Solder Spark STUDIOS

Solder Spark Studios

Privacy Policy

Effective Date: September 18, 2026

This Privacy Policy explains how Solder Spark Studios Inc. (“Solder Spark Studios,” “we,” “us,” or “our”), a California corporation, collects, uses, and shares personal data, and the choices you have. It applies to our games, our websites and store, and our subscription software products, Spark Studio and Spark Memory (together, the “Service”).

Two parts of the Service work differently, and we call them out where it matters:

  • Games and websites are consumer services that are supported in part by advertising.
  • Spark Studio and Spark Memory are paid business products. We do not advertise in them and we do not use your workspace or memory content for advertising. See the dedicated section on our subscription products below.

1. INFORMATION WE COLLECT

Information you provide.

  • Contact details such as name and email address;
  • Account information, including a player name or tag, or a Spark account identifier and password;
  • Profile information, such as a profile photo or display name;
  • Content and messages you submit, such as chats, comments, support tickets, and, in Spark Studio and Spark Memory, the documents, messages, and project data in your workspace or memory, including content ingested from systems you choose to connect;
  • Information you provide in surveys, promotions, and events;
  • Payment details, which are collected and processed by our third-party payment processor; we do not store full card numbers.

Information we collect automatically.

  • Account and gameplay or product-usage data, including an internal account identifier;
  • Device and connection data, such as IP address, device and advertising identifiers, device type and operating system, browser type and language, and mobile carrier or internet service provider;
  • Approximate location derived from IP address;
  • Data collected with cookies and similar technologies (see “Cookies” below).

Information from partners.

We receive data from analytics, advertising, anti-fraud, and platform partners, and from social or login providers you choose to connect, to supplement the information above and to operate and secure the Service.

2. HOW WE USE INFORMATION

  • To provide, operate, secure, and improve the Service;
  • To create and manage accounts and process payments;
  • To provide customer and player support and send service-related messages;
  • To personalize and develop the Service;
  • To deliver and measure advertising in our games and websites (not in Spark Studio or Spark Memory);
  • To prevent fraud and abuse and to keep the Service safe and fair;
  • To comply with law and enforce our agreements.

3. LEGAL BASES (EEA AND UK)

Where the GDPR or UK GDPR applies, we rely on the following legal bases: performance of a contract with you; our legitimate interests in operating, improving, securing, and marketing the Service; your consent (which you may withdraw at any time), including for certain advertising and cookies; and compliance with legal obligations.

4. HOW WE SHARE INFORMATION

  • Service providers who process data on our behalf to provide the Service, such as cloud hosting and infrastructure, payment processing, email delivery, and analytics.
  • Advertising and analytics partners. For our games and websites, we share certain data (such as identifiers, device data, and activity) with advertising and analytics partners, including Google, Meta, CrazyGames, and other ad networks, to deliver and measure interest-based advertising. Under California and certain other state laws, this sharing may be considered a “sale” or “sharing” of personal information. See “Your Choices” and “Do Not Sell or Share” below.
  • Platforms that our games run on or that process payments, for verification, anti-fraud, and operation.
  • Legal and safety: to comply with law, respond to lawful requests, and protect the rights, property, or safety of Solder Spark Studios, our users, or others.
  • Business transfers: in connection with a merger, acquisition, financing, or sale of assets.

We do not sell or share the content of your Spark Studio workspace or your Spark Memory memory, and we do not use it for advertising.

5. ADVERTISING AND YOUR CHOICES

Our games and websites show advertising, including interest-based advertising delivered by our partners. You have choices:

  • Opt out of interest-based advertising from participating companies through the Digital Advertising Alliance (optout.aboutads.info) and the Network Advertising Initiative (optout.networkadvertising.org);
  • Adjust your choices in your Google and Meta account settings;
  • Use your mobile device settings (for example, “Limit Ad Tracking” or resetting your advertising identifier);
  • Exercise the California opt-out described in “Do Not Sell or Share” below.

