Privacy Policy

Effective Date: June 19, 2025

Key Points

If you decide not to read this entire Privacy Policy, we want you to walk away with a few key points about our privacy practices:

• We use third-party cloud provider - Amazon Web Services - to process and edit photographs and messages.
• The App only uploads to the cloud the photographs that you specifically select for editing.
• Photographs are temporarily cached on the cloud servers during the editing process and encrypted using a key stored locally on your mobile device.
• Photographs and messages remain in the cloud for a limited period of 4 days.
• We do not use the photographs or messages you provide when you use the App for any reason other than to provide you with the App functionality.

Personal Information We Collect

When you use the App, we may collect information about you, including:

• Photographs you provide when you use the App, via your camera or camera roll (if you have granted us permission to access your camera or camera roll), the in-App internet search functionality, or your social media account (if you choose to connect your social media account). We obtain only the specific images you chose to modify using the App; we do not collect your photo albums even if you grant us your access to them. We encrypt each photograph that you upload using the App. The encryption key is stored locally on your device. This means that the only device that can view the photo is the device from which the photograph was uploaded using the App - the user's device. Please note that while we do not require or request any metadata attached to the photographs you upload, metadata (including, for example, geotags) may be associated with your photographs by default. We take steps to delete any metadata that may be associated with a photograph you provide when you use the App.
• Messages, if you choose to chat with the chatbots.
• App usage information, such as information about how you use the App and interact with us, including your preferred language, the date and time when you first installed the App and the date and time you last used the App.
• Purchase history, if you choose to purchase an App subscription, such as confirmation that you are a paid subscriber to the App.
• Social media information, if you choose to login to the App via a third-party platform or social media network (for example, Facebook), or otherwise connect your account on the third-party platform or network to the App. We may collect information from that platform or network, such as your social media alias, first and last name, number of "friends" on the social media platform and, if depending on your Facebook or other network settings, a list of your friends or connections (though we do not use or store this information). Our collection and processing of the information we obtain from social media platforms is governed by the requirements these social media platforms impose on us in their relevant terms and conditions.
• Device data, such as your computer and mobile device operating system type and version number, manufacturer and model, device ID, push tokens, Google Advertising ID, Apple ID for Advertising, browser type, screen resolution, IP address (and the associated country in which you are located), the website you visited before visiting our Site; and other information about the device you are using to visit the App.
• Online activity data, such as information about your use of and actions on the App and the Sites, including pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and certain third parties (e.g., online advertising networks and their clients) also may collect this type of information over time and across third-party websites and mobile applications. This information may be collected on our Site using cookies, browser web storage (also known as locally stored objects, or "LSOs"), web beacons, and similar technologies. We may collect this information directly or through our use of third-party software development kits ("SDKs"). SDKs may enable third parties to collect information directly from our App.

How We Use Your Personal Information

We do not use the photographs you provide when you use the App for any reason other than to provide you with the editing functionality of the App. We may use information other than photographs for the following purposes:

• To operate and improve the App:
  • Enable you to use the App's features;
  • Establish and maintain your account, if you choose to login to the App using your social media account;
  • Communicate with you about the App, including by sending you announcements, updates, and security alerts, which we may send through a push notification, and responding to your requests, questions and feedback;
  • Provide technical support and maintenance for the App; and
  • Perform statistical analysis about use of the App (including through the use of Google Analytics).
• To send you marketing and promotional communications. We may send you marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.
• To display advertisements to you. If you use the free version of the App, we work with advertising partners to display advertisements within the App. These advertisements are delivered by our advertising partners and may be targeted based on your use of the App or your activity elsewhere online.
• For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or Appropriate to: (a) protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
• With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
• To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes.

