Sparklife AI Limited

Effective date: 2 November 2026 · Version 1.0

This Privacy Policy applies to all apps published by Sparklife AI Limited. It is organised in two parts so that it can cover every Sparklife app in a single, consistent document.

Part A sets out the general terms that apply to all our apps — who we are, what data we process, the legal bases, how long we keep it, who we share it with, and your rights. Part B sets out the terms that are specific to an individual app. To understand how this policy applies to you, read Part A together with the Part for the app you use.

At present, this policy covers the Liv app (Part B). As we release further apps, each will be added as its own Part. Each Sparklife app is a wellness companion for adults. None of our apps is a medical device, a therapy service, or a crisis support service. If you ever need urgent support, the app’s Talk to someone screen lists helplines you can contact at any time.

PART A — GENERAL TERMS

A1. Who we are

Our apps are operated by Sparklife AI Limited, a company registered in England and Wales under company number 15758263. Sparklife AI Limited is the data controller for all personal data processed through our apps.

Registered name: Sparklife AI Limited

Company number: 15758263 (registered in England and Wales)

Registered address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom

Trading name: Sparklife

Website: sparklife.co.uk

Support email: support@sparklife.co.uk

If you have any questions about this policy or about how your data is handled, please contact us at support@sparklife.co.uk.

A2. What this policy covers

This policy explains what personal data our apps collect from you, why we collect it, how long we keep it, who we share it with, and what your rights are. It is written in plain language and applies to all users of our apps, wherever they are located.

This policy covers Sparklife apps available on the Apple App Store and Google Play. It does not cover third-party services that our apps link to, such as Apple’s or Google’s own subscription management systems.

A3. Data we collect and why

We collect only the data that is necessary to provide the companion service. The sections below describe each category of data, its purpose, and the legal basis under UK GDPR on which we process it.

A3.1 Account and identity data

When you create an account, we collect your email address. Sign-in is by a one-time code sent to that email address — we do not collect or store a password. During onboarding, the app asks for your preferred name, your gender, and your age range. We store your age only as a broad range (for example, 25–44) — we do not store your date of birth or your exact age.

Data collected: Email address, preferred name, gender, age range.

Purpose: To create and manage your account and to deliver the service to you.

Legal basis: Contract performance — UK GDPR Article 6(1)(b). This data is necessary to provide the service you have subscribed to.

A3.2 Conversation and health-related data

Each Sparklife app is a companion you converse with, and the heart of the service is the conversation. Across all our apps we collect and process the following in this category:

Full conversation transcripts from your chat sessions and your practice (role-play) conversations, and any feedback you ask for on a practice.

Memories — short factual notes extracted from your conversations, such as your goals, current situations, and things you are working through. These are kept while your account exists and updated or replaced as your circumstances change so that they stay accurate. See Section A6 for how long each category is kept.

Your answers to the onboarding questions (the specific topics each app asks about are described in that app’s Part below).

Mood selections from the daily check-in chips, stored as simple text labels, not clinical assessments.

Wins you record and activity you log, with any short note you write and how it felt.

Weekly reviews — short summaries of your previous week that Liv writes from what you have recorded in the app.

This data is classified as special category data under UK GDPR because it relates to your mental health and emotional state.

Purpose: To power the app’s conversations and to allow it to build a meaningful, continuous relationship with you over time.

Legal basis: Explicit consent — UK GDPR Article 6(1)(a) and Article 9(2)(a). You will be asked to give explicit consent to this processing before your first conversation. You may withdraw this consent at any time by requesting deletion of your data — see Section A7.

Because our apps process health-related information, we ask for your explicit consent before your first conversation. This is not a buried checkbox — it is a dedicated screen. If you do not consent, you cannot use the app, because the processing is essential to the service. The specific health-related topics each app asks about are set out in that app’s Part below.

A3.3 Subscription and payment data

Your subscription is managed through Apple App Store or Google Play. We do not process your payment card details — these are held by Apple or Google. We receive confirmation of your subscription status (trial, active, or cancelled) from our subscription management provider.

