Sparklife AI Limited

Effective date: 14 August 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 are in crisis, please use the crisis resources available in the app at any time.

PART A — GENERAL TERMS (all Sparklife apps)

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. During onboarding, the app asks for your preferred name, your pronouns, 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, pronouns, 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 daily check-ins.
Memories — short factual notes extracted from your conversations, such as your goals, current situations, and things you are working through. Liv keeps these while your account is active, updating or replacing them as your circumstances change so that they stay accurate; notes that have been superseded are removed automatically.
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.

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, which automatically schedules deletion of your data, or by requesting immediate deletion.

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.

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, 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.

A4. How your data is used

Your conversation data and memories are sent to Anthropic, our AI provider, to generate the app’s responses. 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 — they do not use your data to train their models.

We access individual conversation data only in the following circumstances:

In response to a support request 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. 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 provider changes. 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. The following retention periods apply across all our apps:

Conversation transcripts: Kept while your account is active, so your history remains available to you in the app. The app only ever uses your most recent conversations to generate responses; older transcripts are retained for your own reference. All transcripts are permanently deleted when your account is deleted, as described under “Account data” below.

Memories: Memories are kept while your account is active, 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, and any that have been superseded are automatically deleted (within 30 days of being replaced). All memories are permanently deleted when your account is deleted, as described below.

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

Daily reflections: At the end of each day, Liv writes a short reflection on your recent conversations. Reflections are kept for 12 months from the date they are written and then automatically and permanently deleted. Reflections are also deleted in full when your account is deleted.

Account data: Kept while your subscription is active. When you cancel your subscription, deletion of your data is automatically scheduled for your subscription’s end date — there is no choice to make and no separate deletion request is needed. You retain full access until that date. Shortly after your subscription end date (within 24–48 hours), your data is automatically and permanently deleted. If you resubscribe before deletion takes place, the scheduled deletion is cancelled and your data is retained.

If you would prefer not to wait, you may request immediate deletion instead. Your access ends immediately and your data is permanently and irreversibly deleted within 48 hours. There is no restoration option once immediate deletion has been requested, and no refund is issued for any unused portion of an annual subscription.

In both cases, your entire account record is fully deleted. The only thing that survives is 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). This 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, reflections, mood logs, and all other personal content — including the account record itself, which is fully deleted. The only thing we retain is your record of consent to health data processing (a separate consent record containing the email address you provided when consent was given), kept solely as legally required proof that consent was given under UK GDPR Article 9(2)(a). This 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 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 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.

Free trial users who do not subscribe: If your free trial ends and you choose not to subscribe, your account and existing data are not automatically deleted. You keep full access to the app itself, including your conversation history, memories, and any other content you have already saved. A subscription is required only to start new conversations or role-play sessions with Liv. You may request deletion of your data at any time, as described in Section A7.

If your free trial has expired and you have not yet subscribed, 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 cancelled or fully 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 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, including during a free trial. Cancelling your subscription automatically schedules deletion for your subscription’s end date, with no further action required; your data is then permanently deleted within 24–48 hours of that date unless you resubscribe first. If you would prefer immediate deletion, you may request this instead — access ends immediately and your data is permanently deleted within 48 hours, with no restoration option. 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, 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.

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.

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, 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.

Crisis resources are always available in the app, regardless of your subscription status.

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 cancel your subscription and request data deletion at any time before or after the change takes effect, as described in Section A6, 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 cancel and 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 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.

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 your social-anxiety context, the kinds of situations you find draining, an upcoming situation you are navigating, and your goal.
Your mood selections from Liv’s daily check-in chips. Liv’s mood options are: Good, Calm, Okay, Anxious, and Worried. These are stored as simple text labels, not clinical assessments.

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.

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. Crisis resources are always available in the app, regardless of your subscription status.