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Privacy Policy

Last Updated: September 5, 2025

Spark Timing, Inc. (“Timing”, “we”, "our", or "us") is committed to protecting your privacy. This Privacy Notice explains how your personal information is collected, used, and disclosed by Timing. This Privacy Policy applies to our mobile Applications (“Applications”, or “Apps”), our website sparkingtiming.com (“Website”, or “Sites”), and our corporate activities, collectively referred to as our Services (“Services”).

This Privacy Policy is incorporated into and forms part of our Terms of Services available through the Applications and the Website and at www.sparkingtiming.com/terms.

Please read this Privacy Policy carefully. The provisions contained in this Privacy Policy supersede all previous notices and statements regarding our privacy practices with respect to the Services. If you do not agree to all provisions of this privacy policy, please do not access or use our Services.

This Privacy Policy will help you understand the following:

  • Information we collect
  • How do we use your personal information
  • How we entrust third parties to process, provide, transfer, and publicly disclose your personal information
  • How do we protect your personal information
  • User-Generated Content Regulation
  • How we handle information about minors
  • International Users
  • Changes to This Policy
  • Contact us

1. Information We Collect

We collect personal information in connection with your visits to and use of the Services. This collection includes information that you provide in connection with the Services, information from third parties, and information that is collected automatically, such as through the use of cookies, interaction with our AI chat, and other technologies.

We Do Not Sell or Share Personal Information

We do not sell your Personal Information, nor do we share your Personal Information to provide personalized or targeted advertising.

A. Information You Provide to Us Directly

We collect Personal Information from you when you voluntarily interact with our Services, such as when you register for an account, enter information through forms or surveys, input information while using our Services, customer support purposes, interact with our AI chat, and more.

The categories of information you may provide for us include:

Registration: If you register for an account with our Services, we collect your name or alias, email address, phone number, or other similar identifiers (i.e. Apple ID). We use this information to administer your account, and for customer support purposes.

Services Use: In order to provide our Services, we collect information voluntarily provided from you such as your birth date, the time of your birth, the country, state, and city of your birth, your gender, location, and photo (if uploaded) to create your profile. We use this information to provide you with the relevant Services and information, communicate with you regarding your account and your use of the Services. The information is private with our Applications and website, which can be only viewed through your logged in accounts.

OPTIONAL Information: You may provide additional categories of Personal Information such as Professional or employment-related information, Education information, reflections, goals, and more when answering our survey and use our Services.

Payment Information: If you pay for the Services, we may collect payment information, including credit or debit card number, expiration date, security code, and billing address. Please note we collect and process all financial information, such as credit card numbers, through third-party payment processing providers including Stripe. As such, we do not retain any personally identifiable financial information in connection with your payments, such as credit card numbers. Rather, all such information is provided directly by you to our third-party payment processors or financing providers. Their use of your personal information is governed by their privacy notice. To view Stripe’s privacy policy, please click here.

AI Chat (Optional Services): When you use our AI chat, the content of your prompts and our responses (“Chat Data”) may be collected and processed to operate and improve the chat service. We may use de-identified or aggregated Chat Data to train or improve our machine learning models. We will not use Chat Data containing Personal Information to train models for purposes beyond providing the Services without obtaining explicit consent. If you do not want your Chat Data used for model training or improvement, you may opt-out by changing your account settings or submitting an opt-out request to privacy@sparkingtiming.com; we will detail how such an opt-out affects service personalization and troubleshooting.

Inquiries and Troubleshooting: If you communicate with us through any form, we may collect your name, email address, or any other personal information you choose to provide to us. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the Services we offer to our users and to manage and grow our organization.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy.

B. Information We Collect Automatically through Use of the Services

When you access our Services, we may automatically collect information that is linked to your computer, phone, or other device, including information related to your behavior and activity while interacting with our Services, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Services and any errors that may occur during the visit to our Services), analytics data (such as the electronic path taken to our Services, through our Services and when exiting our Services, as well as usage and activity on our Services such as the pages you view, the links you click, features and functionalities you utilize, how frequently you access the Services, the site from which you came and the site to which you are going when you leave the Services, whether you open emails or click on the links contained in emails, whether you access the Services from multiple devices, or other actions you take on the Services. We may also work with third-party partners to employ technologies, including statistical modeling tools, which attempt to recognize you across multiple devices); and location data (such as general geographic location based on the log data we or our third-party providers collect).

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information.

To manage cookies, an individual may change their browser settings. Please note that doing so may negatively impact an individual’s experience using our Services, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use.

