Privacy Policy

IMPORTANT PRIVACY INFORMATION

SPARK is an AI communication coach for dating. To give you reply suggestions, profile feedback and training, the app processes what you choose to give it: messages and chat screenshots, profile screenshots, photos and bio, your onboarding and test answers, trainer answers (including voice), and text you send from the SPARK keyboard. This content is sent to OpenAI to generate the result.

We also collect some data automatically: IP address, language, time zone, device model and settings, operating system, app version, unique identifiers (IDFV, IDFA if you allow tracking), in‑app activity, purchases and crash reports.

To run and improve SPARK we use providers such as OpenAI, Apple, Google and Adapty, as well as our hosting, analytics, attribution and advertising partners. See Section 3 for why, Section 6 for your rights and Section 1 for who controls your data.

California and other U.S. state residents: see Section 11. Questions: [email protected] or via our contact form at puredating.club.

This Privacy Policy explains what personal data we collect when you use the SPARK mobile app, the SPARK keyboard extension and our website (together, the “Service”), and how we use and share it.

BY USING THE SERVICE YOU CONFIRM THAT YOU (I) HAVE READ AND UNDERSTOOD THIS PRIVACY POLICY, (II) ARE AT LEAST 18 YEARS OLD, AND (III) ACCEPT THE DATA PRACTICES DESCRIBED BELOW. If you don’t agree, stop using the Service, ask us to delete your data, cancel any subscription through the App Store or the website where you bought it, and delete the app.

Translations are provided for convenience; if versions differ, the English version prevails. “GDPR” means Regulation (EU) 2016/679. “EEA” means the EU and EFTA countries and, for this Policy, also the United Kingdom. “Process” includes collecting, storing, using and disclosing data.

TABLE OF CONTENTS

• Data controller
• Categories of personal data we collect
• Purposes of processing
• How we use AI (OpenAI)
• Legal bases (EEA and UK users)
• Your privacy rights
• With whom we share data
• Age limitation
• International data transfers
• Data retention and security
• U.S. state privacy notice
• Changes and contact

1. DATA CONTROLLER

Limited Liability Company “DEXTONS” (LLC “DEXTONS”), a company incorporated under the laws of Ukraine, registered office at 2B Pavla Li Lane, premises 8, Holosiivskyi District, Kyiv, 03195, Ukraine (USREOU code 45985709) (“we”, “us”), is the controller of your personal data.

2. CATEGORIES OF PERSONAL DATA WE COLLECT

2.1. Data you give us

2.1.1. Account data. If you sign in with Apple or Google, we receive an account ID, your email (or Apple’s private relay address) and your name if you share it.

2.1.2. Onboarding and preferences. Your goals, who you want to connect with, communication style, self‑rated confidence and similar answers, app language and theme.

2.1.3. Conversation content. Messages you type or paste and screenshots of chats you upload to get reply suggestions.

2.1.4. Profile content. Screenshots of dating profiles (yours or a match’s), photos, bio and prompts you upload for Match Score, profile score, Photo Lab and bio rewrites. Access to your photo library is requested only when you choose to upload.

2.1.5. Keyboard text. Only text you actively send to SPARK from the SPARK keyboard (e.g. by tapping “Get reply”). The keyboard does not log keystrokes and is not active in password or other secure fields. “Full Access” is needed only to connect to our servers.

2.1.6. Learn and training data. Baseline test answers, trainer answers, completed tasks, streaks and your Communication Score across five skills (Confidence, Empathy, Humor, Initiative, Boundaries).

2.1.7. Voice input. If you answer a trainer by voice, we access the microphone with your permission, convert the recording to text and delete the audio after transcription.

2.1.8. Purchase data. We don’t receive or store full card details. We receive limited data needed to provide your plan: product, price, currency, date, trial status, renewal and, for web purchases, your email and personal activation code. Web purchases are processed by Paddle.com, our authorised reseller and Merchant of Record, which collects your payment details and billing address directly and processes them as an independent controller under its Privacy Policy.

2.1.9. Support communications. Your email and anything you send to our support team.

2.2. Data we collect automatically

2.2.1. How you found us — the ad, app or web page that brought you to SPARK.

2.2.2. Device data — IP address (and the country/region it indicates), language, time zone, device type and model, OS version, app version, carrier.

