Legal

Privacy Policy

Effective date: [To be confirmed: effective date] · Last updated: 9 November 2026

Sparkwizz is built so that your ideas stay yours. This policy explains in plain words what stays on your phone, what leaves it, where it goes, why, and for how long.

The short version

1. Who is responsible

The controller of your personal data is the publisher of Sparkwizz:

[To be confirmed: publisher’s legal name]

[To be confirmed: registered address]

[To be confirmed: tax ID (NIP) and business register number]

Email: privacy@sparkwizz.app

Write to this address about anything in this policy or to use your rights. For help with the app, write to support@sparkwizz.app.

In this policy, “we” and “us” mean the publisher, and “Sparkwizz” or “the app” means the Sparkwizz app for iPhone and Android.

2. What this policy covers

This policy covers the Sparkwizz app, the website sparkwizz.app, and emails you send to our addresses. It does not cover the App Store, Google Play or other services you reach from Sparkwizz, which have their own privacy policies.

3. What stays on your phone

The following is stored only in the app’s own storage on your phone:

We have no access to this data. None of it is sent to us unless you use a cloud feature, as described in section 4.

Voice

On iPhone, Sparkwizz uses speech recognition on the phone only: your voice is turned into text on the phone, and the audio never leaves it. On Android, voice uses your phone’s speech recognition service. If it can’t work offline (for example on Android versions before 12, or without the offline language pack), Android may send the audio to Google to turn it into text, under Google’s privacy policy. Sparkwizz does not save recordings.

Exports and backups

You can export your ideas in a readable form, or make a backup encrypted with a passphrase you choose. Both are created on your phone and leave it only if you save or share them somewhere yourself, for example to Files, a cloud drive or a message. We never receive them. We can’t open an encrypted backup or recover its passphrase.

Your phone’s own backup

Your phone’s backup (iCloud Backup on iPhone, Google’s backup on Android) may include Sparkwizz’s data, depending on your phone’s settings. Apple or Google handle those backups under their own terms.

4. What our server processes, and why

Our server runs on Supabase in the European Union (Frankfurt, Germany). It is used only when you use something that needs it: cloud reactions, Sharpen, Whoosh, purchases and paywalls, or reporting an AI answer. Showing a paywall, including the one at the end of the first-run setup, uses it even if you buy nothing: it creates your anonymous ID and contacts RevenueCat and our server. The content of your ideas goes only to the cloud features you choose. Each card below says what we process, why, on which legal basis under the EU General Data Protection Regulation (GDPR), and how long we keep it.

Your anonymous ID

What
A random ID, created the first time the app uses our server, for example to show a paywall or for a cloud feature you choose (an anonymous sign-in), with its session tokens and sign-in times. While a session exists, Supabase Auth also keeps the IP address and device user agent it was started from; they are deleted with the ID. No email, name, phone number or password.
Why
To tell your requests apart, apply daily limits, and link your whooshes and purchases to your app.
Legal basis
Performance of our contract with you (Art. 6(1)(b) GDPR).
Kept
Until you use Delete all my data. It is also deleted automatically after 180 days without any activity, unless it still holds something you paid for or are owed: an active Pro subscription, unused whooshes from a pack or added by us, or a purchase on record. An unused free whoosh doesn’t stop the deletion.

What you send to cloud features

What
  • Cloud reactions (only if you choose “In the cloud”): the text and language of each idea you save from then on. Ideas saved before are never sent on their own.
  • Sharpen: the text, title and language of the idea you sharpen, when you tap it.
  • Whoosh: the text, title, tags and Sharpen answers of the idea you whoosh, what you tell it about yourself, the App Store country, and the evidence the app gathered; later, the corrections and test results you add, with the report’s evidence. The consent screen shows what will be sent before each whoosh.
Why
To produce the title and tags, the Sharpen questions or the Whoosh report you asked for.
Legal basis
Performance of our contract with you (Art. 6(1)(b) GDPR).
Kept
Not stored. The text passes through our server to the AI model and back, in memory, for the length of the request. Our logs record status codes, counts and durations, never the text. The AI provider works with zero data retention (section 5).

Usage records

What
For each cloud request: the time, the feature and step, the AI model, the number of tokens, the cost, the duration and an outcome code, linked to your anonymous ID. Never any text.
Why
To enforce limits, keep costs under control, find failures and prevent abuse.
Legal basis
Our legitimate interests in running a reliable, affordable service and preventing abuse (Art. 6(1)(f) GDPR).
Kept
90 days. After that, only daily totals remain, and they contain no IDs. If you delete your data sooner, the remaining records lose their link to your ID.