Every new account begins with a free trial managed by the app itself, not by Apple or Google — see Section A5 of our Terms of Service for how this works and what that means for trial eligibility.

Data collected: Subscription status, trial start and end dates, subscription end date.

Purpose: To verify your access to the app and manage your subscription.

Legal basis: Contract performance — UK GDPR Article 6(1)(b).

A3.4 Analytics and crash data

We use analytics to understand how the app is being used so we can improve it. We also collect crash reports when the app encounters a technical error. Analytics events are anonymised or pseudonymised where possible.

Data collected: In-app events (such as session starts and feature use). Analytics events never include your mood selections or anything you write. Device model, operating system version, and app version are appended to crash reports only.

Purpose: To improve the app, monitor performance, and detect errors.

Legal basis: Legitimate interests — UK GDPR Article 6(1)(f). We have assessed that our interest in improving a safe, functional product is proportionate and does not override your interests or rights.

A3.5 Notifications and bug reports

If you allow notifications, we store a token that identifies your device to Apple’s or Google’s notification service, so that we can send you reminders (for example, if you have not opened the app for a while). You can switch reminders off in the app’s Settings or in your device settings. Unlocking the app with Face ID or Touch ID happens on your device; we never receive your biometric data.

If you send us a bug report from the app, we receive what you write, up to three screenshots you attach, and your name and email address, so that we can reply to you.

Data collected: Device notification token (if you allow notifications); the content of any bug report you send.

Purpose: To send the reminders you have not switched off, and to investigate and answer your report.

Legal basis: Contract performance — UK GDPR Article 6(1)(b) for the notification token (reminders are part of the service); legitimate interests — Article 6(1)(f) for bug reports, which you start yourself.

A4. How your data is used

Your conversation data and memories are sent to our AI provider, Anthropic, to generate the app’s responses, to write memories, practice feedback and weekly reviews, and to recognise signs of serious distress. This is the core function of the app and cannot be provided without this processing. Our AI provider processes your data as a data processor acting on our instructions — it does not use your data to train its models.

We access individual conversation data only in the following circumstances:

In response to a support request or bug report that you have made to us.

Where required by law or a court order.

We do not sell your data. We do not use your data for advertising. We do not share your data with any third party except as described in Section A5 of this policy.

A5. Third-party processors

We use a small number of trusted third-party services to operate our apps. Each acts as a data processor under a Data Processing Agreement with Sparklife AI Limited. They process your data only on our instructions and for the purposes described.

Cloud database and authentication provider: Stores your account data, conversation history, memories, and mood logs. Servers are located in the United Kingdom.

Anthropic: Receives your conversation messages to generate the app’s responses and to check for signs of serious distress. Data is not used for model training. Based in the United States, operating under appropriate transfer safeguards.

Subscription and payments management provider: Receives your subscription status and purchase events from Apple and Google. Does not receive your conversation data. Based in the United States, operating under appropriate transfer safeguards.

Analytics provider: Receives anonymised or pseudonymised app usage events. Does not receive your conversation content. Based in the United States; the analytics data is stored in the European Union.

Crash reporting provider: Receives error logs and device information when the app encounters a technical fault. Does not receive your conversation content. Based in the United States, operating under appropriate transfer safeguards.

Email delivery provider: Sends the sign-in codes and other service emails, and delivers bug reports to us. Receives your email address and the content of those emails and, for a bug report, what you wrote, your name and any screenshots.

Notification services: If you allow notifications, Apple’s or Google’s notification service, and the service that passes our reminders to them, receive your device’s notification token and the text of each reminder.

Apple and Google process subscription and billing data under their own terms. We do not control this processing.

We will update this section if our AI provider changes or if we add another. If you require confirmation of the current data processing position with our AI provider, please contact us at support@sparklife.co.uk.

A6. How long we keep your data

We keep your data only for as long as it is necessary. A subscription lapsing or being cancelled does not, by itself, delete anything. Chat and role-play access are gated to paying subscribers, but your account, your history, and all of your existing content remain in place and accessible in the app for as long as your account exists — whether you are on an active trial, an active subscription, a lapsed trial, or a cancelled subscription. Deletion happens only when you ask for it (Section A7), or in the limited dormancy circumstance described below.

