SparkoAI Privacy Policy

Effective Date: 2026.8.17

Last Updated: 2026.8.17

Welcome to SparkoAI.

NAVIEMU PTE. LTD ("SparkoAI," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, store, disclose, transfer, and protect personal data when you access or use the SparkoAI app, website, features, content, products, and related services (collectively, the "Services").

By using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services.

1. Scope of This Privacy Policy

This Privacy Policy applies to personal data processed by us in connection with the Services. It does not apply to third-party websites, platforms, products, or services that are not owned or controlled by us, even if they are linked from or integrated with the Services.

For the purposes of this Privacy Policy, "personal data" means information that identifies, relates to, describes, or could reasonably be linked to an identified or identifiable individual. Personal data does not include information that has been irreversibly anonymized or aggregated so that it can no longer reasonably identify you.

2. Personal Data We Collect

Depending on how you use the Services, we may collect the categories of personal data described below.

2.1 Information You Provide to Us

We may collect information that you provide directly, including:

  • Automatically created account information, such as a unique internal account identifier and account settings. When you first use the Services, we automatically create an account associated with your device or installation so that you can access and manage your generated content. We do not provide third-party or social-media login.
  • Contact information, such as email address and information you provide when contacting customer support.
  • User content, such as photos, videos, text, prompts, comments, feedback, uploaded materials, generated outputs, project history, saved creations, and other content you submit, create, upload, edit, save, or share through the Services.
  • Survey, feedback, or support information, such as messages, requests, ratings, bug reports, and other communications you send to us.

2.2 Payment and Subscription Information

If you make purchases or subscribe to paid features, we may collect order-related information, such as product type, subscription status, transaction time, order number, price, country or region, device identifier, IP address, and payment channel information.

Payments may be processed by third-party platforms or payment providers, such as Apple App Store, Google Play, or other payment processors. We do not directly collect or store your full credit card number or payment card security code unless expressly stated otherwise.

2.3 Device, Log, and Usage Information

When you use the Services, we may automatically collect technical and usage information, including:

  • Device type, model, operating system, browser type, app version, language, time zone, network provider, and mobile carrier.
  • Device identifiers, installation identifiers, advertising identifiers, and similar identifiers, such as IDFA, Android Advertising ID, IDFV, or other platform identifiers where available and permitted.
  • IP address, approximate location derived from IP address, crash logs, diagnostic information, system activity, access times, referral URLs, pages or features viewed, interactions with content, and the time and duration of your activities.
  • Information about how you interact with features, subscriptions, prompts, generated outputs, notifications, and other Services.

2.4 Camera, Photos, Videos, and Local Files

With your permission or at your direction, the Services may access your camera, photo library, videos, or files stored on your device to provide features such as upload, editing, AI generation, filters, effects, templates, video creation, export, and sharing.

Camera access is used only when you choose to take photos for your project. Photo library access is used when you choose existing media as input or save generated images or videos.

You may disable or change these permissions through your device system settings. If you do so, some features of the Services may not function properly.

2.5 AI Processing Data

SparkoAI provides AI image and video generation features. When you use these features, the photos, videos, prompts, and related content you choose to submit are transmitted through APIs to our backend services and, depending on the requested feature, to ByteDance and Alibaba Cloud third-party image model services solely to process your request and generate the requested output.

By choosing to submit content for AI generation, you direct us and the applicable service providers to process that content for the requested feature. We do not use your uploaded photos, videos, prompts, or generated outputs to train, retrain, or fine-tune SparkoAI's models or the applicable third-party providers' models.

2.6 Face-Containing Media and Biometric Information

To provide AI image and video generation features, SparkoAI processes photos and videos that users choose to upload. These photos and videos may contain a user's face or the faces of other individuals.

SparkoAI does not collect, create, retain, or use facial geometry, facial landmarks, faceprints, biometric templates, or other biometric identifiers. We do not perform facial recognition, face matching, identity verification, or authentication using facial data.