2.2.3. Usage data — screens and features you use, session length, onboarding steps completed, paywall views, purchases, errors and crashes.

2.2.4. Identifiers — IDFV, an app‑generated user ID, and IDFA only if you allow tracking. You can reset or limit these in your device settings.

Other people’s data: screenshots and messages may include other people’s names, photos and words. Share only what you’re allowed to and crop out details that aren’t needed. We use such content only to answer your request and never to identify, profile or contact those people.

3. PURPOSES OF PROCESSING

3.1. To provide the Service

Generate reply suggestions, profile and match analysis, trainer feedback and your progress; run the keyboard; keep you signed in; fix errors. Hosting and backend: our cloud hosting and infrastructure providers. Sign‑in: Apple and Google. Session tokens are stored securely in Apple Keychain. AI processing: OpenAI (see Section 4).

3.2. To personalise your experience

Use your onboarding answers, preferred tone and skill scores to tailor suggestions, your 5‑day plan, trainer difficulty and recommended articles.

3.3. To manage payments and subscriptions

Verify purchases, activate trials and web codes, handle renewals and refund requests. Providers: Apple App Store, Paddle (our Merchant of Record for web purchases), Adapty (subscription management and purchase analytics). When Apple asks, we may share information about your use of purchased content to help it decide on a refund request.

3.4. To provide customer support

Answer your requests and send service messages about security, payments and changes to our documents.

3.5. To communicate with you

If you opt in, we send push notifications such as daily drill reminders, streak updates and your evening task. Delivery uses Apple Push Notification service and Firebase Cloud Messaging. You can turn notifications off in your device settings.

3.6. To research and analyse use of the Service

Understand which features help, test new versions and improve onboarding. Providers: Adapty and our analytics, attribution and crash‑reporting providers. Analytics events don’t include the content of your conversations, screenshots or photos.

3.7. To market the Service and measure ads

Show and measure SPARK ads on other platforms and send offers. Providers: the advertising networks and platforms on which we run SPARK campaigns. On iOS, cross‑app tracking happens only if you allow it in the App Tracking Transparency prompt. You can limit personalised ads in Settings → Privacy & Security → Tracking / Apple Advertising.

3.8. To keep the Service safe and enforce our Terms

Detect abuse (harassment, scams, content involving minors), prevent trial and payment fraud, and enforce our Terms and Conditions.

3.9. To comply with the law

Keep tax and accounting records and respond to lawful requests from authorities.

4. HOW WE USE AI (OPENAI)

SPARK’s AI features run on the OpenAI API. When you ask for a reply, score, rewrite or trainer feedback, we send OpenAI the content needed for that request — text, screenshots, photos or transcribed voice answers — plus limited context such as the tone you picked or your skill level. OpenAI returns the result, which we show in the app.

• We don’t send your name, email or account ID to OpenAI.
• Under OpenAI’s API terms, API data is not used to train OpenAI’s models by default, and may be kept by OpenAI for a limited period (currently up to 30 days) for abuse monitoring.
• We don’t use your content to train our own models without your separate consent.
• Results are generated automatically, may be inaccurate, and don’t produce legal or similarly significant decisions about you.

Learn more in OpenAI’s Privacy Policy.

5. LEGAL BASES (EEA AND UK USERS)

5.1. Consent — processing content you upload, sensitive data you choose to share (for example, who you want to connect with may reveal your sexual orientation), microphone access, push notifications and IDFA/ad tracking. You can withdraw consent at any time.

5.2. Performance of a contract — providing the Service, personalisation, support, service messages and payments.

5.3. Legitimate interests — analytics and product improvement, marketing our Service in a measured way, fraud prevention, enforcing our Terms, handling complaints, corporate transactions and legal claims. You can object to this processing (see Section 6).

