NeuralSpark — Privacy Policy

NeuralSpark is a brain training game app developed by WizusLabs. This Privacy Policy describes how the NeuralSpark application (“the App”) handles your information. We are committed to transparency about what data exists on your device, what third-party services may collect, and what choices you have.

1. Data We Collect

1a. Data Stored Locally on Your Device (Never Transmitted)

NeuralSpark is designed with an offline-first architecture. The following data is created and stored entirely on your device. It is never transmitted to our servers or any third party.

• Game results — scores, timestamps, difficulty levels, and performance history for each mini-game. Stored in a local Hive database on your device.
• App preferences — language selection, sound toggle, metacognition mode toggle, and other settings. Stored in SharedPreferences (device-local key-value storage).
• Progress data — XP totals, player level, streak count, daily challenge completion status, game level progression, and streak freeze usage. Stored in SharedPreferences.
• Feature flag states — Pro subscription status cached locally for offline access. Stored in SharedPreferences.
• Metacognition data — if you enable Metacognition Mode, your confidence ratings (Sure/Unsure) for each answer are stored locally alongside your game results.
• Optional placement-improvement data (from version 1.9.2): if and only if you explicitly enable the “Help improve placement (anonymized)” toggle in Settings → Privacy, the App stores anonymized aggregate data from each placement test you complete. The stored payload contains: the placement-test version, the overall aggregate score (rounded to 2 decimals, range 0.0–1.0), four per-category correctness fractions, the speed-bonus value, the recommended starting tier name, and the calendar date (YYYY-MM-DD with no time-of-day). It does NOT contain any personal identifier, IP address, device information, raw question answers, response times, or any user-generated text. The toggle is OFF by default; you may turn it on or off at any time. As of this release, this data is stored only on your device and is never transmitted anywhere. A future release may add an opt-in transmission path; if it does, this Privacy Policy will be updated with effective-date notice before any transmission occurs.
• Optional endless-practice data (from version 1.9.2): the same opt-in toggle covers Endless Practice session events. When enabled, the App stores per-session anonymized data (per-game skill rating before/after, aggregate accuracy, episode index, calendar date) on your device. Same privacy guarantees as placement-improvement data: no PII, no IP address, no transmission, OFF by default.

We do not operate servers, databases, or cloud services that receive any of this data. Your game data exists only on your device.

1b. Data Collected by Third-Party SDKs

The App integrates the following third-party services that may collect data independently:

Unity LevelPlay (advertising, free-tier users only)

• The App displays advertisements in the following formats only: interstitial ads between game sessions, opt-in rewarded video ads to unlock game round blocks, and opt-in rewarded video ads to unlock individual theory articles. The App does not display banner ads on any screen. All ad formats are shown only to users who have not purchased NeuralSpark Pro or NeuralSpark Gate Pass (where applicable).
• Theory-article rewarded gate (free-tier users): Within the App’s theory section, free-tier users may be asked to watch a single rewarded video to unlock an individual theory article they tap. Each article’s unlock state is stored locally on the device (in SharedPreferences) and is never transmitted to our servers. Watching the rewarded video is fully optional — users may instead choose to upgrade to NeuralSpark Pro (which removes the gate entirely and grants ad-free access to all articles), use the existing batch-unlock action, or simply leave the article locked at no penalty. Pro subscribers are never shown the rewarded gate. The choice is the user’s; no article unlock is forced.
• Unity LevelPlay (operated by Unity Technologies; formerly ironSource LevelPlay, rebranded mid-2024) is an ad mediation platform that serves ads from multiple integrated demand sources. In this build, the App ships with adapters for the following mediated ad-network families, any of which may serve a given impression: Google AdMob, Unity Ads, ironSource, AppLovin, Meta Audience Network, Mintegral, Vungle (Liftoff), Bigo Ads, InMobi, Yandex, MyTarget, DT Exchange (Fyber), BidMachine, Pangle, Chartboost, HyprMX, Smaato, Verve, and Ogury. The specific networks that serve a given impression are determined at request time by LevelPlay’s mediation waterfall, and the active set may change as the publisher dashboard configuration evolves.
• In the course of serving ads, the Unity LevelPlay SDK and its mediated networks may collect:
  • Device identifiers (such as the Advertising ID / IDFA / GAID)
  • IP address
  • Device properties (screen resolution, display properties, battery level, available memory)
  • Device settings (language, timezone, volume)
  • App session information (session duration, app version, SDK version)
  • Country and timezone derived from IP address
  • Ad interaction data (impressions, clicks, video completion events)
  • Ad preferences and interest segments
  • SKAdNetwork postbacks (iOS) for measurement and conversion attribution
• Third-party measurement partners may process ad viewability and verification data in accordance with the Open Measurement Working Group standards.
• Rewarded video ads may additionally collect video completion data (e.g., quartile progress and reward grant events).
• On iOS, the App declares the SKAdNetwork identifiers required by LevelPlay’s mediated networks in Info.plist so Apple-attested ad attribution can occur without cross-app tracking.
• If you upgrade to NeuralSpark Pro or purchase NeuralSpark Gate Pass, no ads are displayed and no ad-related data collection occurs.
• Unity LevelPlay’s Privacy Policy: https://www.is.com/legal/privacy-policy/. Privacy policies for the major mediated networks are available on each provider’s site (for example: AdMob/Google, Unity Ads, ironSource, AppLovin, Meta Audience Network, Mintegral, Vungle/Liftoff, Bigo Ads, InMobi, Yandex, MyTarget, DT Exchange, BidMachine, Pangle, Chartboost).

