Privacy Policy

Spark may process the following categories of personal information:

Account information

• email address;
• internal account identifier; and
• information required for authentication.

Users may access Spark through Apple. If a user chooses to hide their actual email address, Spark will receive the alternative email address provided by Apple.

Usage information

Spark may store information related to the use of the application, including:

• number of available writing warm-ups;
• history of completed writing warm-ups;
• days of use and consecutive usage days;
• selected preferences and categories;
• duration and stages of writing warm-ups;
• number and types of exercises completed; and
• information related to exercise completion and evaluation.

This information may be linked to the user’s account to operate Spark’s features, maintain usage history, and adapt the writing warm-up experience.

Analytics data

To understand how the application is used and identify improvements, Spark uses a specialized usage analytics tool (PostHog), which may record events such as screens accessed, taps, and in-app navigation.

These events are linked to a random identifier, not to the user’s name or email address, and do not include the content typed during exercises. Aggregated country-level information may also be available through Apple’s own reports on application usage.

Text entered during exercises

Content entered during an exercise may be processed temporarily to provide the exercise’s functionality.

The full text is not retained as permanent account history and is not used to train artificial intelligence models, display advertising, sell personal information, or perform human analysis of the user’s writing.

Certain information derived from the completion of an exercise may be stored, such as its duration, completed stages, exercise type, and evaluation or completion data.

Purchase and subscription information

When a user makes a purchase through the App Store, Spark may receive information such as:

• product or package purchased;
• purchase date;
• subscription status and subscription period;
• transaction identifiers; and
• purchase and renewal history.

Payments are processed by Apple. Spark does not receive complete payment card details, Apple Account passwords, or other complete payment method information.

Technical information

During the use of Spark, technical information required for the operation and security of the service may be processed, including:

• IP address;
• access date and time;
• account identifier;
• request logs; and
• error and technical failure logs.

IP addresses are not stored in Spark’s database. They are processed temporarily by Spark itself solely to limit abuse attempts (rate limiting). Infrastructure, security, and, where applicable, usage analytics providers may automatically process IP addresses when they receive a connection or event, for security, service operation, and, in the case of the analytics tool, usage measurement.

Support information

When a user contacts Spark, Apollo may process the user’s name, email address, message content, and any other information voluntarily provided in the communication.

Personal information may be used to:

• create, authenticate, and manage accounts;
• provide exercises and writing warm-ups;
• maintain preferences and usage history;
• calculate available writing warm-ups;
• adapt and improve the user experience;
• validate purchases, packages, and subscriptions;
• restore eligible purchases;
• maintain application security;
• identify errors, failures, fraud, or misuse;
• respond to support requests;
• comply with legal and regulatory obligations; and
• exercise or protect the rights of Apollo and its users.

Where a legal basis is required, processing may be based on providing the service requested by the user, complying with legal obligations, exercising legal rights, Apollo’s legitimate interests, or the user’s consent, as applicable.

Apollo may allow service providers required for Spark’s operation to process personal information, including providers of:

• authentication and account management;
• hosting and infrastructure;
• data storage;
• security and fraud prevention;
• application usage and performance analytics;
• technical logs and error diagnostics;
• application development, distribution, and updates; and
• customer support and email communication.

These service providers receive only the information required to perform their respective services.

Apple may also process information related to authentication, application distribution, purchases, subscriptions, purchase restoration, cancellations, and refunds in accordance with its own terms and privacy policies.

Personal information may also be disclosed when necessary to:

• comply with a legal or regulatory obligation;
• respond to a court order or valid request from a public authority;
• investigate fraud or unlawful activity; or
• protect the rights of Apollo, Spark users, or third parties.

Spark does not:

• sell personal information;
• display third-party advertisements within the application;
• share personal information for personalized advertising;
• use text entered during exercises for advertising; or
• track users across third-party applications or websites for advertising purposes.

Spark’s official website currently functions as an informational website and does not use advertising cookies, advertising pixels, or behavioral analytics tools.

Some service providers used by Apollo may maintain infrastructure or conduct operations outside Brazil.

