Privacy policy
Welcome to the sparx Policy (“Policy”)! This explains how we collect, store, protect, and share your information.
INTRODUCTION
The sparx mobile application (referred to as the “App”), our websites, including sparx.samalan.com and samalancorp.com, and our digital products and services, such as competitions, marketing and surveys, are collectively termed as our “Sites.” In this Policy, the term “Services” encompasses the use of our App and Sites, along with all related services.
For the purposes of this Policy, “You” or “User” refers to any natural or legal person who agrees to become a buyer or User on the App and Sites, which is confirmed through the provision of registration data on the App. You have the option to use the App or Sites to share information with other Users, including friends who are also Users. Occasionally, it may be necessary for us to share your information. The App and Sites are operated by Samalan Corporation (OPC) Private Limited, also referred to in this Policy as “Samalan Corporation”, “We”, “Organisation”, or “Us”. We are the controllers of personal information collected and processed through the sparx App and Sites.
CONTACT
Contact Us:
- App: hello.sparx@samalan.com
- Organisation: hello.sparx@samalan.com
YOUR ACCOUNT
Usually, We collect personal data which includes but is not limited to:
Registration Information: When You download the App and create an account (“Account”), We collect certain information (“Registration Information”) about You, such as:
- Name
- Email address
- Phone number
- Gender identity
- Date of birth
- Photographs
- Location
- Education
- Work title
- Hometown
- About You (bio)
- Languages spoken
- Your interests and hobbies
Once You register, You will be able to review and change this information at any time just by logging in to sparx (other than your name, date of birth and location (which, if You have given sparx access to your location in your device settings, is automatically updated based on the location of your device)) before the Account verification. It is your responsibility to ensure that your Account details are kept up to date. Please contact Us if You need to change your phone number. We recommend and encourage You (and all our members) to think carefully about the information You disclose about yourself. We also do not recommend that You put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ license details and other sensitive information which is open to abuse and misuse on your profile.
When You post information about yourself or use the messaging function to communicate with other Users, the amount of personal information You share is at your own risk.
Profile Verification Information: For safety and security and to ensure You have the best possible User experience, We require Users to verify their Accounts through a video call with their government ID. We want to avoid fake sparx Accounts being created. This verification is required by Us for the prevention of fraud. We do not add the verification photos to your profile. We retain these photos so that We can verify You in the future and for our record-keeping purposes until We no longer need them for such purposes or for three years after your last interaction with Us, whichever occurs first. After the applicable retention period expires, We take commercially reasonable steps to permanently and securely delete the scans from our systems.
Geolocation Information: If You have given sparx access to your location in your device settings, when You use the App, We will collect information about your location such as longitude and latitude and save your device’s coordinates to offer certain features to You. This information helps Us identify your physical location and We use it to personalize the App and make it easier for You to interact with other Users.
Device Information: We may collect information about your device when You use the App including the unique device identifier, device model, and operating system, for a number of purposes, as set out in this Policy.
Surveys and other Contributions: From time to time, We run surveys for research purposes and We may contact You to find out if You would like to take part. We may also contact You to find out if You would like to provide feedback, a testimonial or take part in marketing campaigns. Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. If You do not wish to be contacted to take part in a survey or marketing campaign, please contact Us via email provided.
Customer Support: If You contact our Customer Support team, We will receive your email address, and may track your IP address, as well as the information You send to Us to help resolve your query. We will keep records of our communications with You, including any complaints that We receive from You about other Users ( and from other Users about You ) for 6 years after deletion of your Account.
USE OF YOUR INFORMATION
In order to deliver an enjoyable experience to You, We may use your Registration and other information to:
- offer You our Services and features;
- to improve and optimize the Services;
- contact You with information about the App (e.g., updates and new features);
- personalize the App/Sites and the content We deliver to You;
- conduct research and analytics about how You use and interact with the App/Sites;
- to test new technologies and processes designed to enhance and improve the App/Sites;
- resolve disputes, troubleshoot problems and to enforce our Terms & Conditions;
- for customer support;
- investigate fraud, protect our legal rights; and
- protect our Users and third parties from harm.
OUR MATCHING ALGORITHM
We have developed matching algorithms to predict your compatibility with other Users and so We can show You people We think are a good match for You. Our matching algorithms use the following data about You to predict your compatibility with others and generate profile recommendations:
- the things You tell Us about yourself in your profile;
- your location; and
- information about your activity in our App
DISCLOSURE OF INFORMATION TO THIRD PARTY
Your personal data may be disclosed by Us to third parties. This disclosure may be required for Us to provide You access to our Services, to comply with our legal obligations, in business transfers, to enforce our Terms and Conditions to facilitate our marketing and advertising activities, or to prevent, detect, mitigate, and investigate fraudulent or illegal activities related to our Services. We do not disclose your personal data to third parties for their marketing and advertising purposes without your explicit consent. We may disclose personal data if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process.
AGE
sparx does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If You are less than 18 years old, We request that You do not submit information to Us. If We become aware that a child, minor or anyone under the age of 18 has registered with Us and provided Us with personal information, We will take steps to terminate that person’s registration.
INVITING FRIENDS
If You refer a friend to sparx , You will send an email message, WhatsApp message, SMS, Messenger message to the contact details You submitted to Us. We won’t share these details with anyone else. By choosing to invite your friend to join sparx , You confirm that your friend is happy to receive the invitation. You also hereby agree to indemnify and hold sparx harmless from all claims arising out of your messages to any person through sparx . You must and will not use our invite friends feature to send spam.
