This Privacy Policy ("Privacy Policy") has been prepared by MIDAS GAMES KFT, Registration number: 01-09-432808, Registered Seat: 1061 Budapest, Anker köz 2-4, Hungarian VAT Number: 32600207-2-42, EU VAT Number: HU32600207 (collectively, "Midas Games," "we," "us," or "our") to explain how we process the personal data of players and users of Spark Win Cash and any other same-business-model mobile application, game, or product owned, operated, published, or made available by Midas Games that references or incorporates this Privacy Policy, including any such App introduced after this Privacy Policy is posted (collectively, the "Apps" and each an "App"). All personal data shared with Midas Games will be processed in accordance with applicable law, in connection with our activities and service purposes, and in a measured manner. Before you access or use an App or the Services, please read and understand how Midas Games collects, stores, uses, and shares your personal information as described in this Privacy Policy.
The concepts of personal data and data processing used in this Privacy Policy are used in accordance with the definitions made in the GDPR. The concept of “personal data” stipulated in the GDPR refers to any information relating to an identified or identifiable natural person; the concept of “processing of personal data” refers to all kinds of operations performed on personal data such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automated or non-automated means provided that it is part of any data recording system.
For purposes of this Privacy Policy, "Apps" has the meaning given in the Introduction. The "applicable App" means the App through which you access or use the Services or to which particular personal data relates. "Services" means the Apps, the sparkwincash.com website, and any games, tournaments, Cash Games, features, App Accounts, payment services, promotions, and other products or services provided by Midas Games through or in connection with the Apps. An "App Account" means the account a user creates or maintains for a particular App.
Pursuant to the GDPR, personal data belonging to the data subject shall be processed by the data controller Midas Games for the following purposes in accordance with the law and good faith, accurate and, where necessary, up-to-date, for specific, explicit and legitimate purposes, in connection with the purpose for which they are processed, limited and measured, in accordance with the rules of retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
Midas Games may collect and process your Identity Information (Name, Surname, Username, Date of Birth), Contact Information (E-Mail Address, Mobile Phone Number), Location Information (Precise and Imprecise Location Information, Country Information, Zip Code Information), IP Information (IP Address, VPN Usage Status, Internet Provider Information), User Data (User IDs, Publisher User IDs, pseudonymized or hashed advertising identifiers, email domain information, advertising identifiers such as IDFA where permitted, ad interaction data, User Tracking Data, Game Playing Data, Time Spent in the Application Data, Device Accessed Information, General Tracking Data, App-specific wallet and App Account movements, applicable-App identifiers, Application History), Security Data (Suspicious Activity Detection Data, Data Showing How Many Different Cards You Logged In With), PayPal Verification Data (PayPal Verification Data), and Correspondence Data (Correspondence with Midas). We process these categories only as relevant to the purposes and lawful bases described in Section 4 and subject to the sharing conditions in Section 5.
For advertising purposes, we may provide the email address and mobile phone number you have supplied to us, together with a Publisher User ID assigned by Midas Games, to the AppLovin MAX SDK through its additional user data feature. When provided through this feature, email addresses and phone numbers are converted on your device into SHA-256 hashes before transmission to AppLovin. The email domain, such as the part after the @ symbol, is transmitted in readable form. The Publisher User ID is transmitted as supplied by us; we use an internal identifier that does not itself contain an email address, phone number, or another personal or third-party identifier. Hashing and pseudonymization do not make these identifiers anonymous, because they may still be matched to a person or device. This description concerns transmission through this advertising feature and does not change our processing of contact information for account and other purposes described in this Privacy Policy.
Midas Games reserves the right to request additional information and/or documents in order to prevent all kinds of forgery and fraud due to its business model.
App Accounts and the operational records for wallets, balances, offers, privileges, Memberships, rewards, Virtual Items, and benefits are maintained separately for each App. Those operational amounts and entitlements do not transfer, combine, or carry over from one App to another unless Midas Games expressly states otherwise. Midas Games may nevertheless process the personal data associated with those records as described in this Privacy Policy.
We may collect, generate, and process gameplay replay data relating to your participation in games and competitions through the Services. Gameplay replay data may include the identity of the applicable App, gameplay inputs, game state information, timing information, scoring events, gameplay events, and other technical data necessary to reconstruct and review gameplay. Gameplay replay data is not intended to capture audio or video recordings of players.
We process gameplay replay data for the following purposes:
Gameplay replay data is used solely for Midas Games' internal review, operational, security, and compliance purposes in connection with the applicable App and the Services. Replay data is not publicly available and is not shared with other players except where required by applicable law.
Gameplay replay data is generally retained for up to 90 days from the date of collection. Where replay data is relevant to an ongoing investigation, enforcement action, legal claim, regulatory requirement, or dispute, we may retain such data for a longer period until the relevant matter has been resolved, after which it will be securely deleted or anonymized.
Midas Games processes your personal data for the purposes listed below:
We use your information to operate, maintain, and provide the features of the Services. Each processing activity must have an appropriate lawful basis; listing a purpose above does not authorize every category of personal data to be used for that purpose. Where the GDPR applies, we rely on the following bases according to the activity:
We may use your contact information to send marketing messages about our products and Services or to request feedback. We obtain consent where required by applicable electronic marketing law; where that law permits marketing without prior consent, we rely on our legitimate interest in promoting our Services, subject to your rights. You may stop marketing messages through the unsubscribe link in the message or by contacting us. Unsubscribing from marketing messages and changing advertising data-sharing preferences are separate choices.
