Privacy Policy
Sparkwell · Effective 1 October 2026
Sparkwell is operated by Bossa Ventures LLC, a limited liability company registered in the State of Wyoming, United States (8200 NW 41st Street, 2nd Floor, Doral, FL 33166). Bossa Ventures LLC is the data controller.
1. Scope
This policy applies to sparkwell.win, the Sparkwell quiz and the Sparkwell web application.
2. Data we collect
Data you give us.
- Account data: your email address.
- Quiz answers: your relationship to the child; the child's first name and age range; the area you most want to change; the hardest part of your day; answers about the child's attention, emotional outbursts, energy, empathy, interests and curiosity; how you feel as a caregiver; what you have already tried or paid for.
- Optional health-related answers: whether the child currently takes medication and whether the child sees a therapist or specialist. Both questions offer a "prefer not to say" style option. We use these answers only to adjust the tone of the plan. We never use them for advertising.
- In-app activity: daily check-ins ("Hard", "Okay", "Lighter"), practices marked as done, saved phrases, reminder time, edits to the child's name or hardest time of day, and the optional reason you give if you cancel.
- Subscription data: plan, purchase, renewal and refund history. Card details are entered with Stripe and never stored by us.
- Support messages you send us.
Collected automatically. Device and technical data (device model, browser, operating system, language, time zone, error reports); usage data (screens opened, steps completed, session length); IP address and approximate location (country or region).
From third parties. Stripe confirms purchases, renewals, refunds and disputes so we can grant or revoke access. Advertising and analytics platforms may report aggregated campaign performance. We do not buy personal data from data brokers.
3. Why we use it (and our legal basis)
To build your plan and provide the service and your subscription (contract); to process payments, renewals, refunds and chargebacks (contract, legal obligation); to provide support (contract, legitimate interest); to keep the service secure and prevent fraud (legitimate interest); to measure and improve the product (legitimate interest, or consent where required); to send service messages, and marketing only with your consent; to meet tax, accounting and legal duties. We do not sell personal data.
4. Who we share it with
Only service providers acting on our instructions:
- Hosting and content delivery: Vercel.
- Database and authentication: Supabase.
- Payments and subscription management: Stripe.
- Email delivery (receipts, account and service emails): Resend.
- Product analytics: Google Analytics, through Google Tag Manager.
- Advertising measurement: Meta Pixel and Meta Conversions API. We send events such as "quiz started" and "purchase completed". We do not send quiz answers, the child's name or health-related answers to advertising platforms.
- Error monitoring: Sentry.
- Customer support email: Google Workspace.
We may also disclose data where required by law, to enforce our terms, or in a merger or sale of assets.
5. International transfers
We operate from the United States and sell internationally, so data may be processed in the United States and other countries where our providers operate. For transfers from the EEA, UK or Switzerland we rely on Standard Contractual Clauses.
6. Retention
Account data and in-app activity: while the account exists, then up to 30 days after deletion. Quiz answers from people who do not subscribe: up to 12 months. Subscription and transaction records: up to seven years (tax and accounting). Support correspondence: up to three years after closure. Diagnostic logs: up to 12 months.
7. Your rights
Depending on where you live you may access, correct, delete or export your data, object to or restrict processing, and withdraw consent. California residents may also request disclosure of the categories of data collected. Write to privacy@bossa-ventures.com; we reply within 30 days and may ask to verify your identity. You may also complain to your local data protection authority.
8. Security
We use encryption in transit, restrict access to production systems and keep access logs. No system is perfectly secure; we will notify you and the competent authorities of a breach where the law requires.
9. Children
Sparkwell is used by parents and caregivers. It is not directed at children, and children do not create accounts or use the app. The information about a child (first name, age range and the answers described above) is provided by the parent or caregiver, who can edit or delete it at any time. If you believe a child has given us personal data directly, write to privacy@bossa-ventures.com and we will delete it.
10. Changes
We post changes here and update the effective date; material changes are notified by email or in the product.
11. Contact
privacy@bossa-ventures.com · Bossa Ventures LLC, 8200 NW 41st Street, 2nd Floor, Doral, FL 33166, United States.