Privacy Policy
This notice explains what personal information we collect through sparkling-app.us and the Sparkling app, why we collect it and the choices you have, including rights under California and other US state privacy laws. Effective 21 October 2026.
1. Who This Notice Covers
Sparkling, an AI-assisted crypto trading tool where users keep their own keys, runs in web browsers and inside Telegram. It is provided by Swarming Labs Ltd, Intershore Chambers, Road Town, Tortola, British Virgin Islands (“we”). This notice applies to visitors of sparkling-app.us and to users of the app located in the United States.
2. Information We Collect
| Category | Examples | How we get it |
|---|---|---|
| Identifiers | Email address, Telegram ID and username, wallet addresses, IP address | From you and your device |
| Login data | One-time codes, kept only in a non-readable form | From you |
| Identity documents | Name, date of birth, government ID and address, only if a verification is required | From you, via a verification vendor |
| Commercial and transaction data | Agent prompts, price quotes, approved transactions and hashes | From your use of the app |
| Internet activity | Pages viewed, features used, device and browser type, crash logs | Automatically |
| Approximate location | Region derived from your IP address, used to apply availability rules | Automatically |
| Compliance data | Sanctions screening results | From screening providers |
Blockchain transactions are public by design. Anyone can see wallet addresses and amounts on-chain, independently of this notice.
3. How We Use It
- to create and secure your account and to prepare, route and record the transactions you approve;
- to apply location-based availability and sanctions rules;
- to detect and prevent fraud, abuse and unauthorized access;
- to respond to support requests and send service messages;
- to analyze and improve the website and the app;
- to meet legal, tax and record-keeping obligations and respond to lawful requests.
4. Sale, Sharing and Targeted Advertising
We do not sell personal information, and we do not share it for cross-context behavioral advertising. We do not use sensitive personal information to infer characteristics about you. Marketing emails are sent only if you opt in, and each one contains an unsubscribe link.
5. Who We Disclose It To
Service providers and contractors that host, secure, analyze or support the service, bound by written terms that limit their use of the data; infrastructure partners that route or settle approved transactions and follow their own privacy notices; government authorities when required by law, subpoena or court order; and a successor entity in a merger, acquisition or asset sale.
6. Retention
| Data | Kept for |
|---|---|
| Account profile | While your account is active and 12 months after closure |
| Transaction history | Seven years |
| Identity verification files | Five years after closure |
| Support tickets | Three years |
| Server and security logs | 30 days, extended to 90 days for investigations |
| Website analytics | 14 months |
7. Your Privacy Rights
Depending on your state of residence, including California, Colorado, Connecticut, Virginia, Texas and other states with consumer privacy laws, you may have the right to:
- know what personal information we hold and how we use and disclose it;
- get a copy of it in a portable format;
- correct inaccurate information;
- delete information, subject to legal exceptions;
- opt out of sale, sharing and targeted advertising, which we do not engage in;
- appeal a decision about your request.
Send requests from the email linked to your account so we can verify you. An authorized agent may submit a request with your signed permission. We answer within 45 days and will not discriminate against you for exercising your rights. If we deny a request, you can appeal by replying to our decision; if the appeal is denied, you may contact your state attorney general.
8. Global Privacy Control
Our website recognizes the Global Privacy Control signal. When your browser sends it, we treat it as a request to opt out and keep analytics cookies switched off for that browser.
9. Security
Data is encrypted when stored and when sent, staff access is limited and protected by MFA, and we run periodic security reviews. If a breach affects your personal information, we will notify you as required by applicable state law.
10. Children
The service is for adults 18 and over. We never knowingly gather data from children under 13, or from anyone under 18, and we delete it if we discover it.
11. International Processing
We and our providers may process information outside the United States, where privacy laws may differ. We protect it with contractual and technical safeguards.
12. Updates and How to Reach Us
Updates appear on this page and notify account holders of material changes. Questions or requests:
- Privacy requests: [email protected]
- Legal notices: [email protected]
- General questions: [email protected]
- Mail: Swarming Labs Ltd, Intershore Chambers, Road Town, Tortola, British Virgin Islands
Updated: