Privacy Policy

Tangent Works LLC, a Wyoming (USA) limited liability company, acting as the editor and operator of the Sparkles product ("we", "our", or "us"), is committed to protecting your privacy. This Privacy Policy describes how we collect, use, and share your personal information when you use the Sparkles mobile and web application ("App") and any related services (collectively, the "Services").

By accessing or using our Services, you agree to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree with our policies and practices, please do not use our Services.

1. Information We Collect

We collect the following types of personal data when you use Sparkles:

A. Information You Provide Directly

• Account Information: When you create an account, we collect information such as your username, email address, and display name.
• User-Generated Content: The core functionality of Sparkles relies on the content you create and exchange with the AI companion. This includes your chat conversations, photos, and any other text or media you upload.
• Purchase Information: If you make a purchase, we collect payment details through our third-party payment processor.

B. Information We Collect Automatically

• Device and Usage Data: We automatically collect information about your use of the Services, such as your IP address, device type, operating system, browser type, and information about how you interact with the App.

C. Cookies and Tracking Technologies

We use cookies and similar technologies (e.g., pixels) for analytics and marketing purposes. Third-party services like Google Analytics, Hotjar, and Meta Ads may collect information about your behavior on our platform.

2. How We Use Your Information

• To Provide and Personalize the Services: To operate and maintain the Services, to provide you with a personalized experience with your AI companion.
• To Improve and Train Our AI Models: We use the content you provide to train and fine-tune our AI models.
• To Process Transactions: To process your purchases of in-app items and manage subscriptions.
• For Analytics and Research: To analyze usage patterns and monitor the performance of the App.

3. Legal Bases for Processing

• Your Consent: For data uploads, tracking, and the use of sensitive information.
• Contractual Necessity: To deliver the services you have requested.
• Legitimate Interests: For fraud prevention, security, and analytics.

4. Sharing of Your Information

We do not sell your personal data. However, we may share it with:

• Trusted Third-Party Service Providers: For cloud hosting, data analysis, payment processing, and image generation.
• Analytics and Advertising Partners: Such as Google Analytics, Hotjar, and Meta Ads.
• Legal and Regulatory Authorities: When required by law or to protect our rights.

5. Biometric and Sensitive Data

If you upload biometric, erotic, or sensitive content, you grant Sparkles the right to process it solely:

• To provide personalized responses or features.
• To improve the service and train AI models.

6. International Transfers

Your data may be stored or processed outside of your country, including in the EU or the US. We take appropriate safeguards to protect your data.

7. Your Privacy Rights

Depending on your jurisdiction, you may have the following rights:

• Access to your personal information
• Correction of inaccurate data
• Deletion of your data ("Right to be Forgotten")
• Data portability
• Withdrawal of consent

8. Data Retention

We will retain your personal information as long as your account is active or as needed to provide you with the Services. Financial and transaction records are kept for the period required by applicable tax and accounting law (generally up to ~10 years). When we no longer need your information, we delete or anonymize it; some data is removed shortly after account deletion, and backups are overwritten on our regular rotation cycle.

9. Security Measures

We implement commercially reasonable security protocols to protect your personal information, including encryption and access restrictions.

10. Children

Sparkles is strictly for users aged 18 or older. We do not knowingly collect data from minors.

11. Updates to This Policy

We may update this Privacy Policy from time to time. If significant changes are made, we will notify you through the Service.

12. Your U.S. State Privacy Rights (CCPA/CPRA & other states)

If you are a U.S. resident (for example in California, Colorado, Connecticut, Virginia, Texas, Utah or Oregon), you have additional rights under your state privacy law:

• We do not “sell” or “share” your personal information (as defined by the CCPA/CPRA) and do not use it for cross-context behavioral advertising.
• Right to know and access the categories and specific pieces of personal information we collect.
• Right to request deletion of your personal information.
• Right to correct inaccurate personal information.
• Right to opt out of any sale/sharing or targeted advertising.
• Right to limit the use of sensitive personal information.
• Right not to be discriminated against for exercising these rights.

To exercise these rights or appeal a decision, contact us at contact@sparkles-app.com or use our “Your Privacy Choices” link. We verify requests and respond within statutory deadlines; an authorized agent may submit a request on your behalf.

13. Contact Us

If you have any questions about this Privacy Policy, please contact us:

• Email:contact@sparkles-app.com
• Address: 75 E 3rd St, Sheridan, WY 82801, USA
• Website: https://www.sparkles-app.com