Privacy Policy for Pocket Spark

Kwalee Ltd
Last updated: September 29, 2026

1. Introduction

Welcome to Pocket Spark. “Pocket Spark” is a mobile game publishing brand and Google Play Store developer account operated by Kwalee Ltd (“we”, “us”, or “our”). Kwalee Ltd is a company registered in England (Company No. 07648078) with its registered office at Midlands Technical Centre, Southam Road, Radford Semele, Leamington Spa, CV31 1FQ, United Kingdom.

Kwalee Ltd is the legal entity responsible, and data controller, for all games published under the Pocket Spark account. This Privacy Policy describes how we handle information in our Pocket Spark games.

2. General Terms and Acknowledgement

By downloading, accessing, or playing Pocket Spark games, you acknowledge that you have read and understood this Privacy Policy. This policy explains the lawful basis on which your non-identifiable data is collected, used, and processed by us or on our behalf.

Where consent is legally required for specific tracking technologies (such as for delivering advertising via our third-party partners), we will request your explicit, affirmative consent directly within the game via a consent management platform before any such data collection occurs.

3. Information We DO NOT Collect

We design our Pocket Spark games with a minimal data footprint:

• We do not collect personal contact details like your real name, physical address, email address, or phone number through game play.
• We do not collect sensitive personal information such as passwords, financial details, or biometric data.

4. Information We Collect (Our Game Telemetry)

When you play our games, we directly collect lightweight, non-identifying gameplay events strictly for operating the game, tracking progression, and aggregated performance reporting. We collect the following categories of telemetry data:

• Installation & Session Data: Randomly generated, anonymous identifiers assigned to your game installation and active play sessions, along with your device platform (Android or iOS).
• Gameplay Progression: Data related to your in-game activity, such as when you start, complete, or fail a level, and when you complete the game’s content.
• Timestamps: Local device timestamps to record when the above gameplay events occur.

5. Advertising and Third-Party Partners

We display advertisements in our games through our ad mediation platform, Almada, and third-party advertising partners.

• With Your Consent: If you choose to grant consent through our Consent Management Platform (CMP), our advertising partners may collect and process device identifiers—such as your Google Advertising ID (GAID)—to serve personalized, targeted advertisements relevant to your interests.
• Without Consent: If you decline or opt out of personalized advertising, our partners will only serve non-personalized, contextual ads and will not use your Advertising ID for behavioral profiling. They may still process basic technical metadata (such as IP address and device specifications) strictly for ad delivery, frequency capping, and fraud prevention.

6. Third-Party Analytics and Attribution (AppsFlyer SDK)

We integrate the AppsFlyer Software Development Kit (SDK) to help us measure the performance of our marketing campaigns (attribution) and to analyze general game usage.

• Attribution and Analytics: AppsFlyer processes technical network information (such as IP address, device specifications, and installation timestamps) on our behalf to determine how you discovered our game and to measure overall performance.
• Consent and Compliance: If you are in a region that requires a Consent Management Platform (CMP), the AppsFlyer SDK reads your consent choices (such as your TCF string) directly from your device. It uses this information to ensure that any data processed for attribution respects your privacy preferences.

For more details on how AppsFlyer handles data, visit the AppsFlyer Privacy Policy.

7. Our Lawful Bases for Processing

Operating the game and gameplay telemetry (Section 4): contract, since you agree to terms and conditions for play, and/ or our legitimate interests in providing, maintaining and improving our games, tracking progression and producing aggregated performance reports.

• Personalised advertising (Section 5): your consent, which you can give or refuse through our Consent Management Platform and withdraw at any time in the game’s privacy settings.
• Non-personalised advertising, frequency capping and fraud prevention (Section 5): consent and/or our legitimate interests, and those of our advertising partners, in funding our free games through advertising and protecting them against fraud.
• Attribution and analytics through AppsFlyer (Section 6): your consent, where the law requires consent for accessing information on your device; otherwise, our legitimate interests in measuring the effectiveness of our marketing campaigns.
• Responding to enquiries and data protection requests: our legitimate interests in responding to you and, where you exercise your data protection rights, compliance with our legal obligations.