5.4. Legal obligation — tax, accounting and lawful requests from authorities.

6. YOUR PRIVACY RIGHTS

• Access and correct — review and edit your answers and profile in the app, or ask us for a copy of your data.
• Delete — delete individual conversations and uploads from History, or your whole account in Profile → Settings → Delete account. Some records (e.g. purchases) may be kept as the law requires.
• Object or restrict — ask us to stop or limit certain processing.
• Withdraw consent — turn off microphone, photo, notification or tracking access in device settings, or disable the keyboard.
• Portability (EEA/UK) — receive your data in a machine‑readable format.
• Complain (EEA/UK) — lodge a complaint with your local data protection authority. We’d appreciate the chance to fix it first.

Send requests to [email protected] or via our contact form at puredating.club. We reply within 30 days and may ask you to verify your identity.

7. WITH WHOM WE SHARE DATA

7.1. Service providers acting on our instructions:

• AI processing — OpenAI;
• hosting and storage — our cloud hosting and storage providers;
• sign‑in, notifications and secure storage — Apple, Google;
• payments and subscriptions — Apple, Paddle, Adapty;
• analytics, attribution and crash reporting — Adapty and our analytics, attribution and crash‑reporting providers;
• marketing — advertising networks and email delivery providers.

7.2. Authorities — when required by law or needed to protect the rights and safety of users and others.

7.3. Business transfers — a buyer or successor in a merger, acquisition or asset sale.

7.4. Affiliates — companies in our corporate group, under this Policy.

We do not sell the content of your conversations, screenshots, photos or voice answers, and we never share it with advertising partners.

8. AGE LIMITATION

SPARK is only for people aged 18 and over. We don’t knowingly process data of anyone under 18. If you believe a minor has used SPARK, contact us and we will delete the data and close the account. Uploading content that depicts or concerns a minor in a sexual context is prohibited and may be reported to authorities.

9. INTERNATIONAL DATA TRANSFERS

We and our providers, including OpenAI, may process data outside your country, including in the United States. For transfers from the EEA/UK to countries without an adequacy decision, we rely on the European Commission’s Standard Contractual Clauses (and the UK Addendum) or on adequacy decisions, such as the EU‑U.S. Data Privacy Framework where the recipient is certified.

10. DATA RETENTION AND SECURITY

• Screenshots and photos: deleted from our servers within 30 days after processing, or sooner if you delete them.
• Conversation text and results: kept in your History until you delete them or your account.
• Voice recordings: deleted right after transcription.
• An unfinished baseline test: cleared after 10 minutes in the background.
• Account, progress and preferences: kept while your account is active; deleted within 30 days after account deletion.
• Purchase and trial records: kept as long as tax law requires and as long as needed to prevent repeated trial use.

Data may be kept longer if it’s relevant to a legal claim. We use encryption in transit and at rest, access controls and vetted providers, but no system is 100% secure.

11. U.S. STATE PRIVACY NOTICE

This section applies to residents of U.S. states with consumer privacy laws (e.g. California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia). For California residents, it is also our Notice at Collection.

11.1. Categories we collect and why

11.2. Sharing

In the past 12 months we disclosed the categories above to service providers for business purposes (Section 7). We don’t sell personal information for money. Sharing identifiers, app activity and purchase events with advertising partners for targeted ads may count as a “sale” or “sharing” under some state laws. We never share conversation, photo or voice content this way, and we don’t knowingly sell or share data of anyone under 18.

11.3. Your rights

Depending on your state, you may have the right to know, access, delete, correct, receive a portable copy, opt out of sale, sharing and targeted advertising, limit use of sensitive personal information, withdraw consent, and not be discriminated against for using these rights. Email [email protected] or write to us via our contact form at puredating.club (use the subject “Do Not Sell or Share” or “Limit Sensitive Information” for those requests). We verify requests using details like your account email and purchase date. Authorised agents need written permission or a power of attorney. If we deny a request you can appeal by replying to our decision, and then contact your state Attorney General. California residents may also request our “Shine the Light” disclosure once a year.

12. CHANGES AND CONTACT

We may update this Privacy Policy. For material changes, we’ll notify you in the app or by email before they take effect. Continuing to use the Service after that means you accept the updated Policy.

Questions about your data or previous versions of this Policy: [email protected] or via our contact form at puredating.club. General support: [email protected] or via our contact form at puredating.club.

Effective as of: 8 October 2026