Notice
This English version is provided for reference only, as a courtesy translation of the original Japanese Privacy Policy. In the event of any discrepancy, the Japanese version shall prevail.
Effective date: December 15, 2026
1. Introduction (Controller and Scope)
Knightage ("we," "us," or "our") respects the Act on the Protection of Personal Information of Japan (the "APPI"), the EU General Data Protection Regulation (GDPR), the UK GDPR, the California Consumer Privacy Act (CCPA/CPRA), and other laws applicable to users, and handles information appropriately in accordance with this Privacy Policy (this "Policy") in connection with the iOS application "Sparkee" (the "App") that we provide. This Policy covers the handling of information through the App and the website we operate at https://sparkee.knightages.com/ (including the contact form; the "Website"), and does not apply to other sites or apps that we operate separately.
We are the controller of information we obtain in connection with the App (including where we are a data controller under the GDPR). For contact details, see Section 22. Information obtained by Apple Inc. ("Apple") in connection with Game Center and In-App Purchase, and information independently obtained by Google LLC ("Google") in connection with ad delivery, is handled by Apple or Google, respectively, as an independent controller (see Sections 4 through 6).
The App has no account registration and never asks you to enter identifying information such as your name, email address, or phone number in the App (for information you enter in the contact form, see Section 15). On this basis, this Policy explains the scope of information the App handles and how we handle it.
2. Information We Handle and Information We Do Not Collect
The App itself (the program we created) handles the following information, all of which is stored only on your device and never sent to our servers.
| Game Data | Coin balance, stage progress, stars (★) earned, scores, best records for each mode, in-progress game states, records of login bonuses, daily missions, and ad views, and settings such as sound effects and vibration ("Game Data") |
|---|---|
| Purchase records | Numbers identifying In-App Purchase transactions (used to prevent Coins from being granted twice for the same purchase) |
| Management information | Information needed to manage the App's operation (such as your consent status for the terms and the display status of notices) |
| Storage location | Your device |
| Sent to our servers | No |
We do not collect directly identifying personal information such as your name, address, phone number, or email address through the App. We also do not build our own analytics tools or crash reporting tools into the App. For information obtained through the contact form on the Website, see Section 15.
The App communicates with external servers (our Website and the hosting/CDN providers we use) to obtain configuration information, such as the latest version of the terms, in-app notices, the minimum version required for operation, and game settings. This communication consists only of technical requests to obtain configuration information, and no Game Data is sent. For technical information that may be automatically recorded during this communication, see Section 9.
However, as set forth in Section 4, scores and the like are sent to Game Center; as set forth in Section 5, In-App Purchases are made through Apple; and as set forth in Section 6, Google AdMob (a third-party SDK) may independently collect information such as advertising identifiers for ad delivery.
3. Handling of Game Data (Stored on Your Device)
Game Data is stored only on your device (such as in the iOS Keychain), and no third party, including us, can view or obtain it. We have no means of accessing Game Data.
Game Data (including purchased Coins) cannot be transferred to another device, such as when you change devices. It may also be lost due to loss, failure, or reset of your device. We are not responsible for storing or backing up Game Data. We have not implemented any feature in the App to sync or transfer data via iCloud or the like.
4. Use of Game Center
The App uses Game Center, provided by Apple, for leaderboards and achievements. If you are signed in to Game Center, the App sends your scores for each mode and your achievement progress to Game Center. On the leaderboards, your Game Center nickname and scores are shown to other users.
Information obtained and sent through Game Center (such as Game Center player information, nickname, scores, and achievements) is handled by Apple as an independent controller. We do not send or store this information on our servers. You can change your Game Center sign-in, nickname, visibility, and other settings in the Settings app (Game Center) on your iPhone or iPad. If you are not signed in to Game Center, no scores or other data are sent, and you can use all features other than leaderboards and achievements as usual.
- Game Center & Privacy: https://www.apple.com/legal/privacy/data/en/game-center/
- Apple Privacy Policy: https://www.apple.com/legal/privacy/
5. In-App Purchase (Buying Coins)
Coins are purchased through Apple's In-App Purchase, and payments are processed by Apple. We do not obtain or hold payment information such as your name or credit card number in connection with purchases.
