Privacy Policy of the platform

1. Introduction

Welcome to CreateSpark (“we,” “us,” “our”). We respect your privacy and adhere to the EU General Data Protection Regulation (“GDPR”) and other applicable laws. This Privacy Policy explains how we collect, use, share, and secure your data when you use the CreateSpark mobile application or website (“Service”). It also describes your rights under the GDPR and how to exercise them.

2. Who We Are

Data Controller: CreateSpark, registered in the Netherlands.

Contact: For any privacy-related questions or requests, email us at hello@createsparkapp.com.

Data Protection Officer: We have not appointed a Data Protection Officer as we are not required to do so under the GDPR. If you have concerns, please contact us using the email above.

3. Eligibility

Our Service is intended for individuals aged 18 or older. We do not knowingly process personal data of minors. If you are a parent or guardian and believe a minor has provided us with data, please contact us so we can delete it.

4. Personal Data We Collect

• Account Details: Name, username, email address, and any additional profile information (creative roles, interests).
• Content & Portfolio: Text, images, or other media you upload or share publicly (e.g., project ideas, photos, comments).
• Usage Data: Interactions with our Service (pages viewed, features used, timestamps, etc.).
• Technical Data: IP address, device type, operating system, browser version, and diagnostic information.
• Payment Data: Processed securely by Stripe. We do not store full payment details on our servers. Stripe’s privacy policy applies to their handling of your financial data.
• Cookies & Tracking: We (and our partners) may use cookies and similar technologies to analyze usage (via Google Analytics) and improve user experience.

We practice data minimization, collecting only data that is relevant and necessary for the purposes described in this Policy.

5. Legal Bases for Processing

Under GDPR, we rely on:

• Consent (Article 6(1)(a)): For optional services (e.g., marketing communications, certain cookies).
• Performance of a Contract (Article 6(1)(b)): To provide our Service features (user accounts, collaboration) and process payments.
• Legitimate Interests (Article 6(1)(f)): For product enhancement, security measures, and fraud prevention.

6. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to:

• Remember user preferences (e.g., logins).
• Conduct analytics (e.g., Google Analytics) to understand Service performance.
• Show limited relevant messaging.

Where required by law, we will request your consent for non-essential cookies. You can withdraw consent or disable cookies through your browser settings at any time. For more details, please see our [Cookie Notice/Section] (if you have one).

7. How We Use Your Personal Data

• Account Management: Create user profiles, facilitate project collaboration, and handle Service administration.
• Improvement & Analytics: Understand user engagement, troubleshoot errors, and develop new features using aggregated analytics.
• Communications: Send emails or push notifications for account updates or marketing (with your consent).
• Payments: Process transactions securely via Stripe.
• Compliance & Security: Detect and prevent fraud or illegal activities, ensure network and information security, and comply with legal obligations.

8. How We Share Your Data

• Other Users: Portions of your profile (e.g., username, portfolio) are visible to other CreateSpark users to enable collaboration.
• Service Providers: We share necessary data with trusted third parties (Stripe, Google Analytics, hosting providers) bound by confidentiality.
• Legal or Regulatory: We may disclose personal data to comply with legal requirements (court orders, government requests) or to protect our rights and property.

We do not sell or rent your personal data.

9. International Data Transfers

Our servers or some of our processors (e.g., Google Analytics, Stripe) may be located outside the European Economic Area. We use Standard Contractual Clauses or other safeguards as required by GDPR to ensure equivalent protection of your data.

10. Data Retention

We retain personal data as long as needed to fulfill the purposes stated in this Policy, or as required by law. When your data is no longer necessary, we will securely delete or anonymize it. If you request deletion of your account, we will erase or anonymize your data (including backups) within [e.g., 30 days], except where legally required to retain it.

11. Your GDPR Rights

You have the right to:

• Access: Request a copy of your data.
• Rectification: Correct inaccurate or incomplete data.
• Erasure: Request deletion of your data if processing is no longer necessary.
• Restriction: Request restricted processing under certain circumstances.
• Object: Object to processing based on legitimate interests or direct marketing.
• Data Portability: Obtain and reuse your data across different services.

If you wish to exercise any of these rights, or withdraw consent where processing is based on consent, please contact us at info@createsparkapp.com. We may need to verify your identity before processing your request.

Right to Lodge a Complaint: You have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) if you believe we have not addressed your concerns. For more details, visit: https://autoriteitpersoonsgegevens.nl/.

12. Security Measures

We implement administrative, technical, and physical safeguards to protect your data from unauthorized access or misuse. Although we strive to ensure security, no system is 100% foolproof, and we cannot guarantee absolute protection.

13. Changes to This Policy

We may update this Policy as our practices evolve or as legal requirements change. When we do, we revise the “Last Updated” date above. In case of significant changes, we will notify you via email or a prominent notice. Your continued use of CreateSpark after the changes take effect indicates acceptance.

14. Contact Us

If you have questions or concerns about this Privacy Policy or any privacy-related issue, please email us at: info@createsparkapp.com