Conversation transcripts: Kept while your account exists, so your history remains available to you in the app. The app only ever uses your most recent day’s conversation to generate new responses; older transcripts are retained for your own reference and are not resent to the AI model. All transcripts are permanently deleted when your account is deleted, as described under “Account data” below.

Memories: Memories are kept while your account exists, so Liv can maintain a continuous understanding of you. They are not fixed in number: as your circumstances change, Liv updates or replaces individual notes. A memory that you have set aside is retained, not deleted — setting aside is a way to tell Liv to leave something out without losing it, and you can bring it back at any time. A memory that has been superseded by Liv because the underlying fact changed is excluded from future conversations but is not currently deleted from our systems on any fixed schedule; it is deleted only when your account is deleted.

Mood logs: Kept while your account exists, so Liv can reflect your mood over time. They are deleted when your account is deleted.

Practice conversations and feedback: Kept while your account exists. You can delete an individual practice, with its transcript and feedback, from the Library at any time. They are deleted in full when your account is deleted.

Wins and logged activity: Kept while your account exists, and deleted in full when your account is deleted.

Weekly reviews: Liv may write a short review of your previous week. It is kept while your account exists, shown on the Progress screen until you dismiss it, and always available in the Library. It is deleted in full when your account is deleted.

Bug reports: Kept in our support mailbox for as long as we need them to deal with your report. To limit reports to three a day, we also record the time of each report you send, linked to your account; this record contains nothing you wrote and is deleted with your account.

Notification token: Kept while your account exists and deleted with it.

Account data: Kept while your account exists — including through a lapsed trial or a cancelled subscription. Your account is deleted only when you ask us to delete it (Section A7), or if it becomes dormant through extended inactivity (below). Cancelling your subscription, on its own, does not delete anything and does not need to be followed by a separate deletion request unless you actually want your data deleted.

Dormant accounts. If your account has no activity at all for 6 months, we will flag it as dormant and email you a notice giving you 30 days to come back before deletion proceeds. Using the app again during that time (for example, chatting with Liv, practising, or logging a check-in) cancels the scheduled deletion. This applies only to accounts without an active paid subscription: while you are paying for a subscription, your account is never flagged as dormant, however long it is since you last used the app.

If you would prefer not to wait for either of the above, you may request immediate deletion at any time — see Section A7.

In all cases, your entire account record is deleted. The only things that survive are your record of consent to health data processing (held in a separate consent record, which includes the email address you provided at the time consent was given, the date your account was deleted and how — by you straight away, by you through a queued request, or because the account was inactive) and a log of subscription events (see below). The consent record is kept solely as legally required proof that explicit consent was given — it is not used to recognise, link, or restore a returning user’s account. If you sign up again with the same email address after deletion, you will receive a completely fresh, unconnected account with no history.

What we keep after deletion. When your account is deleted, we remove your conversations, memories, practice sessions, wins, logged activity, weekly reviews, mood logs, and all other personal content — including the account record itself. The only things we retain are your record of consent to health data processing (a separate consent record containing the email address you provided when consent was given, with the date and route of the deletion), kept solely as legally required proof that consent was given under UK GDPR Article 9(2)(a), and the subscription event log described under “Subscription and payment records” below. The consent record is not used to recognise you, link you to a previous account, or restore any data. If you return and sign up again, you will start a completely fresh, unconnected account with no history.

Consent records: Your record of consent to health data processing is kept for 6 years from the date it was given, on accountability grounds under UK GDPR Articles 5(2) and 7(1) — we must be able to demonstrate that consent was given. Consent records are not deleted when other data is deleted.

Subscription and payment records: Your payment records are held by Apple, Google, and our subscription-management provider under their own terms and applicable financial and tax law (in the UK, generally six years). We do not hold your payment card details. We keep a minimal record of your subscription status for as long as necessary to administer your account and to meet our legal obligations. We also keep a log of the subscription events our subscription provider sends us (such as a purchase, renewal or cancellation). The log carries your account’s identifier but not your conversations, and at present it is not deleted when your account is deleted.

