Privacy Policy
Last update: 10 November 2025
This Privacy Policy ("Privacy Policy") describes how we collect, use, share, and protect your information when you use SparkOn in its entirety, including all subpages and associated sites ("Website"), and the SparkOn mobile and web app, accessible via browser on your mobile phone, tablet, and personal computer ("App") (together, "SparkOn").
We act as the controller for all information relating to an identified or identifiable natural person and, where applicable, legal person ("Personal Data") that we collect, process, and use in connection with your use of SparkOn.
This Privacy Policy explains how we handle your Personal Data when you use SparkOn and in other related contexts. The Website may contain links to third-party websites. When you click such links or enable those connections, third parties may collect or share data about you. We do not control these third-party websites and strongly recommend that you review their own privacy policies.
1. Our Privacy-First Approach
We are committed to protecting your privacy and processing your Personal Data in accordance with applicable laws and regulations. To do this, we follow two key principles:
- Data minimization – we only collect and process the Personal Data that is necessary for the specific, clearly defined purposes set out in this Privacy Policy.
- Purpose limitation – we only use your data for the purposes we tell you about, and keep it only for as long as needed for those purposes or to comply with legal obligations.
You have choices and control over your data. Where applicable, you can exercise rights such as access, correction, and deletion of your Personal Data. Keeping SparkOn a trusted service depends on respecting your privacy and maintaining high standards of data protection and user control.
2. What Personal Data Do We Collect?
Some information is required so that SparkOn can function properly. Other information is optional and helps us improve and personalize your experience. If you do not provide required data, you may not be able to use SparkOn.
2.1 When You Access the Website or App
When you visit the Website or use the App, we may collect:
- Technical Information
Such as IP address, operating system, date and time of access, country derived from IP, browser type, referrer URL, login data, device type, and similar technical identifiers.
- Tracking Data
For more detail on cookies and analytics, see Section 5 – Online Tracking and Analysis.
2.2 When You Create an Account
When you register for a SparkOn account, you voluntarily provide certain details. Some fields are required to create an account and use the service; others are optional.
Mandatory data may include:
- Gender (e.g., man, woman, non-binary)
- Sexual orientation (e.g., heterosexual, bisexual, lesbian, gay, queer, asexual)
- Account details (such as User ID)
Optional data may include:
- Email address
- Identity details (e.g., personal description, age, height, languages you speak)
- Sexual preferences and interests
2.3 When You Use SparkOn
As you interact with SparkOn, you can choose to provide additional information. Some of this is necessary for core functionality, while other data helps us tailor and improve your experience.
We may process, for example:
- Location Data (optional)
With your explicit permission, SparkOn may use your device's GPS or similar technologies to obtain your location so we can connect you with nearby users. You can disable location access at any time via your device or browser settings. If you share your location on SparkOn, other users may see it and could potentially misuse it, so please use this feature carefully.
- Transaction Information (optional)
Data related to purchases, contracts, subscriptions, and account management.
- Financial Information (optional)
Billing and payment information (e.g., masked card details, payment tokens from payment providers).
- User Submissions (optional)
Photos, videos, audio, messages, and other content that you share in chats or on your profile. We may process this content for security, moderation, and community protection purposes. Automated systems can review images to detect scams, fraud, or other harmful behavior, in line with applicable law. Content used for these purposes is anonymized, and we do not attempt to re-identify individuals.
- Uploaded Media (optional)
Any photos, videos, or other media you upload, which may require access to your device's camera or gallery. Metadata (e.g., generalized location, device information) may be processed for moderation and safety, but location data is typically generalized to protect your privacy.
- Augmented Reality (AR) Features (optional)
Some AR experiences may be provided through third parties such as Snap Inc. and require access to your device's camera. You will be asked to review and accept their terms and privacy policy before using such features. You can withdraw consent by adjusting your device settings, bearing in mind that certain AR features may no longer work.