USER RIGHTS
- Right of Access: You can request a copy of your data.
- Right to Rectification: Users have the right to request the rectification of inaccurate or incomplete personal data.
- Right to Erasure (Right to be Forgotten): Users have the right to request the erasure of their personal data under certain circumstances. This right is not absolute and may not apply in certain situations, such as when We are required to retain data for legal reasons.
- Right to Restriction of Processing: Users have the right to request the restriction of processing of their personal data in certain situations. If You contest the accuracy of your personal data or if the processing is unlawful, You may request restriction.
To exercise these rights, please contact Us through the provided contact details.
CONSENT AND CONTROL
Explicit Consent:
By using the sparx App and Sites, You acknowledge and agree that We collect, process, and store your personal data as outlined in this Privacy Policy. We emphasize the importance of obtaining explicit consent for specific data processing activities. You have the right to withdraw your consent at any time. To withdraw your consent or modify your preferences, contact Us using the details provided in the Contact section of this Privacy Policy.
COOCKIE POLICY
Our Sites may use cookies to enhance your User experience. Cookies are small pieces of data stored on your device that help Us improve our Services and provide a more personalized experience.
Types of Cookies Used:
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Essential Cookies: These cookies are necessary for the proper functioning of Sites.
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Analytics Cookies: We use analytics cookies to understand how Users interact with our content, which helps Us improve our Services.
Managing Cookies:
You have the option to manage your cookie preferences. By accessing your browser settings, You can control and delete cookies. Please note that disabling certain cookies may affect the functionality of Sites.
Consent:
By continuing to use Sites, You consent to the use of cookies as described in this Cookie Policy. If You do not agree with the use of cookies, You may adjust your browser settings or refrain from using Sites.
Updates to Cookie Policy:
We reserve the right to update this Cookie Policy to comply with new legal requirements or reflect changes in how We use cookies.
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SECURITY
We pride ourselves on taking all appropriate security measures to help protect your information against loss, misuse, and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information, such as secured servers using firewalls.
Data Breach Notification:
In the unfortunate event of a data breach compromising your personal data, We are committed to notifying You and relevant authorities promptly. Our procedures for data breach notification include:
- Timely Notification: We will notify affected Users without undue delay once We become aware of a data breach that poses a risk to their rights and freedoms.
- Information Provided: The notification will include details about the nature of the breach, the types of data affected, and the measures We are taking to address the situation.
- Coordination with Authorities: We will work closely with relevant data protection authorities in compliance with the Digital Data Protection Law to ensure transparency and adherence to legal requirements.
- User Guidance: Alongside notifications, We will provide guidance on steps Users can take to mitigate potential risks and protect their information.
If You suspect a data breach or have concerns about the security of your data, please contact Us immediately through the provided contact details.
Unfortunately, no website or internet transmission is ever completely 100% secure, and even We cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur.
STORAGE AND TRANSFER OF DATA
We collect and store your personal data in India. Payment information (after We roll out payment options) is processed and securely stored within the territorial boundaries of India, adhering to data protection standards and regulatory requirements. The sparx app is free to use until We roll out payment options.
When You delete your Account, your personal data is deleted after 6 years of retention window. We only retain your email address and phone number in order to be able to contact You with regard to payment or other necessary matters. For internal use, We may store generic, non-personal data regarding your activity as a User (number of people invited, number of logins, term of your subscription, payment method, etc).
DATA RETENTION AND DELETION
We keep your personal information only as long as We need it for the legal basis relied upon (as set out above) and as permitted by applicable law.
When your Account is Deactivated or Paused, it won’t be visible within the App.
Pause - If You want to take a break, You can Pause your Account without needing to delete it. You can Pause for up to 30 days. After the Pause period, You must log in to reactivate your Account. Failing to log in within 10 days will result in your Account status being changed to ‘Deactivated’, and it will be permanently Deleted after 30 days.
Deactivate - You have up to 30 days to restore your Account in case it was Deactivated accidentally. After this 30-day period, your Account will be permanently Deleted. Following the retention period, We initiate the process of removing your personal information from our systems, except in cases where:
- We must keep it to comply with applicable law (for instance, if You make purchases within the App, some personal data may be kept for tax and Accounting purposes);
- We must keep it to evidence our compliance with applicable law (for example, if an Account is blocked, We keep some Account information and a record of the behavior that led to the block - this information is retained for evidential purposes in case of queries or legal claims concerning the block);
- there is an outstanding issue, claim, or dispute requiring Us to keep the relevant information until it is resolved; or
- the information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a User who was banned for unsafe behavior or security incidents from opening a new Account).
Warning: Even after You remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do We accept any liability for this. If You have given third-party applications or websites access to your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.
AMENDMENT
We reserve the right, at our sole discretion, to change, modify, add, or remove portions of this Policy at any time without prior written notice to You. It is your responsibility to periodically review the Policy for updates/changes. Your continued use of the App following the posting of changes will mean that You accept and agree to the revisions. As long as You comply with the Policy, We grant You a personal, non-exclusive, non-transferable license to enter and use the App. By implicitly or expressly accepting the Policy, You also accept and agree to be bound by our Organisation Policies and Terms, including but not limited to our Terms and Conditions, as amended from time to time.
Effective date
The Terms were last updated on 18th November, 2023.