Privacy Policy — Sparks

1. Who we are

Registered / office addresses

• India: H.No. 8-2-293/82/JIII/443, Jubilee Hills Cooperative House Building Society Ltd, Road No. 58, Jubilee Hills, Hyderabad, Telangana 500033, India
• UAE: IFZA Business Park, DDP Premises Nu-88519-001, Building A1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, UAE
• USA: 700 E Algonquin Rd, Unit 2104, Schaumburg, IL 60173, United States

2. Who this policy applies to

The Services are for people who are 18 years of age or older. We do not knowingly collect personal information from children. If you believe someone under 18 has created an account, please report it in the app or email support@life2sparks.com. We will delete that account and related data.

This policy covers members, event/holiday/booking customers, doctors and companions who use the app, and visitors to our websites.

3. Information we collect

We collect information you give us, information generated when you use the Services, and information from third parties you connect.

3.1 Information you provide

Account and identity

• Name, date of birth, gender, and who you want to meet
• Email address and/or mobile number (and OTP verification)
• Password (stored in hashed form)
• Country / mobile code
• Profile type (for example member, doctor, or companion)

Profile and preferences

• Photos, videos, bio, height, weight, body type, occupation, education
• Interests, hobbies, languages, religion, community, zodiac
• Marital status, children, dating goals, smoking, drinking, diet, workout habits
• Sexual orientation or role, if you choose to share it
• Social links (Instagram, Facebook, LinkedIn) if you connect them
• Answers to onboarding or profile questions
• Referral code

Some of this may be treated as sensitive personal data in certain countries (for example sexual orientation, religion, health-related wellness information, or biometric data used for verification). We process it only with your consent or another lawful basis described in Section 5.

Content you create

• Chat messages, reactions, GIFs, photos, videos, voice notes
• Stories, albums, posts, comments, and video spotlights
• Trip plans, travel partner requests, pickup/drop locations, and privacy mode
• Event, holiday, flight, hotel, or shopping bookings (name, email, phone, and booking details)
• Doctor / wellness appointment details and reviews
• Messages you send to Sparks AI (trip planning and wellness chat)
• Reports you submit about other members

Safety and verification (optional features)

• KYC / identity verification photos and documents (via our verification partner)
• Face / liveness images used to confirm you are a real person
• SOS emergency contact email and phone, live location, city/state, and (if you choose) the person you are meeting

Payments

• Subscription and in-app purchase records (plan, status, transaction IDs)
• Energy / coin purchases and usage history
• If you pay us directly (for example via Stripe), our payment processor collects card or other payment details. We do not store full card numbers. Purchases through Apple or Google are processed by those stores under their own terms.

Support

• Information you send to Help & Support, email, or phone (including screenshots you attach)

3.2 Information collected automatically

• Device type, OS, app version, language, time zone
• IP address and approximate location derived from IP
• Advertising identifiers (for example Google Advertising ID) where permitted
• Crash logs and performance data
• How you use the app (screens, features, matches, likes, calls, ads you see or tap)
• Push notification tokens
• Cookies and similar technologies on our websites

3.3 Location

If you allow location access, we collect precise location (latitude/longitude) to:

• Suggest nearby people and trips
• Fill city / area on your profile
• Power maps, pickup/drop points, and travel features
• Send SOS location updates when you enable SOS

You can turn location off in device settings. Some features will not work without it. We request location while you use the app; background location is used only where you have enabled a feature that needs it (for example SOS).

3.4 Device permissions

The app may ask for:

Denying a permission limits the related feature. It does not stop you from using the rest of the app.

3.5 Information from others

• Other members (likes, matches, messages, reports, blocks)
• Sign-in providers if you use Google, Apple, Facebook, or LinkedIn (name, email, and profile photo they share with us)
• Apple, Google, and payment processors (purchase receipts and verification)
• Advertising and attribution partners (for example campaign performance)
• Maps and places providers (search and geocoding results)
• Public or partner sources used for safety (for example to investigate abuse)

4. How we use information

We use your information to:

Provide the Services

• Create and manage your account
• Show your profile to other members and recommend people, trips, and content
• Enable chat, group chat, voice and video calls
• Run stories, albums, posts, games, quizzes, and similar features
• Process bookings (events, holidays, flights, hotels, shopping, doctor slots)
• Run subscriptions, coins, and companion / energy features
• Provide AI trip and wellness chat
• Send transactional messages (OTP, booking confirmations, security alerts)

Keep people safe

• Verify identity and photos (KYC / liveness)
• Detect spam, fraud, scams, and policy violations
• Handle reports, blocks, and bans
• Operate SOS and share location with your nominated emergency contact when you trigger it
• Enforce our Terms of Use

Improve and operate the business

• Analytics, crash reporting, and product improvement
• Customer support
• Personalise content and, where allowed, advertising
• Measure marketing (including AppsFlyer and similar tools)
• Comply with law, tax, and accounting rules
• Defend legal claims

We may use automated systems (including profiling) to rank suggestions, detect abuse, and personalise what you see. These systems do not, on their own, make decisions that produce legal effects about you. Human review is available for account actions such as bans.

5. Legal bases (EEA, UK, and similar laws)

Where those laws apply, we process personal data on these bases:

• Contract — to create your account, show profiles, enable matching, chat, calls, bookings, and paid features
• Consent — precise location, optional tracking, KYC/biometrics, and sensitive profile fields you choose to add. You can withdraw consent in settings or by contacting us
• Legitimate interests — safety, fraud prevention, analytics, service improvement, marketing of our own Services, and enforcing our rights, balanced against your rights
• Legal obligation — tax, accounting, law-enforcement requests, and similar duties

6. How we share information

We do not sell your personal information.