C. Information From Third Party Sources

We may receive personal information about you from third parties and combine this information with other information we have.

Affiliates. We may receive personal information from other companies owned or controlled by Spark Timing, Inc., and other companies owning or under common ownership with Spark Timing, Inc. This includes any subsidiaries (i.e., any organization we own or control) or our parent company (i.e., any organization that owns or controls us) and any subsidiaries it owns.

Third-Party Integrations. In order to login or to use certain features of our Services, you may be required to connect certain third-party integrations with your Timing account, which may ask for certain permissions to access data or send information to the Services. For example, you may be required to login using Apple, Google, or Microsoft. These Services will authenticate your identity and provide you the option to share certain data or features to the Services with us, such as access to your Apple, Google, or Microsoft Calendar. Through the use of the Services, you will have the ability (or we will automatically suggest as part of the Services) to create or change your integrated calendars, assign tasks, and update individual calendar events. As such, the data shared with us will depend on your setting and the information you have included in your calendars, which may include personal information such as your name, email, access tokens, and other information related to your account with the third party Services such as email addresses included in your calendars events, or any information or included in your calendar notes or documents that have been attached (“User Content”). Note we are not responsible for the practices of third-party integrations, so please carefully review the permissions you grant to third-party Applications.

Data Protection Mechanisms for Sensitive Data. All of our Services are hosted with Amazon Web Services (AWS); they employ a robust security program with multiple certifications. These servers are located in the United States. If you are located in another jurisdiction, you should be aware that once your Personal Information is submitted through our Services, it will be transferred to our servers in the United States and therefore governed by local data protection laws, which can vary state by state.

Social Media Platforms. When an individual interacts with us through various social media networks, we may receive some information about the individual that they permit the network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the network. Individuals should review and, if necessary, adjust their privacy settings on third-party Websites and networks before sharing information with us or the platform.

D. Do Not Track

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. The Services may not currently respond to all Do Not Track (“DNT”) or similar signals, as we are awaiting consensus from the Internet policy and legal community on the meaning of DNT and the best way to respond to these signals.

2. How We Use Your Personal Information

We use the information we collect for purposes to provide you with the best possible Services, and continually improve them over time. For example, we use your information to:

  • Provide the Services and related notices, including automatically suggest goal break down, time entries, assign tasks, and generate daily flows;
  • Create, maintain, and Services user accounts and/or profiles;
  • Training and developing machine learning algorithms, and identification of industry trends and developments, and anonymous benchmarking;
  • Operate, maintain, test, enhance, update, monitor, diagnose, and fix the Services as well as perform overall Services quality improvements, troubleshooting, debugging, and resolving technical issues;
  • Receive feedback and provide customer and technical support for the Services;
  • Conduct market research and project planning, which may include conducting surveys, research, and audits;
  • Provide analytics Services, such as analyzing customer usage and improving Services offered;
  • Fulfill any orders placed through the Services (including processing your payment information through a third-party payment processor and providing you with invoices and/or order confirmations);
  • Verify and respond to your requests regarding your Personal Information or questions you may have about this Privacy Policy;
  • Detect, prevent, and investigate actual or suspected fraud, hacking, infringement, or other misconduct involving the Services; and for other purposes disclosed at the time of collection; and
  • Comply with legal obligations

We may aggregate, de-deidentify, and/or anonymize any information collected through the Services so that such information is no longer reasonably capable of being associated with you. We may use aggregated or anonymized information for any purpose, including research and marketing purposes, and we may also share such information for any purpose with any third parties, at our discretion.

Data Retention: We retain personal information for the duration of your account and for up to one year after an account is deleted, unless you request earlier deletion. After that period — or upon your verified request — we permanently delete or de-identify the data from all active systems and backups.

For the purposes discussed in this Privacy Notice, we may combine the information that we collect through the Services with information we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Notice.

3. Sharing Of Your Information

Timing does not sell your Personal Information to third parties, nor do we disclose Personal Information to third parties for targeted or cross-context behavioral marketing purposes.

We may share Anonymous information in the instances described elsewhere in this Privacy Policy and to improve our Services and for other commercial purposes.