If your free trial expires, or your subscription lapses or is cancelled, and you have not yet subscribed or resubscribed, we may contact you by email to let you know about the opportunity to subscribe. We do this under the soft opt-in rule permitted by the Privacy and Electronic Communications Regulations (PECR), which allows contact about similar services. Every email we send includes an unsubscribe option. You can opt out at any time by clicking unsubscribe in any email from us. We never contact a user after their account has been deleted, and we never use the retained consent-record email for any communication.

A7. Your rights

Under UK GDPR, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at support@sparklife.co.uk. We will respond within one month.

Right of access: You may request a copy of the personal data we hold about you. You can export your data directly in the app, as a Summary Report (PDF) or a Full Data Report (PDF or JSON).

Right to rectification: You may correct inaccurate data. You can update your name, gender, age and email address directly in the app, and you can set aside or delete your memories.

Right to erasure: You may request deletion of all your data at any time, whether or not you currently hold a subscription, using the “Delete app” option in the app’s account settings. This is separate from cancelling a subscription — cancelling your subscription does not delete your data (see Section A6), so if you want your data deleted you need to take this additional step. Once requested, your data is permanently deleted and there is no restoration option. In the rare case that the immediate deletion cannot complete, your request is queued and carried out overnight, and you are signed out in the meantime. No refund is issued for any unused portion of an annual subscription where you request deletion before it ends. In all cases, only your record of consent to health data processing is retained (as legally required proof of consent), not your account record or any personal content.

Right to withdraw consent: You may withdraw your consent to health data processing at any time. Withdrawing consent means we can no longer provide the service to you. To withdraw consent, request data deletion using the “Delete app” option described above. Cancelling your subscription alone does not withdraw consent or delete your data, since your account and its content remain usable (other than chat and role-play) as a free account.

Right to data portability: You may request your data in a portable format. Use the in-app export function to download the Full Data Report as a PDF or as a machine-readable JSON file.

Right to object: You may object to processing based on legitimate interests (analytics and crash reporting). Contact us at support@sparklife.co.uk to make an objection.

Right to restrict processing: You may request that we restrict processing of your data in certain circumstances. Contact us at support@sparklife.co.uk.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection:

ICO website: ico.org.uk

ICO telephone: 0303 123 1113

If you are located in the European Economic Area, you may also have the right to lodge a complaint with your local supervisory authority.

A8. Data security

We take reasonable and proportionate steps to protect your data. These include:

Data is transmitted between the app and our servers using industry-standard TLS encryption. Data stored on our servers is protected by the security controls provided by our cloud database provider.

Access to the database is restricted to authorised personnel and automated systems only.

Row-level security controls mean that no user can access any other user’s data through the app.

API keys and credentials are never stored in the app code and are managed through secure environment configuration.

Crash reports and analytics data are anonymised or pseudonymised and do not include your conversation content. Face ID and Touch ID are handled by your device; we never receive biometric data.

No system is completely secure. If you become aware of any security concern related to one of our apps, please contact us immediately at support@sparklife.co.uk.

A9. Age requirement

Our apps are intended for adults aged 18 and over. We do not knowingly collect data from anyone under the age of 18. If you believe a minor has created an account, please contact us at support@sparklife.co.uk and we will delete the account promptly.

A10. International data transfers

Some of our third-party processors are based in the United States. Where data is transferred outside the UK, we ensure that appropriate safeguards are in place, including Standard Contractual Clauses approved by the UK Information Commissioner’s Office or equivalent transfer mechanisms.

Our cloud database provider stores data in the United Kingdom. Our AI provider (Anthropic), subscription management provider, analytics provider, and crash reporting provider are based in the United States and operate under appropriate transfer safeguards including Standard Contractual Clauses approved by the UK Information Commissioner’s Office.

A11. About our AI

Our apps are powered by artificial intelligence. They are not human, not a therapist, and not a doctor. Each is a conversational AI companion designed to listen, support, and help you think things through.

