Privacy Policy

Last updated: November 2, 2026

About This Policy

This policy explains how personal data is handled by the developer behind Romily and by the group companies it belongs to (referred to here as "Romily", "we", "us" or "our"). It reaches across everything we put in your hands — our mobile apps, our websites, and any feature or service connected to them (together, the "Services").

Three questions shape what follows: which personal data we hold; what happens to it once we have it, including who else may see it; and how much say you have over it. This policy sits alongside our Terms of Service and forms part of our agreement with you.

Please read it before you begin using the Services or hand us any personal data. Going ahead and using the Services tells us that you accept what is described here. If any part of it does not sit right with you, the Services and our websites are best left unused.

A word that appears here with a capital letter but is not explained carries the meaning it has in the Romily Terms of Service.

1. The Personal Data We Handle

1.1 What you hand over yourself

Part of what we hold arrives because you decided to share it — as you use the Services, when you write to us, or when you ask to receive our newsletters. It may be about you, and it may be about somebody else. As a rule it covers:

• the messages you send in chats, the images you upload, and the Characters you share — all of which count as User Content under the Terms of Service;

• whatever you say to us when you make contact.

1.2 What we record as you use the Services

(a) Cookies, web beacons and similar tracking tools — ours and those of our third-party vendors — are used to record particulars of the computers and devices (mobile ones included) from which you reach the Services. Among the particulars that we and our vendors gather and study are: the type of browser in use; internet service provider or operating system; domain name; the time of access; IP address; identifiers unique to a device, such as IDFA or Android ID; the version of the Services you are running; and the kind of device itself. That list is not exhaustive. We likewise observe how often you open the Services and when, and the route you take through our website or mobile app.

(b) Data of that kind — our vendors' contributions included — serves our analytics. It shows us which corners of the Services attract the most use and what users enjoy or find frustrating, and it allows us to judge whether our advertising campaigns delivered. Further uses appear elsewhere in this policy.

(c) Our vendors and we also rely on cookies, clear GIFs, pixel tags and comparable tools. They give us a clearer view of how people behave, let us hold on to individual preferences, support research and analytics work, and feed improvements into the Services. With them we can, for instance, shape the Services around what you need, keep your password stored inside password-protected areas, see which pages get opened, keep our content in order, and compile statistics on how the Services are used. Some of these tools may also sit inside the emails we send customers, which lets us follow response rates, learn when an email has been opened, and see whether it has been passed along.

(d) A general sense of your whereabouts — such as the approximate area an IP address points to — may be picked up while you use the Services.

1.3 What comes to us from elsewhere

Information about you can reach us through other parties, for instance when another user introduces you to us. It can also arrive from third-party social platforms such as Facebook or Instagram, if you interact with our profiles there.

1.4 Meta Platform Data (Facebook)

The Services do not offer Facebook Login, and we do not collect or store any Facebook user data through Meta's Platform sign-in features. Certain Meta SDKs integrated into the Services (Meta Audience Network and the Facebook SDK for App Events and App Links, as listed in Section 9) send limited app event and advertising data to Meta on our behalf; that data flows from us to Meta in connection with our own app events, and does not give us access to your Facebook account data. This data sharing is governed by the Meta Platform Terms and our agreements with Meta.

Romily integrates with the Meta Marketing API, accessed solely through our own developer access tokens, to support our internal advertising management and analytics platform. Through this integration, we retrieve Platform Data relating to ad accounts that we own or are authorized to manage, including campaign configurations and performance metrics such as spend, impressions, clicks, and conversions. Such Platform Data is Processed solely to provide campaign management, reporting, and analytics, in accordance with the Meta Platform Terms and Developer Policies. Access to this data is restricted to authorized personnel only. We do not sell this data, do not use it to build or augment user profiles, and do not Process it for any unrelated purpose; it is deleted when no longer needed for the purposes described or upon request.

We do not and will not: (a) sell Platform Data (as defined in the Meta Platform Terms) or license it to any third party; (b) process Platform Data without valid user permission in order to build or augment user profiles, for any purpose; (c) use Platform Data to perform, facilitate, or provide tools for surveillance; or (d) use Platform Data to discriminate against individuals, or to determine their eligibility for housing, employment, insurance, education, credit, government benefits, or immigration status.

