Legal & Privacy
Legal Address

WIZN4-02Shed No. N4 -Al Hamra NFZAl Hamra Industrial Zone-NFZRAK, United Arab Emirates RAKEZ.

Sparklo is veryserious about protecting your privacy.

This Policy describesSPARKLO policies and procedures on collecting, processing, transferring, andstoring information when you use the Service and tells you about privacy rightsand how the law protects your Personal Data.

The Service and theWebsite use your Personal Data provided by you to provide and improve SPARKLO’sServices. By using the Services, you agree to collect and use informationfollowing this Policy.

By using ourApplication, you automatically agree with this Policy and all terms andconditions of this Policy and agree to share your personal data with us forfurther collecting and processing purposes, as it is described in this Policy.

1. Interpretation anddefinitions

Interpretation

The words in which theinitial letter is capitalized have meanings defined under the followingconditions. The following definitions shall have the same meaning regardless ofwhether they appear in singular or plural.

Definitions

"Application"means the application provided by SPARKLO and is available for downloading via AppleApp Store and Google Play Market. The Application shall be used with thepurpose of to get and use bonuses from Sparkomat using.

"Device"means any device where the Application can be downloaded.

"SPARKLO", "Sparklo","we", "our", and "us" means the company that isan owner of the Application. The name of the company: Sparklo General PurposeMachinery Parts Manufacturing LLC, registered in accordance with thelegislation of UAE, with its principal place of business at WIZN4-02Shed No. N4- Al Hamra NFZAl Hamra Industrial Zone-NFZRAK, United Arab Emirates RAKEZ.

"GDPR" meansgeneral data protection rules relating to the protection of natural personsabout the processing of personal data and rules relating to the free movementof Personal Data.

"PersonalData" means any information relating to an identified or identifiablenatural person (“data subject”); an identifiable natural person is one who canbe identified, directly or indirectly, in particular by reference to anidentifier such as a name, location data, an online identifier, etc.

"Processing"means any operation or set of operations that are performed on personal data orsets of personal data, whether or not by automated means, such as collection,recording, organization, structuring, storage, adaptation or alteration, retrieval,consultation, use, disclosure by transmission, dissemination or otherwisemaking available, alignment or combination, restriction, erasure, ordestruction.

«Sharing» data meansthe transferring Data (in full or partial), in original or processed form tothird party  (business partners, clients,etc.) on the conditions defined by Sparklo , including cross-border datatransfer (not limited by the country of person residency),  to other countries where Sparklo operates orplanning to operate the business.

"Usage Data"refers to data collected automatically, either generated using theApplication’s infrastructure itself (for example, the duration of a visit,website usage, and the number of users).

"User","you", and "your" means any individual or legal entity whois using the Application from SPARKLO.

“Sparklo+” means apremium subscription-based digital functionality made available by SPARKLOthrough the Application and/or third-party platforms, which may provideenhanced rewards mechanics, premium features, profile customization, counters,multipliers, and other digital benefits.

“SubscriptionServices” means any subscription-based services, premium digital functionality,or recurring paid features offered by SPARKLO from time to time.

“Third-Party PlatformProviders” means Apple App Store, Google Play Store, and/or any otherthird-party platform through which Subscription Services may be distributed ormanaged.

2. Collecting andusing your personal data

Personal Data:

While using theApplication, you may provide certain personally identifiable information thatcan be used to contact or identify you. Personal Data that we collect mayinclude, but is not limited to:

Full name and surname;

Email;

Contact phone number;

Country of residence;

Mailing address andlegal address;

SPARKLO has the right,at any time, at its sole discretion, to request that you confirm your personalinformation or any other information related to using the Application.

SPARKLO mayadditionally collect and process information related to Subscription Services,including subscription status, subscription activation and expiration dates,platform identifiers, purchase verification data, subscription history, andtechnical information related to subscription functionality.

3. Usage data

Usage Data iscollected automatically when using the Application and filling out the forms onSPARKLO’s Application from time to time.

Usage Data may includeinformation, type of the Device, your visit pages, the time and date of yourvisit, the time spent on those pages, unique device identifiers and otherdiagnostic data and diagnostic data of your account information.

When you visit theApplication, SPARKLO has the right to collect, process and transfer thefollowing data:

the type of Devicethat is used;

Device operatingsystem which you used;

The type of internetbrowser that is used for using the Application;

Unique Deviceidentifiers and other diagnostic data of the Device you used for access to ourApplication; and

SPARKLO has the rightto check and control the Application using to keep the functionality andprotect it from any infringements by third parties.