To grant purchased Coins, the App receives purchase transaction information (such as the number identifying the transaction and the type of product purchased) through iOS. Of this, the number identifying the transaction is stored only on your device to prevent Coins from being granted twice for the same purchase, and is never sent to our servers. Information about purchases is handled in accordance with Apple's privacy policy.
6. Advertising (Google AdMob) and Related Information Handling
The App uses "Google AdMob," an ad delivery service provided by Google, and covers its operating costs by showing video ads that you choose to watch (rewarded ads). Ads are shown only when you tap a button to watch an ad.
Google AdMob (and the advertising network partners included in its SDK) may independently collect and use information such as the following for purposes such as ad delivery, measurement, and fraud prevention.
- Advertising identifier (IDFA; only if you allow tracking)
- IP address and approximate location based on it
- Device information such as device model, OS version, and language settings
- Ad interaction information such as ad impressions, views, and taps
This handling is carried out by Google, not us, as an independent controller. For details, please see the following Google policies.
- Google Privacy Policy: https://policies.google.com/privacy
- How Google uses information from sites or apps that use its services / Advertising: https://policies.google.com/technologies/ads
- Data handling in Google AdMob: https://support.google.com/admob/answer/6128543
- Ad personalization settings: https://adssettings.google.com/
The App itself does not perform its own tracking. You can choose whether to allow personalized ads by the methods described in the next section.
7. Tracking Permission (ATT) and Consent for Advertising
The first time you tap a button to watch an ad, a dialog asking for "tracking permission" is shown based on iOS's App Tracking Transparency (ATT) framework. This is for showing ads tailored to your interests (personalization).
If you do not allow tracking, personalized ads using the advertising identifier are not shown, and non-personalized ads are shown instead. Even if you do not allow tracking, you can use all features of the App as usual, including watching ads to receive Rewards. You can change this permission at any time in the iOS Settings app (Privacy & Security > Tracking).
For users residing in the European Economic Area (EEA), the UK, Switzerland, and other countries and regions where consent is required by law, we obtain and manage consent for ad delivery through a consent management mechanism (Google User Messaging Platform) in accordance with applicable laws and Google's EU User Consent Policy. You can withdraw or change this consent at any time. To withdraw, you need to change it yourself in the iOS settings (Privacy & Security > Tracking) or on the consent management screen.
8. Notifications
The App may use notifications scheduled on your device (local notifications) to let you know about login bonuses and the like. Notifications are scheduled and shown on your device, and no information is sent to our servers for notifications. You can change notification permission at any time in the iOS Settings app or on the App's settings screen.
9. Technical Information About Devices and Usage
The ad SDK (Google AdMob) may automatically collect technical information such as OS version, device type, and approximate region for purposes such as ad delivery, counting impressions, and detecting fraud. As described in Section 6, this information is managed by Google, and we do not directly obtain or hold it.
In addition, when the App communicates with external servers to obtain the configuration information described in Section 2, the access logs of the hosting/CDN providers we use may automatically record your IP address, access date and time, and user agent (such as device, OS, and app version information). These are automatically recorded by those providers for stable service operation and prevention of unauthorized access, and we do not use them to identify individuals. We ourselves do not store anonymous identifiers (such as UUIDs) or consent histories on servers.
10. Purposes of Use and Legal Bases for Processing
The purposes of use of information handled in connection with the App, and the legal bases for processing (where the GDPR or similar laws apply), are as follows.
| Processing | Purpose and legal basis |
|---|---|
| Storing Game Data and purchase records on your device (core function of the App) | Providing the Service to you (performance of a contract; GDPR Art. 6(1)(b)). We do not access this data. |
| Sending scores and achievements to Game Center | Providing leaderboard and achievement features (performance of a contract; GDPR Art. 6(1)(b)) |
| Showing personalized ads (processing of advertising identifiers and the like by Google) | Operating a free service funded by ad revenue (consent; GDPR Art. 6(1)(a), obtained through ATT and the consent management mechanism) |
| Showing non-personalized ads, and ad fraud prevention and measurement | Operating a free service funded by ad revenue and preventing fraud (legitimate interests; GDPR Art. 6(1)(f)) |
| Responding to inquiries (information entered in the contact form, and emails for replies) | Responding to inquiries and requests to exercise rights (disclosure, correction, deletion, suspension of use, etc.) (legitimate interests or performance of a contract) |
11. Provision to Third Parties
Because we do not obtain Game Data through the App, we never provide it to third parties. We do not sell users' personal information to third parties.
