TR EN ◆ SPARK SAGA

Privacy Policy — SPARK SAGA

Effective Date: 13.08.2026 Last Updated: 01.08.2026

1. Introduction

DivuSpark LLC ("we", "us", "our") develops and operates SPARK SAGA (the "Game"), a single-player 2D skill game available on the web and mobile, in which you steer a spark, grow by collecting light, and complete levels without hitting obstacles. This Privacy Policy explains what personal data we collect when you play the Game, how we use it, who we share it with, and the rights you have.

SPARK SAGA currently has no chat, no messaging, no user-generated public content, no social features, no multiplayer, no leaderboards, and no public profiles. If any such features are introduced in a future version, this Policy will be updated to describe any additional processing of personal data, and any required consent will be obtained before that processing begins.

For users in Turkey: Please also refer to our KVKK Aydınlatma Metni (KVKK Information Notice), which provides the disclosures required under Turkish law.

For users in the European Union/EEA/UK: Additional rights are described in Section 8 (Rights of EU/EEA/UK Users).

2. Data Controller

For the purposes of the EU/UK GDPR:

We have not appointed a mandatory Data Protection Officer (DPO) but designate link@divuspark.com as the point of contact for all privacy matters.

3. Information We Collect

We only collect what we need to run the Game, save your progress, and keep the service secure.

3.1 Account Information (via Firebase Authentication)

When you create an account, you may sign in using:

In all cases, Firebase assigns your account a Firebase user ID (uid) that we use to associate your saved data with you.

3.2 Game Data (stored in Firebase Firestore)

To let your progress follow you across devices, we store in the cloud, linked to your account:

This data is held in a document that belongs to you alone, keyed to your Firebase user id (uid). Your personal best is private to you; it is not published on a public leaderboard or shared with other players.

Data that stays only on your device: your language, sound, and reduced-motion preferences, along with daily-reward timing and your Season progress, are kept in your browser's local storage and are not sent to the cloud.

3.3 Information Collected Automatically

3.4 Analytics Data — ONLY WITH YOUR EXPLICIT CONSENT

The Game includes anonymous usage statistics (Firebase Analytics), and these are off by default. Unless you turn on Settings → Anonymous usage statistics, no measurement data is collected at all — the analytics code is not even downloaded to your device.

If you do consent, we record only these events: starting a level, completing a level, game over (and its cause: darkness or collision), completing a map, and linking an account. Only numeric values accompany them (such as map and level number, or tail length).

Analytics data never includes your name, email address, location, or any free-text field. We do not build behavioural profiles, do not read advertising identifiers, and do not track you outside the Game. We do not share this data with advertising networks.

Legal basis: explicit consent under GDPR Art. 6(1)(a) and KVKK Art. 5(1).

You may withdraw consent at any time: collection stops the moment you switch the setting off (GDPR Art. 7(3)). If you decline or withdraw, the Game remains fully playable and no feature is restricted.

3.5 Cookies and Local Storage

The Game uses browser local storage for offline game saving and to remember your settings. No advertising or tracking cookies are used. See our Cookie & Tracking Policy for details.

4. How We Use Your Information

We use your information to:

Provide the Game:

Secure the Game:

Meet legal obligations:

4.1 Legal Bases (EU/EEA/UK Users)

Under the GDPR, we process personal data on the following legal bases:

Activity Legal Basis
Account creation and sign-in Contract (Article 6(1)(b))
Saving and syncing your game data Contract (Article 6(1)(b))
Security and abuse prevention Legitimate interest (Article 6(1)(f))
Legal compliance Legal obligation (Article 6(1)(c))

5. How We Share Your Information

We do not sell your personal data. We do not currently run or participate in advertising networks and do not share your data with advertisers. If advertising is introduced in a future version, we will update this Policy and, where legally required, obtain your consent before any advertising-related data processing begins. We share data only in the following cases.

5.1 With Our Service Provider (Google / Firebase)

The Game is built on Google Firebase. Google acts as our data processor for:

Service Purpose Data Involved
Firebase Authentication Sign-in and account management Email, password (hashed by Google), Google account identifier, uid
Google Sign-In Google-based sign-in Google account name and email
Cloud Firestore Cloud storage of your game data Game progress, inventory, score, powers, preferences, uid

Google processes this data under Google's data processing terms. We do not currently use any other third-party processors (no payment processors such as Stripe, no advertising networks, no data brokers). If we add such processors in a future version (for example, in connection with in-app purchases or advertising), this Policy will be updated and any required consent will be obtained.