Ad Consent

How the App asks for advertising consent depends on where you are. There are two paths.

For users in the European Economic Area (EEA), the United Kingdom, and Switzerland (and any user whose region cannot be determined, who are treated as if they were in this group):

• A consent form is shown up front, at first launch, before any personalized ads are served. The App presents a consent form provided by Google’s User Messaging Platform (UMP) — a Google-certified Consent Management Platform that implements the IAB Transparency and Consent Framework (TCF v2.2). You make your advertising-consent choices on this form before personalized advertising can be requested. If your region is undetermined, the App takes this same path by default; Google’s UMP then determines whether a form is actually required and, if you are not in fact in a covered region, proceeds without showing one.
• Legal basis is consent. For these users, the legal basis for personalized advertising is your consent under GDPR Article 6(1)(a) (and the equivalent UK GDPR and Swiss FADP provisions), captured through the Google-certified TCF v2.2 form. It is not legitimate interest plus a later in-app opt-in. Your choices are recorded on your device as a standard IAB TCF consent string (see “Data Stored Locally” above), which the advertising SDK and Google read to decide whether personalized ads may be requested.
• Withdraw or change your consent at any time. You can re-open the consent form at any time from Settings → Privacy & ads inside the App. Re-opening the form re-presents the same Google-certified TCF v2.2 choices, so you can change or withdraw any of your advertising-consent selections (GDPR Article 7(3)). Your updated choices take effect for future ad requests; ads served before you change your choices cannot be retroactively un-personalized.
• On iOS, the App Tracking Transparency (ATT) prompt is presented after the consent form is resolved — never before it. ATT asks separately whether you allow the App to track your activity across other companies’ apps and websites; the App passes your ATT decision to Unity LevelPlay, which applies the appropriate signal to all mediated networks.

For users in all other regions (including the United States / California and Vietnam):

• No upfront consent dialog blocks your first session. NeuralSpark uses a just-in-time model for these regions. The App goes directly to gameplay on first launch; a short branded privacy screen is shown as part of onboarding, but it does not require a consent decision before you can play.
• Non-personalized vs. personalized ads. By default these users may receive personalized advertising, and can switch to non-personalized ads only at any time by opening Settings → Privacy & ads inside the App and turning OFF the “Personalized ads” toggle. Non-personalized ads do not use your interests or activity to select which ad to show. Where local law treats this as a legitimate-interest processing of an ad-supported free-tier game (rather than a consent question), that remains the basis for serving ads to free-tier users; you may object at any time as described under “Your Rights and Choices” below.
• The “Personalized ads” toggle is the control. Turning the toggle OFF immediately switches the App to non-personalized ads and propagates the signal to Unity LevelPlay and its mediated networks. Turning it ON requests personalized ads; on iOS the ATT prompt is presented at that moment (not at first launch).