- Usage Information
Data on how you use SparkOn, such as features you interact with, time spent, and interactions with other users.
- Sexual Identity & Preferences (optional)
Information about your sexual identity and the kinds of connections or relationships you're interested in.
- Feedback and Insights
Survey responses, ratings, testimonials, and feedback about our services.
- Contests and Promotions
Data you provide when you participate in events, contests, or other promotions.
- Customer Support
Information contained in messages or communications with our support team.
- Age Verification
If you appeal a decision to restrict your access for not meeting the minimum age, we may request a photo of you and an ID document showing your date of birth.
Most Personal Data is provided directly by you. Where permitted by law, we may also receive Personal Data from publicly available sources, public authorities, or third-party providers. Details on data sharing with third parties are set out in Section 7.
3. How We Use Your Personal Data
We use your Personal Data to provide and improve SparkOn, communicate with you, protect our community, and meet legal obligations. Examples include:
- Managing Business Relationships
Using transactional, financial, and user-generated data to establish, manage, and perform our contractual relationship with you (e.g., creating your account, enabling full access to SparkOn).
- Core Functionality of SparkOn
Using your location (where enabled), identity data, and sexual identity and preferences to operate key features, maintain and improve SparkOn, match and connect users, and show relevant content.
- Security and Access Management
Using location data, timestamps, activity logs, and usage information to maintain and test network and IT security, perform system checks and backups, and communicate important updates or alerts.
- Fraud Detection and Prevention
Using data collected at sign-up and anonymized user content (including images, metadata such as approximate location and device details) to detect and prevent fraud, scams, and abuse, through both automated tools and manual review where needed.
- Market Research and Analytics
Using usage patterns, demographic data (e.g., age, gender, approximate location), and feedback to understand how SparkOn is used, run internal analyses, and improve features and the overall user experience.
- Advertising and Promotions
Using data from your participation in events, contests, and promotions—and sometimes other profile/usage information—to tailor offers, invitations, or promotions we think may interest you.
- Legal and Regulatory Compliance
Processing data required to meet legal, tax, accounting, and regulatory obligations, and to prevent or investigate potential criminal or unlawful activity.
- Legal Claims
Using data as needed to establish, exercise, or defend legal claims.
- Other Purposes with Your Consent
Where you have explicitly agreed that we may use your data for a specific additional purpose, we will do so on the basis of that consent.
4. Legal Bases for Processing
Depending on the context and the type of Personal Data, we may rely on one or more of the following legal bases:
- Performance of a Contract
Processing necessary to provide SparkOn and fulfill our contractual obligations to you (e.g., account creation, processing payments, providing core features), as set out in the Terms & Conditions.
- Legitimate Interests
Processing necessary for our legitimate interests or those of a third party, provided that your interests and fundamental rights do not override those interests. Examples include maintaining platform security, improving services, preventing fraud, and supporting business operations.
- Legal Obligations
Processing necessary to comply with legal, regulatory, accounting, and tax obligations or mandatory retention requirements.
- Consent
Processing based on your explicit consent, particularly for:
- Sensitive categories of data (such as sexual orientation) where required by law
- Precise geolocation data
- Transfers of Personal Data to countries without an equivalent level of data protection, where needed
- Certain types of direct marketing
You can withdraw your consent at any time as described in Section 12, but this will not affect the lawfulness of processing carried out before your withdrawal.
5. Online Tracking and Analysis
We use various technologies to understand how SparkOn is used and to improve performance and personalization.
a. Cookies
We and certain third parties use cookies and similar technologies on SparkOn to recognize you and/or your device. Cookies are small text files stored on your device that help us:
- remember your preferences and settings,
- keep you logged in,
- analyze usage, and
- improve functionality.
