Privacy Policy - Sparktonic, LLC

Our website address is: https://sparktonic.co

Last updated: February 26, 2026

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.
Application means any mobile application(s) published by the Company and available for download on electronic devices.
Business, for the purpose of the CCPA, refers to the Company as the legal entity that collects Consumers' personal information and determines the purposes and means of the processing of Consumers' personal information.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Sparktonic. For the purpose of the GDPR, the Company is the Data Controller.
Consumer, for the purpose of the CCPA, means a natural person who is a California resident.
Country refers to: United States.
Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier, or factors specific to Your identity. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, or could reasonably be linked with You.
Service refers to the Application(s).
Service Provider means any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, provide the Service on the Company's behalf, perform services related to the Service, or assist in analyzing how the Service is used. For the purposes of the GDPR, Service Providers are considered Data Processors.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
You means the individual accessing or using the Service. Under GDPR, You can be referred to as the Data Subject or as the User.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may collect certain personally identifiable information that can be used to contact or identify You. This may include, but is not limited to:

Email address (if You contact support)
Usage Data

Usage Data

Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (IP address), device type, device unique identifier, mobile operating system, mobile browser type, time and date of use, time spent on features, and other diagnostic data.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain the Service, including monitoring usage and performance.
To manage Your Account: to manage Your registration as a user and provide access to features available to registered users.
For the performance of a contract: to fulfill purchase contracts for subscriptions or other services.
To contact You: via push notifications or email regarding updates, service communications, or security notices.
To manage Your requests: to respond to and manage requests You submit to Us.
For business analytics: to understand user behavior in aggregate, measure product performance, and improve the Service. Where data is anonymized or aggregated such that individuals cannot be identified, it falls outside the scope of personal data and may be retained indefinitely for business intelligence purposes.

Sharing Your Personal Information

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, process payments, and support service delivery.
For Business Transfers: We may share or transfer Your personal information in connection with a merger, sale of Company assets, financing, or acquisition.
With Affiliates: We may share Your information with Our affiliates, who will be required to honor this Privacy Policy.
With Business Partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, and to comply with Our legal obligations, resolve disputes, and enforce Our agreements.

The following retention guidelines apply:

Device-level identifiers and Usage Data: retained for up to 24 months from collection, after which they are deleted or anonymized.
Purchase and transaction records: retained for up to 7 years to satisfy legal, tax, and accounting obligations.
Support communications: retained for up to 2 years following resolution.
Anonymized and aggregated analytics data: data that has been fully anonymized or aggregated such that no individual can be identified is not subject to GDPR retention limits and may be retained indefinitely for business intelligence and product improvement purposes.

Transfer of Your Personal Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of Your state, province, country, or other governmental jurisdiction where data protection laws may differ from those of Your jurisdiction.

Where Personal Data is transferred from the European Economic Area (EEA) to the United States or other countries not recognized by the European Commission as providing an adequate level of data protection, the Company relies on Standard Contractual Clauses (SCCs) as approved by the European Commission under Article 46(2)(c) of the GDPR as the legal mechanism for such transfers. All third-party Service Providers receiving EEA personal data are required to execute SCCs or operate under an equivalent approved transfer mechanism.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us. While We strive to use commercially acceptable means to protect Your Personal Data, no method of transmission over the Internet or method of electronic storage is 100% secure, and We cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to Your Personal Data only to perform their tasks on Our behalf and are obligated not to disclose or use it for any other purpose. The following third-party Service Providers process data in connection with Our Service:

Analytics

Firebase (Google LLC)

Firebase is an analytics and app performance service provided by Google LLC. Firebase may collect Usage Data including device identifiers, session data, and in-app behavior to help Us understand how the Service is used and diagnose technical issues. You may opt out of certain Firebase features through your device advertising settings or by following Google's instructions.

Superwall

Superwall is a paywall and subscription analytics platform. Superwall collects data related to paywall presentation events, subscription conversion, and in-app purchase behavior to enable Us to optimize subscription flows. Superwall does not perform advertising attribution.

Subscription & Receipt Management

RevenueCat

RevenueCat is a subscription management platform that processes in-app purchase receipts, validates subscription status, and manages entitlements across devices. RevenueCat receives purchase receipt data from Apple to confirm and manage Your subscription state. RevenueCat does not perform advertising attribution.

