Privacy Policy

Effective Date: October 16, 2024

Last Updated: September 28, 2025

Update Notice (2025-09-28): This update clarifies our use of a third-party push notification service provider, EngageLab. We may collect your device push identifiers (e.g., device tokens, browser identifiers) and share them with EngageLab solely to deliver system notifications and tournament reminders. No other personal content is accessed or used for unrelated purposes.

Entity Change Notice (2025-09-19): For unified operations and compliance, the legal entity of this App has been updated to Spark Mars Sdn Bhd (Company Reg. No.: 202301013472 / 1507394-H; Registered Address: No. 5-1, Jalan SL 1/12, Bandar Sungai Long, 43000 Kajang, Selangor, Malaysia). This change does not affect your rights or existing services.

Spark Mars Sdn Bhd (“we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Asia Poker Union mobile application (“the App”). By using the App, you agree to the collection and use of information in accordance with this Policy.

1. Information We Collect

Personal Information: name (including legal name matching an ID/passport for identity verification), email address, phone number, club membership info, ID or passport number (for tournament verification), location (optional), and precise location (for maps and venue assistance).
Media files & ID images (only when you intentionally upload): used to set/update profile avatar, attach images/videos to Community posts/comments, merchant accounts’ club logos/photos (and promotional videos if enabled), and KYC document photos/scans. We do not scan your entire media library in the background; the App can access only the files you select via the system picker.
Usage Data: device info (model, OS version), IP address, browser type, App usage analytics (e.g., interactions, time on sections).
Push Notification Identifiers: device tokens, browser identifiers, and related system info used solely to deliver notifications (e.g., system alerts, tournament reminders).
Anti-abuse signals:
- Google reCAPTCHA v3.0: may collect device, IP, and behavioral data to distinguish humans from bots; processed under Google’s Privacy Policy, solely for spam/abuse prevention.
- Alibaba Cloud International reCAPTCHA: may collect device fingerprint, IP, slider trajectory, and other risk signals; processed under Alibaba Cloud’s Privacy Policy, solely for abuse detection and security.

2. How We Use Your Information

Provide, maintain, and improve the App; notify you about updates/changes; customer support; analytics; and legal compliance.
Offline tournament identity verification: we may process your legal name, ID/passport number, phone, and email for on-site verification; shared only with authorized club staff.
Location-based services: show your precise location in Google Maps to help you find nearby clubs and tournaments.
Email & phone verification: we share your email/phone with third parties (Google, AWS, Alibaba Cloud International) to send codes and verify ownership.
Anti-abuse: analyze interactions via Google reCAPTCHA v3.0 and Alibaba Cloud International reCAPTCHA to detect suspicious activity and prevent unauthorized access.
Avatars / Community / Merchant materials / KYC: process photos/videos only when you choose to upload for avatar updates, Community posts/comments attachments, merchant club logos/photos/promotional videos (if enabled), and KYC document review (manual/semi-automated).

3. How We Share Your Information

We do not sell or rent your personal information.
Service providers: we may share necessary data to operate the App (e.g., AWS for SMS, Google for email verification, Google reCAPTCHA / Alibaba Cloud International reCAPTCHA for risk control). For uploaded photos/videos and ID images, we may use entrusted processors (e.g., object storage/CDN) strictly under contract; they may not use data beyond our instructions.
Push notification provider: to deliver system alerts and tournament reminders, we may share device tokens and related info with EngageLab. EngageLab acts only as a delivery channel and does not access or store your personal content.
Legal requirements: we may disclose data if required by law, regulation, or governmental request.
Google Maps: precise location may be shared with Google Maps to provide real-time map services.
Verification services: we share email/phone and risk signals with Google, AWS, and Alibaba Cloud International to send codes and mitigate abuse.

4. How We Protect Your Information

We implement industry-standard safeguards; however, no method of transmission or storage is 100% secure. We protect transfers to third parties (e.g., Google, AWS, and Alibaba Cloud International) and limit use to verification/security purposes.

5. Data Retention

We retain personal data only as necessary for the purposes described and to meet legal obligations. For media files and ID images, we delete or anonymize them after avatar/Community/merchant display purposes are fulfilled or after KYC is completed, unless longer retention is required by law/compliance. You may request deletion via in-App channels or email.

6. Cross-Border Transfers

Your data may be processed in countries different from where it was collected. We take reasonable measures to ensure adequate protection under this Policy and applicable laws.

7. Your Rights

Access, rectify, delete, and portability of your personal data (subject to legal exceptions).
Withdraw consent (e.g., location/media access) via device/system settings or by contacting us. Some features may stop working after withdrawal.
If you are in the EEA, you may lodge a complaint with your local data protection authority.

8. Tournament Identity Information

When you participate in offline tournaments, you may be required to provide legal name, ID/passport number, phone, and email for registration and verification. This is shared only with the hosting club and used solely for these purposes.

9. Children’s Privacy

The App is not directed to children under 13 in the U.S. In the EU, the minimum digital consent age may range from 13 to 16. We do not knowingly collect data from children below the applicable age; if we learn that we have done so without consent, we will delete it promptly.

10. Changes to This Policy

We may update this Policy from time to time. Updates will be posted here with revised “Effective Date” and “Last Updated”.

11. Contact Us

Spark Mars Sdn Bhd
Company Reg. No.: 202301013472 / 1507394-H
Registered Address: No. 5-1, Jalan SL 1/12, Bandar Sungai Long, 43000 Kajang, Selangor, Malaysia
Email: privacy@spark-mars.com
Tel: +60 3-4032 2746

12. Device Permissions & System Picker (Android)

READ_MEDIA_IMAGES: used only when you select files via the system picker for avatar updates, Community post/comment images, merchant logos/photos, and KYC documents.
READ_MEDIA_VIDEO (if enabled): used only when you select files via the system picker for Community post/comment videos and merchant promotional videos.

On Android 13+, we prefer the system photo/video picker; the App can access only the files you select and does not conduct ongoing/background library access. If video upload is not available, the App will not request READ_MEDIA_VIDEO.