Starlark Privacy Policy

Effective date: Jan 1,2020


At Starlark, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal information. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use, and share your information as described in this Privacy Policy.

Remember that your use of Starlark is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Categories of Personal Data We Collect

The following chart details the categories of Personal Data that we collect and have collected over the past twelve (12) months. For each category of Personal Data, the chart also sets out:

·       the categories of source(s) of that Personal Data (Column 3),

·       the categories of third parties with whom we share that Personal Data for a business purpose (Column 4).


You can find additional information about columns 3 and 4 in sections following the chart.



1. Category of Personal Data

2. Personal Data Collected

3. What is the source of this Personal Data?

4. Categories of third parties with whom we share this Personal Data for a Business Purpose


Personal identifiers

device identifiers,

Internet Protocol address, Facebook username (if you login through your Facebook account)


-Service Providers



-Selected Recipients


Commercial information

 in-app purchases,

products or services purchased,

purchasing or consuming histories and tendencies



-Service Providers



-Selected Recipients


Internet or other similar network activity information


 information on your interaction with our gaming application

You /

Affiliates /

Third Parties

-Service Providers



-Selected Recipients


Inferences drawn from other personal information

In-game behaviors


-Service Providers



-Selected Recipients


Sources of Personal Data (Column 3)

We collect Personal Data about you from the following categories of sources:

·       “You”

o   When you provide such information directly to us.

o   When Personal Data about you is automatically collected in connection with your use of our Services (see the subsection titled “Information Collected Automatically” below).

·       “Affiliates”

o   Our subsidiaries and affiliates when they provide us with Personal Data about you.

·       “Third Parties”

o   Third parties that provide us with Personal Data about you. Third Parties that share your Personal Data with us include:

§  Service providers. For example, we may use analytics service providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

§  Social networks connected to the services. If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, you understand some content and/or information in those accounts may be transmitted into your Account with us.

§  Advertising partners. We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.



Information Collected Automatically


The Services use ad identifiers, which are non-permanent, non-personal identifiers such as the Android advertising ID and/or Apple's ID for advertising (the ‘IDFA’) uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow us and our advertising partners (including marketers and advertisers) to recognize your device when you use the Services. Our advertising partners (e.g. Facebook and Google) may also transmit cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to your device, when you click on ads that appear on the Services. IDFAs and Cookies enable our servers to recognize your device and tell us how and when you access and use our Services, to analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that this Privacy Policy does not cover the use of Cookies by any third parties, and we aren’t responsible for their privacy policies and practices.  Please be aware that Cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device.



Information about Interest-Based Advertisements:


We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Internet-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.


We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at or


How We Use Your Personal Data

We process Personal Data to operate, improve, understand and personalize our Services. We use Personal Data for the following purposes:

·       To meet or fulfill the reason you provided the information to us.

·       To communicate with you about the Services, including Service announcements, updates or offers.

·       To provide support and assistance for the Services.

·       To create and manage your Account or other user profiles.

·       To personalize website content and communications based on your preferences, including targeted offers and ads served through the Services.

·       To process orders or other transactions.

·       To respond to user inquiries and fulfill user requests.

·       To improve and develop the Services, including testing, research, analysis and product development.

·       To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of our Services.

·       To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use.

·       To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

·       For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).


We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.


As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Services. Also, we may receive a confirmation when you open an email from us, which helps us improve our Services. If you do not want to receive communications from us, please indicate your preference by emailing us at

How We Share Your Personal Data


Column 4: Categories of Third Parties with Whom We Share Personal Data

We disclose your Personal Data to the following categories of service providers and other parties:

  • “Service providers”, which help us provide our Services, including:
    • Payment processors, such as Apple (for in-app purchases made in our iOS apps) and Google (for in-app purchases made in our Android apps).
    • Ad networks, such as
      • Facebook
      • Google Admob
      • Unity
      • Ironsource
      • Applovin
      • Vungle
      • Adcolony
    • Security and fraud prevention consultants.
    • Hosting and other technology and communications providers.
    • Analytics providers, such as Appsflyer.
  • “Affiliates”.
  • “Acquirors”, who acquire your Personal Data through an acquisition or other change of control.
    • Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).
  • “Selected Recipients”, which are third parties that we share your Personal Data with at your direction, including:
    • Other users (where you interact with other users through the Services or direct us to effect any interaction or communication with other users as initiated or authorized by you through the Services).
    • Social media services (if you intentionally interact with them through your use of the Services).
    • Third-party business partners who you access through the Services.
    • Other parties authorized by you.



Disclosures of Personal Data for a Business Purpose

We disclose your Personal Data to service providers and other parties as explained in the chart above for the following business purposes:


·       Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

·       Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

·       Debugging to identify and repair errors that impair existing intended functionality.

·       Short-term, transient use of Personal Data that is not used by another party to build a consumer profile or otherwise alter your consumer experience outside the current interaction.

·       Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

·       Undertaking internal research for technological development and demonstration.



Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data you provide to us. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at

California Resident Rights

If you are a California resident, you have the rights outlined in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at


You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

·       The categories of Personal Data that we have collected about you.

·       The categories of sources from which that Personal Data was collected.

·       The business or commercial purpose for collecting or selling your Personal Data.

·       The categories of third parties with whom we have shared your Personal Data.

·       The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.

If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.


You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identify and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

·       Call us at:    +861062927872

·       Emailing us at:


Personal Data Sales Opt-Out and Opt-In

In this section, we use the term ‘sell’ as it is defined in the CCPA. We sell your Personal Data, subject to your right to opt-out of these sales.


We sell your Personal Data to the following categories of third parties:


·       Advertisers


Over the past twelve months, we have sold the following categories of your Personal Data to third parties:


·       A. Personal identifiers.

·       D. Commercial information.

·       F. Internet or other similar network activity information.

·       G. Geolocation data.

·       K. Inferences drawn from other personal information.


You have the right to opt-out of the sale of your Personal Data.  You can opt-out by clicking the  Do Not Sell My Information page.

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.  

We do not sell the Personal Data of minors under 16 years of age without affirmative authorization. If you are between 13 and 16 years of age, you must authorize us to sell your Personal Data. If you are under 13 years of age, your parent or guardian must authorize us to sell your Personal Data.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account.

Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice within the games (apps) by sending you a notification, and/or by some other means. Please note that if you’ve opted not to receive legal notice from us , those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data, your choices and rights regarding such use, please do not hesitate to contact us at:

·       +861062927872





“Do Not Sell My Personal Information”



Starlark Starlark may share your information with third parties to serve you offers for Starlark, or offers from our third-party advertising partners. This sharing could get you a personalized advertising and gaming experience. 

But, Starlark gives you the ability to disable targeted advertising provided by third-party partners at any time and If you wish to disable targeted advertising, you can do so by limiting ad tracking in your device settings:

For iOS devicesplease follow the instruction provided by Apple

For Android devices, please follow the instruction provided by Google


If you still couldn’t fix it on your device, you can also send an email to including your account and device information. Once we receive your information and locate your account, Starlark will disable the personalized advertising and no longer share your information with third-party partners, but it may take a little bit of time before your opt-out takes effect.


If you or your legally authorized agent need help, do not have an account, or would like to submit an opt-out notice to us directly, please email us at


If you want to know more about our sharing activities, please read our Privacy Policy.