SPARKS is an application (the "Application") published by InMobi, its affiliate(s) and/or its group companies (collectively referred to as "InMobi," "we", "us" or "our"). SPARKS is a mobile rewards-and-entertainment application that allows users to play games and engage with advertising content, including video advertisements, in exchange for in-app rewards. Rewards accumulated through such engagement may be redeemed by eligible users for cash or cash-equivalent value, subject to the applicable terms and conditions governing redemption.
This Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information and to help you understand and exercise your privacy rights. Please read this policy carefully to understand our practices regarding your personal data or personal information.
Notice at Collection. At or before the time of collection, certain countries and/or States may provide its residents with the right to receive notice of our practices, including the categories of personal or sensitive information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how to opt-out of such uses, and how long such information is retained. You can find those details in this statement by clicking on the below links. Please see sections below on Supplemental Notice as required by certain countries or States regarding your rights, Retention of Personal Information and How We Use Your Personal Information sections below.
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 Application, and other online or offline related consumer offerings. To make this Privacy Policy easier to read, the SPARKS Application, its updates, enhancements and/or features, and other related offerings are collectively called "Services." Our affiliate PinSight Media Inc. is the primary operator of the Application 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.
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. Please note that you may interact with our customers, telecom partners, advertisers and media partners directly and their respective privacy policies govern their collection and use of your data.
We may collect the following personal information that you provide to us when you download, install, launch, and/or interact with the Application.
We may collect personal information automatically when you use our Services:
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
We use your information to fulfil our contract with you and/or provide you with our services, such as:
We use your information in our legitimate interest, such as:
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 email campaigns, 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.
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.
We also use your information for other purposes as requested by you or as permitted by applicable law.
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:
The categories of third parties with whom we may share your information are described below.
"Group" as used in this policy, means, with respect to InMobi, its affiliates and group entities listed here.
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.
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.
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
Tracking Technologies and Interest-Based Advertising. You may opt-out of personalized advertisements by following the instructions on Android devices to limit ad tracking. Please note that limiting advertising tracking will not eliminate advertisements but may make them less relevant to you. Opting-out does affect your ability to earn and redeem awards.
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.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
All personal information processed by us, Advertising Partners, the Group or our Service Providers, may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavour to safeguard your information consistent with the requirements of applicable laws.
For more information about the safeguards we use for international transfers of your personal information, please "contact us" as set forth below.
We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfil the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defences, conduct audits, identify you if you decide to again access the Service, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
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 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 InMobi disclosed that personal information to a service provider or a contractor for a business purpose in the preceding 12 months, whether InMobi "sold" that personal information, and whether InMobi "shared" that personal information for "cross-context behavioural advertising" in the preceding 12 months. You can find this information below:
Category of Personal Information Collected by SPARKS | Category of Third Parties To Whom Personal Information is Disclosed to for a Business Purpose | Category of Third Parties To Whom Personal Information is Sold and/or Shared |
|---|---|---|
Identifiers Unique personal identifier, online identifier (such as Google Advertisement Identifier) or other similar identifiers. |
|
|
Internet or other electronic network activity Information on a consumer's interaction with Glance application and advertisements on Glance. |
|
|
Geolocation data General area inferred from IP address. |
|
|
Inferences drawn from other personal information to create a profile about a consumer User's past interactions |
|
|
Sensitive Personal Information Facial Scan (that may be considered as Biometric information) |
|
|
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, 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.
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
The Service is 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. 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. 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.
Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
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