Plim Plim on YouTube
Plim Plim on Instagram
Plim Plim on Facebook
Plim Plim on TikTok

Privacy Policy

Last updated: October 5, 2026

1. Terms and definitions

This Online Privacy Policy (the “Policy”) is a document developed to help Users understand how CIRCLES MAGIC LLC collects, processes, uses, discloses and manages Personal Data.

Users are people using any digital products or services produced or provided by CIRCLES MAGIC LLC on the Platform (hereinafter the “User” / “Users” or “you”).

The Platform is an Internet platform that hosts applications, games or any other digital products produced by CIRCLES MAGIC LLC (hereinafter the “Platform”).

Personal Data is information relating to an identified or identifiable person that can be obtained by CIRCLES MAGIC LLC when the User is using digital products or services produced or provided by the Company (hereinafter “Personal Data”). Aggregated and otherwise non-identifiable data is information that cannot be used to identify a User.

Personal Data Processing is an action performed by Controllers or Processors (under GDPR), including automatic and non-automatic operations with Personal Data of Users.

Data Processor is an organization that processes Personal Data on behalf of the Data Controller.

Application is the software developed by CIRCLES MAGIC LLC that performs a specific function directly for a User.

Game is a game developed by CIRCLES MAGIC LLC.

2. General Terms

CIRCLES MAGIC LLC is committed to protecting and respecting your privacy. This Policy has been developed to inform you about the ways we collect, process, use and manage information in connection with any game, application or other digital product or service produced or provided by CIRCLES MAGIC LLC (hereinafter referred to as “Products” and/or “Services”). The scope of this Policy is limited to information collected through the use of the Products. The practices of the third parties listed in section 3 are governed by their own privacy policies, which are linked in that section.

By using the Products you acknowledge that you have read this Policy. If you do not agree with it, please do not use the Products.

3. Data collected by our partners

Our apps do not ask for your name, email address or any other contact information, and do not offer user accounts. When you use them, the third-party services built into the app automatically collect the following:

  • Device and app identifiers that are not linked to a person's identity: an app instance ID and an installation ID (Google Firebase), an app set ID (Google AdMob, Android only) and, on iOS, the identifier for vendor (IDFV).
  • IP address, used to estimate approximate location (country or region).
  • Technical information: operating system, device model, language, app version and performance diagnostics.
  • Usage data: games opened, screens viewed, game progress and interactions with ads.
  • Purchase and subscription events (product and price). Payments are processed by Google Play or the Apple App Store; we never receive card or bank details.

We never collect the Android Advertising ID or the iOS IDFA, precise location, contacts, photos, audio or any other content from the device.

These partners are:

Every ad request from our apps is flagged as directed to children, so ads are contextual only and are never personalized or based on behavior. This data is used only to run the apps, measure how the games are played, show contextual ads and prevent fraud, which is what COPPA calls support for the internal operations of the app. It is never used to contact, profile or identify a child. Each partner keeps this data according to its own privacy policy, linked above.

Our partners may process this data in the United States and in other countries outside your own, which may have different data protection laws. Where required, they rely on legally recognized safeguards for these transfers, such as the European Commission's Standard Contractual Clauses.

4. Personal Data that we can obtain from other sources and/or share with third parties

We may cooperate with third parties (including, for example, partners, technical contractors, payment services and analytics providers) and may receive data from them as part of the service we provide to you, or for legal reasons, and share data with such third parties. Any such sharing is limited to the data and purposes described in section 3.

We may disclose aggregated and non-identifiable data to third parties for any purpose.

We do not sell personal information, and we do not share it for cross-context behavioral advertising.

5. Why your Personal Data is collected and processed

Our Company collects Personal Data for some or all of the following reasons:

  • To provide you with the Products and Services under the terms and conditions specified herein.
  • For legal reasons, for example if you have entered into a contract with us.
  • To provide you with information on our Products and Services, if you have consented to receive it.
  • To show contextual, non-personalized advertising and to improve the quality of the Products and Services.

Your Personal Data may be processed because:

  • It is necessary to operate the Products, measure their use and prevent fraud (our legitimate interest).
  • You have given us permission to do so.
  • We need to provide Services to you after you have purchased a Product from us.
  • We need to comply with laws.

6. Rights and Options

Pursuant to GDPR you have certain data subject rights, including the right to request access to your Personal Data and its rectification or deletion, to obtain restriction of processing, to ask for a copy of your Personal Data and to object to its processing.

We do not collect or store your Personal Data ourselves. As described in section 3, it is collected automatically by third parties (controllers or processors under GDPR). If you wish to access, rectify or delete your Personal Data, send an email request to legales@spiritum.tv. We will make every reasonable effort to help you and will forward your request to our partners, who operate under their own privacy policies. We will respond to all requests within a reasonable time.

Because our apps do not collect names, email addresses or account information, we may not be able to link a request to specific data held by our partners. In that case we will explain this in our reply and forward the request to the partners listed in section 3, who can act on it using the identifiers they hold.

If you are in the European Economic Area or the United Kingdom, you also have the right to lodge a complaint with your local data protection authority. If you are in Brazil, you have the rights set out in Article 18 of the Brazilian General Data Protection Law (LGPD) and may lodge a complaint with the National Data Protection Authority (ANPD). Data about children is always processed in their best interest, as required by Article 14 of the LGPD.

We will use your Personal Data in accordance with this Policy to the extent reasonably necessary to serve our legitimate business purposes, and we will maintain appropriate safeguards to ensure its security, integrity, accuracy and privacy.

If you have any questions, comments or concerns about this Policy, please contact us by email: legales@spiritum.tv

7. Minors

We follow the principles of the Children's Online Privacy Protection Act (“COPPA”), a U.S. law designed to protect the online privacy of children on the Internet. To learn more about COPPA, see the “Children's Privacy” section of the website of the Federal Trade Commission of the United States of America.

Our apps are directed to children. We never ask children for personal information such as their name, email address or photos. The only data collected is described in section 3: device identifiers and technical data used solely to support the internal operations of the app, as permitted by COPPA, without behavioral advertising or profiling. Parents can stop all further collection at any time by uninstalling the app, and may ask us to delete data already collected by writing to legales@spiritum.tv, and we will forward the request to our partners.

If a child contacts us through a support request or any other feedback, we will use the information only to reply to that message and will then delete it securely.

Our Games and Apps may contain advertisements for third-party products and services, but these are always contextual and never behaviorally targeted.

8. Changes in the Policy

The Company may change this Policy from time to time. Any changes will be posted on this page, and the date at the top of the Policy will be updated. Please check this page periodically to stay informed of any changes in our privacy practices. Your continued use of the Products after a change is posted means you acknowledge the updated Policy.

9. Company's contact information

CIRCLES MAGIC LLC.

Registered address: 7950 NW 53rd Street, Suite 337, Miami, Florida 33166, USA.

Email: legales@spiritum.tv

If you contact us by email, we will collect your name and email address, as well as any other information included in the email, in order to respond to you. We will use this information only to contact and respond to you.

Top