Privacy Policy

This policy explains what personal data we collect when you use the Spark Guide mobile application or the spark-guide.app website, why we collect it, how long we keep it, and what your rights are. We wrote it to be read: no hidden data, no reselling, no advertising.

1. Who is responsible for your data

The data controller is Spark Guide LLC, a company incorporated in the State of Wyoming (United States), whose contact address is 12411 W Fielding Cir, Los Angeles, CA 90094, United States. For any question about your data: contact@spark-guide.app.

Spark Guide is an independent service, with no connection to the amusement parks covered by the application (in particular Disneyland Paris): no data is exchanged with the parks.

2. The data we collect

Your account

You can use the application with an anonymous account (created automatically, with no identity data). If you create a full account, we collect your email address, verified by a one-time code, and optionally a display name. The application is reserved for adults (18 and over): children do not have accounts.

Your visits and your group

To build your day plan, you tell us: the date and times of your visit, the parks chosen, your preferred activities, any reservations you have, and the composition of your group: number of people, age ranges, walking pace preference and, if you wish, the height of children (in centimeters, to check the minimum heights for attractions) and any accessibility needs (for example reduced mobility or pregnancy).

Accessibility and pregnancy information are special category data (health data) within the meaning of Article 9 of the GDPR. They are strictly optional: by voluntarily entering them, you consent to our using them solely to adapt your day plan. You can remove them at any time by editing your visit. Information about children (ages, heights) is entered by the adult account holder, who warrants that they hold parental authority; children do not have their own accounts and we do not collect any data directly from them.

Your location during your visit

During your day at the park, and only if you authorize it through your phone's settings, the application uses your location to guide you: to show your position on the map, estimate walking times, and automatically detect your arrival at an activity (including in the background, via detection zones managed by your phone).

Your location is not stored on our servers : it is processed on your phone. Only derived events (for example "arrived at the attraction") are transmitted to adapt your plan. We do not build a history of your movements and we never sell or share your location. You can withdraw the authorization at any time in your phone's settings; the application remains usable without location.

Your purchases

Purchases are made through Apple in-app purchases. We never see your bank card number. We keep the information necessary for unlocking and support: transaction identifier, product purchased, price paid, and any promo code used.

The conversational assistant (Sparkie)

If you use the built-in chat, your messages are processed by our artificial intelligence provider (Anthropic, Claude API) to generate the response. We keep the content of your exchanges with the assistant in order to verify that it works properly, improve its quality and safety, and prevent abuse. These exchanges are neither resold nor used for advertising purposes.

Error reports

In the event of a bug or crash, a technical report is sent to our error tracking tool (Sentry): information about the device, the state of the application at the time of the error, account identifier, and IP address. These reports are used solely to fix problems.

Personalized recommendations

To build your activity suggestions and your day plan, we apply automated processing (light profiling) based on the composition of your group and your preferences. This processing serves solely to personalize suggestions: it produces no decision with a legal effect or that significantly affects you, and you remain free to ignore our recommendations at any time.

Website

If you sign up for the waitlist on spark-guide.app, we keep your email address to notify you of the launch. The site uses no tracking cookies or audience analytics tools. Neither does the application: no third-party advertising or analytics SDK.

3. Why we use it (purposes and legal bases)

To send you reminders and useful information (before and during your visit), the application may send you notifications. If you allow them, your phone generates a notification token, a technical identifier provided by Apple, which we use solely to deliver these notifications to you. You can turn off notifications at any time in your phone's settings.

4. How long we keep it

• Account, visits, and plans: for as long as your account exists. Deleting the account immediately erases everything (profile, visits, plans, favorites, preferences).
• Location: never stored on our servers.
• Exchanges with the assistant: kept for the time necessary for the proper functioning, quality, and safety of the assistant.
• Notification token: for as long as you keep notifications enabled; deleted when you disable them or delete your account.
• Error reports: approximately 90 days with our provider.
• Purchase records: up to 10 years, in accordance with our accounting and tax obligations.
• Waitlist: until you unsubscribe or at the latest 2 years after launch.

5. Who has access (processors)

We never sell your data and do not share it with any advertiser. It is processed by the following technical providers, on our behalf and under contract:

6. Transfers outside the European Union

Your main data (account, visits, plans) is hosted in the European Union. Some processing, however, involves a transfer to the United States: Spark Guide LLC is a U.S. company, and some providers (Anthropic, Vercel, Apple) are established there. In practice, the data transferred to the United States is limited to the content of the messages you send to the chat (processed by Anthropic to generate the response) and, for the website waitlist, to your email address. These transfers rely on the mechanisms provided for by the GDPR, in particular the European Commission's standard contractual clauses and, where applicable, the providers' certification under the EU/U.S. Data Privacy Framework.

7. Security

All communications are encrypted (HTTPS/TLS). Access to the data in the database is partitioned per user: each account can only read its own data. Passwords and login codes are managed by our authentication provider and are never visible to us in clear text.

8. Your rights

In accordance with the GDPR, you have the rights of access, rectification, erasure, portability, restriction, and objection regarding your data, as well as the right to withdraw your consent at any time (for example by turning off location in your phone's settings, or by removing the accessibility information from your visit).

• Delete your account and all your data: directly in the application, Profile screen, "Delete my account" button (immediate effect).
• Exercise another right: write to us at contact@spark-guide.app. We respond within one month (extendable by two months if the request is complex).
• Complaint: if you believe your rights are not being respected, you may lodge a complaint with the CNIL (cnil.fr) or the data protection authority of your country.

9. Changes to this policy

If we change our processing (for example a new provider), we will update this page and, for any significant change, we will inform you in the application or by email. The date of the last update appears at the top of the page.

10. Contact

Spark Guide LLC, 12411 W Fielding Cir, Los Angeles, CA 90094, United States. contact@spark-guide.app.