Privacy Policy

Depending on how you use our services, we may process:

Game and device data

• device type, operating system and app version;
• IP address and approximate location derived from it;
• device, installation and advertising identifiers;
• gameplay events, progress, sessions and interactions with the game;
• advertising impressions, interactions and related technical information; and
• diagnostic, performance and error information.

Information you provide

• your email address and the contents of messages you send to us, for example when contacting customer support.

When you make a privacy request, we may process the request type, game or website involved, contact details you choose to provide, relevant identifiers and the details of your request. You may also tell us if you are acting as a parent, guardian or authorised agent. Please do not send passwords, full payment details, identity documents or unnecessary sensitive information in your initial request.

We do not require players to provide their real name, address or other unnecessary personal information simply to play our games.

Games

Rumble Spark Games operates several games which can be played via an app or website. List of Rumble Spark Games:

• Folded Flyer
• Cubo
• Aztec Temple Quest
• Shiny Treasure
• Joe Cable
• Fruity Gardens
• Mahjong Mandy
• Slingshot Junkyard
• Nine Nests

Our games use Unity Analytics to help us understand how our games are played and improve gameplay, balancing, performance and user experience.

Unity Analytics may process information such as IP address, installation identifiers, device information and gameplay events.

We do not use Google Analytics or Firebase Analytics inside our games.

Our website, rumblespark.com, does use Google Analytics to help us understand website traffic and usage. Website analytics are separate from analytics used inside our games.

See our Cookie Policy for website tools and choices.

Some of our games display advertising.

We use Unity LevelPlay as our advertising mediation platform. LevelPlay may select and deliver advertisements from advertising networks including:

• Unity Ads; and
• Google AdMob.

Advertising providers may process information such as advertising identifiers, IP address, device information, approximate location, ad impressions and interactions with advertisements.

Where required by law, we request consent before using personal data for personalized advertising. We use Google’s User Messaging Platform (UMP) to present applicable advertising privacy choices and consent messages.

Depending on your location and choices, you may receive personalized or non-personalized advertising.

Where available, you can change your advertising privacy choices through the privacy options provided within the game or your device settings.

You can also use our privacy-request page to make an applicable sale, sharing or targeted-advertising opt-out request. Tell us which game or service it concerns; a website cookie choice does not automatically change settings inside a game.

Some Rumble Spark games offer optional in-app purchases, including:

• Folded Flyer;
• Mahjong Mandy;
• Shiny Treasure: Pirate Blast; and
• Nine Nests.

Purchases are processed through the platform from which you obtained the game, such as the Apple App Store or Google Play.

Rumble Spark does not receive or store your full payment card details. The applicable platform provider processes payment information under its own privacy policy.

We may receive transaction information necessary to confirm purchases, restore purchases, provide purchased content and prevent fraud.

We process personal data where necessary to:

• provide and operate our games and services;
• save or deliver game functionality;
• understand and improve our games;
• provide customer support;
• process and verify in-app purchases;
• display and measure advertising;
• prevent fraud, abuse and security incidents;
• comply with legal obligations; and
• establish or defend legal claims.

Where applicable under data protection law, our legal bases include performance of a contract, our legitimate interests, compliance with legal obligations and your consent.

Where processing is based on consent, you may withdraw that consent at any time.

We use privacy-request information to handle and document your request, communicate with you, protect the person concerned and meet applicable legal obligations. Making a request is not a marketing sign-up or consent to advertising.

Our games may use services provided by third parties. These providers may process personal data according to their own privacy policies and, depending on the service and applicable law, may act as our processor or as an independent controller.

The principal services currently used in our games are:

• Unity Analytics — game analytics;
• Unity LevelPlay — advertising mediation;
• Unity Ads — advertising;
• Google AdMob — advertising; and
• Google User Messaging Platform (UMP) — advertising privacy and consent management.

For more information, please review the privacy information provided by Unity and Google.

Apple and Google may also process information when you download our games or make purchases through their respective app stores.

Relevant hosting, email and technical providers may process support or privacy-request information where needed to deliver those services. We may also need to involve a relevant service provider to locate records or act on an applicable request.

Our games do not rely on ordinary browser cookies in the same way as websites.

Our website may use cookies and similar technologies, including Google Analytics, for website functionality, analytics and measurement.