We may share your personal information with:

  • Affiliates. We may share personal information with other companies and brands owned or controlled by Spark Timing, Inc. and other companies owned by or under common ownership as Spark Timing, Inc., which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Notice;
  • Services Providers. We may share personal information with third-party Services providers that perform Services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing tax and accounting Services, web hosting, or providing analytic Services;
  • Payment Processors. You provide your information directly to our payment processors through our Services. The processors are lawfully permitted to process your information for their own business purposes and legal requirements. We currently use Stripe for payment processing. Please review Stripe’s privacy policy if you have any questions about how it processes your personal information https://stripe.com/privacy.
  • Business Transfers. We may disclose personal information with other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
  • Regulatory or Legal Requirements, Safety and Terms Enforcement. We may disclose personal information to third parties as required by law or subpoena or meet law enforcement requirements. We may be under a duty to disclose or share your Personal Information to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
  • Consent. We may disclose personal information with any other entity disclosed to you at the time we collect your information or with your consent.

We may also share information with others in de-identified, aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

4. How We Protect Your Personal Information

We place a high value on the security of your personal information and take all reasonable and feasible measures to protect it:

  • We have implemented industry-standard data protection technologies and management practices, such as network isolation, data encryption, and employee access control, to prevent unauthorized access, disclosure, alteration, loss, or destruction of your personal information.

Please be aware that while we strive to ensure the security of any information you send to us, the internet environment is not 100% secure. Therefore, we do not accept responsibility for any risks or losses arising from or related to security issues in this regard.

In the unfortunate event of a personal information security incident, we will promptly notify you in accordance with legal and regulatory requirements, including: basic information about the security incident and its possible impact, the corrective actions we have taken or will take, recommendations on how you can prevent or mitigate risks, and any remedial measures we offer to you. We will inform you of the incident via push notifications, emails, text messages, phone calls, or other appropriate methods. If it is not feasible to inform each individual, we will post an announcement using reasonable and effective means. In addition, we will proactively report the handling of personal information security incidents to the regulatory authorities as required.

5. User-Generated Content Regulation

You may submit content through the App, including but not limited to journal entries, reflections, goals, feedback, and other personal inputs ("User Content").

Purpose of Processing

Your User Content may be stored, processed, and analyzed for the purpose of delivering personalized insights, improving app functionality, training AI models, or conducting anonymized internal research.

Ownership and License

You retain full ownership of your original User Content. However, by submitting it, you grant us a non-exclusive, royalty-free, worldwide license to use, modify, aggregate, and analyze such content for internal purposes, including but not limited to product development, Services optimization, and quality improvement.

Privacy and Attribution

We will not publicly share, publish, or attribute your User Content without your explicit consent.

Responsibility and Content Standards

You are solely responsible for any content you submit. Your submissions must not infringe upon any third-party rights, and must not contain offensive, illegal, abusive, or harmful material. We reserve the right to remove any content and take appropriate action, including account suspension, if we determine that submitted content violates our Terms and Privacy Policy.

If you wish to delete previously submitted content, please contact us at privacy@sparkingtiming.com.

6. Protecting Children's Privacy

Our App is not intended for children under the age of sixteen (16). We do not knowingly collect Personal Information from children under the age of sixteen (16). If you are not sixteen (16) years or older, do not use our Website, Apps, or Services. If you believe that we have received the information of a child, please contact us at privacy@sparkingtiming.com.

In accordance with California law, minors under the age of eighteen (18) residing in California may remove, or request and obtain the removal of, content and information that they share on the Website or Applications. To remove or to request and obtain the removal of such content and information, the user must email privacy@sparkingtiming.com. Users should be aware that removing content and information posted by a minor does not ensure complete or comprehensive erasure of content or information posted on our Services.

Under certain circumstances, Timing may not have to comply with the above removal requirements. Timing also reserves the right, to the extent permitted by law, to anonymize the posted content or information or to make such content or information invisible to other users and the public, instead of removing or deleting the content or information.

7. US and International Users

If you are accessing the App from outside the United States, you understand and agree that your data may be stored and processed in the U.S. or other countries where our servers or third-party providers are located.

Privacy rights & additional disclosures for certain U.S. residents

Several states within the United States grant residents with rights over their Personal Information. We provide the following information to further help you understand your potential privacy rights. If you would like to exercise any rights, or inquire as to whether such rights are available to you, please contact us at privacy@sparkingtiming.com.

Request for Information, Correction, or Deletion

Residents of certain U.S. states have the right to know whether we are processing their Personal Information, and in some instances, you have the right to request that we disclose to you the categories listed below for the preceding 12 months.

  • The categories of Personal Information we collect about you.
  • The categories of sources from which your Personal Information is collected.
  • The business or commercial purpose(s) for collecting, selling, sharing, or disclosing your Personal Information, and the categories of Personal Information disclosed for such purpose(s).
  • The categories of third parties with whom we share your Personal Information.
  • The categories of Personal Information we have sold, if any, about you and the categories of third parties to whom your Personal Information was sold, by category or categories of Personal Information for each third party to whom the Personal Information was sold.
  • The specific pieces of Personal Information we have collected about.