Depending on your location, you may be able to manage cookie settings through in-app settings, a cookie banner, and/or your browser.
b. Analytics Tools
We use analytics tools and services to understand user behavior, measure engagement, and improve features. These tools collect information about how you interact with SparkOn, which pages or screens you visit, and how often you use certain features.
c. Log Files
When you access SparkOn, certain data is automatically stored in log files, such as access times, general usage patterns, and server loads. We analyze this data—usually in aggregated or anonymized form—for technical, statistical, and security purposes. No personal evaluations are conducted from these log files.
6. Transfers of Personal Data to Other Countries
We may transfer your Personal Data to third parties located outside your country, including partners involved in analytics, data processing, business operations, content moderation, marketing, and app tracking.
Where we transfer data internationally, we take steps to ensure that your Personal Data is provided with a level of protection consistent with this Privacy Policy and applicable law. This includes:
- Assessing whether the destination country is covered by an adequacy decision or equivalent mechanism;
- Implementing appropriate safeguards, such as standard contractual clauses or similar legal instruments;
- Obtaining your explicit consent where required by law.
We conduct risk assessments for such transfers and implement technical and organizational measures to protect your data.
7. Third Parties with Whom We Share Data
We may share your Personal Data with:
- Service Providers
Trusted service providers who process Personal Data on our behalf or as joint controllers. These may include providers of telecommunications, email services, hosting and cloud services, database management, outsourcing, payment processing, user verification, advertising, marketing, analytics, anti-spam, and anti-fraud tools. Some of these providers may also process data for their own purposes, which they describe in their own privacy policies.
- Business Partners, Buyers, or Merger Parties
In connection with any actual or potential merger, acquisition, restructuring, or sale of all or part of our business, assets, or interests, we may share Personal Data with prospective or actual buyers, sellers, partners, and their advisers.
- Public Authorities and Legal Representatives
Government agencies, courts, regulators, and other authorities (domestic or foreign), as well as lawyers and other professional advisers, where we are required to do so by law or where we believe such disclosure is necessary to:
- protect our rights or those of our users, partners, or others,
- reduce potential liability in actual or threatened legal proceedings,
- enforce our agreements, or
- prevent, detect, or respond to illegal activities, suspected fraud, or other misconduct.
We aim to be transparent about such sharing and comply with applicable data protection laws.
8. Safety and Transparency in Sharing Personal Data
We prioritize transparency and security whenever we share Personal Data with third parties. We only do so where there is a legitimate business purpose and ensure that appropriate safeguards are in place to protect confidentiality and integrity.
As SparkOn may operate globally, the recipients and their processing locations can vary depending on your location and the nature of the services involved. Third-party recipients may be located, for example, in:
- the United States and other countries in North and South America (such as Canada, Mexico, Brazil),
- European countries (including, but not limited to, the United Kingdom and other EEA or non-EEA countries), and
- various countries in Asia (such as China, Israel, India, Vietnam, Japan, Singapore).
Whenever we engage third parties, we implement safeguards consistent with data protection requirements, such as contractual obligations, security assurances, and where necessary, additional technical protections.
9. Personal Data Received from Third-Party Logins
If you log into SparkOn using your Apple ID, Apple will share certain information with us, such as your Apple login, name, and email address. Apple also offers a feature that lets you hide your real email address by providing a random relay email that forwards messages to your inbox while keeping your actual email private.
If you sign in using your Google Account, Google may share with us your name, email address, and language preference.
We use this information to create and manage your account on SparkOn. You can later revoke our access to your Apple or Google account by removing SparkOn from your account settings with those providers. However, data that has already been shared with us during account creation will remain with us until and unless you delete your SparkOn account.
For more details on how Apple and Google process your data and your privacy options, please see their respective privacy notices and visit 【网址】.
10. How Long We Keep Your Personal Data
We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected, or as required by laws, regulations, or contractual obligations.
In some cases, certain data may be retained for up to 180 days after deletion (or account closure) for reasons including:
- maintaining security and stability,
- protecting against fraud and misuse,
- meeting legal and regulatory obligations, and
- establishing, exercising, or defending legal claims.