For all users:

• Removing ads entirely. Declining or withdrawing personalized-ads consent does NOT remove ads — it changes which ads you see. To remove all advertising from the App, upgrade to NeuralSpark Pro or purchase NeuralSpark Gate Pass.
• Device-level controls remain available. Independent of the in-App controls, you can adjust your device’s ad settings at any time (iOS: Settings > Privacy & Security > Tracking; Android: Settings > Privacy > Ads).

RevenueCat (in-app purchase processing)

• The App uses RevenueCat to manage NeuralSpark Pro subscriptions, NeuralSpark Gate Pass subscriptions, and other in-app purchases.
• RevenueCat may collect transaction identifiers, device identifiers, and purchase history in order to process and verify your purchases.
• RevenueCat’s Privacy Policy: https://www.revenuecat.com/privacy

Firebase Crashlytics (crash reporting)

• The App uses Firebase Crashlytics to collect crash reports and diagnostic data when the App encounters an unexpected error. This helps us identify and fix stability issues.
• Firebase Crashlytics may collect:
  • Crash stack traces and exception information
  • Device model, OS version, and orientation
  • App version and build number
  • A Crashlytics installation UUID (a random identifier, not tied to your personal identity)
  • Amount of free RAM and disk space at the time of the crash
• Crash data is sent to Google’s Firebase servers. It does not include your game results, preferences, progress, or any other user-generated content.
• Firebase Crashlytics’ Privacy Policy: https://firebase.google.com/support/privacy

2. Data We Do NOT Collect

NeuralSpark does not collect, transmit, or process any of the following:

• No account creation, email addresses, names, or personal identifiers
• No analytics or telemetry data (no Firebase Analytics, no Mixpanel, no Amplitude, or similar services)
• No location data
• No contacts, photos, camera, microphone, or other sensitive device permissions
• No data synced to any cloud service or remote server
• No browsing history, search history, or usage patterns transmitted off-device

3. Data Sharing

We do not sell, rent, share, or transfer your personal data to any third party.

• Unity LevelPlay (and its mediated ad networks), RevenueCat, and Firebase Crashlytics operate under their own respective privacy policies (linked above) and may collect data as described in Section 1b. We do not receive personally identifiable information from these services.
• Game results and progress data are stored only on your device and are never transmitted anywhere.

4. Data Retention

• All locally stored data (game results, preferences, progress) persists on your device until you uninstall the App or manually clear the App’s data through your device settings.
• We do not maintain any server-side data stores. There is no server-side data to retain, expire, or delete.
• Third-party services (Unity LevelPlay and its mediated ad networks, RevenueCat, Firebase Crashlytics) retain data according to their own privacy policies.

5. Data Security

• All data stored by the App resides in your device’s local storage, protected by your device’s built-in security features (device encryption, lock screen, biometric authentication).
• The App does not transmit your game data or preferences over any network.
• Communications between the App and third-party services (Unity LevelPlay for ad delivery, RevenueCat for purchase processing, Firebase Crashlytics for crash reporting) use industry-standard encrypted connections (HTTPS/TLS).

6. Children’s Privacy

• NeuralSpark is a general-audience brain training game. It is not directed at children under the age of 13.
• We do not knowingly collect personal information from children under 13.
• If we become aware that we have inadvertently collected data from a child under 13, we will take prompt steps to delete such data.
• If you are a parent or guardian and believe your child has provided information through the App’s third-party services, please contact us at the address below so we can assist.

7. Your Rights and Choices

All users:

• You can delete all App data at any time by uninstalling the App or clearing the App’s data in your device settings (iOS: Settings > General > iPhone Storage > NeuralSpark; Android: Settings > Apps > NeuralSpark > Storage > Clear Data).
• You can opt out of personalized advertising by adjusting your device’s ad settings (iOS: Settings > Privacy & Security > Tracking; Android: Settings > Privacy > Ads).
• You can upgrade to NeuralSpark Pro or purchase NeuralSpark Gate Pass to remove all advertising from the App.