4. Trackingtechnologies and cookies

We Share personalinformation for the purposes set out in this Privacy Statement and with thefollowing categories of recipients:

Social Media Services:We may work with certain third party social media providers to offer you theirsocial networking services through our Services. These social networkingservices may be able to collect information about you, including your activity onour Services.

In the Event ofMerger, Sale, or Change of Control: We may transfer this Privacy Statement andyour personal information to a third party entity that acquires or is mergedwith us as part of a merger, acquisition, sale, or other change of control(such as the result of a bankruptcy proceeding, company restructuring in anyform ).

Other Disclosures: Wemay disclose your personal information to third parties if we reasonablybelieve that disclosure of such information is helpful or reasonably necessaryto comply with any applicable law or regulation, to comply with or respond to alegal process or law enforcement or governmental request, to enforce our termsand conditions or other rights (including investigations of potentialviolations of our rights), to detect, prevent, or address fraud or securityissues, or to protect against harm to the rights, our users, or the public.

5. Use of yourpersonal data

SPARKLO may usePersonal Data for the following purposes.

To provide andmaintain the Application, including monitoring the Application usage.

To provide you withnews, special offers and general information about services and events thatSPARKLO offers, like those you have already used unless you have opted not toreceive such information.

To manage yourrequests: To attend to and manage your requests to the Application.

For businesstransfers: SPARKLO may use your information to evaluate or conduct a merger,divestiture, restructuring, reorganization, dissolution, or another sale ortransfer of some or all SPARKLO assets, whether as a going concern or as partof bankruptcy, liquidation, or similar proceeding, in which Personal Data heldby SPARKLO about the Application’s users is among the assets transferred.

For other purposes:SPARKLO may use your information for other purposes, such as data analysis,identifying usage trends, determining the effectiveness of the Application’spromotional campaigns, evaluating and improving the Application, products, andservices, marketing, and your experience.

SPARKLO may Share yourPersonal Data in the following situations:

With serviceproviders: SPARKLO has the right to Share your Personal Data with serviceproviders to monitor and analyze the use of the Application and to contact you.

For businesstransfers: SPARKLO may Share or transfer your Personal Data in connection with,or during negotiations of, any merger, sale of SPARKLO’s assets, financing, oracquisition of all or a portion of SPARKLO’s business to another owner.

With Affiliates:SPARKLO has the right to Share your Personal Data with SPARKLO affiliates, inwhich case SPARKLO will require those affiliates to honour this Privacy Policy.Affiliates include SPARKLO’s parent company and any other subsidiaries, joint venturepartners or other companies that SPARKLO controls or are under common controlwith SPARKLO.

With businesspartners: SPARKLO has the right to Share your Personal Data with businesspartners to offer you certain products, services, or promotions.

With your Consent:SPARKLO has the right to disclose your Personal Data for any other purpose onlywith your advance consent, except in situations under request from governmentauthorities and under the court resolutions where we are not eligible to notifyyou.

SPARKLO may usePersonal Data and subscription-related information for:

(a) verification andadministration of Subscription Services;

(b) activation andmanagement of premium functionality;

(c) fraud preventionand abuse detection;

(d) synchronization ofsubscription status across devices and services;

(e) customer supportrelated to subscriptions and premium functionality.

6. Retention of yourpersonal data

SPARKLO will retainyour Personal Data only as long as necessary for the purposes set out in thisPrivacy Policy.

SPARKLO will retainand use your Personal Data to the extent necessary to comply with SPARKLO’slegal obligations (for example, if we are required to retain SPARKLO’s PersonalData to comply with applicable laws), resolve disputes, and enforce our legal agreementsand policies.

SPARKLO will alsoretain Usage Data for internal analysis purposes. Usage Data is generallyretained for a shorter period, except when this Personal Data is used tostrengthen the security or improve the Website's and/or the Service’sfunctionality, or SPARKLO is legally obligated to retain this data for moreextended periods.

SPARKLO will retainyour personal data with PostgreSQL database service providing the safest andmost stable data protection as it is possible.

7. Transfer of yourpersonal data

Your information,including Personal Data, processing by SPARKLO’s operating offices and in anyother places where the parties involved in the processing are located. Thisinformation may be transferred to — and maintained on — computers outside yourstate, province, country, or other governmental jurisdiction where the dataprotection laws may differ from those of your jurisdiction.