As described above, information relating to Game Center and In-App Purchase is handled by Apple, and the collection and use of information by Google AdMob is handled by Google, each as an independent controller. Other than this, we do not provide personal data to third parties except as required by law, when necessary to protect a person's life, body, or property, or with your consent. The only personal data we hold on servers is information obtained through inquiries.
12. International Transfers of Information
Apple and Google are located in the United States, and part of the information processing relating to Game Center, In-App Purchase, and AdMob may take place in the United States and other countries and regions. Although we ourselves do not send Game Data abroad, due to the technical design of these services, information may be processed across borders by Apple or Google. We disclose this here in light of the purpose of Article 28 of the APPI.
For users to whom the GDPR or similar laws apply, any transfer outside the EEA or UK is carried out by Apple or Google based on appropriate safeguards, such as European Commission adequacy decisions (including the EU-U.S. Data Privacy Framework) or Standard Contractual Clauses (SCCs). For details, please see each company's privacy policy.
In addition, the App's communication to obtain configuration information passes through the hosting/CDN providers we use. These providers may have servers around the world, and the technical information described in Section 9 (such as IP addresses) may be processed outside Japan. In that case, those providers handle the information based on appropriate safeguards such as SCCs.
Information sent through the contact form may also be processed and stored on Zoho Forms servers, as described in Section 15. Zoho Corporation has adopted safeguards for international data transfers based on SCCs.
13. Retention Period
Game Data, purchase records, and the management information described in Section 2 are stored on your device. Because they are not stored on our servers, we do not set or manage a retention period for them. Some Game Data and purchase records are stored in the iOS Keychain and may remain on your device even if you delete the App (they are erased when you reset your device).
The retention period for scores and achievements sent to Game Center and for information relating to In-App Purchase follows Apple's policies. The retention period for information Google obtains in connection with ad delivery follows Google's policies. Information provided to us through inquiries and our reply emails will be deleted within a reasonable period after the inquiry is resolved (generally up to one year), except where retention is required by law.
14. Use of Cookies and Similar Technologies
The App is a native app and does not directly use web browser cookies, but the ad SDK may use identifiers similar to cookies (such as advertising identifiers and SDK internal identifiers). For how these are handled, please see Google's policies listed in Section 6.
The Website currently does not use Google Analytics or other third-party analytics tools. The contact form (Zoho Forms) page may set cookies required for Zoho's own functionality. For details, please see Zoho's Cookie Policy. If we introduce web analytics tools in the future, we will update this Policy to let you know.
15. Contact Form (Zoho Forms)
The contact form on the Website uses "Zoho Forms," provided by Zoho Japan Corporation (the Japanese entity of Zoho Corporation Pvt. Ltd.; "Zoho"). When you submit the form, the information you enter, such as your name, email address, and inquiry, is sent to and stored on Zoho's servers.
We reply to inquiries by email. Please note that we do not promise to reply to every inquiry.
Submitting the form is optional, but if you submit it, you must enter the information needed to respond to your inquiry. Information obtained through inquiries is used only to answer your inquiry and provide support, and not for any other purpose. Zoho Corporation offers a GDPR-compliant Data Processing Addendum (DPA) and has adopted safeguards for international data transfers based on SCCs.
- Zoho Privacy Policy: https://www.zoho.com/privacy.html
16. Your Rights (APPI of Japan)
We do not obtain or store retained personal data that can identify you through the App. Therefore, if you request disclosure, correction, addition, deletion, suspension of use, erasure, or suspension of provision to third parties under the APPI, we will promptly check and respond within the scope of the data we hold. Please note in advance that Game Data exists only on your device and cannot be checked by us, and that information relating to Game Center and advertising is managed by Apple or Google. For your name, email address, and other information provided through inquiries, we will respond to requests for disclosure, correction, deletion, suspension of use, and the like to the extent we hold such information.
You can make requests or changes regarding Game Center information through Apple's contact channels or the iOS settings, and regarding advertising information obtained by Google through Google's contact channels or the ad settings page (https://adssettings.google.com/).