6. DO NOT SELL OR SHARE (CALIFORNIA AND OTHER STATES)

If you are a California resident (or a resident of another U.S. state with similar rights), you have the right to opt out of the “sale” or “sharing” of your personal information for cross-context behavioral advertising. To exercise this right, use our Do Not Sell or Share My Personal Information page, also linked in our website footer. This opt-out applies to the browser or device you use to submit it. We do not knowingly sell or share the personal information of anyone under 16.

7. COOKIES AND SIMILAR TECHNOLOGIES

We and our partners use cookies and similar technologies to operate and personalize the Service, remember your preferences, analyze use, deliver and measure advertising, and prevent fraud. You can control cookies through your browser settings, though some features may not function without them. Where required by law, we request consent for non-essential cookies. Our advertising partners may operate under their own privacy policies.

8. DATA RETENTION

We retain personal data for as long as needed to provide the Service and for legitimate business or legal purposes. We may periodically de-identify inactive game accounts and unnecessary data. Spark Studio and Spark Memory retention is described in the section on our subscription products below. If you ask us to delete your data, we may retain limited data as necessary to meet legal obligations, resolve disputes, and enforce our agreements.

9. SECURITY

We maintain administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, loss, misuse, or alteration. No method of transmission or storage is completely secure.

10. INTERNATIONAL DATA TRANSFERS

We operate globally, and your data may be transferred to and processed in countries other than your own. Where required, we use appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, to protect your data.

11. YOUR PRIVACY RIGHTS

Depending on where you live, you may have the right to access, correct, delete, or receive a portable copy of your personal data; to opt out of sale, sharing, or targeted advertising; to limit the use of sensitive personal information; and to withdraw consent. You also have the right not to receive discriminatory treatment for exercising these rights.

To exercise your rights, contact us using the details under “Contact Us,” or use the support features in the relevant game or product. We will verify your identity before acting on certain requests, and you may use an authorized agent where the law allows. If we decline a request, you may appeal by replying to our response. You may also contact your local data protection authority.

12. CHILDREN

Our games and websites are not directed to children under 13 (or a higher age where required by local law), and we do not knowingly collect personal data from them, except as permitted by law. Where a game may appeal to younger players, we take steps to limit features and data collection for users who indicate they are under the applicable age. Spark Studio and Spark Memory are business tools intended for adults 18 and over. If you believe a child has provided us personal data, contact us and we will take appropriate action.

13. SPARK STUDIO AND SPARK MEMORY (SUBSCRIPTION SERVICES)

This section applies to our paid business products: Spark Studio, our workspace product for game studios, and Spark Memory, our memory service for AI agents. The advertising, interest-based advertising, and ad-network sharing described above do not apply to either product. We do not show third-party advertising in them, we do not sell or share your workspace or memory content, and we do not use it to train our own general-purpose AI models.

Data we collect in Spark Studio.

  • Account data: your Spark account identifier and email, display name, and the workspaces and roles you belong to;
  • Subscription and billing data: plan, subscription status, and billing records (card details are handled by our payment processor);
  • Your Content: the documents, notes, and project data you create or upload to your workspace vault;
  • Usage and log data: actions in the product, requests to the AI features, timestamps, IP address, and device and browser information, used to operate, secure, and meter the Service.

Data we collect in Spark Memory.

  • Account data: your Spark account identifier and email, display name, and the organizations, memories, and roles you belong to;
  • Subscription, billing, and usage-metering data: plan, subscription status, metered AI usage, and billing records (card details are handled by our payment processor);
  • Your Content: the messages, documents, files, and extracted records in your memory, including content ingested from the systems you or your organization choose to connect (such as chat, email, and document storage);
  • Access and audit data: a record of each agent and user access (allowed, held for approval, or denied), approval decisions, sign-ins, timestamps, IP address, and device and browser information, kept to operate, secure, and audit the Service.