If you previously authorized our app through Facebook and would like any related data deleted, email sparking321.game@gmail.com with the subject line "Data Deletion Request". We will complete the deletion within seven (7) business days and confirm by reply. You can also remove the app's authorization at any time in Facebook under Settings > Apps and Websites.

2. How Personal Data Is Used

2.1 The purposes behind our processing

We may process your data for any of the purposes below. Alongside each one you will find what it involves, why we carry it out, and the legal ground we stand on.

3. Who Else Receives Personal Data

3.1 Our workforce and our suppliers

Your information may be passed to employees, consultants and other suppliers who need it in order to work for us or provide services on our behalf — among them providers of data storage, payment processing, technical support and services, customer service, analytics, fraud prevention, legal services and marketing.

3.2 Fellow members of our group

Information may be passed to members of our group, meaning any entity that controls Romily, is controlled by Romily, or sits under common control with Romily. Such entities use the information only in ways that match this policy.

3.3 Where safety or rights are in play

Where we honestly believe it is needed or fitting, certain information may be passed on in order to (i) shield or defend Romily and other parties, which includes defending or enforcing this policy, our Terms of Service or any other contractual arrangement; and/or (ii) shield the rights, property or personal safety of Romily, our agents and group companies, our employees, our users and/or the wider public.

3.4 Advertising and analytics partners

We carry on advertising in the Services, and some of your information may be passed to, or made available to, advertising and analytics partners so that advertisements can be served for us and to you across the internet and analytics services supplied. Partners of that kind may use cookies and tracking technologies, which lets us do such things as follow and study data, gauge how popular particular content is, place advertising and content matched to your interests, and form a clearer picture of your activity online. The advertising SDKs currently integrated into the App, and links to their privacy policies, are listed in Section 9.

3.5 Where the law demands it

Where we honestly believe it is needed or fitting in order to satisfy any law enforcement, legal or regulatory process — answering a warrant, a subpoena, a court order or other applicable laws and regulations — certain information may be passed on.

3.6 Where a life may be in danger

Should we have reasonable grounds to think somebody's life is in danger, we may release that person's data to the entities best placed to help. A person threatening suicide is one instance.

3.7 Where a legal claim arises

Where legal claims are brought against us or against one of our users, information may be shared as the situation requires. If, for example, you contest a notice of that kind, your response may go to the person who complained.

3.8 If our business changes hands

Information may be passed on in the course of — or while negotiating or completing — a merger, the sale of company assets, financing, or the acquisition of our business in whole or in part by another company.

3.9 Content other people can see

Some of what you do can be seen by other users of the Services, or can produce content that becomes available to them.

3.10 When you ask us to

Information may go to third parties outside our group wherever you consent to it. One example: you ask us to pass on information about you because you want to recommend us or the Services to a friend or acquaintance.

4. Safeguards We Apply

• Our users' personal data is shielded by technical and physical measures designed to prevent loss, destruction, alteration, unauthorised access, disclosure, or any other unlawful processing.

• The protections we use reflect current industry practice, firewalls, password protection and other access and authentication controls among them.

• Only Romily staff with a genuine need can reach personal data, and strong authentication — complex passwords or two-factor authentication, for instance — is required first.

• Data is held in data centres with effective physical and logical security controls; we work with established third parties that show real security awareness; and our own premises and staff meet clear data-protection standards.

• Even so, no transmission over the internet and no electronic storage is ever entirely secure. We cannot promise, or warrant, that information you send us or keep on our service will be safe, and you accept that risk; nor can we promise that a failure of our physical, technical or managerial safeguards will never result in information being accessed, disclosed, altered or destroyed.

5. Sending Personal Data Across Borders

Servers on which your personal data is kept may sit in, and be reached by Romily's employees and contractors in, countries other than the one you live in. Using an Application or the Services amounts to your consent to your information being sent to such countries, which may lie outside your country of residence and may operate data protection rules that differ from — and are weaker than — those you enjoy at home. Should that be unacceptable to you, please leave every Application unused and delete all of them from your devices straight away.

6. How Long We Keep Personal Data

Personal data is kept only for as long as the purposes behind its collection require, which includes meeting any legal, accounting or reporting duty.

