Privacy Policy

Effective Date: October 23, 2025

This Privacy Policy describes how Naolito Games SL, operating under the commercial name "Spark Games" ("we," "us," or "our"), collects, uses, and shares your personal information when you use our mobile games, websites, and related services (collectively, the "Service").

1. Information We Collect

1.1 Information You Provide to Us

We may collect information you provide directly to us, such as when you:

• Create an account or profile
• Make in-app purchases
• Contact us for customer support
• Participate in surveys or promotions
• Subscribe to our newsletters or marketing communications

This information may include your name, email address, username, password, payment information, and any other information you choose to provide.

1.2 Information We Collect Automatically

When you use our Service, we may automatically collect certain information about your device and usage, including:

• Device Information: Device type, operating system, unique device identifiers, IP address, mobile network information
• Game Data: Game progress, scores, achievements, in-game purchases, gameplay statistics
• Usage Information: How you interact with our games, features used, time spent playing, session frequency
• Location Data: Approximate location based on IP address (precise location only with your consent)
• Advertising Data: Ad interactions, preferences, and advertising identifiers

1.3 Information from Third Parties

We may receive information about you from third parties, such as:

• Social media platforms (if you connect your account)
• Advertising partners
• Analytics providers
• App stores (Apple App Store, Google Play Store)

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our games and services
• Process transactions and deliver purchased content
• Provide customer support and respond to your inquiries
• Personalize your gaming experience
• Send you technical notices, updates, security alerts, and administrative messages
• Communicate with you about new games, features, offers, and promotions
• Monitor and analyze trends, usage, and activities in connection with our Service
• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Comply with legal obligations and protect our rights

3. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), our legal basis for processing your personal information includes:

• Contract Performance: Processing necessary to provide our services and fulfill our contractual obligations
• Legitimate Interests: Processing for our legitimate business interests, such as improving our services and preventing fraud
• Consent: Processing based on your explicit consent (which you may withdraw at any time)
• Legal Compliance: Processing necessary to comply with legal obligations

4. How We Share Your Information

We may share your information in the following circumstances:

4.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, including:

• Cloud hosting and data storage providers
• Payment processors
• Customer support platforms
• Analytics and advertising services
• Email and communication services

4.2 Advertising Partners

We may share certain information with advertising partners to show you relevant ads. This may include advertising identifiers and usage data, but does not include personally identifiable information.

4.3 Legal Requirements

We may disclose your information if required by law or if we believe such disclosure is necessary to:

• Comply with legal processes or government requests
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users or the public
• Prevent or investigate possible wrongdoing

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

5. Data Retention

We retain your personal information for as long as necessary to provide our services and fulfill the purposes outlined in this Privacy Policy. We may also retain information to comply with legal obligations, resolve disputes, and enforce our agreements.

Specific retention periods depend on the type of information and how it is used, but generally:

• Account information is retained until you delete your account
• Game data and progress are retained to maintain your gaming experience
• Transaction records are retained for legal and accounting purposes
• Analytics and usage data may be aggregated and retained indefinitely

6. Your Rights and Choices

6.1 GDPR Rights (EEA Users)

If you are located in the EEA, you have the following rights:

• Access: Request access to your personal information
• Rectification: Request correction of inaccurate or incomplete information
• Erasure: Request deletion of your personal information
• Portability: Request transfer of your information to another service
• Restriction: Request restriction of processing
• Objection: Object to processing for legitimate interests or direct marketing
• Withdraw Consent: Withdraw consent for consent-based processing

6.2 Account Management

You can:

• Update your account information through the game or by contacting us
• Delete your account by contacting customer support
• Opt out of marketing communications

6.3 Advertising Choices

You can control personalized advertising by:

• Adjusting your device's advertising settings
• Using the advertising choices provided in our games
• Visiting industry opt-out pages (e.g., NAI, DAA)

7. Children's Privacy

Our services are not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, please contact us immediately, and we will take steps to delete such information.

For children between 13 and 16 in the EEA, we require parental consent for certain processing activities.

8. International Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws than your country. When we transfer your information internationally, we implement appropriate safeguards to protect your information, including:

• Standard contractual clauses approved by the European Commission
• Adequacy decisions
• Other appropriate safeguards as required by applicable law

9. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is completely secure, so we cannot guarantee absolute security.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. For significant changes, we may also provide additional notice (such as through in-game notifications or email).

11. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us:

Data Controller:
Naolito Games SL (operating as Spark Games)
Sor teresa prat 15, Polo de contenidos digitales
Málaga (Spain) 29003
Email: contact@naolito.com

Data Protection Rights:
For questions specifically related to your data protection rights or to exercise your rights under GDPR, please contact us at contact@naolito.com with "Data Protection Request" in the subject line.

Supervisory Authority:
If you are located in the EEA and have concerns about our processing of your personal information, you have the right to lodge a complaint with your local data protection authority.