Spark Legal

Privacy Policy for Spark Waitlist

Last updated: March 2026

1. Who we are

This waitlist and website are operated by Nikodem Zelenak("we", "us", or "our").

If you have any questions about this Privacy Policy or how we handle your personal data, you can contact us at:
Email: nikodemzelenak@icloud.com

2. What data we collect

When you interact with this waitlist, we may collect the following information:

  • Email address - when you join the waitlist.
  • Technical information - basic logs automatically provided by your browser, such as IP address, browser type, and approximate time of access. This is used only for security and abuse prevention (for example, to detect bots or mass sign-ups), not for marketing analytics.

We do not intentionally collect sensitive categories of personal data.

3. How we use your data (Purpose & Legal Basis)

We use your personal data only for the following purposes:

1. Managing the waitlist

  • To register your email on the Spark waitlist.
  • To maintain your position and status on the waitlist.
  • Legal basis: Consent (Article 6(1)(a) GDPR).

2. Referral and rewards program

  • To generate and track your unique referral link.
  • To count valid referrals and determine eligibility for rewards or early access.
  • Legal basis: Legitimate interest (Article 6(1)(f) GDPR) - our interest in running a fair referral program and preventing abuse.

3. Communication about Spark

  • To send you occasional emails about your waitlist status, app launch updates, rewards, invitations, or early access.
  • Legal basis: Consent - by joining the waitlist you agree to receive these emails, and you can unsubscribe at any time.

4. Security and abuse prevention

  • To prevent fake sign-ups, bots and abuse of the referral system.
  • Legal basis: Legitimate interest - ensuring the integrity and security of our service.

We do not use your data for targeted advertising or sell it to advertisers.

4. Where and how your data is stored

  • Your email and referral data are stored in our backend database hosted by Supabase, a third-party service provider that offers secure managed PostgreSQL hosting.
  • Supabase acts as our data processor and processes personal data only on our instructions and in accordance with appropriate security measures.

We take reasonable technical and organisational measures to protect your data against loss, misuse, unauthorised access, disclosure, alteration or destruction.

5. How long we keep your data

We keep your email address and associated referral data for as long as the Spark waitlist and pre-launch program are active, or until:

  • You ask us to delete your data; or
  • You withdraw your consent.

After the waitlist phase ends, we may either:

  • Delete your data permanently; or
  • Migrate it into the production version of the Spark app (for example, to create your user account or honour rewards), in which case we will update this Privacy Policy and/or ask you for additional consent if required.

6. Sharing of your data

We do not sell, rent or trade your personal data.

We may share your data only with:

  • Service providers that help us operate the waitlist (for example, Supabase for secure data storage). These providers are bound by confidentiality and data-processing agreements and may not use your data for their own purposes.
  • Authorities or regulators, if we are legally required to do so (for example, in response to a lawful request from a court or data protection authority).

We do not use third-party analytics tools (such as Google Analytics) or advertising trackers on this waitlist page.

7. International transfers

Depending on where Supabase and its infrastructure are located, your data may be stored or processed outside your home country, possibly outside the European Economic Area (EEA).

Where such transfers occur, we aim to rely on appropriate safeguards (such as Standard Contractual Clauses) as required by GDPR to protect your data.

8. Your rights under GDPR

As an individual located in the European Union, you have the following rights regarding your personal data:

  • Right of access - to obtain confirmation of whether we hold your personal data and, if so, receive a copy.
  • Right to rectification - to request correction of inaccurate or incomplete data.
  • Right to erasure ("right to be forgotten") - to ask us to delete your personal data in certain circumstances.
  • Right to restrict processing - to ask us to limit how we use your data.
  • Right to data portability - to receive the data you provided in a structured, commonly used and machine-readable format.
  • Right to object - to object to processing based on legitimate interests.
  • Right to withdraw consent - where processing is based on your consent, you can withdraw it at any time.

To exercise any of these rights, send an email to nikodemzelenak@icloud.com with the subject line "Data Request". We may ask you for reasonable information to confirm your identity before we act on your request. We aim to respond within 30 days as required by GDPR.

You also have the right to lodge a complaint with your local data protection authority if you believe your rights have been violated.

9. Children's data

This waitlist is not intended for individuals under the age of 16. We do not knowingly collect personal data from children.

If you believe that a child has provided us with personal data, please contact us so we can delete it.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the law, our services, or how we process personal data.

When we make changes, we will update the "Last updated" date at the top of this page. If the changes are material, we may also provide an additional notice (for example, by email).

By continuing to use this website or remaining on the waitlist after changes take effect, you agree to the updated Privacy Policy.

11. Contact

If you have any questions, concerns or requests about this Privacy Policy or your personal data, please contact:

Nikodem Zelenak
Email: nikodemzelenak@icloud.com

Back to Spark