Pixel Arcade Studio — Privacy Policy (COPPA-Aligned)

1) Operator Information (Who We Are)

Operator: SparkNgine (sole proprietorship), operator of Pixel Arcade Studio
Email: support@sparkngine.com
Mailing Address: 3494 Camino Tassajara #1033, Danville, CA 94506
Service URL: https://pixel.sparkngine.com

2) Scope

This Policy applies to information collected through:

• The Service website and web app (including sign-up, account, billing, and support pages)
• Features used to create, edit, save, and publish games
• Customer support communications

This Policy does not apply to third-party websites or services you may access via links from the Service; those services have their own privacy policies.

3) Key Definitions

• Parent: A parent or legal guardian authorized to consent on behalf of a child.
• Child: A user under 13 years old.
• Personal Information (COPPA context): Information that can identify a child or be used to recognize a user over time, such as a name, email address, persistent identifier (cookies/device identifiers), or other identifiers linked to a child.
• Persistent Identifiers: Cookies, IP address, device identifiers, session tokens, and similar identifiers used to recognize a user over time for purposes such as authentication, security, and service operation.

4) Information We Collect

4.1 Information Parents Provide

We collect information Parents provide to create and manage an account, such as:

• Parent email address (required)
• Parent name (optional, if provided)
• Account credentials (or authentication tokens if using a passwordless method)
• Billing and subscription status (payment details are processed by our payment processor; we do not store full payment card numbers)
• Support messages and attachments you send us

4.2 Information About Children (Collected With Parental Consent)

We collect limited child information to provide and personalize the Service, such as:

• Child first name or nickname (provided by the Parent)
• Child age (provided by the Parent)
• Child-created content (e.g., game prompts, game code, game titles, descriptions, configurations, and any assets uploaded to the Service)

Data minimization: We do not require a child to provide more information than is reasonably necessary to use the Service.

4.3 Automatically Collected Information (Usage, Device, Logs)

When the Service is used, we may automatically collect:

• Usage data (e.g., number of games created, features used, session events)
• Device and browser data (e.g., browser type, OS, language settings)
• Log data (e.g., timestamps, error logs, security logs)
• Persistent identifiers needed for authentication, security, and operating the Service (e.g., session cookies or tokens)

No behavioral ads to kids: We do not use children's personal information for behavioral advertising.

5) How We Use Information

We use collected information to:

5.1 Provide and Operate the Service

• Create and manage Parent accounts
• Create child profiles under Parent control
• Save and retrieve game projects and drafts
• Provide support and respond to inquiries

5.2 Safety, Security, and Integrity

• Authenticate access and prevent unauthorized use
• Detect and prevent abuse, fraud, or security incidents
• Enforce platform rules and safety controls

5.3 Improve and Maintain the Service

• Fix bugs, monitor reliability, and measure performance
• Understand feature usage to improve user experience
• Maintain internal analytics (preferably aggregated where feasible)

5.4 Communicate With Parents

• Account-related messages (verification, consent confirmations, security notices)
• Billing and subscription communications
• Service updates and policy changes
• Support responses

We do not knowingly send marketing communications to children.

6) COPPA: Parental Notice, Consent, and Rights

6.1 Verifiable Parental Consent (VPC)

Before collecting, using, or disclosing a child's personal information, we seek verifiable parental consent, except where a limited COPPA exception applies (for example, collecting an email address solely to respond once to a specific request and not using it for any other purpose).

6.2 Direct Notice to Parents

When required, we provide Parents with notice about our information practices and request consent using a method reasonably designed to ensure the person providing consent is the child's Parent.

6.3 Parental Choices and Controls

Parents can:

• Review the personal information we have collected about their child
• Request deletion of their child's personal information
• Revoke consent and stop further collection or use of their child's personal information

To exercise these rights, email support@sparkngine.com from the Parent account email address. To protect children, we may require reasonable verification before fulfilling a request.

7) AI-Assisted Features (Safety and Data Handling)

Pixel Arcade Studio may include AI-assisted features that help generate or modify game logic and code.