17. Rights of Residents of the EEA, UK, and Similar Regions (GDPR, etc.)
If you reside in the European Economic Area (EEA), the UK, or Switzerland, you have the following rights regarding your personal data under applicable data protection laws.
- Right of access (to obtain a copy of the personal data being processed)
- Right to rectification (of inaccurate personal data)
- Right to erasure (the so-called "right to be forgotten")
- Right to restriction of processing
- Right to data portability
- Right to object to processing (including processing for direct marketing purposes)
- Right to withdraw consent at any time (without affecting the lawfulness of processing before withdrawal)
- Right to lodge a complaint with a supervisory authority, such as in your place of residence
Because we do not hold Game Data, you can exercise these rights with respect to Game Data yourself on your device. You can withdraw consent for advertising by the methods described in Section 7 (changing the iOS tracking setting or changing it on the consent management screen). You can exercise your rights regarding personal data managed by Apple or Google directly with each company. For other requests and questions, please contact us via the contact point in Section 22.
We do not engage in automated decision-making, including profiling, that produces legal effects on you.
18. Rights of Residents of California and Other U.S. States
If you reside in California and the CCPA/CPRA applies, you have the right to know the categories of personal information collected and the purposes of use, the right to request deletion, the right to request correction, the right to opt out of the "sale" or "sharing" (provision for cross-context behavioral advertising) of personal information, and the right not to be discriminated against for exercising these rights.
We do not sell users' personal information in exchange for money. Because the collection of advertising identifiers and the like by the ad SDK may constitute "sharing" under state law, the App provides a way to opt out of it by declining tracking via ATT (which you can change at any time in iOS Settings > Privacy & Security > Tracking).
The categories of personal information collected through the App are limited to device identifiers and internet activity information obtained by the ad SDK (corresponding to categories (A) identifiers and (F) internet or other electronic network activity information under California law), and we ourselves do not access them. During the 12-month disclosure period required by the CCPA, we have not collected, sold, or shared any other categories of personal information.
Users to whom the privacy laws of other states (such as Virginia's VCDPA and Colorado's CPA) apply may have similar rights under those laws. To exercise your rights, please contact us via the contact point in Section 22. We will not change the content of the Service in a discriminatory manner because you exercised your rights.
19. Security Measures
Game Data is stored on your device under iOS's standard security mechanisms (such as the Keychain and device encryption). In developing and maintaining the App, our basic policy is not to obtain or retain unnecessary information (data minimization) and to follow the OS's standard recommendations. However, we cannot accept responsibility for risks arising from factors beyond our control, such as loss or theft of your device or OS vulnerabilities. We recommend that you use your device's security features, such as setting a passcode.
For information sent through inquiries, Zoho has implemented appropriate technical and organizational security measures. However, no method of transmission over the internet can be guaranteed to be 100% secure.
20. Children's Privacy
The App is not directed at children.
Regardless of age, the App does not collect personal information such as names or email addresses from any user. Regardless of age, information entered in the contact form is used only to respond to inquiries as described in Section 15. If a child's personal information may have been provided to us and you would like it deleted, please have a parent or guardian contact us via the contact point in Section 22. We will delete it promptly.
Parents and guardians can manage their child's In-App Purchases and usage time with iOS features such as "Screen Time" and "Ask to Buy."
21. Changes to This Policy
We may change the content of this Policy due to amendments to laws, additions or changes to the App's features, or other circumstances. If we make important changes, we may announce them in the App or on the Website. The revised Policy takes effect when posted on the Website. For changes that require your consent under law, we will obtain your consent in the manner we specify.
22. Contact
For questions about this Policy, requests for disclosure, requests to exercise your rights, or other inquiries about the handling of personal information, please contact us via the contact form below. We may ask you for additional information, such as to verify your identity. We can respond only in Japanese and English. We will respond to requests to exercise statutory rights within the period required by applicable law. We will respond to other general inquiries depending on their content, but we do not promise to reply to every inquiry.
If you are not satisfied with our response to your inquiry about the handling of personal information, you may also consult the Personal Information Protection Commission of Japan or (if you reside in the EEA or UK) the data protection supervisory authority in your country.
- Personal Information Protection Commission (Japan): https://www.ppc.go.jp/en/
- List of EEA data protection supervisory authorities: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en
- UK Information Commissioner's Office (ICO): https://ico.org.uk/
Established: December 15, 2026