Users in the European Union / European Economic Area (GDPR):

• You have rights under the General Data Protection Regulation including the right to access, rectification, erasure, restriction of processing, data portability, and objection.
• Because NeuralSpark stores all user data locally on your device and we do not maintain any server-side data, these rights are exercised entirely through your device. You have full control over your data at all times.
• For ad-related data collected by Unity LevelPlay and its mediated ad networks:
  • Consent for personalized advertising (Article 6(1)(a)). For users in the EEA, the UK, and Switzerland, personalized advertising is served on the basis of the consent you give through the Google-certified IAB TCF v2.2 consent form (Google’s User Messaging Platform) shown at first launch. This is the lawful basis for that processing.
  • Right to withdraw consent (Article 7(3)). You may withdraw or change your advertising consent at any time by opening Settings → Privacy & ads and re-opening the consent form. Re-opening the form re-presents the certified TCF v2.2 choices, so you can withdraw any consent you previously gave; your updated choice is written as a new TCF consent string and propagated to Unity LevelPlay and the mediated networks. Withdrawal is effective for future ad requests. (Users outside the EEA/UK/CH use the “Personalized ads” toggle in the same screen instead — see “Ad Consent” in Section 1b.)
  • Right to object (Article 21). You may also object to ad-related processing at any time by upgrading to NeuralSpark Pro or NeuralSpark Gate Pass, which removes ads entirely and ends all related processing by Unity LevelPlay and its mediated networks for your device.
  • Right to access / rectification / erasure (Articles 15–17). Because ad-related data is processed by Unity LevelPlay and the mediated networks rather than by us, exercise these rights through Unity LevelPlay’s privacy contact (see the LevelPlay Privacy Policy linked in Section 1b) or through each mediated network’s own controls.
• For data collected by RevenueCat, please refer to their privacy policy (linked in Section 1b) for information on exercising your GDPR rights.

Users in Vietnam (Personal Data Protection Law — Decree 13/2023/ND-CP):

• You have rights under Vietnam’s Personal Data Protection Law (PDPL) including the right to be informed, to consent or withdraw consent, to access, to delete, and to object to processing.
• Withdrawal of consent for personalized advertising is exercised through Settings → Privacy & ads in the App, using the “Personalized ads” toggle described for non-EEA regions in Section 1b. Turning the toggle OFF switches the App to non-personalized ads. The mechanism is equivalent in effect to withdrawing consent.
• Because NeuralSpark does not transmit your locally-stored game data, preferences, or progress to any server, server-side access / deletion requests do not apply to that data — it lives entirely on your device and is under your direct control.

Users in California (CCPA / CPRA — Do Not Sell or Share):

• California residents have the right to know what personal information is collected, to request deletion, and to opt out of the sale or sharing of personal information.
• We do not sell personal information that we collect directly. All locally stored data is under your direct control on your device.
• However, Unity LevelPlay’s (and its mediated ad networks’) use of device identifiers and ad interaction data to serve personalized advertisements may constitute a “sale” or “sharing” of personal information under the CCPA / CPRA’s broad definitions. California residents can exercise their “Do Not Sell or Share My Personal Information” right by opening Settings → Privacy & ads in the App and leaving (or turning OFF) the “Personalized ads” toggle — when the toggle is OFF, the App signals “non-personalized ads only” to Unity LevelPlay and its mediated networks, which is the equivalent of opting out of CCPA “sale” / “sharing” for advertising purposes. The toggle is accessible at any time. You may also opt out via your device settings (iOS: Settings > Privacy & Security > Tracking; Android: Settings > Privacy > Ads) or by purchasing NeuralSpark Pro or NeuralSpark Gate Pass to remove ads entirely.

8. Third-Party Links and Services

The App may contain links to third-party websites or services (such as subscription management pages). These third-party services have their own privacy policies, and we encourage you to review them. We are not responsible for the privacy practices of third-party services.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the App, our practices, or applicable law. When we make changes:

• The updated policy will be posted at this URL.
• The “Last updated” date at the top of this document will be revised to reflect the date of the most recent changes.
• For material changes, we will update the App’s store listing to note the revision.

We encourage you to review this Privacy Policy periodically.

10. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or the App’s data practices, please contact us at:

Email: [email protected]

11. App Information

• App Name: NeuralSpark
• Developer: WizusLabs
• Platforms: iOS (App Store), Android (Google Play)
• Category: Games (Puzzle) on iOS; Brain Games on Android