Limits and whoosh history

What
Today’s count of cloud reactions and Sharpen requests; your whoosh balance; and for each whoosh, when it started, its status, how many steps, corrections and results it took, and whether it came from the free gift, Pro or a pack.
Why
To apply the daily limit, count your whooshes, and return a whoosh automatically when a report can’t be made.
Legal basis
Performance of our contract with you (Art. 6(1)(b) GDPR).
Kept
Daily counts: deleted within a day after the day (UTC) ends. Balance and whoosh history: as long as your anonymous ID exists.

Purchases and subscription

What
When you buy something or your subscription changes: the product, whether it is a trial, its status and renewal, the period dates, the store, the price in US dollars and the currency you paid in, and the transaction’s event ID. We never receive your name, Apple ID or Google account, card details or billing address.
Why
To unlock Pro and whoosh packs, and to keep accounting records.
Legal basis
Performance of our contract with you (Art. 6(1)(b) GDPR) and our legal obligation to keep accounting and tax records (Art. 6(1)(c) GDPR).
Kept
Subscription status: as long as your anonymous ID exists. Purchase records: as long as accounting and tax law requires [To be confirmed: retention period for accounting records]. If you delete your data, they are kept without your anonymous ID.

Paywall views

What
Which version of the paywall you saw, where in the app, and whether you closed it or started a purchase, with the time and your anonymous ID.
Why
To learn which paywall works best (A/B tests), and to credit a purchase to the paywall that led to it.
Legal basis
Our legitimate interests in improving our offer (Art. 6(1)(f) GDPR). You can object at any time (section 14).
Kept
As long as your anonymous ID exists, and deleted with it.

Technical logs

What
Supabase, which hosts our server, logs requests and sign-ins: your IP address, the time, the address requested, the result and your device’s user agent. Supabase Auth also writes an audit record of sign-ins and other Auth events, with your anonymous ID, the time and the IP address.
Why
Security, finding faults and preventing abuse.
Legal basis
Our legitimate interests in keeping the service secure and working (Art. 6(1)(f) GDPR).
Kept
For the short period Supabase keeps logs on our plan [To be confirmed: Supabase log retention, for example 7 days]. Auth’s audit records: [To be confirmed: the database audit log is turned off, or how long its records are kept].

Abuse prevention

What
If an anonymous ID is used to abuse the service, we can block it, with the time and a short internal note on why. We can also add whooshes to an ID by hand, for example to make up for a fault. Our admin log records each such change with the anonymous ID it concerns.
Why
To stop abuse, and to keep a record of what our admin changed.
Legal basis
Our legitimate interests in preventing abuse and keeping the service accountable (Art. 6(1)(f) GDPR).
Kept
A block and added whooshes: as long as your anonymous ID exists, and deleted with it. Admin log entries stay as our record [To be confirmed: admin log retention]; once the ID is deleted, the ID they hold no longer leads to anything.

Please don’t put other people’s personal details, or sensitive information about yourself, into ideas you send to cloud features.

5. How the AI features work

7. Purchases

8. Usage statistics and crash reports

Both are optional and stay off until you agree, in onboarding or in Settings → Privacy. Nothing is collected before you agree.

Usage statistics (PostHog, EU)

What
Which screens you open and which buttons you use, steps such as onboarding and purchases, and errors; with the app version, device model, operating system, language and a random analytics ID. Never the text of your ideas or reports, and no screen recordings. PostHog may derive an approximate country from your IP address [To be confirmed: IP addresses are not stored in the PostHog project].
Why
To see what works and what breaks, and to improve the app.
Legal basis
Your consent (Art. 6(1)(a) GDPR, and the rules on storing and reading information on your device).
Kept
[To be confirmed: PostHog retention period, for example 12 months]

Crash reports (Sentry, EU)

What
The error, where in the code it happened, the app’s recent steps, the app version, device model and operating system. The text of ideas is removed before a report is sent.
Why
To find and fix crashes.
Legal basis
Your consent (Art. 6(1)(a) GDPR).
Kept
[To be confirmed: Sentry retention period, for example 90 days]

You can withdraw your consent at any time in Settings → Privacy. Withdrawing doesn’t affect what was collected before.

9. Reporting an AI answer

If an AI answer is wrong, offensive or harmful, you can report it in the app. The report sends us the AI text you chose to report, the reason, and your comment if you write one, with your anonymous ID. Our server adds the models and instruction versions in use when you send the report. Your idea itself is not sent.