7.1 Safety Controls

We use layered safety controls intended to reduce harmful or inappropriate outputs, which may include:

• Content filtering to block inappropriate themes or language
• Age-aware responses based on a child's age profile
• Automated detection/flagging for disallowed content
• Limited manual review of flagged content for safety and compliance

7.2 AI Inputs and Outputs

• Inputs may include prompts and instructions entered by the Parent or Child while using AI features.
• Outputs may include generated code, explanations, and game behavior suggestions.

7.3 Model Training and Improvement

We do not intentionally use children's personal information to train public-facing or general-purpose models.

We may use aggregated or de-identified service metrics to improve reliability, safety performance, and user experience where feasible.

8) Sharing and Disclosure

We do not sell personal information. We do not share personal information with third parties for their own marketing purposes.

We may share information in limited circumstances:

8.1 Service Providers (Processors)

We use vendors to operate and support the Service. They process information only on our instructions and for purposes such as:

• Hosting and infrastructure (e.g., storing projects and running the Service)
• Analytics and performance monitoring
• Notifications and messaging (e.g., service messages to Parents)
• Payment processing and subscription management
• Customer support tooling

Examples of categories of providers we may use include:

• Hosting/infrastructure (e.g., cloud hosting)
• Analytics (e.g., product analytics/performance metrics)
• Notifications (e.g., email/push delivery)
• Payments (e.g., subscription billing)

8.2 Legal, Safety, and Compliance

We may disclose information if we believe disclosure is reasonably necessary to:

• Comply with applicable law, regulation, legal process, or governmental request
• Enforce our Terms & Conditions
• Protect the rights, property, and safety of SparkNgine, our users, or the public
• Detect, prevent, or address fraud, security, or technical issues

8.3 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction. We will take reasonable steps to require continued protection of personal information.

A current list of subprocessors is available at: /legal/subprocessors

9) Data Retention

We retain personal information only as long as reasonably necessary to:

• Provide and operate the Service
• Maintain security, prevent fraud, and resolve disputes
• Comply with legal obligations

Typical retention (unless a longer period is required for legal or security reasons):

• Parent account data: retained while the account remains active
• Child profile data and saved projects: retained while the account remains active
• Logs and security records: retained for a limited period for security and troubleshooting
• Support communications: retained as needed to resolve issues and maintain records

Parents can request deletion at any time (see Section 6.3). Some limited information may be retained if required by law or for legitimate security purposes.

10) Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect information from unauthorized access, loss, misuse, alteration, or disclosure, including (as appropriate):

• Encryption in transit (HTTPS/TLS)
• Access controls and least-privilege practices
• Monitoring and logging to detect suspicious activity
• Risk-based vulnerability management and security testing

No system can be guaranteed 100% secure; we continuously improve our security practices.

11) No Public Social Features

Pixel Arcade Studio does not provide public social feeds, public child profiles, or public commenting systems. Any collaboration or sharing features are designed to be opt-in and Parent-controlled.

If you publish a game, certain information may become visible to anyone with access to the link (such as the game's title and content). Parents should avoid including personal information in published content.

12) Cookies and Similar Technologies

We may use cookies, local storage, and similar technologies to:

• Keep users signed in and maintain session state
• Support security and fraud prevention
• Remember preferences
• Measure performance and reliability

We do not use cookies for behavioral advertising to children.

13) Parent Rights Under U.S. State Privacy Laws (Summary)

Depending on where you live, you may have additional rights regarding personal information, such as the right to request access, correction, or deletion (subject to exceptions) and the right not to be discriminated against for exercising privacy rights.

To submit a request, email support@sparkngine.com.

We do not sell personal information, including personal information of minors.

14) International Users

The Service is intended primarily for users in North America. If you access the Service from outside the United States, your information may be processed and stored in the United States or other jurisdictions where our service providers operate.

15) Changes to This Policy

We may update this Policy from time to time. We will update the "Last Updated" date and, when appropriate, provide additional notice to Parents (for example, via email or an in-product notice).

16) Contact Us

For privacy questions or to exercise parental rights, contact:

Email: support@sparkngine.com
Mailing Address: 3494 Camino Tassajara #1033, Danville, CA 94506