Your consent to thisPrivacy Policy, followed by submission of such information, represents youragreement to that transfer.

SPARKLO will take allsteps reasonably necessary to ensure that your Personal Data is treatedsecurely and following this Privacy Policy, and no transfer of your PersonalData will take place to an organization or a country unless there are adequatecontrols in place, including the security of your Personal Data and otherpersonal information.

Certainsubscription-related information may be processed or verified throughThird-Party Platform Providers, including Apple App Store and Google PlayStore, in accordance with their applicable policies and technical requirements.

8. Disclosure of yourpersonal data

Business Transactions

If SPARKLO is involvedin a merger, acquisition or asset sale, your Personal Data may be transferred.SPARKLO will provide notice before your Personal Data is transferred andbecomes subject to a different Privacy Policy.

Law enforcement

Under certaincircumstances, SPARKLO may be required to disclose your Personal Data ifrequired to do so by law or in response to valid requests by public authorities(e.g. a court or a government agency).

Other legalrequirements

SPARKLO may discloseyour Personal Data in the good faith belief that such action is necessary to:

Comply with legalobligations.

Protect and defend therights or property of SPARKLO.

Prevent or investigatepossible wrongdoing in connection with the Service.

Protect the personalsafety of you, the Service, or the public

Protect against legalliability.

9. Children's privacydata

SPARKLO’s Applicationdoes not address anyone under 18 (eighteen). SPARKLO does not knowingly collectpersonally identifiable information from anyone under 18 (eighteen). If you area parent or guardian and are aware that the child has provided SPARKLO withPersonal Data, please contact us immediately.

If SPARKLO becomesaware that we have collected Personal Data from anyone under 18 (eighteen)without verification of parental consent, SPARKLO takes steps to remove thatPersonal Data from our servers or/and any storage used by SPARKLO.

If SPARKLO needs torely on consent as a legal basis for processing your information and yourcountry requires consent from a parent, SPARKLO may require your parent’sconsent before SPARKLO collects and use that information.

By using ourApplication, you automatically agree with this Policy and represent and warrantthat:

(a) you are 18(eighteen) years old or older; or

(b) you have obtainedvalid parental or guardian consent to share your personal data with us and touse the Application in accordance with applicable law.

 10. Security of yourpersonal data

SPARKLO takes allreasonable steps to protect information that is received from you fromaccidental or unlawful destruction, loss, alteration, and unauthorizeddisclosure or access. SPARKLO has put in place appropriate physical, technical,and administrative measures to safeguard and secure your information, andSPARKLO makes use of privacy-enhancing technologies such as encryption. If youhave any questions about the security of your personal information, you cancontact us VIA email support@sparklo.com.

SPARKLO, in any case,is not responsible for losses and/or disclosures of your Personal Data or anydamages related to losses and/or disclosure of the Privacy Data as a result ofany unauthorized or technical problem.

11. Links to otherwebsites

SPARKLO’s Applicationmay contain links to other websites or applications not operated by us. If youclick on a third-party link, you will be directed to that third-party’s websiteor application. SPARKLO strongly advises you to review the Privacy Policy ofevery site that you visit.

SPARKLO has no controlover and assumes no responsibility for any third-party sites or services'content, privacy policies or practices.

12. Changes to thisprivacy policy

SPARKLO may update thePolicy from time to time. SPARKLO is not obliged to notify you and any otherthird parties of any changes by posting the new Policy on this page.

SPARKLO has the rightto update the Policy. SPARKLO will let you and any other third parties know viaupdating the “Last Updated” date at the top of this Policy.

You and any otherthird parties are advised to review this Policy periodically for any changes.Changes to this Privacy Policy are effective when posted on this page.

 PUBLIC OFFER OF THEBONUS PROGRAM

Terms and Definitions

Sparklo, Organizer ofthe Bonus Program – SPARKLO GENERAL PURPOSEMACHINERY PARTS MANUFACTURING LLC, having its principal office at Al HamraIndustrial Zone-NFZ, WIZN4-02, Ras Al Khaimah, United Arab Emirates

Bonus – a virtualconditional unit within the Bonus Program, credited to a participant uponsubmission of Empty Containers via Sparklo reverse vending machines (RVMs), inaccordance with this Offer.

Bonus Program – aprogram to incentivize the submission of Empty Containers for recycling byaccruing and using Bonuses, organized by Sparklo.