We share information in these situations:

With other members
Your public profile (photos, name/age, bio, and the details you choose to show) is visible to other members according to your privacy settings. Messages, calls, and trip requests are visible to the people involved.

With service providers who process data for us under contract, including:

• Cloud hosting and our API / chat servers
• Firebase (authentication, push notifications, analytics, crash reporting, app integrity)
• Google Maps / Places
• Agora (voice and video calls)
• Apple and Google (sign-in, in-app purchases, notifications, ads)
• Meta (Facebook Login) and LinkedIn (sign-in), if you use those options
• Stripe and store billing (payments)
• AppsFlyer (install attribution and marketing measurement)
• Google Mobile Ads (advertising)
• Giphy (GIFs you send)
• InstaFido or similar KYC / liveness vendors
• Email, SMS, and customer-support tools

With booking and professional partners
When you book an event, holiday, flight, hotel, doctor visit, or similar service, we share the details needed to fulfil that booking with the relevant organiser, airline, hotel, doctor, or vendor.

With your emergency contact
If you enable SOS and it is triggered, we may send your location and related details to the email/phone you nominated.

For legal and safety reasons
If required by law, court order, or to protect someone's safety, investigate crime, or enforce our terms.

Business transfers
If we merge, sell, or reorganise the company, your information may transfer to the successor, still subject to this policy or a successor policy.

With your direction
If you share a profile or content outside the app, or ask us to share data with a third party.

7. Advertising, analytics, and tracking

We use first- and third-party analytics and advertising tools, including Firebase Analytics, Firebase Crashlytics, Google Mobile Ads, and AppsFlyer.

On iOS we request tracking permission through App Tracking Transparency. If you decline, we do not track you across other companies' apps and websites for advertising. You can also reset or limit advertising identifiers in device settings.

We do not currently respond to browser “Do Not Track” signals because there is no consistent standard.

8. International transfers

We operate from India, the UAE, and the United States, and we use vendors in other countries. Your information may be processed outside the country where you live, including jurisdictions that may not provide the same legal protections.

Where required (for example transfers from the EEA, UK, or Switzerland), we use appropriate safeguards such as standard contractual clauses or another approved transfer mechanism.

9. How long we keep information

We keep personal information only as long as needed for the purposes in this policy and as required by law.

• Active accounts: while you use the Services
• Closed or deleted accounts: we delete or anonymise profile and content after a short safety retention window (typically up to 30–90 days), unless we must keep records longer
• Inactive accounts: we may close accounts that have been unused for two years
• Transactions and tax records: up to 10 years, or as local law requires
• Safety / ban records: as long as needed to stop banned users from returning and to protect others
• Support tickets and logs: typically up to 5 years
• KYC / biometric verification data: only as long as needed to complete verification and meet legal or safety obligations; then deleted or reduced to a verification status

Backups may persist for a limited period after deletion.

10. Your rights and choices

Depending on where you live, you may have the right to access, correct, delete, export, restrict, or object to certain processing, and to withdraw consent.

You can do a lot of this in the app:

• Edit your profile and photos
• Change location, notification, and visibility settings
• Disconnect social accounts
• Block or report users
• Delete your account from Profile → Delete account
• Uninstall the app (this does not delete your account; use in-app deletion or email us)

To exercise other rights, email support@life2sparks.com from the address on your account. We may need to verify your identity. We will respond within the time required by applicable law.

If we refuse a request, you may appeal by emailing the same address with the subject “Privacy Request Appeal.” You may also complain to your local data protection authority.

Residents of certain US states: we do not “sell” personal information or share it for cross-context behavioural advertising as those terms are defined in those laws, except as described in Section 7 where you have opted in to tracking.

11. Security

We use technical and organisational measures appropriate to the sensitivity of the data, including:

• Encryption in transit (HTTPS / TLS)
• Access controls and authentication
• Encryption of certain sensitive fields
• App integrity checks
• Limited employee access on a need-to-know basis

No system is completely secure. Please use a strong password and do not share OTPs or account details.

12. Communications

We send:

• Service messages — OTPs, security alerts, booking and payment notices, match/chat/call notifications you have enabled
• Marketing — offers and product news, where allowed. You can opt out of marketing emails using the unsubscribe link or by contacting us. You cannot opt out of essential service messages while you have an account

Push notifications can be turned off in device settings.

13. Third-party links and partners

The Services may link to airlines, hotels, shops, payment pages, social networks, or other sites. Their privacy practices are their own. Review their policies before you provide information.

14. Changes to this policy

We may update this Privacy Policy from time to time. We will change the “Last updated” date and, for material changes, notify you in the app or by email before the change takes effect. Continued use after the effective date means you accept the updated policy.

15. Contact us

For privacy questions, requests, or complaints:

LIFE2SPARK SOLUTIONS PRIVATE LIMITED
Email: support@life2sparks.com
Copy: operation@life2sparks.com
Phone: +91 76809 80150

India office: H.No. 8-2-293/82/JIII/443, Jubilee Hills Cooperative House Building Society Ltd, Road No. 58, Jubilee Hills, Hyderabad, Telangana 500033, India

If you are in the EEA or UK and we appoint a representative or Data Protection Officer, we will publish those details on this page.