Privacy.

Operator and Controller

Spark Pro is operated from the United Arab Emirates by SDFY Innovations Ltd, registration number 01010939, license number 07010912. Registered office: Office A, RAK DAO Business Centre, RAK BANK ROC Office, Ground Floor, Al Rifaa, Sheikh Mohammed Bin Zayed Road, Ras Al Khaimah, United Arab Emirates.

For privacy questions, access requests, account data, or legal notices, contact support@sparkswarm.ai. Additional tax, invoice, or rail-specific disclosures may be shown in checkout, receipts, invoices, or this page where required.

Data We Collect

We may process account identifiers, email addresses, password credential records, GitHub or Google profile identifiers, wallet addresses, signed wallet verification messages, x402 payment metadata, session data, IP-derived security signals, device approvals, access codes, drop delivery events, package fingerprints, canary or abuse signals, support messages, and operational logs.

We do not ask for wallet seed phrases or private keys. We do not intentionally collect sensitive personal data such as government IDs, health data, biometric data, precise location, or payment-card numbers for the current x402 rail.

How We Use It

We use this data to verify access, authenticate members, bind lifetime wallets to accounts, process x402 access, deliver private packages, operate hosted tools, prevent abuse, protect drops from unauthorized sharing, recover accounts, reconcile purchases, improve member flows, comply with legal obligations, and communicate about Spark Pro.

Legal Bases and Purposes

Depending on your location and the data involved, we process data to perform the Spark Pro agreement, comply with legal obligations, protect legitimate security and business interests, handle support or disputes, prevent fraud and abuse, and use consent where required for optional communications or optional tracking.

Payments

x402 purchases are processed through the relevant payment rail, wallet, facilitator, and onchain network. We store the records needed to confirm access and reconcile purchases, including transaction hash, payer wallet, receive wallet, network, terms version, grant metadata, and settlement response data. Stripe/card rails are prepared for later but are not the current launch rail, and Spark does not store full card data.

Security and Abuse Prevention

We may use session records, device approvals, delivery logs, package fingerprints, canaries, wallet records, rate-limit events, and support evidence to detect unauthorized sharing, credential abuse, payment disputes, package leaks, fraud, or attempts to bypass member gates. These records may be retained where needed to protect members, investigate abuse, preserve evidence, or comply with legal duties.

Sharing

We may share data with hosting, database, storage, email, security, identity, payment, wallet, blockchain, package delivery, analytics, legal, accounting, and support providers that help run Spark Pro. We do not sell member account data. We may disclose information if required by law, to enforce terms, to protect rights and security, or as part of a merger, acquisition, financing, restructuring, or transfer of the Spark Pro business.

International Transfers

Spark operates from the UAE, but service providers, wallets, infrastructure, support tools, and blockchain systems may process or expose data in other countries. Where required, we use contractual, technical, and organizational safeguards intended to protect personal data during cross-border transfer and processing.

Retention

We keep account and access records while your account is active and for as long as needed for security, delivery, support, accounting, payment reconciliation, tax, dispute handling, abuse prevention, legal compliance, or backup integrity. We may keep limited records after deletion requests where retention is legally required or necessary to protect Spark Pro and other members.

Your Choices

You can contact us to ask about access, correction, deletion, restriction, objection, portability, consent withdrawal, or information about account and access records. Some rights depend on your location and the legal basis for processing. Some records may be retained where needed for security, fraud prevention, accounting, payment reconciliation, dispute handling, abuse evidence, or legal reasons.

Marketing

We may send service messages about login, access, payment, security, drops, and policy updates. Optional marketing or retargeting should use consent or another lawful basis where required, and you can ask us to stop non-essential marketing messages.

Automated Decisions

Security systems may flag suspicious activity, rate-limit requests, or pause access for review. Spark does not currently use fully automated decisions that create legal or similarly significant effects without a support review path.

Children

Spark Pro is intended for adults and is not directed to children. Do not use Spark Pro if you are under 18 or unable to enter a binding agreement.

Applicable Law

We operate from the UAE and aim to handle personal data in line with applicable UAE privacy, consumer-protection, electronic-commerce, and international data-protection requirements, without limiting any mandatory rights that may apply.

Updates

We may update this policy as Spark Pro, payment rails, identity providers, analytics, package delivery, or legal requirements change. Material changes will be posted here or shown in the product where appropriate.