Privacy Policy — Sparkle5

Sparkle5, LLC ("Sparkle5", "we", "us", "our"), 30 N. Gould Street #10391, Sheridan, WY 82801, USA, operates the website sparkle5.com and provides platform hosting and game monetisation services.

This Privacy Policy explains what personal data we collect about visitors to this website and registered clients, how we use it, and your rights. It does not cover the personal data of end users on platforms operated on behalf of our clients — those platforms have their own privacy policies controlled by the respective client (data controller).

1. Data Controller

For the purposes of applicable data protection law, Sparkle5, LLC is the data controller for personal data collected through sparkle5.com and the client portal.

Contact: support@sparkle5.com

2. Data We Collect

2.1 Website Visitors

Server log data — IP address, browser type, pages visited, timestamps. Retained for 30 days for security purposes.
Contact form submissions (Game Monetisation) — name, email, company, game details, and any information you voluntarily provide.

2.2 Clients (Registered Portal Users)

Account data — email address, company name, contact name, phone number (optional).
Billing data — payment method details are held solely by our payment processor. We store only a customer reference ID and invoice metadata.
Usage data — portal login timestamps, subscription status, correspondence.

3. Legal Basis for Processing (GDPR)

Contract performance (Art. 6(1)(b) GDPR) — processing your account and billing data to fulfil our service contract with you.
Legitimate interests (Art. 6(1)(f) GDPR) — server security logging, fraud prevention, and service improvement.
Consent (Art. 6(1)(a) GDPR) — marketing communications, if you opt in.

For clients located outside the EEA (including US-based clients), processing is based on contractual necessity and our legitimate business interests.

4. How We Use Your Data

To create and manage your client account and subscription;
To process payments and send invoices;
To provision and maintain your hosting environment;
To respond to support requests and enquiries;
To send service notices, renewal reminders, and updates;
To detect and prevent fraud and security incidents;
To comply with legal obligations.

5. Sharing Your Data

We share personal data only as necessary:

Payment processor — secure payment processing. Your payment data is subject to their privacy policy.
Infrastructure provider — server hosting. Data is stored in the region you select at checkout (EU, US, or SG).
Email service providers — transactional email delivery (e.g., welcome emails, invoices).
Legal authorities — when required by law, court order, or to protect our legal rights.

We do not sell your personal data to third parties.

6. International Transfers

Sparkle5 is based in the United States. If you are located in the EEA, UK, or Switzerland, your data may be transferred to and processed in the US. We rely on Standard Contractual Clauses (SCCs) and, where applicable, the EU–US Data Privacy Framework, to provide appropriate safeguards.

7. Retention

Active client accounts — retained for the duration of the contract plus 6 years for tax/legal compliance purposes.
Game monetisation leads — retained for 2 years from submission, unless a contract is concluded.
Server logs — 30 days.

8. Your Rights

Depending on your location, you may have the following rights:

Access — request a copy of the personal data we hold about you.
Rectification — ask us to correct inaccurate data.
Erasure — request deletion of your data where we have no overriding legal basis to retain it.
Restriction — ask us to limit processing in certain circumstances.
Portability — receive your data in a structured, machine-readable format.
Object — object to processing based on legitimate interests.
Withdraw consent — where processing is based on consent, withdraw it at any time without affecting prior processing.

To exercise your rights, email support@sparkle5.com. We will respond within 30 days. EEA residents have the right to lodge a complaint with their local supervisory authority.

California residents: under CCPA you have the right to know, delete, and opt-out of sale of personal information. We do not sell personal information.

9. Security

We implement appropriate technical and organisational measures to protect your personal data, including encrypted connections (HTTPS), access controls, and regular security reviews. No method of transmission over the internet is 100% secure; we cannot guarantee absolute security.

10. Cookies

This website uses strictly necessary cookies for session management (login state) and security. We do not use advertising or tracking cookies. We do not use Google Analytics or other third-party tracking scripts.

11. Children

Our services are directed at businesses and are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors.

12. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated by email to registered clients. The "last updated" date at the top of this page indicates the most recent revision.

13. Contact

Privacy enquiries: support@sparkle5.com
Sparkle5, LLC · 30 N. Gould Street #10391 · Sheridan, WY 82801 · USA