Where legally required, non-essential website cookies require your consent. Our Cookie Policy explains website tools and available cookie choices. Google advertising tools may also support website ads and measurement where enabled.

If you do not want websites to place cookies on your devices, you can adjust the browser settings so that your browser refuses all cookies or only third-party cookies. You can also delete cookies that have already been placed. Note that you must adjust the settings separately for each browser and computer that you use. If you decide to disable all cookies, some parts of our Services may not function properly. How you can adjust the settings differs per browser. If necessary, consult the help function of your browser, or click on one of the links below to go directly to the manual of that specific browser.

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Apple Safari

Participating advertising providers may also offer choices through:

• https://youronlinechoices.eu/
• https://thenai.org/how-to-opt-out
• https://optout.aboutads.info/

These third-party services do not replace your applicable rights or our privacy-request route. Changing a website cookie choice does not automatically delete data already collected or change settings inside a mobile game.

Our games and services are not directed to children under 13, and we do not knowingly collect personal data directly from children under 13.

Where a game, platform or jurisdiction requires additional protections for younger users, we apply the appropriate age-related privacy and advertising restrictions.

If you believe a child has provided personal data to us contrary to applicable law, please contact us at privacy@rumblespark.com.

A parent or guardian may also explain a concern through our privacy-request page.

We may share personal data with service providers where necessary to operate our games and business, including analytics, advertising, hosting, platform and technical service providers.

We may also disclose information where required by law, to protect our legal rights or users, or in connection with a merger, acquisition, restructuring or sale of our business or assets.

We do not sell personal information to data brokers.

Advertising providers may process or share certain identifiers and advertising data for advertising purposes subject to your consent and applicable privacy law.

Depending on the law and how information is used, disclosures for advertising can count as a “sale” or “sharing” even without payment for the information. Where applicable, request an opt-out through Do Not Sell or Share My Personal Information / Privacy Requests or email privacy@rumblespark.com.

Some of our service providers operate internationally. Personal data may therefore be processed outside your country, including outside the European Economic Area.

Where required, appropriate safeguards are used for international transfers, such as adequacy decisions or approved Standard Contractual Clauses.

We keep personal data only for as long as reasonably necessary for the purposes described in this Policy, including providing our services, complying with legal obligations, resolving disputes and protecting our legal rights.

Retention periods may vary depending on the type of information and the service provider involved.

We retain privacy-request information only as needed to handle the request, document our response and meet applicable legal or record-keeping obligations. Any verification information is limited to what is necessary for that purpose and retained only as needed for it or an applicable legal obligation.

Depending on where you live, you may have rights concerning your personal data, including the right to:

• access your personal data;
• correct inaccurate information;
• request deletion;
• restrict or object to certain processing;
• withdraw consent;
• request portability of certain data; and
• opt out of certain targeted or personalized advertising.

You may exercise applicable rights by contacting privacy@rumblespark.com.

You can also use our privacy-request page for applicable requests. It explains what information may help us locate relevant records and what happens next.

For access, deletion and other requests where verification is appropriate, we may need proportionate information to protect the person concerned. Where the GDPR applies and we have reasonable doubts about identity, we may request only additional information necessary to confirm it. We may also need proportionate evidence that you are authorised to act for another person.

Sale, sharing and targeted-advertising opt-outs do not require an account or identity verification. We may ask only for information needed to locate the relevant service or information and apply the choice. Providing an email address is optional for an opt-out, although it helps us follow up.

We handle requests within applicable deadlines and explain any lawful limits or exceptions. A request does not itself confirm that deletion or an opt-out is complete. Deletion may affect game progress or features tied to the relevant data.

Residents of the European Economic Area may also lodge a complaint with their national data protection authority. In the Netherlands, the supervisory authority is the Autoriteit Persoonsgegevens.

Residents of U.S. states with applicable privacy laws may have additional rights, including rights relating to targeted advertising and the sale or sharing of personal information.

We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration or disclosure.

No internet or electronic storage system can, however, be guaranteed to be completely secure.

We may update this Privacy Policy when our games, technology providers or legal obligations change.

The current version will be published at rumblespark.com/privacy-policy/ together with its last-updated date. Where required by law, we will provide additional notice of material changes.

Rumble Spark Games
Zwolle, The Netherlands

Privacy enquiries and data protection requests:

privacy@rumblespark.com

You can also use Privacy & Data Requests. For website cookie information and choices, see our Cookie Policy.