Several things guide the retention period we settle on: how much personal data there is and how sensitive or significant it is; the harm that could follow from it being used or disclosed without authority; the purposes we collected it for and whether we can meet those purposes another way; and what the applicable law demands.

7. Your Rights and How to Use Them

Depending on where you live, the law may give you some or all of the rights below. A support form, or an email to sparking321.game@gmail.com, is all it takes to exercise any of them.

7.1 Being told what we do. You are entitled to clear, transparent and easily graspable information about the way Romily gathers and uses personal data, and about your rights. That is precisely why this policy exists.

7.2 Seeing your data. You may obtain access to the personal data Romily holds about you (where we are processing it), along with certain other information of the kind this policy contains. You may also ask about our disclosure of personal information to third parties during the previous calendar year for those parties' own direct marketing. Such a request costs nothing and can be made once a year.

7.3 Having mistakes put right. Where your personal data is inaccurate or incomplete, you are entitled to have it corrected.

7.4 Having data erased. This right to be forgotten lets you ask that your personal data be deleted or removed where Romily has no compelling reason to go on using it. It is not a blanket right to erasure, and exceptions apply. We will complete a verified erasure request within seven (7) business days and confirm the outcome by reply.

7.5 Limiting what we do with it. In certain circumstances you may "block" or suppress any further use of your personal data.

7.6 Opting out of sales. You may opt out of your personal information being sold to a third party.

7.7 Taking your data with you. You may receive the personal data Romily holds about you in a structured, commonly used and machine-readable format, and may pass that data on to another controller.

7.8 Objecting to processing. You may object at any time, on grounds that relate to your particular situation, to your personal data being processed.

7.9 Complaining to a regulator. You may complain to your national supervisory authority about the way Romily handles or processes your personal data.

7.10 Taking back consent. Where you have consented to Romily processing your personal data for a particular purpose, you may withdraw that consent at any time. Withdrawal does not make unlawful anything Romily already did on the strength of your consent, but it stops us using your personal data for that purpose going forward.

7.11 Leaving instructions for later. You may set out general or specific instructions about how your personal data is stored, deleted and used after your death.

7.12 Deleting your account. You can delete your Romily account at any time through the account settings in the app, or through the account deletion page on our official website. Account deletion is permanent: your profile, messages, uploaded images, Characters and other User Content will be removed and cannot be restored. Deleting your account does not cancel an active subscription — please cancel it first in your App Store or Google Play settings. If you only want specific data deleted (for example, your conversation history) without deleting your account, use the in-app support form or email us; verified requests are completed within seven (7) business days. For step-by-step guidance, see our Data Deletion Instructions page on our official website.

8. Age Limits and Children

8.1 Romily is not aimed at children. Anyone below the minimum age the Romily Terms of Service set may not open a Romily account and may not use Romily's services, and should not hand any personal data to the App.

8.2 No form of child abuse or exploitation is tolerated by Romily. Where we have reasonable grounds to think you have engaged in child pornography, or where law enforcement asks us to, your data — group messages and private messages included — may be given to law enforcement agencies. How younger users are protected, and how to raise a concern, is set out in our Child Safety Policy.

9. Third-Party SDKs and Services

Third-party software development kits (SDKs) and services help us add functionality and improve what you get from the Services. Personal data — usage data, device information and location data among it — may be collected, stored or processed by those SDKs, each according to its own privacy policy.

Essential functions of the Services depend on third-party SDKs, data analytics and advertising delivery among them. Partners are chosen with care, but their independent privacy practices and the content they serve remain theirs, not ours. Third parties may therefore collect and process your data under their own privacy policies, and we suggest you read those policies to see what your rights are and how your data gets used.

Below is the list, as it stands, of the third-party SDKs built into our App, with what each is for and where its privacy policy lives:

10. How This Policy May Change

10.1 Romily revises this policy from time to time. Its terms may change without notice being given to you first, so please look it over periodically for anything new.

10.2 Anything material will be shown on our App. Personal data is handled under the version of this policy that stood when it was collected. Keep using the Services after changes have been posted and we take it that you accept them.

11. How to Reach Us

Questions about this policy, or anything else you want to ask Romily, can go to sparking321.game@gmail.com.