How We Handle Face Data

• Explicit statement on retention of face data: We do not retain face data or any photographs after 4 days. All face data is permanently deleted after this period.
• Reason for storing face data: Face data is temporarily stored to allow users to make additional edits to their photographs within the App. This enables a smoother user experience by ensuring users can continue editing without needing to upload their photographs again.
• Length of time face data is stored: Face data is stored for a maximum of 48 hours to provide users the opportunity to return and continue editing their photographs. After 48 hours, all data is automatically deleted from our servers to ensure user privacy.
• Third-party sharing of face data: We use third-party cloud providers (Amazon Web Services and Google Cloud Platform) for secure temporary storage of face data. These third parties are responsible for hosting the data during the 4 days period and do not retain or use the data beyond this period.
• Reasons for sharing face data with third parties: We share face data with AWS and Google Cloud solely for the purpose of providing secure storage and processing during the editing session. These third-party services are necessary to ensure the efficient functioning of our App and safeguard user data through encryption.
• Third parties storing face data: Amazon Web Services and Google Cloud Platform temporarily store face data during the 4 days editing period. After this time, the data is automatically deleted. These third-party services do not retain or store face data beyond the defined period.

How We Share Your Personal Information

We do not disclose user photographs or videos to third parties (with the exception of uploading an encrypted image to our cloud providers Google Cloud Platform and Amazon Web Services to provide the photo editing features of the App). We may share your non-photograph and non-video information in the following circumstances:

• Affiliates. We may share App usage information with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.
• Service providers. We may share your personal information with services providers that perform services on our behalf or help us operate the App (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
• Advertising partners. When we use third-party cookies and other tracking tools, our advertising partners may collect information from your device to help us analyze use of the Site and the App, display advertisements on the App and advertise the Site and App (and related content) elsewhere online.
• Third-party platforms and social media networks. If you have enabled features or functionality that connect the App to a third-party platform or social media network (such as by logging into the App using your account with the third-party, providing your API key or similar access token for the App to a third-party, or otherwise linking your account with the App to a third-party's services), we may disclose the personal information that you authorized us to share (such as when you elect to upload a photograph or video to your social media account). We do not control the third-party platforms' use of your personal information, which is governed by that third party's privacy policy and terms and conditions.
• Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
• For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
• Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Compliance with Law

We may be required to use and share your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

Your Choices

In this section, we describe the rights and choices available to all users. Users who are located within European can find additional information about their rights below.

• Opt out of marketing communications and other push notifications. You may opt out of marketing-related communications and other notifications we may send you via push notification by changing the settings on your mobile device.
• Device permissions. You may revoke any permissions you previously granted to us, such as permission to access your camera, camera roll, or microphone through the settings on your mobile device.
• Cloud processing. You may request that we remove your information, including photographs, from the cloud before the 4 days period after which Google Cloud Platform or Amazon Web Services automatically deletes the information by clicking the "Request cloud data removal" button in the "Support" section of the App Settings on your mobile device.
• Cookies & Browser Web Storage. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Site may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.
• Targeted online advertising. Some of the business partners that collect information about users' activities on or through the Site or App may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Site users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. App users may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user's choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

In addition, your mobile device settings may provide functionality to limit our, or our partners', ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

If you choose to opt-out of targeted advertisements, you will still see advertisements online but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, so you may still receive some cookies and tailored advertisements from companies that are not listed.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the App to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to use the App by designating it as required at the time of collection or through other appropriate means.

Third-party platforms or social media networks. If you choose to connect to the App via a third-party platform or social media network, such as by using Facebook login, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the App using the third-party's authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party's platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.

Other Sites, Mobile Applications and Services

The App may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security Practices

We use commercially reasonable security practices to help keep the information collected through the App secure and take reasonable steps to verify your identity before granting you access to your account (if you have an account with us). However, Spark Dynamics cannot ensure the security of any information you transmit to Spark Dynamics Service or guarantee that information on the App may not be accessed, disclosed, altered, or destroyed.

Please do your part to help us. You are responsible for maintaining the confidentiality of your login information and device identifiers, and for controlling access to communications between you and Spark Dynamics Service, at all times. Your privacy settings may also be affected by changes the social media services you connect to Spark Dynamics Service make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.

Retention

We configure Google Cloud Platform and Amazon Web Services to delete photographs, and the information associated with the photographs within 4 days after the photograph was last edited using the App. This allows you to revisit the image for additional modifications during that time.

With respect to non-photograph information that we may collect, we will retain such information in a personally identifiable format only for as long as necessary to fulfill the purposes we have set out in this Privacy Policy. You may also ask that we delete your information using the "Request cloud data removal" button as described above or by contacting us.