This retention helps us safeguard the integrity of SparkOn and protect users and the platform from ongoing or repeated violations.
For more detailed information about specific retention periods or criteria, you can contact us at [email protected]
11. How We Protect Your Personal Data
We use a combination of technical and organizational measures to protect your Personal Data against loss, misuse, unauthorized access, alteration, or destruction. Our staff and third-party service providers are required to maintain confidentiality and comply with data protection rules.
However, no system can guarantee absolute security. Data transmitted over open networks (such as the internet or standard email) can be vulnerable to access or interception by unauthorized third parties. For this reason:
- We cannot guarantee the confidentiality of information transmitted over open networks.
- Personal Data transmitted through such channels may not benefit from the same level of protection as data stored within SparkOn.
We continuously review and improve our security measures, but we encourage you to exercise care when sharing sensitive information online, especially over unsecured networks.
12. Your Rights
Depending on your location and applicable laws, you may have some or all of the following rights in relation to your Personal Data:
- Right of Access
To obtain confirmation as to whether we process your Personal Data and, if so, to receive a copy of that data.
- Right to Rectification
To have inaccurate or incomplete Personal Data corrected. Where appropriate, we will also inform relevant third-party recipients of such corrections unless this would be impossible or require disproportionate effort.
- Right to Erasure ("Right to be Forgotten")
To request deletion of your Personal Data under certain conditions (for example, where it is no longer needed for the purposes we collected it for), subject to legal or legitimate grounds for retention.
- Right to Restrict Processing
To request that we restrict processing of your Personal Data under certain circumstances (e.g., while we verify its accuracy or the reason for processing).
- Right to Data Portability
In some cases, to receive your Personal Data in a structured, commonly used, and machine-readable format and to transmit it to another controller, where technically feasible.
- Right to Lodge a Complaint
If you believe that your Personal Data has been processed in violation of applicable data protection laws, you may have the right to lodge a complaint with a competent supervisory authority in the U.S. state (or country) where you live, work, or where the alleged violation occurred.
- Right to Withdraw Consent
Where processing is based on your consent, you may withdraw that consent at any time at no cost and without needing to provide a reason, by contacting us using the details below. Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal.
These rights may be subject to limitations and conditions under applicable law.
To exercise any of your rights, please contact us at: [email protected]
California Residents
If you are a California resident, you may have additional rights under California law relating to your Personal Data. California Civil Code Section 1798.83 may allow you to request information about how we share Personal Data with third parties for their direct marketing purposes.
You may also request to opt out of such sharing by emailing us using the contact details below. However, at present, we do not share your Personal Data with third parties for their own direct marketing purposes. If you opt out, you may still receive offers directly from us, in compliance with California law.
13. Children's Privacy
Minors—defined as individuals under 18 years of age, or older where required by applicable state laws—are not permitted to use or access SparkOn. We do not knowingly collect Personal Data from minors.
We strongly encourage parents and legal guardians to monitor their children's online activity and to ensure that they do not access SparkOn or share any Personal Data on the platform.
If you believe that a minor has provided us with Personal Data, please contact us promptly. We will take reasonable steps to delete such data and, if applicable, close the associated account.
14. Changes to this Privacy Policy
We may update this Privacy Policy from time to time, for example to reflect changes in law, technology, or how SparkOn operates.
When we make changes, we will post the updated Privacy Policy on the Website or within the App. Unless otherwise stated, changes take effect upon posting. We encourage you to review this Privacy Policy periodically to stay informed about how we handle your Personal Data.
15. Contact
If you wish to exercise any of your rights, or if you have questions, feedback, or concerns about this Privacy Policy or our data protection practices, you can contact us at:
Our support team will do their best to respond and help address your concerns about privacy and data protection.
This policy applies to the "SparkOn: Swipe On Real Sparks" mobile application by Luminaris Technology Limited available on the Google Play Store.