Where we rely on legitimate interests, we have balanced those interests against your rights and freedoms. You may object to this processing at any time, as explained in the Your Data Protection Rights section below.

8. Children’s Privacy

Our games are designed for a general audience. We do not knowingly collect or solicit personal data from children. Because our telemetry system uses pseudonymous UUIDs and does not collect personal identifiers, we treat all player data with standard, non-targeted privacy protection safeguards.

9. Who We Share Your Data With

We share your data only with the following categories of recipients, each of which is bound by contractual confidentiality and data protection obligations:

• Hosting and cloud infrastructure providers: who store and process our game telemetry on our behalf as processors.
• Analytics and attribution providers: such as AppsFlyer, who help us measure game performance and marketing effectiveness.
• Ad mediation and advertising partners: who deliver advertisements in our games, as described in Section 5. Where these partners use your data for their own purposes, they act as independent controllers and their own privacy policies apply.
• Professional advisers and authorities: where reasonably necessary to comply with law, enforce our rights, or respond to lawful requests from public authorities.

10. International Data Transfers

Some of our service providers and partners are located, or process data, outside the United Kingdom and the European Economic Area (EEA), including in the United States. Where we transfer your data to a country that has not been recognised as providing an adequate level of protection, we put appropriate safeguards in place. These include the UK International Data Transfer Agreement (IDTA), the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, the EU Standard Contractual Clauses (SCCs), or, where applicable, certification under the UK Extension to the EU-U.S. Data Privacy Framework.

11. How Long We Keep Your Data

We keep data only for as long as necessary for the purposes described in this Privacy Policy:

• Installation, session and gameplay telemetry: retained for up to 24 months from the date of collection, after which it is deleted or fully anonymised.
• Attribution and analytics data processed by AppsFlyer: retained for up to 24 months, in line with our agreement with AppsFlyer.
• Advertising data: retained by our advertising partners in accordance with their own privacy policies; your consent choices are stored on your device by our Consent Management Platform and can be changed at any time in the game’s privacy settings.
• Correspondence: if you contact us, we retain your message and contact details for up to 6 months after our last communication.
• We may retain data for longer where required by law or to establish, exercise or defend legal claims.

12. Your Data Protection Rights

Depending on where you live, you may have the following rights in relation to your personal data:

• Access: to obtain confirmation of whether we process your data and a copy of it.
• Rectification: to have inaccurate data corrected.
• Erasure: to have your data deleted in certain circumstances.
• Restriction: to ask us to limit how we use your data in certain circumstances.
• Portability: to receive data you have provided to us in a structured, commonly used and machine-readable format, where processing is based on consent or contract and carried out by automated means.
• Objection: to object to processing based on our legitimate interests and, at any time, to the use of your data for direct marketing or related profiling.
• Withdrawal of consent: where we rely on consent, to withdraw it at any time through the privacy settings in the game, without affecting the lawfulness of processing before withdrawal.

Because we identify players only by randomly generated identifiers, we may ask you to provide your installation identifier (available in the game’s settings) so that we can locate your data.

To exercise any of these rights, contact us using the details below. We will respond within one month, which may be extended where permitted by law.

You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at www.ico.org.uk or by calling 0303 123 1113, or with the data protection authority in your country of residence. We would, however, appreciate the chance to address your concerns first.

13. Is Providing Your Data Required?

You are not under any statutory or contractual obligation to provide personal data. The gameplay telemetry described in Section 4 is collected automatically and is necessary to operate the game, so we cannot provide the game without it. Consent to personalised advertising is entirely optional: if you decline, you can still play the game in full and will see non-personalised ads instead.

14. Contact Us & Data Protection

If you have questions regarding this Privacy Policy or Kwalee’s privacy practices for Pocket Spark, please contact our Data Protection team:

Email: privacypolicy@kwalee.com

Postal Address:
Kwalee Ltd
Midlands Technical Centre, Southam Road
Radford Semele, Leamington Spa
CV31 1FQ, United Kingdom