Privacy Policy

Effective Date: [August 1, 2025]

This Privacy Policy ("Policy") explains how StarPlay Interactive Limited ("We", "Us", or "Our"; Company Registration Number: 78495457-000-07-25-4, Registered Address: Flat E19, 10/F, No.52 Hung To Road, Kwun Tong, Hong Kong (Pak Ben Centre)) collects, uses, stores, and protects your personal data when you use our mobile game [Crazy knitting] (the "Game") available on Google Play. We use the Google User Messaging Platform (UMP) SDK to obtain your consent for data processing as required by laws such as the General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA). Additionally, we use the AppsFlyer SDK for attribution purposes. By interacting with the UMP popup and using the Game, you acknowledge that you have read and understood this Policy.

1. Data Collection Through Google UMP Popup

When you first launch the Game, the Google UMP popup will appear to request your consent for the following data collection activities. Your consent choices will be recorded and respected by us:

Consent for Personalized Advertising: If you consent, we will collect your device information (such as Android ID, IDFA, device model, and operating system version) to display personalized advertisements through ad partners like AppLovin MAX. If you decline, we will only display non-personalized ads and will not collect data for ad personalization.

Consent for Non-Essential Data Processing: We may collect non-essential data (such as game usage data including playtime and level attempts) for improving game performance and user experience only if you provide consent. Essential data (such as crash logs for fixing technical issues) will be collected without additional consent as it is necessary for the Game's basic functionality.

Consent for AppsFlyer Attribution Data Collection: If you consent to non-essential data processing, we will use the AppsFlyer SDK to collect certain device and install-related data for attribution purposes. This includes device identifiers (such as Android ID, IDFA, OAID), device model, operating system version, installation timestamp, and referral source information. This data is collected solely to analyze the installation source of the Game and measure the effectiveness of our marketing campaigns. No personal identifiers (such as name, email address) are collected by the AppsFlyer SDK.

2. Purpose of Data Processing

The data we collect with your consent through the UMP popup is used for the following purposes:

 

Data Type

Purpose of Processing

Legal Basis

Device Information (for ads)

Displaying personalized/non-personalized ads, measuring ad performance

User Consent (obtained via UMP popup)

Game Usage Data

Analyzing user behavior to optimize game features, fix bugs, and enhance user experience

User Consent (obtained via UMP popup)

Crash Logs

Identifying and resolving technical issues to ensure the Game runs smoothly

Legitimate Interests (not harming user rights and interests)

AppsFlyer Attribution Data

Analyzing the Game's installation sources and measuring the effectiveness of marketing campaigns

User Consent (obtained via UMP popup)

3. Data Sharing

We only share your data with trusted third parties as necessary, and all such parties have signed data processing agreements to ensure compliance with applicable privacy laws:

Google UMP SDK Provider: Google may receive your consent status to manage the UMP popup and ensure compliance with advertising regulations.

Ad Partners (e.g., AppLovin MAX): If you consent to personalized ads, we share your device information with ad partners to deliver relevant ads. These partners do not have the right to use your data for other purposes.

Analytics Providers (if applicable): We may share game usage data with analytics providers (e.g., Firebase) to improve the Game, only if you provide consent.

AppsFlyer SDK Provider: If you consent to non-essential data processing, we share the attribution data collected by the AppsFlyer SDK with AppsFlyer Inc. ("AppsFlyer") to enable the attribution and marketing effect measurement services. AppsFlyer will process this data in accordance with its own privacy policy (available at https://www.appsflyer.com/privacy-policy/) and the terms of the data processing agreement between us and AppsFlyer. AppsFlyer does not have the right to use your data for any purposes other than providing the agreed-upon attribution services, and will not share your data with third parties without our authorization, except as required by law.

4. Your Data Rights

You have the following rights regarding your personal data, and you can exercise them at any time:

Right to Access: You can request a copy of your personal data we hold (such as device information, consent records, and AppsFlyer attribution data) by sending an email to starplayhk020@gmail.com with the subject "Data Access Request". We will respond within 1 month.

Right to Withdraw Consent: You can change your consent choices at any time by going to "Settings > Privacy Center" within the Game. Withdrawing consent for non-essential data processing will stop further collection and processing of attribution data by the AppsFlyer SDK. Withdrawing consent will not affect the lawfulness of data processing based on your previous consent.

Right to Erasure ("Right to be Forgotten"): You can request to delete your personal data (including AppsFlyer attribution data) by sending an email to starplayhk020@gmail.com or by canceling your Game account in "Settings > Account Security". We will delete your data within 30 days of receiving the request, and will instruct AppsFlyer to delete the corresponding data in accordance with the data processing agreement, except as required by law to retain it.

Right to Correct: If your personal data is inaccurate or incomplete, you can request correction by contacting us via the above email.

5. Data Security and Retention

We take appropriate technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction, including using AES-256 encryption for data storage and restricting employee access to data. AppsFlyer also implements industry-standard security measures to protect the attribution data it processes.

Data retention periods are as follows:

• Consent records are retained for 2 years;

• Device information for advertising is retained for 30 days after you withdraw consent;

• Game usage data is retained for 6 months;

• Crash logs are retained for 90 days and then anonymized (personal identifiers removed);

• AppsFlyer attribution data is retained for 12 months from the date of collection, after which it will be anonymized (personal identifiers removed) or deleted in accordance with the data processing agreement with AppsFlyer.

6. Policy Updates

We may update this Policy from time to time. When we do, we will revise the "Effective Date" at the top and notify you via an in-game popup or email. Your continued use of the Game after the update constitutes your acceptance of the revised Policy.

7. Contact Us

If you have any questions, concerns, or requests regarding this Policy or your personal data (including the data processed by the AppsFlyer SDK), please contact us:

• Email: starplayhk020@gmail.com

• In-Game Support: "Settings > Help & Support"

• Registered Address: Flat E19, 10/F, No.52 Hung To Road, Kwun Tong, Hong Kong (Pak Ben Centre)