Attribution

AppsFlyer

AppsFlyer is a mobile attribution platform used to understand which marketing channels lead users to install Our applications. AppsFlyer may process device identifiers and install event data. AppsFlyer does not process payment or billing data.

Payments

Apple In-App Purchases

All payment processing for subscriptions and in-app purchases is handled exclusively by Apple through its App Store infrastructure. The Company does not collect, store, or process payment card details. Apple acts as the merchant of record for all transactions. Your payment information is governed solely by Apple's Privacy Policy.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Processing is necessary for the performance of an agreement with You.
Legal obligations: Processing is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing is necessary to protect Your vital interests or those of another natural person.
Public interests: Processing is related to a task carried out in the public interest or in the exercise of official authority.
Legitimate interests: Processing is necessary for the purposes of the legitimate interests pursued by the Company, provided those interests are not overridden by Your rights and freedoms.

Your Rights under the GDPR

If You are within the EU or EEA, You have the following rights:

Right of access: You have the right to request access to, or a copy of, the Personal Data We hold about You.
Right to rectification: You have the right to request correction of any incomplete or inaccurate Personal Data We hold about You.
Right to erasure: You have the right to request deletion of Your Personal Data where there is no compelling reason for its continued processing.
Right to object: You have the right to object to processing of Your Personal Data where We are relying on legitimate interests, or where processing is for direct marketing purposes.
Right to data portability: You have the right to receive Your Personal Data in a structured, commonly used, machine-readable format, where processing is based on consent or a contract.
Right to withdraw consent: You have the right to withdraw consent at any time where We are relying on consent as the legal basis for processing.

Exercising Your GDPR Data Protection Rights

You may exercise any of the above rights by contacting Us using the details provided at the end of this Policy. We may ask You to verify Your identity before responding to such requests and will endeavor to respond within 30 days. You also have the right to lodge a complaint with Your local Data Protection Authority in the EEA.

CCPA / CPRA Privacy

Your Rights under the CCPA / CPRA

If You are a California resident, You have the following rights:

Right to know: You have the right to know what categories of Personal Data We collect, the sources from which it is collected, the purposes for which it is used, and the categories of third parties with whom it is shared.
Right to access: You have the right to request the specific pieces of Personal Data We have collected about You in the past 12 months.
Right to deletion: You have the right to request deletion of Personal Data We have collected about You, subject to certain exceptions.
Right to opt out of sale or sharing: We do not sell Your Personal Data. If You believe any data processing by Our third-party SDK partners constitutes "sharing" under CPRA for cross-context behavioral advertising purposes, You may opt out by adjusting Your device's advertising preferences (see below).
Right to non-discrimination: We will not discriminate against You for exercising any of Your CCPA / CPRA rights.

Do Not Sell or Share My Personal Information

We do not sell Personal Data. However, certain third-party SDK partners integrated into our Service may process device identifiers and usage data in ways that could constitute "sharing" under CPRA for interest-based advertising purposes.

To opt out of interest-based advertising on Your iOS device:

Go to Settings > Privacy & Security > Tracking and disable "Allow Apps to Request to Track"
Go to Settings > Privacy & Security > Apple Advertising and disable "Personalized Ads"

These device-level controls apply across all applications on Your device.

Exercising Your CCPA / CPRA Rights

California residents may exercise their rights by contacting Us using the details provided below. We will respond to verified requests within 45 days, with the possibility of a 45-day extension where reasonably necessary.

Children's Privacy

Our applications are not directed at children under the age of 13, and We do not knowingly collect Personal Data from children under 13. Our applications are not designed or marketed toward minors.

If You are a parent or guardian and You believe Your child has provided Us with Personal Data, please contact Us immediately using the details below. If We become aware that We have collected Personal Data from a child under 13 without verified parental consent, We will take steps to remove that information promptly.

Do Not Track

Our Service does not respond to Do Not Track (DNT) signals. DNT is primarily a browser-based mechanism and is not applicable to native iOS applications. iOS users may manage tracking preferences through device-level privacy settings as described in the "Do Not Sell or Share" section above.

Links to Other Websites

Our Service may contain links to third-party websites that are not operated by Us. We strongly advise You to review the Privacy Policy of every site or service You visit. We have no control over and assume no responsibility for the content or privacy practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this document. You are advised to review this Privacy Policy periodically for any changes. Changes are effective when posted.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a privacy-related concern, You can contact Us:

By email: support@sparktonic.co
By website: https://sparktonic.co