Content about other people in Spark Memory.

Content ingested from a connected source may include personal data about individuals other than the account holder, such as colleagues and correspondents. We process that data on behalf of and under the instructions of the customer who connected the source, as a processor under our Data Processing Agreement. The customer is responsible for having a lawful basis to connect a source and for any required notices to the individuals concerned. Consent choices are honored at capture: where a customer’s configuration records that a person has opted out, that person’s messages are not ingested. If your information appears in a customer’s memory, direct requests to that customer; we support customers in honoring access and deletion requests, and the deletion path removes a person’s data across current records, historical records, and stored source material.

AI processing.

When you use the AI features of Spark Studio or Spark Memory, relevant portions of Your Content and your prompts are processed automatically through our AI gateway to generate outputs returned to you. Requests are served first by models we run on our own infrastructure, where inputs are not retained after processing and are not used for training. When additional capacity is needed, or when our own infrastructure is down or degraded, requests are routed to a third-party AI provider. We have enabled that provider’s zero-data-retention and no-training settings, and we contract with our providers to process content only to deliver the Service. We take reasonable steps to keep these protections in place, but we do not operate the provider’s systems, and no safeguard is absolutely certain.

Subprocessors.

We rely on a small number of third-party service providers to operate Spark Studio and Spark Memory, who process data on our behalf only to provide the Service. They fall into the categories of cloud hosting and infrastructure, payment processing, email delivery, and AI and large language model processing (for capacity beyond the models we run ourselves). Sign-in and identity are handled by our own authentication service. We can provide our current list of named providers to business customers on request.

Retention and rights.

We retain your workspace or memory content while it is active. After you cancel or delete a workspace or memory, you may export Your Content for 30 days, after which we delete it from active systems within 30 days, except for limited records (such as billing) we must keep by law. We retain diagnostic logs for up to 90 days and then delete or de-identify them. You can access and export Your Content at any time, and request correction or deletion by contacting us.

14. TANKGAME.IO (SPARK SIGN-IN AND PURCHASES)

This section applies to TankGame.io, our browser tank game, and adds to the games and websites disclosures above.

Spark sign-in and game profiles.

When you sign in to TankGame.io using Spark, we receive an account identifier and account information, including your email address, email verification status, and account name. We use account information to provide signed-in features and associate your game profile and purchases with your account.

Your in-game name is separate from your Spark account name. Other players can see your in-game name and equipped customizations during matches. Payment details and purchase history are not public game profile information.

Purchases and billing.

Stripe collects payment and billing information through its checkout fields. TankGame.io stores the account reference, order and payment identifiers, purchased pack, payment amount and tax, purchaser declaration and its timestamp, delivery status, and refund adjustments. We use these records to deliver purchases, maintain balances, handle support and refunds, and reconcile payments.

We do not store complete card numbers or card security codes in the game database. Billing country is checked before an authorized payment is collected. The purchaser checkbox is a declaration, not identity verification or verified parental consent.

Stripe’s handling of payment information is described in its Privacy Policy.

Account and purchase data requests.

For questions about your TankGame.io account or purchase records, or to request access, correction, or deletion, contact contact@solderspark.com. We may need to verify that the request relates to your account. Some records may need to be retained for legal, accounting, dispute, or fraud-prevention purposes even after an account deletion request. We will explain relevant limitations when responding to your request.

15. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. When we do, we will revise the Effective Date above and, if the changes are material, provide additional notice as required by law. Your continued use of the Service after the changes take effect constitutes acceptance of the updated policy. Earlier versions of this policy are available on request.

16. CONTACT US

Solder Spark Studios Inc.
Email: contact@solderspark.com

For the fastest response, you may also use the support features within each game or product.

FOR CALIFORNIA RESIDENTS

Additional disclosures for California residents, including the categories of personal information we collect, the purposes and parties with which we disclose or share it, and how to exercise your rights, are available at solderspark.com/privacy-ca.