Where we rely on consent, we obtain it before the relevant processing, separately from acceptance of our Terms of Use. You may refuse or withdraw consent at any time through the consent controls made available to you or by contacting support@sparkwincash.com. Withdrawal must be as easy as giving consent and does not affect the lawfulness of processing before withdrawal. Declining optional advertising consent does not prevent access to the core Services. You may still see advertisements that do not rely on the processing you have declined.
You may object, on grounds relating to your particular situation, to processing based on legitimate interests. You may object to processing for direct marketing, including related profiling, at any time; we will stop processing your data for those purposes. The advertising choices described in Section 5 also apply.
If we intend to use your personal data for a new purpose, we will provide the information required by applicable law before that further processing and obtain any consent required for it. Updating this Privacy Policy or continuing to use the Services does not, by itself, constitute consent to new advertising processing.
Midas Games shares personal data only for specified purposes, on an appropriate lawful basis as described in Section 4, and in accordance with applicable law. Where consent is required, we obtain it before sharing. We respect applicable consent withdrawals, objections, and opt-outs. A lawful basis for processing does not replace any safeguards required for an international transfer.
Your Personal Data may be shared with the following organizations, to the extent relevant to their services:
We work with AppLovin to serve advertisements in the Apps. Subject to the lawful bases and choices described in Sections 4 and 5, we may share the hashed email address, hashed phone number, readable email domain, and Publisher User ID described in Section 3. AppLovin's SDK may also collect device, application, advertising interaction, and identifier data, including IP addresses and, where permitted, advertising identifiers. AppLovin may match this information with data received from advertisers or other partners to select and personalize ads, measure their effectiveness, support bidding and monetization, and develop or improve its advertising services, including AI-powered advertising technology. AppLovin may share information with its affiliates, service providers, and advertising or measurement partners for the purposes described in its privacy policy. This does not mean that every MAX-mediated network receives every additional identifier.
Midas Games and AppLovin act as independent controllers for the personal data shared under AppLovin's Platform Data Processing Agreement. AppLovin determines its own processing purposes and means within the applicable agreement and law. For information about AppLovin's collection, use, sharing, retention, and privacy choices, please see the AppLovin Privacy Policy at https://legal.applovin.com/privacy/.
The additional user data feature is limited to the identifiers described above. We do not include gameplay replay data, wallet or payment account records, identity verification documents, precise location, passwords, or correspondence contents in these fields.
On Apple platforms where App Tracking Transparency applies, we obtain your permission through Apple's tracking prompt before using or sharing identifiers for tracking across other companies' apps or websites. We do not use hashed contact information or a Publisher User ID to bypass a refusal or absence of that permission. Any consent required by privacy law is obtained in addition to the applicable Apple permission. You can manage the App's tracking permission in your device settings.
Depending on applicable U.S. state privacy law, disclosure of identifiers and advertising activity to advertising partners may constitute a sale of personal information, sharing for cross-context behavioral advertising, or processing for targeted advertising, even where we receive no direct monetary payment for the data. Where you have these rights, you may opt out of the relevant sale, sharing, or targeted advertising. Where required, we provide an accessible “Do Not Sell or Share My Personal Information” or equivalent privacy choices control in the applicable App and on the relevant website. You may also contact support@sparkwincash.com. We honor applicable opt-out preference signals, including Global Privacy Control where required, and communicate relevant privacy choices to advertising partners. After an applicable opt-out or consent withdrawal, we stop sharing the additional identifiers for the affected advertising purposes and do not use other identifiers to circumvent your choice.
We may share personal information with providers that perform services for us, including postal, email and chat services, payments, identity verification, fraud prevention, web hosting, and analytics. Integrated software may collect usage, installation, download, device, and advertising data for those services, subject to required permissions. Where ad measurement technology is used, third-party measurement partners, including those participating in the IAB Open Measurement Working Group, may process data to measure ads and provide related services. Providers acting on our behalf process personal data under appropriate contractual restrictions; advertising partners acting as independent controllers process it under their own disclosed responsibilities and applicable law.
We may share your information with companies owned by, controlling, or under common ownership with Midas Games where necessary for the purposes described in this Privacy Policy and on the relevant lawful basis. Separate App Accounts, balances, and benefits remain subject to the provisions in Section 3.
In connection with a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or part of our business, we may disclose relevant personal information to prospective or actual counterparties and their advisers, subject to applicable law and appropriate confidentiality and data protection safeguards.
We may disclose relevant personal information to law enforcement, public authorities, or other recipients where legally required or otherwise lawfully necessary to respond to valid legal requests, establish or defend legal claims, protect the security and integrity of the Services, or protect users or others from fraud, harm, or unlawful activity.
Personal data may be transferred to or accessed in countries outside the European Economic Area, including the United States in connection with AppLovin. Where the GDPR applies, we use an applicable adequacy decision or appropriate safeguards, such as European Commission approved Standard Contractual Clauses, together with any supplementary measures required for the transfer. We assess the applicable protection and use technical and organizational safeguards appropriate to the risks. For more information about a transfer and the safeguards that apply, or to request a copy of relevant safeguards, please contact support@sparkwincash.com.
As a data subject, you have the following rights under the GDPR:
You can exercise these rights by sending us a request using the contact information below. We will respond to your request in accordance with applicable law. Please note that we may need to verify your identity before responding to such requests. We will also provide the requested information without undue delay and in any event within one month of receipt of your request.
Midas Games has implemented appropriate technical and organizational measures to protect personal data against unauthorized access, unlawful processing, accidental loss, destruction or damage. However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of your personal data. We will notify you promptly in the event of a data breach where we are legally required to do so.
Midas Games reserves the right to modify this Privacy Policy at any time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. We will also provide you with notice if we make any significant changes to this Privacy Policy that may impact your rights or your use of the Services.
If you have any questions about this Privacy Policy, please contact us: