This Privacy Policy is formulated by PetalSpark Studio Limited (hereinafter referred to as "the Company", "we", "us" or "our"), a company registered in Hong Kong, in compliance with the Personal Data (Privacy) Ordinance (Chapter 486) of the Hong Kong Special Administrative Region and relevant international privacy norms. It applies to all users (hereinafter referred to as "User", "you" or "your") who access, download, install and use our mobile applications, official websites and all affiliated services (collectively referred to as the "Service").

We fully respect and protect the privacy rights and personal information security of all users, including minors. This Policy elaborates on our rules for collecting, using, storing, disclosing and protecting user information. Please read this Policy carefully before using our Service. Your use of the Service shall be deemed as your full acceptance of all terms of this Policy.

1.1 When you download, install the Company’s applications on your mobile device, access, connect to, browse or use any functions of the Service, you voluntarily agree to all terms stipulated in this Privacy Policy and authorize us to collect, process and use your relevant information in accordance with this Policy.
1.2 If you (or your legal guardian, as applicable) do not agree to any clause of this Policy, you shall not install, access or use our applications and Service. Please immediately uninstall all our applications and related files from your device.
1.3 If you are under 18 years of age, you represent and warrant that your legal guardian has fully reviewed, understood and agreed to this Privacy Policy before you use our Service.

2. Privacy Provisions for Minors (Children under 13 Years Old)

2.1 This special minor privacy clause is formulated for the legal guardians of children under 13 years old who use our applications oriented to minors. We strictly abide by global minor privacy protection regulations and the requirements of Hong Kong’s personal data protection laws.
2.2 We will not knowingly collect any personal identifiable information from users under 13 years old. We explicitly prohibit users under 13 from actively providing any personal information to us.
2.3 If you are the legal guardian of a child under 13 and find that your child has accidentally submitted personal information to us through our Service, please send an email to our official mailbox: contact@petalsparkstudio.com. We will verify the information and completely delete the relevant data from our servers as soon as possible.
2.4 The Company does not directly collect or store user information on its own servers. Part of the information may be collected and stored by our authorized third-party service providers (such as advertising platforms, data analysis services, etc., hereinafter referred to as "Third Parties"). You can view the complete list of cooperating Third Parties via the page: third_parties.html. For questions about the privacy rules of Third Parties, please contact us via the above email, and we will forward your inquiry to the corresponding Third Party and follow up to feed back the reply within a reasonable period.

3. Offline Use of the Service

3.1 Our applications support partial functional use in an offline state (without network connection and without enabling GPS positioning).
3.2 When you use the Service offline, neither the Company nor our cooperating Third Parties will collect any information related to you, your use of the Service, or the use of the Service by minors under your guardianship.

4. Online Data Collection and Usage Rules

When you use the Service with a network connection, we and our authorized Third Parties may collect three categories of information. All data collection complies with the principles of legality, necessity and non-excessiveness under Hong Kong’s Personal Data (Privacy) Ordinance.

4.1 Non-Personal Anonymous Information

Third Parties may collect non-identifiable anonymous information (hereinafter referred to as "Non-Personal Information"). Such information cannot be associated with any specific individual user identity. The collected content includes but is not limited to:

• Operating system type (Android, iOS, etc.)

• Browser type (Explorer, Firefox, Chrome, Safari, etc.)

• Device screen resolution

• System language, mobile device model

• General geographic location (we will never collect specific street names, district names or city names)

• List of other applications installed on the device

Collection Purpose: This Non-Personal Information is only used to analyze the operation status of the applications, optimize product functions, improve operation performance and upgrade user experience. We will not use such information for other unauthorized purposes.

4.2 Persistent Device Identifier

4.1 Our cooperating Third Parties may collect persistent device identifiers of users, such as IP addresses, unique device codes, etc. (hereinafter referred to as "Device Identifier").
4.2 Except for the Device Identifier collected for the normal operation of the applications, the Company strictly prohibits Third Parties from collecting any other sensitive or personally identifiable information from users (especially minors). We will not associate the Device Identifier with any other personal identifiable information through any channel or third-party service.
4.3 Collection Purpose: The Device Identifier is only used for the internal normal operation of the applications, including delivering advertisements that comply with local privacy laws. For users in the United States, we only provide contextual advertisements and will not push advertisements based on user behavioral portraits.

4.3 Information Collected via "Contact Us" / "Support" Functions

4.1 If you (or a minor user) send consultation, feedback or questions to us through the built-in "Contact Us" or "Support" function of the application, we will use your submitted email address to reply to your message.
4.2 After completing the reply (or deciding not to reply at our sole discretion), we will immediately delete the user’s email address and related message content from our servers, and will not retain such information for a long time.

4.4 Data Collection Methods

The above Non-Personal Information and Device Identifier are collected by Third Parties through the embedded SDK in our applications. Meanwhile, the information may be locally stored on your device through common industry technologies such as Cookies and local storage (see Clause 7 for details).

5. Sharing of User Information with Third Parties

We will not actively sell, rent or trade your personal information to any third party. We may only share relevant user information with third parties under the following legitimate circumstances:
(a) To comply with applicable laws, regulations, judicial procedures, subpoenas or official requests from government departments;
(b) To enforce this Privacy Policy and the Application Terms of Service, including investigating potential violations of relevant agreements;
(c) To detect, prevent and resolve fraud behaviors, network security risks and technical failures;
(d) To respond to claims that the content published by the Service infringes the legitimate rights and interests of third parties;
(e) To protect the legitimate rights, property and personal safety of the Company, all users and the public;
(f) In the event of a change in the Company’s control right (including merger, acquisition, full or substantial asset transfer), the successor entity may obtain the user information held by the Company;
(g) With your explicit consent, to provide the specific services you have requested;
(h) To allow our partners and affiliated institutions to deliver commercial advertisements to you in compliance with laws.

6. Advertisement Service Description

6.1 Our Service carries advertisements provided by qualified third-party advertisers. We will carefully select advertisers to ensure that their products and services are basically in line with user needs.
6.2 If you click on the advertisements in the applications, the corresponding advertisers may use Cookies and other tracking technologies to collect user information. We recommend that you carefully read the terms of service and privacy policy of the corresponding advertiser before interacting with the advertisement content. The interaction behavior between you and the advertiser shall be governed by the advertiser’s privacy policy, not this Policy.

7. Cookies and Local Storage Technology

7.1 When you access and use our Service, we will use mainstream industry technologies such as Cookies, Flash and local storage to store partial information on your device, so as to realize automatic configuration of partial functions and optimize your use experience.
7.2 The Cookies used by our official Service are session-based Cookies, which only contain session keys and do not carry any of your personal information. Such Cookies will be automatically deleted after you exit the Service session.
7.3 You have the right to disable or clear local storage functions: you can set the browser to block Cookies, clear historical Cookies, or set Flash permissions according to the official guidelines of the technology provider. Please note that disabling or clearing Cookies and local storage may cause partial functions of the Service to be abnormal or unavailable.
7.4 Our Service may also use third-party Cookies (such as Google Authentication). Such Cookies are deployed and managed by independent third parties. Our Service only reads but does not modify third-party Cookies. Third-party Cookies usually only store Non-Personal Information such as browsing pages and browsing duration.

8. Information Security Protection

8.1 We attach great importance to user information security and adopt industry-standard encryption technologies, network protection measures and internal management systems to prevent unauthorized access, disclosure, tampering and loss of user information, and strictly abide by the data security requirements of Hong Kong’s Personal Data (Privacy) Ordinance.
8.2 Our Service involves third-party software and services, which are mainly used for: collecting and processing Non-Personal Information, delivering third-party advertisements, and realizing the built-in message communication function of the applications. The main third-party service we cooperate with includes Google AdMob. You can view its privacy policy via: https://www.google.com/policies/privacy/
8.3 Although we have taken comprehensive security protection measures, due to the limitations of the network environment, we cannot absolutely guarantee that user information will never be illegally accessed.

9. Social Platform and Game Center Function Access

9.1 Our applications may support the interconnection function with third-party game platforms and social networks (hereinafter referred to as "Game Center Function"), including Apple Game Center, Google Play Games, Amazon GameCircle, etc. These platforms are independently operated by third parties and have no affiliation with the Company.
9.2 If you enable the interconnection between our applications and the above platforms, your use of the Game Center Function shall be subject to the terms of service and privacy policy of the corresponding third-party platform. Please read the relevant rules carefully in advance:

• Apple Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/us/terms.html

• Google Play Games: https://play.google.com/intl/en-US_us/about/play-terms/index.html

• Amazon Game Circle: https://www.amazon.com/gp/help/customer/display.html?nodeId=201371550
9.3 If you disagree with the rules of the above third-party platforms, please do not enable the interconnection function. Disabling the function may cause you to fail to use partial social interaction functions of the applications.
9.4 After enabling the interconnection, we may synchronize your application data (including game scores, progress, user name, social avatar, etc.) with your platform contacts to realize social interaction functions.

10. Links to Third-Party Websites

10.1 The applications may contain links to third-party websites or services (through advertisements or other entries). These links are only for your convenience to use.
10.2 All linked third-party websites and services are not under the control of PetalSpark Studio Limited. We are not responsible for the normal access of external links, nor do we endorse the content, products, services and other information of third-party websites. We reserve the right to delete any external link at any time.
10.3 You acknowledge and agree that the Company shall not be liable for any losses or damages caused by your access and use of third-party linked websites. Before using third-party websites, please carefully check their terms of service and privacy policy.

11. Revision of This Privacy Policy

11.1 The Company reserves the right to revise the content of this Privacy Policy in accordance with business adjustments, service upgrades and legal updates. Please check this page regularly for the latest version.
11.2 If there are major changes to the Policy content, we will post obvious update notices on the Service page in a timely manner.
11.3 The revised Privacy Policy shall take effect from the marked "Last Revised" date. Your continued use of the Service after the update takes effect shall be deemed as your acceptance of the revised Policy.

12. User Rights and Contact Information

12.1 In accordance with the Hong Kong Personal Data (Privacy) Ordinance, you have the right to inquire, access, correct and request deletion of your relevant information stored by us.
12.2 If you have any questions, suggestions, complaints or information processing requests regarding this Privacy Policy, please contact us via the dedicated email: contact@petalsparkstudio.com. We will reply and handle your legitimate demands within a reasonable time.

PetalSpark Studio Limited
Last Revised: Jun 10th, 2026