5.2 With Authorities

We may disclose information where required by law (valid court order, subpoena, or legal process), or to protect our rights or the safety of users. Where legally permitted, we will notify you.

5.3 Business Transfers

In a merger, acquisition, or sale of assets, your information may be transferred to the successor entity, subject to this Privacy Policy.

5.4 Referral to the DivuSpark Platform (outbound link)

SPARK SAGA is a promotional channel for DivuSpark, the social platform DivuSpark LLC is building. Inside the Game you may be offered a link to divuspark.com to join the platform's waitlist.

What matters here:

6. Data Location and International Transfers

Your game data in Cloud Firestore is stored in the European Union (europe-west region). Keeping data in the EU supports GDPR and KVKK compliance.

Certain Google/Firebase infrastructure functions may involve processing outside the EU. Where that occurs, transfers are made under Google's data processing terms and appropriate safeguards, such as the European Commission's Standard Contractual Clauses (SCCs).

7. Data Retention

We retain your account and game data for as long as your account exists. When you delete your account (see Section 9 and our Account & Data Deletion policy), your Firestore user document and your Firebase authentication user are removed.

We may retain limited information longer where required by law or for security and fraud-prevention purposes, after which it is deleted or anonymized.

8. Rights of EU/EEA/UK Users (GDPR)

You have the following rights:

To exercise these rights, use in-Game Settings or contact link@divuspark.com.

9. Your Right to Delete

You can delete your account and all associated data at any time in Settings → Delete Account. This removes your Firestore user document and your Firebase authentication user. See our Account & Data Deletion policy for details.

10. Rights of Turkish Users (KVKK)

If you are in Turkey, please see our KVKK Aydınlatma Metni for detailed information on your rights under KVKK Article 11 (access, rectification, erasure, objection, and application procedures) and how to exercise them.

11. Security

We rely on Google Firebase's security infrastructure and apply reasonable technical and organizational measures, including:

No system is completely secure. If you suspect unauthorized access to your account, notify us at link@divuspark.com. Where required by law, we will notify affected users and authorities of a personal data breach (typically within 72 hours under GDPR).

12. Virtual Items and Payments

SPARK SAGA is currently entirely free. There are no real-money purchases, no subscriptions, and no in-app purchases; we do not collect payment, card, or billing data, and we use no payment service provider.

The Game includes virtual currencies and items that are earned by playing only:

Item How it is obtained Real-money purchase
✨ Glow Earned by playing None — not sold
☄️ Spark Score Earned by playing (progression score) None — not sold
💎 Energy Core Earned by playing, daily rewards, and the account gift None — not sold in this version
Cosmetic looks Bought with in-game currency None
Season Pass — free track Unlocked by playing None
Season Pass — premium track Locked in this version Not offered for sale

These virtual items have no real-world monetary value, cannot be exchanged for real money, and cannot be traded outside the Game. See our End User License Agreement for details.

Future changes: if in-app purchases (such as buying 💎 Energy Core or a premium Season Pass) are enabled in a later version, the transaction will run through Google Play Billing (or the relevant store infrastructure), payment data will be processed directly by the store, and card details will never reach us. Before any such change, this Policy will be updated, distance-selling terms, pre-contractual information, and a refund policy will be published, and any legally required disclosures and consents will be obtained.

13. Children's Privacy

SPARK SAGA is not directed to children under the applicable minimum age (13, or a higher age where local law requires). We do not knowingly collect personal data from children below that age. If we learn we have collected such data, we will delete it promptly. Parents or guardians who believe a child has provided data should contact link@divuspark.com. See our Child Safety Standards for more.

14. Changes to This Privacy Policy

We may update this Policy from time to time. In particular, if new features are added (for example, advertising, in-app purchases, multiplayer, leaderboards, or other social features), these may involve additional processing of personal data, which will be disclosed through an updated version of this Policy and, where legally required, subject to your consent before that processing begins. Material changes will be notified in-app before they take effect. Continued use after changes constitutes acceptance.

15. Contact Us

Privacy inquiries and data requests: link@divuspark.com General support: link@divuspark.com

DivuSpark LLC 30 N Gould St #65176, Sheridan, WY 82801, USA