For this reason, certain personal data may be processed in other countries.

When an international transfer occurs, Apollo will adopt measures intended to protect personal data in accordance with the LGPD and applicable regulations.

Personal information will be retained for as long as necessary to provide Spark and fulfill the purposes described in this Policy.

While an account remains active, Apollo may retain account information, preferences, usage history, available writing warm-ups, and purchase and subscription information.

Technical and security records may be retained for limited periods for diagnostics, fraud prevention, and infrastructure protection.

Temporary copies may remain in backup systems until they are replaced or deleted through the ordinary technical cycles of the relevant services.

Certain records may be retained for longer periods when required to comply with legal or regulatory obligations, prevent fraud, or exercise rights in administrative, judicial, or arbitration proceedings.

Additionally, to prevent the creation of new accounts intended to improperly obtain free writing warm-ups or other promotional benefits, the identifier linked to a subscription or purchase made through the Apple Account may be retained by Apollo for up to thirty (30) days after deletion of the account to which it was associated. This processing is based on Apollo’s legitimate interest, and that of other users, in preventing fraud and misuse of the service (Article 7, IX, of the LGPD). It is carried out temporarily, proportionally, and limited to the specific purpose of preventing reuse of the same identifier to create a new account during that period. After the thirty (30) day period, the identifier will be deleted, subject to other retention grounds provided in this Policy or applicable law.

Users may request account deletion directly through the Spark application.

After confirmation, the deletion process begins immediately and includes account information, usage history, preferences, available writing warm-ups, and other information maintained directly by Spark.

Deleted information cannot be recovered.

Residual copies may temporarily remain in backups or technical records until they are removed through the ordinary retention cycles of the relevant systems.

Apple may continue to retain its own records relating to purchases, payments, and subscriptions in accordance with its policies and legal obligations.

Deleting a Spark account does not cancel an active App Store subscription. The subscription must be canceled separately through the user’s Apple Account settings.

Specifically for fraud prevention related to the improper obtainment of free writing warm-ups, the identifier linked to a subscription or purchase made through the Apple Account may be retained for up to thirty (30) days after account deletion, as described in Section 6 of this Policy. During that period, it will not be possible to create a new account linked to the same subscription or Apple Account. After that period expires, the identifier will be deleted.

Apollo adopts technical and administrative measures intended to protect personal information against unauthorized access, loss, alteration, improper disclosure, destruction, and unlawful processing.

These measures include access controls, authentication, communication protection, transaction validation, technical records, and the use of specialized infrastructure and security providers.

Spark is not directed specifically to children and is not intended for people under 12 years of age.

The application does not provide public profiles, chat, interaction between users, public rankings, or behavioral advertising.

If Apollo becomes aware that an account belongs to a person under 12 years of age, it may take the necessary measures to verify the situation, restrict access, or delete the account.

The processing of data belonging to children and teenagers will observe their best interests and applicable law.

Under the LGPD, users may request, where applicable:

• confirmation that processing is taking place;
• access to their personal data;
• correction of incomplete, inaccurate, or outdated data;
• information about the use and sharing of their data;
• anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
• portability of data, where applicable;
• deletion of data processed based on consent, subject to legally permitted retention;
• withdrawal of consent;
• objection to processing carried out in violation of the LGPD;
• review of decisions made solely through automated processing, where applicable.

To protect account data, Apollo may request information necessary to confirm the identity of the requester.

Certain data may be retained when its preservation is permitted or required by law.

Requests relating to privacy, personal information, or the exercise of applicable privacy rights may be sent to:

Email: sparksupport@apolloaxial.com

Controller: APOLLO TECNOLOGIAS SERVICOS E EDUCACAO INTERATIVA LTDA

CNPJ: 58.453.144/0001-83

Location: Campinas, São Paulo, Brazil

This Privacy Policy may be updated to reflect changes to Spark’s features, data processing practices, service providers, or applicable law.

The updated version will be made available within the application or on Spark’s official website and will include a new “Last updated” date.

Where a change requires consent or another affirmative action from the user, the request will be presented through the appropriate means.