Personal Account – theBonus Program Participant’s account in the Sparklo Mobile Application or on thewebsite.

Official Bonus ProgramWebsite: sparklo.com

Bonus Program Partners– legal entities and/or individual entrepreneurs that provide discounts ontheir goods and/or services in exchange for Bonuses. The current list of BonusProgram Partners is published on the official website and in the App.

Empty Container – usedplastic and/or aluminum containers or other similar recyclable items.

Bonus ProgramParticipant (Participant) –an individual who has reached the age of 18 andconfirmed their consent to participate in the Bonus Program by registering viaSparklo RVMs or in the App.

Sparklo RVM –equipment manufactured by Sparklo for the collection of empty containers andparticipation in the Bonus Program.

Participant BonusAccount – a conditional account opened by the Organizer in its informationsystem in the name of the Participant in their Personal Account in the App,where Bonuses are credited for each unit of submitted Empty Container(according to the calculation formula provided in Section 5.1 of the Offer).

Offer – this document,which is a public offer by the Organizer addressed to any natural or legalperson to conclude an agreement on the terms specified in the offer, includingall its annexes.

Acceptance – full andunconditional acceptance by a person of the terms of the offer and theirwillingness to become a Participant in the Bonus Program.

Sparklo MobileApplication – software used by individuals on mobile phones, smartphones, orcomputers (including tablets) connected to the Internet to access theOrganizer’s automated systems for earning bonuses, purchasing goods, orobtaining services.

General Provisions

This document is anofficial offer (public offer) within the Bonus Program organized by Sparklo,aimed at incentivizing the submission of Empty Containers for recycling in theUnited Arab Emirates, and includes all essential terms of service provision (hereinafterreferred to as the "Offer"). This Offer is published in the SparkloMobile Application and on the website: sparklo.com

In accordance withapplicable UAE law, by accepting the conditions outlined below, a legal ornatural person who accepts this Offer becomes and is hereinafter referred to asa "Bonus Program Participant." Acceptance of the offer is equivalentto entering into a contract under the terms outlined in the offer.

The moment of full andunconditional acceptance of the Organizer’s proposal (the moment of acceptanceof the Offer) is considered the Participant’s registration in the Bonus Programvia Sparklo RVMs or the Sparklo Mobile Application.

By accepting the Offeras defined in clause 2.3 of the Agreement, the Participant confirms that theyhave read, agree with, and fully and unconditionally accept all terms of thecontract as outlined in the text of the Offer, including its annexes, which arean integral part thereof.

The Offer remains ineffect until withdrawn by the Organizer.

Certainsubscription-based services, including Sparklo+, may affect the mechanics ofbonus accrual, including the application of bonus multipliers or additionalvirtual functionality. Such subscription mechanics shall be governed by theapplicable Public Offer of the Sparklo+ Program.

Subject of theAgreement

The Organizer of theBonus Program, via the use of Sparklo RVMs, offers individuals participation ina recycling program for plastic and aluminum packaging waste, during whichindividuals submit Empty Containers (plastic bottles and aluminum cans) in SparkloRVMs in exchange for participation in a loyalty program entitling them toBonuses.

The Organizer does notverify the accuracy of personal data provided by the Participant and does notcontrol its relevance. The Organizer assumes that the Participant providesaccurate and current personal information. The Participant is solely responsiblefor providing inaccurate or outdated personal data.

Registration Procedure

To register viaSparklo RVMs, the Participant must enter their phone number in the specifiedfield on the RVM screen. By entering their phone number, the Participantaccepts this Offer and agrees to receive Bonuses for submitted containers.

To register via theSparklo Mobile Application, the Participant downloads and installs the app,enters their phone number, and confirms it using a verification code sent viaSMS. Acceptance of this Offer is confirmed by entering the code in the app,thereby confirming participation. By doing so, the Participant agrees toreceive notifications via SMS.

Accrual and Redemptionof Bonuses

For each EmptyContainer submitted via a Sparklo RVM, the Participant is entitled to receive10 Bonuses to their Bonus Account in the Personal Account of the Sparklo App.

Bonuses do not havemonetary value and cannot be exchanged for cash or any other form ofcompensation.

To receive Bonuses,the Participant must enter a correct phone number that matches the numberprovided during registration.

Bonuses are creditedto the Participant’s Bonus Account immediately after the submission process iscompleted.