Responses are generated by a large language model. While our apps are designed to be thoughtful and supportive, AI-generated responses can sometimes be incorrect, unhelpful, or not suited to your specific situation. Please use your own judgement and seek professional support when you need it.

Our apps include automated safety measures designed to recognise signs of serious distress in a conversation and respond appropriately, including showing you helplines. These checks are carried out by an AI provider and see the text of your message. These measures are a safeguard, not a guarantee — they do not replace your own judgement or professional support, and the helplines in the app’s Talk to someone screen are always available regardless of your subscription status, whether or not a safety measure has been triggered.

A12. Changes to this policy

We may update this policy from time to time. How we handle a change depends on how significant it is.

Ordinary changes. For most updates — such as clarifications, minor operational changes, or changes that do not materially affect how we process your data — we will notify you by email at the address associated with your account at least 30 days before the change takes effect, with a link to the updated policy. If you continue to use the app after the change takes effect, you accept the updated policy. If you do not agree, you may request data deletion at any time before or after the change takes effect, as described in Section A7, with no penalty.

Material changes to how we process your health-related data. Because we process special category health data on the basis of your explicit consent (Section A3.2), if we make a material change to how that data is processed — for example, processing it for a new purpose, sharing it with a new category of recipient, or transferring it under materially different safeguards — we will ask you for fresh explicit consent before the change applies to you. We will not rely on your silence or continued use as consent for a material change of this kind. If you do not give fresh consent, we can no longer provide the service to you, and you may request deletion with no penalty.

The effective date at the top of this policy shows when it was last updated. The current version is always available at sparklife.co.uk/privacy. We send change notices by email as a service communication; this is separate from marketing email, and you cannot opt out of receiving important notices about changes to this policy while you hold an account.

A13. Contact us

For any questions, concerns, or requests relating to this policy or your personal data:

Email: support@sparklife.co.uk

Website: sparklife.co.uk

Registered address: Sparklife AI Limited, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom

Sparklife AI Limited is registered in England and Wales under company number 15758263.

PART B — LIV (specific to the Liv app)

This Part applies specifically to the Liv app. Read it together with Part A above, which applies to all Sparklife apps.

B1. What Liv is

Liv is a social confidence companion app for adults who want to feel more confident and at ease with other people. Liv is a conversational AI companion designed to provide a space for reflection, practice, and encouragement. As set out in Part A, Liv is not a medical device, a therapy service, or a crisis support service, and is not a substitute for professional care.

B2. Liv-specific data we collect

In addition to the data described in Part A, Section A3, Liv collects the following information specific to its purpose:

Your onboarding answers about the kinds of social situations you find draining and what you would like to get from Liv.

Your mood selections from Liv’s check-in chips. The morning options are Confident, Calm, OK, Anxious and Worried; the evening options are Relaxed, Good, OK, Drained and Exhausted; and you can also rate your day as Good, OK or Hard. These are stored as simple text labels, not clinical assessments.

The practice conversations you have with Liv, and any feedback you ask for on them.

The situations you save as favourites in the Library.

The wins you record, and the things you log that you have done, with any note you add.

The weekly reviews Liv writes for you.

All of this is part of the conversation and health-related data described in Part A, Section A3.2, and is processed on the same legal basis (explicit consent) and subject to the same retention periods.

What reaches the AI provider. Your chat and practice messages, your memories, and the mood you chose are used when Liv replies. When Liv writes a weekly review, it is given a summary of the week: your mood selections, the wins and activity you logged (including any notes you wrote), the titles of the practices you did and the “what went well” lines from their feedback.

B3. Liv’s AI

Liv is presented as a warm, supportive companion and is referred to as “her” in the app. As set out in Part A, Section A11, Liv’s responses are generated by a large language model and can sometimes be incorrect or unsuited to your situation — please use your own judgement and seek professional support when you need it. Liv includes automated safety measures that can recognise signs of distress in a conversation and respond by pausing to check in with you and showing you helplines — in both ordinary conversation and practice. The helplines in Liv’s Talk to someone screen are always available, regardless of your subscription status.

Sparklife AI Limited