Face-containing photos and videos are used solely to provide the requested AI image and video generation service. They are not used for advertising, behavioral profiling, identity identification, or model training. Original user-uploaded photos and videos are automatically deleted after the generation process is completed.

2.7 Location Information

We may collect approximate location information, such as location inferred from your IP address. We may collect precise geolocation only with your permission and only where needed for a feature, analytics, fraud prevention, compliance, or other purposes disclosed to you.

You can disable location permissions through your device system settings. This may affect some location-based features.

2.8 Analytics, Advertising, and Tracking Technologies

We and our service providers may use cookies, mobile cookies, pixels, SDKs, local storage, web beacons, device identifiers, and similar technologies to:

  • Provide, protect, and improve the Services.
  • Understand usage trends and measure performance.
  • Detect fraud, abuse, security incidents, and technical issues.
  • Personalize content, recommendations, or advertisements where permitted by law.
  • Measure advertising effectiveness and attribution.

Where required by platform rules, including Apple's App Tracking Transparency framework, we will request your permission before using your device's advertising identifier or tracking your activity across apps and websites owned by other companies for advertising or measurement purposes.

You may be able to limit personalized advertising, deny tracking permission, or reset advertising identifiers through your device or platform settings.

2.9 No Third-Party Login

SparkoAI does not offer third-party or social-media login. We automatically create an internal account identifier when you first use the Services.

3. How We Use Personal Data

We may use personal data for the following purposes:

  • To provide, operate, maintain, and improve the Services.
  • To create, manage, and secure automatically created user accounts and associated generated content.
  • To process purchases, subscriptions, refunds, customer support, and service notices.
  • To provide AI generation, editing, filters, effects, templates, recommendations, and other requested features.
  • To process user content, prompts, images, videos, metadata, and generated outputs as needed to provide the Services.
  • To moderate content, detect abuse, enforce our policies, and maintain a safe service environment.
  • To personalize features, content, recommendations, and advertising where permitted by law.
  • To analyze usage, performance, crashes, and trends.
  • To detect, prevent, and investigate fraud, abuse, security incidents, policy violations, and illegal activity.
  • To enforce our terms, policies, and rights.
  • To communicate with you about updates, notices, support, security alerts, and changes to the Services.
  • To comply with legal obligations and respond to lawful requests from public authorities.
  • For other purposes disclosed to you at the time of collection or with your consent.

4. Legal Bases for Processing

Where applicable law requires a legal basis for processing personal data, we rely on one or more of the following:

  • Performance of a contract, where processing is necessary to provide the Services you requested.
  • Consent, where you have given permission, such as for certain device permissions, precise location, sensitive data, tracking, or marketing communications.
  • Legitimate interests, such as improving the Services, securing our systems, preventing fraud, enforcing policies, and understanding how users interact with the Services, provided that such interests are not overridden by your rights and interests.
  • Legal obligations, where processing is necessary to comply with applicable laws, regulations, legal processes, or governmental requests.
  • Protection of rights and safety, where necessary to protect users, us, third parties, or the public.

5. How We Share Personal Data

We may share personal data in the following circumstances:

5.1 Service Providers

We may share personal data with vendors, processors, and service providers that help us operate the Services, including cloud hosting providers, AI infrastructure providers, AI model providers, content moderation providers, analytics providers, customer support tools, payment processors, security providers, advertising partners, attribution providers, and technical service providers.

These parties may process personal data only as needed to provide services to us or as otherwise permitted by law. We require our service providers and partners that process personal data on our behalf to provide the same or equivalent level of protection as described in this Privacy Policy and to process personal data only for permitted purposes.

5.2 Third-Party AI Service Providers

When you choose to use AI generation features, we transmit the photos, videos, prompts, metadata, and related technical information that you submit through APIs to ByteDance and Alibaba Cloud third-party image model services, depending on the requested feature. These providers process the submitted content solely to generate the output you requested.

We do not authorize ByteDance, Alibaba Cloud, or other applicable third-party AI service providers to use your submitted content to train, retrain, or fine-tune their models.