Bonuses can beredeemed through the Personal Account by obtaining discounts from Bonus ProgramPartners, according to the terms outlined in the App.

 If due to technicalreasons the redemption of Bonuses is not possible, the Organizer reserves theright to deny the operation.

 Bonuses do not expireand remain valid indefinitely once credited.

 If for technicalreasons the accrual of Bonuses is not possible, the Organizer reserves theright to deny the operation until the issue is resolved.

 Participants may nottransfer Bonuses to other users.

 Special Conditions andLiability

The Organizer onlyaccepts Empty Containers suitable for further recycling via Sparklo RVMs. TheOrganizer reserves the right to determine the type and form of Empty Containersaccepted via Sparklo RVMs.

 Bonuses provide theParticipant with the right to exchange them for discounts on goods and servicesfrom Partners or to participate in social programs, according to the termsoutlined in the App. Bonuses are non-refundable in case of product returns.

 The Organizer reservesthe right to change the accrual and usage conditions of Bonuses by publishingrelevant information in the App.

 The Organizer is notliable for losses or damages incurred by the Participant due to suspension,amendment, or termination of the Bonus Program unless otherwise required byapplicable UAE law.

 The Organizer is notresponsible for the quality of goods and/or services provided by Partners, norfor any losses incurred due to their use.

 The Participant agreesnot to: a) misuse the Sparklo Mobile Application; b) misuse Sparklo RVMs; c)interfere with software or hardware components; d) provide false information;e) violate container acceptance rules; f) exploit technical or softwaremalfunctions for bonus accrual or unauthorized access; g) engage in fraud; h)violate the Offer or UAE law.

 In case of any suchviolations, the Organizer may terminate the Participant's access and void orblock their Bonus Account without explanation.

 The Organizer mayamend this Offer at any time by publishing the new version in the App or on thewebsite at least one day prior to its effective date.

 Participants areresponsible for monitoring any changes to the Offer.

 The Organizer maysuspend or terminate the Bonus Program at any time, publishing relevantinformation in the App or on the website at least 30 days prior.

 Upon termination ofthe Bonus Program, Bonuses in Participant Accounts will be voided withoutcompensation.

 If the Organizersuspects fraud, it may exclude the Participant from the Program. The results ofan internal investigation will serve as sufficient grounds for exclusion.

 The Organizer reservesthe right to adjust bonus accrual timelines due to technical issues and maynotify Participants accordingly.

 Confidentiality andPersonal Data Protection

By accepting theOffer, the Participant consents to the collection, processing, updating, use,and storage of personal data for registration and participation purposes.

 The Organizerundertakes not to disclose information received from the Participant. TheParticipant consents to data processing according to the Privacy Policyavailable during App registration. The Organizer processes personal data inaccordance with UAE data protection laws.

 The Participant maydelete the App and terminate their account at any time. Further use of thePersonal Account will be unavailable.

 The Organizer is notresponsible for the Participant’s lack of awareness regarding the rules in thisdocument.

 PUBLIC OFFER OF THESPARKLO+ PROGRAM

 Terms and Definitions

 Sparklo+ – a premiumsubscription-based digital functionality provided by SPARKLO within the Sparkloecosystem, granting Participants access to enhanced rewards mechanics, premiumfeatures, profile customization functionality, counters, multipliers, and otherdigital benefits. Sparklo+ is optional and is not required for participation inthe Bonus Program.

 Active Subscription –a valid and active Sparklo+ subscription purchased through an authorizedthird-party platform provider.

 Subscription Period –the paid validity period of the Sparklo+ subscription.

 Multiplier – anincreased Sparklo Points accrual coefficient applied to eligible recyclingactivities.

Counter – additionalvirtual sponsored containers, statistics, achievements, or other digitaltracking functionality available within Sparklo+.

Third-Party PlatformProviders – Apple App Store, Google Play Store, and/or other third-partyplatforms through which Sparklo+ may be distributed, purchased, or managed.

Offer – this PublicOffer of the Sparklo+ Program, including all amendments and annexes thereto.

Acceptance – full andunconditional acceptance of this Offer by the Participant through activation orpurchase of Sparklo+.

General Provisions

This documentconstitutes an official public offer governing participation in the Sparklo+subscription program organized by SPARKLO.

The Sparklo+ Programprovides Participants with access to premium digital functionality within theSparklo ecosystem.

This Offer supplementsthe Terms and Conditions of Sparklo and applies specifically to Sparklo+functionality.