Please don’t include personal details in your comment.

10. When you email us

When you write to support@, privacy@ or ads@sparkwizz.app, we receive your email address, your name if you give it, and your message with any attachments. Our email is hosted by Google Workspace.

11. This website

sparkwizz.app is a static website hosted on GitHub Pages. It uses no cookies, no analytics, no scripts and no third-party fonts. As the host, GitHub processes your IP address to deliver the pages and protect its service, under GitHub’s privacy statement. Our legal basis is our legitimate interest in running the website (Art. 6(1)(f) GDPR).

12. Who receives data

We use these service providers. They process data on our behalf (as processors), under data processing agreements, unless the table says otherwise.

ProviderWhat forWhere
SupabaseOur server and database (section 4)EU (Frankfurt, Germany)
OpenRouterRouting AI requests, with zero data retentionUnited States
The model’s provider (Anthropic) and the cloud that hosts it with zero data retention, currently Google Cloud (Vertex AI) or Amazon Web Services (Bedrock), through OpenRouterRunning the AI model, with zero data retentionUnited States and other countries where the model is hosted
Brave SearchWeb searches for WhooshUnited States
RevenueCatProcessing purchases and subscriptionsUnited States
GrowthBookStatistics for paywall tests[To be confirmed]
PostHogUsage statistics, only with your consentEU (Frankfurt, Germany)
SentryCrash reports, only with your consentEU (Frankfurt, Germany)
Google WorkspaceOur emailEU and United States
GitHubHosting this websiteUnited States

Separate controllers. Apple and Google run the app stores, take payments, and receive App Store searches (Apple) or, on some Android phones, voice audio (Google), under their own privacy policies.

We may also disclose data where the law requires it, or to establish, exercise or defend legal claims. We never sell your data.

13. Transfers outside the EU

Some providers above are based in, or process data in, countries outside the European Economic Area, mainly the United States. For these transfers we rely on the European Commission’s adequacy decision for the EU–US Data Privacy Framework, where the provider is certified under it, or on the Standard Contractual Clauses approved by the European Commission, with additional safeguards where needed. [To be confirmed: the transfer mechanism in each provider’s data processing agreement] You can ask us for a copy of the relevant safeguards at privacy@sparkwizz.app.

14. Your rights

Under the GDPR you have the right to:

How to use them. Most of your data is only on your phone: you can read, edit, export and delete it in the app. To delete what our server holds, use Settings → Data → Delete all my data. For anything else, write to privacy@sparkwizz.app.

Because there are no accounts, our server doesn’t know who you are, and the app doesn’t show your anonymous ID. If you bought something, we can find your data from the order number of a Sparkwizz purchase. If you never bought anything, we usually can’t tell which server data is yours. In that case, as Art. 11(2) GDPR allows, we will tell you so, and we can act on a request to access, correct, restrict or port your data only if you give us details that let us find it. Delete all my data works for everyone, because the app itself proves the ID is yours. We will never ask for more than we need. We answer within one month; for complex requests we may extend this by two more months and will tell you why. Using your rights is free.

Objecting. To object to the processing of your paywall views, or to any other processing based on our legitimate interests, write to privacy@sparkwizz.app; if we can find your data, we stop and delete it. Delete all my data also deletes the paywall views recorded so far.

Do you have to give us data? No law requires you to. The cloud features can’t work without the text they process, and paywalls and purchases need the anonymous ID. Turning down usage statistics or crash reports has no consequences for you.

Complaints. You can complain to a data protection authority, in particular in the EU country where you live, work or where you think the law was broken. For example:

We’d appreciate the chance to sort out your concern first, so please consider writing to us before you complain.

15. Children

Sparkwizz is made for adults: it is not directed at anyone under 18, and we don’t knowingly process children’s personal data. The app has no accounts and doesn’t ask for your age. Its store content rating, which describes the app’s content rather than who it is for, is [To be confirmed: App Store and Google Play age ratings]. If you believe a child has sent us personal data, write to privacy@sparkwizz.app and we will delete it.

16. Security

No system is perfectly secure. If a breach affects your data, we will notify the supervisory authority and, where the law requires, you.

17. Changes to this policy

We’ll update this policy when the app or the law changes, and change the date at the top. If a change is significant, we will tell you in the app before it takes effect.

18. Contact

Privacy questions and requests: privacy@sparkwizz.app

Help with the app: support@sparkwizz.app · Help and support