In addition, you may have the right to request we correct or rectify inaccurate Personal Information, or request that we delete your Personal Information.

Request for Portable Data

Residents of certain U.S. states have the right to receive, in certain circumstances, a portable format of their Personal Information that allows the data to be reasonably transmitted to another entity.

Do Not Sell or Share My Personal Information

Residents of certain U.S. states have the right to opt out of the sale or sharing of your Personal Information. However, we do not sell your Personal Information, nor do we share your Personal Information to provide personalized or targeted advertising.

Limit the Use of Sensitive Personal Information

Residents of California have the right to direct us to use or disclose Personal Information only for providing goods or Services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive Personal Information for any purpose other than providing our goods or Services, or as otherwise minimally permitted under applicable law.

Third Party’s Direct Marketing

If you are one of our Customers, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information to third parties for the third parties’ direct marketing purposes. However, we do not disclose your Personal Information to third parties for third parties’ direct marketing purposes.

Automated Processing and Profiling

Residents of certain U.S. states have the right to opt out of the processing of Personal Information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. However, we do not process Personal Information for these purposes.

Right to Equal Services and Price

Residents of certain U.S. states have the right to receive equal services and price, even if they exercise a privacy right.

Verification Process for Exercising Rights

To protect your privacy, we verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your Personal Information. As part of our verification process, we may request you to submit additional information.

If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information at the top of this Privacy Policy and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.

Appeal Process

In certain cases, we may decline to take action on your request as permitted by law. Should we decline your request, we may provide you with a written explanation of the reasons for our decision and an opportunity to appeal the decision.

If we deny your appeal, we may provide a written explanation of our decision with instructions on how to contact your local Attorney General or Department of Justice for further review, where permitted under certain U.S. state privacy laws.

Additional Information for California Residents

The California Consumer Privacy Act of 2018 (CCPA) gives consumers more control over the personal information that businesses collect about them and the CCPA regulations provide guidance on how to implement the law. Residents of California have the right to direct us to use or disclose Personal Information only for providing goods or Services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive Personal Information for any purpose other than providing our goods or Services, or as otherwise minimally permitted under applicable law. California residents can exercise the privacy rights by contacting us at privacy@sparkingtiming.com.

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Sites and Services who are California residents to request, once per calendar year, certain information regarding our disclosure of Personal Information (if any) to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below. Please include in your request a current California address and your attestation that you are a California resident.

Privacy rights & additional disclosures for EEA, UK, and Swiss individuals

If you are from the European Economic Area (EEA), United Kingdom (UK), or Switzerland, our legal bases for collecting and using your Personal Information is as follows:

  • The performance of your contract or to enter into the contract and to take action on your requests. For example, the processing of your account registration.
  • Our legitimate business interests. For example, fraud prevention, maintaining the security of our network and Services, direct marketing to you, and improvement of our Services.
  • Compliance with mandatory legal obligations. For example, accounting and tax requirements, which are subject to mandatory retention periods. We may also collect your Personal Information to record your requests to exercise your rights and to verify your identity for such requests.
  • Consent you provide where we do not rely on another legal basis. Consent may be withdrawn at any time.

In some limited cases, we may also have a legal obligation to collect Personal Information from you in response to lawful requests by public authorities, including to meet law enforcement requirements, as described above in the “How we share information” section.

Rights

If you are from the EEA, UK, or Switzerland, you have the right, under certain circumstances, to:

  • Access your Personal Information;
  • Correct inaccurate information in your Personal Information;
  • Request erasure of your Personal Information without undue delay;
  • Request restriction of, in certain circumstances, the processing of your Personal Information;
  • Request receiving a portable copy of your Personal Information held by us, and to have that portable copy transmitted to another controller; and,
  • To object to the processing of your Personal Information.

To exercise any of these rights, please contact us using the contact details provided at the top of this Privacy Policy, and please specify which privacy right(s) you wish to exercise. We may need to verify your identity to honor your request.

If you have any issues with our compliance, you have the right to lodge a complaint with the appropriate supervisory authorities. We would, however, appreciate the opportunity to first address your concerns and would welcome you to direct your inquiry to us via the contact information at the top of this Privacy Policy.

8. Changes to This Policy Notice

We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided. We encourage you to review this Privacy Policy regularly to ensure that you are familiar with Timing’s current practices.

9. How to Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at privacy@sparkingtiming.com.