5.3 Affiliates and Corporate Transactions

We may share personal data with our affiliates for the purposes described in this Privacy Policy. If we are involved in a merger, acquisition, reorganization, financing, bankruptcy, sale of assets, or similar transaction, personal data may be transferred as part of that transaction, subject to applicable law.

5.4 Legal, Safety, and Enforcement Purposes

We may disclose personal data if we believe in good faith that disclosure is necessary or appropriate to:

  • Comply with applicable law, legal process, or governmental requests.
  • Protect the rights, property, safety, or security of us, users, third parties, or the public.
  • Detect, prevent, or investigate fraud, abuse, security incidents, or illegal activity.
  • Enforce our terms, policies, and agreements.

5.5 Advertising and Analytics Partners

Where permitted by law and, where required, with your consent, we may share limited device, usage, advertising, or analytics information with advertising, attribution, and measurement partners to help measure and improve advertising performance, provide more relevant content or advertisements, and understand usage trends.

We do not sell personal data for money. Some privacy laws may define certain advertising or analytics sharing as "sale," "sharing," or targeted advertising. Where applicable, you may have the right to opt out of such activities.

5.6 With Your Direction or Consent

We may share personal data when you direct us to do so, such as when you share generated content to a third-party platform, submit content for AI generation, or otherwise give consent.

6. Content Review and Safety

We may use automated systems and, where necessary, limited human review to detect abuse, enforce our policies, investigate safety issues, respond to support requests, improve service reliability, and comply with legal obligations.

Human review, when used, is limited to personnel or service providers with a need to know and is subject to appropriate confidentiality and security measures.

7. International Data Transfers

We provide Services to users globally. Your personal data may be processed in countries or regions other than where you live. These countries or regions may have data protection laws that differ from those in your jurisdiction.

Where required by applicable law, we use appropriate safeguards for international transfers, such as contractual protections, consent, adequacy mechanisms, or other lawful transfer mechanisms.

8. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain account records, comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, and maintain security.

Retention periods may vary depending on the category of data, the nature of the Services, your settings, legal requirements, and operational needs.

Original photos and videos uploaded for AI generation are retained only for the time needed to complete the generation process and are automatically deleted after processing is complete.

Generated images and videos are stored in your automatically created SparkoAI account using Alibaba Cloud OSS in Singapore. Generated images and videos are retained for 180 days from creation, unless you delete them earlier. When you delete generated content through the Services, the related files are immediately deleted from our active storage.

Transaction and subscription records may be retained for as long as needed for accounting, tax, fraud prevention, dispute resolution, and legal compliance purposes.

Crash logs, diagnostic information, and security logs may be retained for a limited period needed to maintain service reliability, investigate issues, and protect the Services.

Face-containing original photos and videos are subject to the deletion practices described in Section 2.6.

9. Data Security

We use reasonable technical, administrative, and organizational measures designed to protect personal data from unauthorized access, disclosure, alteration, loss, misuse, or destruction.

However, no method of transmission or storage is completely secure. We cannot guarantee absolute security of your personal data.

10. Your Choices and Rights

Depending on your location and applicable law, you may have rights regarding your personal data, including the right to:

  • Access the personal data we hold about you.
  • Correct inaccurate or incomplete personal data.
  • Delete personal data.
  • Restrict or object to certain processing.
  • Withdraw consent where processing is based on consent.
  • Receive a copy of your personal data in a portable format.
  • Opt out of certain targeted advertising, sale, or sharing where applicable.
  • Limit the use or disclosure of sensitive personal data where applicable.
  • Lodge a complaint with a competent data protection authority.

You may revoke app permissions, including camera, photo library, notifications, location, and tracking permissions, through your device system settings.

SparkoAI automatically creates an account for you when you first use the Services. You may delete generated content directly through the Services. You may request deletion of your automatically created account by contacting us at support@sparkoai.ai. Account deletion will permanently delete the account and associated personal data, except for information we are required or permitted to retain by law, such as transaction records, fraud prevention records, dispute records, or security logs.

