, completion rate, opt-in behaviour);
  • Gameplay and Activity engagement data;
  • Coin earn and redemption history;
  • Payment Partner account information (collected and processed by the Payment Partner);
  • Biometric data (if applicable, collected by designated vendor for fraud prevention purposes); and
  • Tax documentation where applicable

7. How to Opt In

Participation in the Sparks Rewards Program is voluntary and requires affirmative opt-in. To participate, you must:

  • Access Sparks through a host platform (any InMobi-operated, affiliated, or partner platform on which Sparks is available);
  • Review the EULA, Privacy Policy, and this Notice of Financial Incentive when prompted at first launch; and
  • Tap "Get Started" or an equivalent affirmative consent button to begin earning Coins.

Users who do not wish to participate may tap "No Thanks" or the equivalent decline option. Declining means you will not earn Sparks Coins and will not be able to access Activities on the Sparks platform.

InMobi has made a good faith estimate that the value of the financial incentive offered through Sparks coins redeemable for real-world rewards is reasonably proportionate to the value of personal information collected in connection with the Sparks Rewards Program. This estimate is based on the advertising revenue generated per user through rewarded ad engagement, net of reward payout costs. InMobi does not believe the incentive offered is unjust, unreasonable, coercive, or unconscionable.

9. How to Opt Out

You may withdraw from the Sparks Rewards Program at any time by:

  • Navigating to Settings → Privacy → Sparks Rewards within the platform and toggling off participation; or
  • Contact us at support@sparksgames.io

Upon opting out:

  • You will no longer earn Coins from Activities;
  • Coins already accumulated and not yet redeemed will be retained in your wallet for 12 months before expiry; and
  • Your personal information already collected will be handled in accordance with our Privacy Policy.

11. Contact Us

For questions about this Notice or to exercise your rights described in this Notice, please contact support@sparksgames.io