Cross-Border Data Transfers

We store the information we collect in connection with the App on Amazon Web Services and Google Cloud Platform. For Amazon Web Services, we specify the US as the data storage location, for Google Cloud Platform, we specify data storage at an available location closest to you when you use the App. Your personal information may be accessed by our service providers in other locations outside of your state, province, or country. Your device ID (and general App usage information) may also be accessed by the Company's technical support team in other locations outside of your state, province, or country. We rely on the Privacy Shield, as described below, for transfers of data from the EU and Switzerland to Spark Dynamics in the United States.

Children

The App is not directed at children under the age of 13, and our Terms of Use do not allow children under 13 years of age to use the App. If we learn that we have collected personal information of a child under the age of 13, we will delete it. We encourage parents with concerns to contact us.

California Residents

This section contains disclosures required by the California Consumer Privacy Act ("CCPA") and applies only to "personal information" that is subject to the CCPA.

California Children Under 16 and Advertising. THE Spark Dynamics SERVICES THAT FEATURE ADVERTISING ARE NOT MEANT FOR CALIFORNIA-LOCATED PEOPLE UNDER 16. We do not knowingly collect information for use in connection with advertising from California children under the age of 16. If we receive a verifiable notice through info@sparkdyn.com that a California minor under the age of 16 has signed up for an advertising-based Spark Dynamics Services account and provided us with personal information, we will take measures to delete it as soon as possible. Additional details regarding California consumer rights follow below.

Personal Information We Collect and Disclose for Business Purposes. We collect the following categories of personal information about California consumers from social networks, service providers and directly from California consumers and have disclosed this information in the past 12 months to third parties for business purposes: personal and online identifiers (i.e., username, email address, IP address, or unique online identifiers), internet or other electronic network activity information (i.e., advertisement interaction), and geolocation information, as well as other information about California consumers that is linked to these categories of personal information. We also draw inferences from this information about your predicted characteristics and preferences. Business Purposes: our business purposes for use of California consumer personal information include the purposes described in this Privacy Policy, including, without limitation, marketing; auditing related to our interactions with you; legal compliance; detecting and protecting against security incidents, fraud, and illegal activity; debugging; performing services (by us or our service providers), such as account servicing and analytics; research for technological improvement; internal operations; activities to maintain and improve our services; and other one-time uses. We disclose the categories of personal information designated above to the following categories of third parties for business purposes: service providers; government entities; operating systems and platforms; and social networks.

Personal Information We Collect and Disclose for Advertising Purposes – Applicable to Subscriptions with Advertising Only. In the event a California consumer has a Spark Dynamics Service subscription that features advertisements, we collect and disclose the following information for the purpose of delivering relevant advertising: personal and online identifiers such as IP address and device identifiers, internet or other electronic network activity information (i.e., advertisement interaction), geolocation information, as well as other information about California consumers that is linked to these categories of personal information. We also draw inferences from this information about your predicted characteristics and preferences. We disclose the categories of personal information designated above to the following categories of advertising-related third parties: advertising/marketing companies; advertising networks; and social networks.

Your Rights Regarding Personal Information. California residents have certain rights with respect to the personal information collected by businesses. If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

• The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
• The right to request that we delete the personal information we have collected from you or maintain about you.
• The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales.
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below: please email info@sparkdyn.com or contact us using this address: SPARK DYNAMICS YAZILIM HIZMETLERI LIMITED SIRKETI, Altunizade Mahallesi Kısıklı Caddesi No:35/A Üsküdar /İstanbul.

Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. In the event you designate an authorized agent to make a CCPA request on your behalf, we will require verification of identity and authorization.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to info@sparkdyn.com. You may also write to us via postal mail at:

SPARK DYNAMICS YAZILIM HIZMETLERI LIMITED SIRKETI
Acibadem Mh Cecen Sk Akasya Residence A Kule No 25 D 150
Uskudar Istanbul
info@sparkdyn.com

Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the App. We may, and if required by law, will, provide notification of changes in another way that we believe is reasonably likely to reach you, such as through the App.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the App (or as otherwise indicated at the time of posting). In all cases, your continued use of the App after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.