Privacy policy

This Privacy Policy describes how Spark (“Spark”, the App) handles information when you use our mobile application (“App”). The App is operated by Thjis, registered in the Netherlands (“Thjis”, “we”, “us”, “our”). By using the App, you agree to this policy together with our Terms of Use.

Summary

Spark is built for in-person play and does not require you to create an account. We do not collect, store, or process personal data on our own servers for analytics, advertising, or user profiling. We do not sell personal information or share it for cross-context behavioural advertising.

Data controller (EU / UK)

For the purposes of the EU General Data Protection Regulation (“GDPR”) and the UK GDPR / Data Protection Act 2018, the controller is Thjis, registered in the Netherlands. For privacy requests, contact us at the email below. You may also lodge a complaint with a supervisory authority, including the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or, if you are in the UK, the ICO.

What we do not do

• We do not ask for your name, email, or phone number to use the App.
• We do not run first-party in-app analytics or ad networks that identify you across apps or sites.
• We do not build marketing profiles from your use of the App.

Information on your device

The App may store preferences and similar data locally on your device (for example, settings or progress) so the App works offline and remembers your choices. That information stays on your device unless you delete the App or clear app data, unless a platform feature syncs it under your Apple or Google account according to their policies.

RevenueCat (subscription SDK)

We use RevenueCat, Inc.’s software development kit (“RevenueCat SDK”) to manage in-app purchases and subscriptions. RevenueCat may process technical identifiers and subscription-related data on our behalf (for example, to validate entitlements with Apple or Google). RevenueCat acts as a processor under the GDPR where applicable. How RevenueCat handles data is described in its privacy policy: revenuecat.com/privacy.

Purchases and payment platforms

Paid subscriptions and trials are billed and managed by Apple (App Store) or Google (Google Play), not by us directly. When you subscribe, those companies process payment and subscription data (such as your Apple ID or Google account, transaction identifiers, and subscription status) under their own privacy policies. We do not receive your full payment card details.

• Apple: apple.com/legal/privacy
• Google: policies.google.com/privacy

Offers, pricing display, and product tests

We may show different subscription offers, prices, or paywall layouts to different users based on factors such as region, language, app store country, device type, or similar segments (for example, A/B tests). Segmentation is done in line with platform rules and this policy. Prices we describe on our website or in the App are typically shown in USD; Apple or Google may display charges in another currency at checkout.

Legal bases (EU / UK)

Where the GDPR or UK GDPR applies, we rely on: contract (to provide the App and honour purchases as mediated by stores and RevenueCat), legitimate interests (to secure the App, prevent abuse, and communicate about support you request), and legal obligation where required. We do not rely on consent for third-party advertising because we do not run such advertising in the App.

International transfers

RevenueCat, Apple, and Google may process data in the United States and other countries. Where required, they use appropriate safeguards (such as Standard Contractual Clauses) as described in their respective policies.

Retention

We do not maintain a central database of App users. Support emails are kept only as long as needed to handle your request and for ordinary business, legal, and tax records. Processors such as RevenueCat, Apple, and Google retain data according to their own policies.

Your rights (EU / UK)

Where applicable, you may have the right to access, rectify, erase, restrict, or object to certain processing, and to data portability. To exercise these rights against Thjis, email us at the address below. Because we do not operate user accounts in the App, there may be little or nothing we hold beyond support correspondence. For subscription or payment records, Apple or Google provide self-service tools in your store account.

California residents (CPRA)

This section applies to California residents and supplements the information above. In the preceding twelve months, we have not sold or shared personal information as those terms are defined under the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). We do not use or disclose sensitive personal information for inferring characteristics or for purposes that would require a “Limit the Use of My Sensitive Personal Information” link under the CPRA.

Categories. We do not operate the App in a way that collects the traditional CCPA categories from you directly (identifiers, commercial information, etc.) beyond what you voluntarily send in support email. Apple, Google, and RevenueCat may process identifiers and subscription-related data as described above and in their notices.

Your rights. You may have the right to know, delete, and correct personal information, and to opt out of sale/sharing (not applicable here). To submit a request, contact us at the email below. We will not discriminate against you for exercising CCPA rights. You may designate an authorized agent where permitted by law; we may require proof of authorization.

Support and communications

If you email us for support, we receive the information you choose to send (such as your email address and message content) only to respond to you. We do not use support emails for marketing unless you ask us to.

Legal and safety

We may preserve or disclose information if we believe in good faith it is required by law, legal process, or to protect the rights, safety, or integrity of users or the public.

Children

The App is not directed at children under 13 (or the minimum age required in your country to consent to data processing). If you are not old enough, please do not use the App.

Changes to this policy

We may update this Privacy Policy at our discretion. We will post the revised version on this page and update the “Last updated” date. Unless a shorter period is required by law or by an app store, we will notify users at least one (1) month before changes take effect (for example via an in-app notice, email if we have your address from support, or another reasonable method). Changes apply from the effective date stated in the notice. Continued use of the App after that date means you accept the updated policy, except where applicable law requires your separate consent.

Contact

For privacy questions, contact Thjis at: me@thjis.com