To exercise your rights, contact us at support@sparkoai.ai. We may need to verify your identity before responding to your request. We will respond within the timeframe required by applicable law.

11. Children's Privacy

The Services are not intended for children below the minimum age required by applicable law. We do not knowingly collect personal data from children under 16, or the equivalent minimum age in the relevant jurisdiction, without appropriate consent where required.

If you believe that a child has provided us with personal data in violation of this Privacy Policy, please contact us at support@sparkoai.ai. We will take appropriate steps to delete the data where required by law.

12. AI-Generated Content and User Responsibility

SparkoAI may use generative artificial intelligence to process images, videos, prompts, and other content and to generate outputs. AI-generated outputs may be synthetic, inaccurate, unexpected, incomplete, similar to other outputs, or unsuitable for a particular purpose.

You are responsible for the content you submit to the Services and for how you use, download, publish, or share generated content. You must ensure that your use of the Services and generated content complies with applicable laws, third-party platform rules, and the rights of others.

13. Region-Specific Notices

13.1 European Economic Area, United Kingdom, and Similar Jurisdictions

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with similar data protection laws, you may have rights to access, rectify, erase, restrict, object to processing, receive data portability, withdraw consent, and lodge a complaint with a supervisory authority.

Where required, we process personal data based on legal bases such as contract necessity, consent, legitimate interests, legal obligations, and protection of rights and safety.

13.2 California Residents

If you are a California resident, you may have rights under applicable California privacy laws, including the right to know, access, delete, correct, opt out of certain sale or sharing of personal information, limit certain uses of sensitive personal information, and not be discriminated against for exercising your privacy rights.

We do not sell personal information for money. If our advertising or analytics practices are considered a "sale" or "sharing" under applicable California law, you may have the right to opt out by contacting us at support@sparkoai.ai or by using available device, browser, or platform settings where supported.

13.3 Brazil Residents

If you are located in Brazil, you may have rights under Brazil's General Data Protection Law (LGPD), including rights to confirm processing, access data, correct incomplete or inaccurate data, request anonymization, blocking or deletion of unnecessary or excessive data, request data portability, delete data processed with consent, obtain information about sharing, withdraw consent, and request review of certain automated decisions where applicable.

For Brazilian users, photos and videos that may contain faces are processed only as needed to provide the requested feature, unless we obtain separate explicit consent for another purpose. We do not use such content for behavioral advertising, emotional analysis, identity identification, or AI model training without separate explicit consent where required.

Parents or legal guardians may contact us at support@sparkoai.ai to request review, management, or deletion of a child's personal data where required by applicable law.

14. Cookies and Similar Technologies

Cookies are small text files or similar technologies stored on your browser or device. We may use cookies, SDKs, local storage, pixels, web beacons, and similar technologies to provide, secure, analyze, improve, personalize, and advertise the Services.

You can manage cookies and similar technologies through your browser, device, or platform settings. Disabling some technologies may affect the availability or functionality of the Services.

15. Third-Party Websites, Platforms, and Services

The Services may contain links to or integrations with third-party websites, platforms, app stores, payment processors, social media services, analytics tools, advertising networks, attribution providers, cloud providers, AI service providers, or other services.

We are not responsible for the privacy practices, security, content, or policies of third parties that are not acting on our behalf. Please review the privacy policies of third-party services before using them.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, technologies, legal requirements, or business practices.

If we make material changes, we will take reasonable steps to notify you, such as by posting the updated Privacy Policy in the Services, displaying an in-app notice, or using other appropriate methods.

Your continued use of the Services after the updated Privacy Policy becomes effective means that you acknowledge the updated Privacy Policy.

17. Contact Us

If you have any questions, complaints, requests, or concerns about this Privacy Policy or our privacy practices, please contact us:

Operator: NAVIEMU PTE. LTD

Contact Email: support@sparkoai.ai

IP Complaint Email: support@sparkoai.ai

Official Website: https://www.sparkoai.ai/

NAVIEMU PTE. LTD

2026.8.17