Sparklife AI Limited
Effective date: 22 May 2026 · Version 3.0
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 are in crisis, please use the crisis resources available in the app at any time.
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.
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.
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.
When you create an account, we collect your email address. During onboarding, the app asks for your preferred name, pronouns (optional), and age. Your age is stored as a number only — we do not store your date of birth. We also detect your country from your IP address at sign-up to determine which crisis resources to show you.
Data collected: Email address, preferred name, pronouns (optional), age (integer), country (from IP address at sign-up).
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.
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:
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 cancelling your subscription and requesting data deletion through the in-app cancellation workflow.
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.
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.
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).
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, feature use, and subscription events). 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.
Your conversation data and memories are sent to our AI language model providers to generate the app’s responses. This is the core function of the app and cannot be provided without this processing. Our AI providers process your data as data processors acting on our instructions — they do not use your data to train their models.
We access individual conversation data only in the following circumstances:
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.
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 within the European Economic Area.
Primary AI language model provider: Receives your conversation messages to generate the app’s responses. Data is not used for model training. Based in the United States, operating under appropriate transfer safeguards.
Secondary AI language model provider (fallback): Used to generate the app’s responses when the primary provider is unavailable. 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, operating under appropriate transfer safeguards.
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.
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 providers change. If you require confirmation of the current data processing position with our AI providers, please contact us at support@sparklife.co.uk.
We keep your data only for as long as it is necessary. The following retention periods apply across all our apps:
Conversation transcripts: Kept for 12 months from the date of each session. Sessions older than 12 months are automatically and permanently deleted. The app only ever uses your most recent conversations in any case — older transcripts are not used to generate responses.
Memories: A maximum of 50 memories are kept at any time per user. When a new memory is created and the cap is reached, the oldest memory is automatically deleted. There is no separate time-based retention limit because the cap already prevents indefinite accumulation.
Mood logs: Kept for 12 months from the date of each mood selection. Entries older than 12 months are automatically and permanently deleted.
Account data: Kept while your subscription is active. What happens to your data when you cancel depends on the choices you make at the point of cancellation. There are four scenarios:
Monthly subscriber — cancels without requesting data deletion
Access ends at the next renewal date. Your data is retained for 12 months from your subscription end date and then automatically and permanently deleted. This allows you to return to the app during that period and pick up exactly where you left off. Your account identifier and email address are retained after deletion so that you can re-subscribe in the future.
Monthly subscriber — cancels and requests immediate data deletion
Access ends immediately on the cancellation date. Your data will be permanently and irreversibly deleted within 48 hours. Your account identifier and email address are retained after deletion. There is no restoration option once deletion has been requested.
Annual subscriber — cancels without requesting data deletion (access runs to subscription end)
Access continues until the subscription end date. Your data is then retained for 12 months from that subscription end date and automatically and permanently deleted. The 12-month retention period begins from the subscription end date, not from the date you cancelled. This allows you to return to the app during that period and pick up exactly where you left off. Your account identifier and email address are retained after deletion so that you can re-subscribe in the future.
Annual subscriber — cancels and requests immediate data deletion
Access ends immediately on the cancellation date. No refund is issued for any unused portion of the annual subscription period. Your data will be permanently and irreversibly deleted within 48 hours. Your account identifier and email address are retained after deletion. There is no restoration option once deletion has been requested.
Consent records: Your record of consent to health data processing is kept indefinitely. This is a legal requirement — we must be able to demonstrate that consent was given. Consent records are not deleted even when all other data is deleted.
Subscription status records: Kept for as long as required by applicable financial and tax law, typically 7 years.
Free trial users who do not subscribe: If your free trial expires and you choose not to subscribe, you will see the subscription paywall for 30 days from the date your trial ended. During this period you can subscribe at any time and retain access to all your trial data. If you have not subscribed after 30 days, your data will be automatically and permanently deleted within 48 hours. Your account identifier and email address are retained after deletion. The deletion date is displayed clearly in the app so you are never surprised by deletion.
We may contact you by email after your subscription ends to let you know about the opportunity to return. We do this under the soft opt-in rule permitted by the Privacy and Electronic Communications Regulations (PECR), which allows us to contact former subscribers 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.
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 conversation history and memories directly in the app.
Right to rectification: You may correct inaccurate data. You can update your name, pronouns, and age directly in the app.
Right to erasure: You may request deletion of all your data at any time through the in-app cancellation workflow. If you cancel without requesting immediate deletion, your data is retained for 12 months from your subscription end date before being automatically deleted. If you request immediate deletion, access ends immediately and your data is permanently deleted within 48 hours. There is no restoration option once deletion has been requested. If your free trial expires and you do not subscribe, your data is automatically deleted 30 days after trial expiry. In all cases, your account identifier and email address are retained.
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, cancel your subscription and request data deletion through the in-app cancellation workflow.
Right to data portability: You may request your data in a portable format. Use the in-app export function to download a PDF of your conversations and memories.
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.
We take reasonable and proportionate steps to protect your data. These include:
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.
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.
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 within the European Economic Area. Our AI language model providers, 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.
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.
Crisis resources are always available in the app, regardless of your subscription status.
We may update this policy from time to time. If we make a material change — such as processing a new category of data, changing how we share data, or adding a new app — we will notify you in the app before the change takes effect and, where required by law, ask for your consent again.
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.
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.
This Part applies specifically to the Liv app. Read it together with Part A above, which applies to all Sparklife apps.
Liv is a wellness companion app for adults who experience social anxiety. Liv is a conversational AI companion designed to provide a space for reflection, practice, and emotional support. 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.
In addition to the data described in Part A, Section A3, Liv collects the following information specific to its purpose:
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.
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. Crisis resources are always available in the app, regardless of your subscription status.
Sparklife AI Limited