In case of conflictbetween this Offer and the Terms and Conditions, the Terms and Conditions shallprevail with respect to legal, billing, liability, dispute resolution, andgoverning law matters.

The current version ofthe Offer is published within the Application and/or on the official website ofSPARKLO.

Acceptance of thisOffer occurs upon activation or purchase of Sparklo+.

Sparklo+ Features

Participants with anActive Subscription may receive access to premium functionality including:

(a) increased SparkloPoints accrual rates;

(b) premium profilecustomization functionality;

(c) additionalcounters and virtual statistics;

(d) virtual sponsoredcontainers functionality;

(e) premium icons,badges, and profile indicators;

(f) additional digitalrewards mechanics;

(g) other premiumfunctionality determined by SPARKLO from time to time.

At the effective dateof this Offer:

(a) the standardSparklo+ multiplier equals x1.2 (+20%);

(b) the multiplierapplies to eligible plastic bottles, aluminum cans, and other recyclable itemsdesignated by SPARKLO;

(c) the standardCounter functionality includes accrual of five (5) virtual sponsoredbottles/cans per day during the Active Subscription period.

SPARKLO reserves theright to modify:

(i) multiplier values;

(ii) accrualmechanics;

(iii) counters;

(iv) premiumfunctionality;

(v) digital rewardsmechanics;

(vi) eligibilitycriteria;

(vii) featureavailability;

at any time.

Purchase, Billing, andRenewals

Sparklo+ isdistributed exclusively through Third-Party Platform Providers, including:

(a) Apple App Store;

(b) Google Play Store.

All billing, paymentprocessing, automatic renewals, subscription management, and refundadministration are performed by the applicable Third-Party Platform Provider.

SPARKLO does notdirectly process or store Users’ payment card information for Sparklo+purchases unless expressly stated otherwise.

Unless cancelledbefore the applicable renewal date, Sparklo+ may automatically renew forrecurring billing periods.

Deletion of theApplication does not automatically cancel an Active Subscription.

Cancellation andRefunds

Participants maycancel Sparklo+ through the subscription management settings of the applicableThird-Party Platform Provider.

Refunds are governedby the policies of the relevant Third-Party Platform Provider.

SPARKLO does notguarantee refunds and may be technically unable to independently processrefunds for purchases made through third-party billing systems.

Virtual FunctionalityDisclaimer

Sparklo Pointsmultipliers, Counters, sponsored containers, profile badges, premiumindicators, achievements, and other digital functionality:

(a) have no monetaryvalue;

(b) do not constituteelectronic money, digital assets, securities, or financial instruments;

(c) arenon-transferable;

(d) may not beexchanged for cash or legal tender;

(e) exist solelywithin the Sparklo ecosystem for motivational, gamification, entertainment, andloyalty purposes.

 

Sparklo+ does notcreate ownership rights to recyclable materials, containers, or any propertyrights in relation to virtual functionality.

Liability Limitations

SPARKLO does notguarantee uninterrupted or error-free operation of Sparklo+.

Availability ofSparklo+ may depend on:

(a) internetconnectivity;

(b) mobile devicecompatibility;

(c) cloudinfrastructure;

(d) third-partyservices;

(e) Apple App Storeservices;

(f) Google Play Storeservices.

SPARKLO shall not beliable for interruptions, delays, synchronization failures, billinginterruptions, or technical limitations caused by third-party providers orevents outside SPARKLO’s reasonable control.

Suspension andTermination

SPARKLO may suspend,restrict, or terminate access to Sparklo+ if:

(a) the Participantviolates applicable agreements or policies;

(b) fraudulent,abusive, or suspicious activity is detected;

(c) required by law orby Third-Party Platform Providers;

(d) necessary toprotect SPARKLO, the Application, or other users.

SPARKLO may modify ordiscontinue Sparklo+ at any time by publishing updated information within theApplication or on the website.

Personal Data

By activatingSparklo+, the Participant agrees to processing of subscription-related data inaccordance with the Privacy Policy of SPARKLO.

Subscription-relatedinformation may include:

(a) subscriptionstatus;

(b) purchaseverification data;

(c) subscriptionhistory;

(d) technicalidentifiers;

(e) premiumfunctionality usage information.

Final Provisions

Participants areresponsible for independently reviewing updates to this Offer.

This Offer remainseffective until withdrawn or replaced by SPARKLO.