Privacy Policy

Sparkface AI

Last updated: March 08, 2026

This privacy notice for Sparkface AI ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

• Download and use our mobile application (Sparkface AI), or any other application of ours that links to this privacy notice.
• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. By using our Services, you also agree to our Terms of Service, available at: sparkface.app/terms.html. If you still have any questions or concerns, please contact us at sparkface.app@outlook.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice.

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services.
• Do we process any sensitive personal information? We may process sensitive personal information (such as biometric data/face data) when necessary with your explicit consent.
• Do we receive any information from third parties? We do not receive any information from third parties.
• How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.
• In what situations and with which parties do we share personal information? We share information with specific third parties for infrastructure, AI processing, storage, and notifications (e.g., Google Gemini, DigitalOcean, Aeza.net, OneSignal) solely to improve the application and provide its core functionality.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

The personal information that we collect depends on the context of your interactions with us and the Services. The personal information we collect may include:

• Email addresses
• Names

Sensitive Information. When necessary, with your explicit permission and consent, or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Biometric data / Face data (Photos you upload)

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, photo library, and other features.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application. We use OneSignal to manage and deliver these notifications. If you wish to opt out, you may turn them off in your device's settings. Please note: Our app does not require you to enable system features like push notifications, location services, or tracking to access the app's functions, content, or to use the app.
• App Tracking Transparency (ATT). We will ask for your explicit permission via Apple's App Tracking Transparency API before tracking your activity across other companies' apps and websites.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services, including Log and Usage Data, Device Data, and Location Data.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user.
• To request feedback and to contact you about your use of our Services.
• To identify usage trends and improve user experience.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law.

We rely on Consent, Performance of a Contract, Legitimate Interests, and Legal Obligations to process your data, in compliance with GDPR, UK GDPR, and other applicable laws.

4. DATA SHARING WITH THIRD-PARTY AI SERVICES

In compliance with Apple Developer Guidelines 5.1.1 and 5.1.2, we disclose the following regarding third-party AI processing:

• What data is sent: Only the specific photos you choose to upload for analysis.
• Who it is sent to: Google Gemini (AI Service Provider).
• Personal Data Protection: We do not share your name, email address, device ID, or any other personal identifiers with Google Gemini. All analysis is performed on the visual content only.
• User Consent: We obtain your explicit permission within the app before any data is transmitted to the AI service. You may opt-out at any time by not using the AI-powered features.

Other service providers: DigitalOcean (Secure Data Storage), Aeza.net (Cloud Infrastructure), and OneSignal (Push Notifications).

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice, unless otherwise required by law.

We will only keep your personal information for as long as it is necessary to provide you with access to your previous results. We will only keep your face scans for a maximum of one year, unless required otherwise by law. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the Internet can be guaranteed to be 100% secure.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services.

8. WHAT ARE YOUR PRIVACY RIGHTS AND HOW TO REVOKE CONSENT?

Depending on where you are located geographically (such as the EEA, UK, Canada, California, Virginia, etc.), the applicable privacy law may mean you have certain rights regarding your personal information. These may include the right to request access to your personal data, request correction of inaccuracies, request deletion of your personal data, and opt out of certain processing.

Revoking Consent and Data Deletion: You have the right to withdraw your consent for data processing at any time and request the complete deletion of your data from our servers and third-party partners.

To submit a request to exercise these rights, revoke your consent, or request data deletion, please email us at sparkface.app@outlook.com. We will process your request in a timely manner according to applicable laws.

9. FACE DATA HANDLING SPECIFICS

• What is Face Data? Face Data refers to the images (photos) that you provide, which are essential for conducting our AI analysis services.
• How is it processed and stored? Your Face Data is processed securely using our AI provider, Google Gemini, after obtaining your explicit permission. The photos you upload are securely stored in our databases hosted on DigitalOcean, while our core application infrastructure operates on Aeza.net.
• Why do we store Face Data? We retain Face Data to enable access to your historical results, enhancing your experience by allowing you to track changes and compare past analyses.
• How long do we store this data? Face Data is stored for up to one year to allow you sufficient time to review and compare your results over an extended period, after which it is deleted.

10. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and will be effective as soon as it is accessible.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, or if you would like to review, update, revoke consent, or delete the data we collect from you, you may contact us by email at:
sparkface.app@outlook.com

Please refer to our Terms of Service for additional information regarding the use of our app: sparkface.app/terms.html