Privacy Policy for Sparkle Services USA, LLC

1. Introduction

Welcome to Sparkle Services USA, LLC, the provider of the Sparkle app, designed to enhance and simplify home cleaning needs. This privacy policy outlines the practices regarding the collection, use, and disclosure of information through the Sparkle app. Sparkle Services USA, LLC is committed to protecting privacy and ensuring clarity about what information is collected, how it is used, and how it is secured.

2. Information Collection and Use

2.1 Types of Data Collected

• Personal Data: Sparkle Services USA LLC collects phone numbers as a mandatory requirement for using the app, along with names. Email addresses may also be provided optionally by users.
• Property Information: When scheduling cleaning services through the app, information about the property where the service will be performed is collected. This includes the address, number of bedrooms and bathrooms, square footage, presence of pets, and any access notes that facilitate entry to the property.
• Payment Information: All payment data is securely handled via Stripe, Sparkle Services USA LLC’s payment processing partner. No credit card numbers, expiration dates, or security codes are stored on Sparkle Services USA, LLC servers.
• Photos: To enhance the service and client experience, clients are able to upload photos of their property to define cleaning tasks. After cleaning, staff upload corresponding after-cleaning photos. These photos may also be used for promotional purposes with client consent.

2.2 How Data is Collected

• Account Creation and Login: Accounts are created and accessed via Firebase authentication using phone numbers, which serve as unique identifiers.
• User Submissions: Clients input property details and photos through the app interface, which are then stored on Sparkle Services USA LLC's servers.
• Payment Processing: Payments are processed through Stripe, where only necessary identifiers (like customer IDs and payment method tokens) are stored to facilitate transactions.

2.3 Purpose of Data Collection

• Account Management and Authentication: Phone numbers and optionally provided email addresses are used to manage accounts and authenticate logins.
• Scheduling and Managing Cleaning Services: Property information is utilized to tailor cleaning services to the needs of the client and ensure that staff are properly informed and prepared.
• Processing Payments: Stripe is utilized to securely handle transactions, ensuring that payment information is protected.
• Enhancing User Experience: Photos uploaded by clients and staff facilitate the monitoring and validation of the quality of services provided, enhancing transparency and providing reassurance about the integrity of the cleaning services.

3. Data Storage and Security

3.1 Data Storage

• MySQL Database: Our service data, including job details, property information, tasks, and scheduling events, are securely stored in a MySQL database hosted on Google Cloud's MySQL database service. This includes property-related information such as addresses, number of pets, bedrooms, bathrooms, and square footage.
• Firebase and Google Cloud: Real-time data, such as customer checklists, are managed through Firebase Firestore to leverage its real-time update capabilities. Images associated with cleaning tasks are uploaded and stored securely using Firebase storage, which utilizes Google Cloud buckets for data storage.

3.2 Security Measures

• HTTPS: All connections to our app and its backend are secured using HTTPS, ensuring that all data transmitted between your device and our servers is encrypted and protected against interception.
• Data Encryption: We employ industry-standard encryption protocols for data at rest. All data in transit between our Node Express backend and our MySQL database is encrypted using SSL/TLS, ensuring secure data transmission. Our backend and database connections are configured to use these secure settings by default.
• Access Control: Access to all databases and storage solutions is strictly limited to authorized management personnel within Sparkle Services USA LLC. This is enforced through stringent credential management, ensuring that only authorized operations are allowed and that no unauthorized access occurs. Our protocols ensure that only those who need to know have access to sensitive data, safeguarding our clients' privacy.

3.3 Image Security

• Image Storage and Accessibility: Images uploaded to our service are stored securely and are accessible via links that are only exposed through the app’s frontend for processing. These links are complex and not made public, safeguarding against unauthorized access.
• Link Persistence: The links to the images do not expire while the service is active. Images are retained on our servers for future use by customers, such as reusing the same 'before' images for regular cleaning appointments.
• Retention for Quality Control: Images that have been used in the delivery of services are kept for quality control and liability purposes. This allows for auditing the quality of services provided over time. Images may be retained indefinitely as long as they serve a purpose in managing service quality or are needed for ongoing services.

3.4 Enhancing User Experience

• Photo Usage: Photos uploaded by clients and our staff enable the monitoring and validation of the quality of our services. This process provides transparency and reassures clients about the integrity and quality of the cleaning services provided by SparklSparkle Services USA, LLC.

4. Data Sharing and Disclosure

4.1 Limited Data Sharing with Cleaners

• Operational Use: Information necessary for completing cleaning services, such as property details and temporary access to before and after photos, is made available to cleaners. This access is strictly limited to the duration of the job and is secured through HTTPS protocols.
• Data Access Control: Once a job is completed, access to the data is automatically revoked, ensuring that information is only available when absolutely necessary for service execution.

4.2 Legal and Regulatory Compliance

• Exceptional Circumstances: While it is highly unlikely, Sparkle Services USA LLC may be required to disclose certain information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. However, such circumstances are considered to be exceptional.
• No Set Protocols: Currently, there are no specific protocols in place for responding to legal requests, due to the rarity of such situations. Any such requests would be handled on a case-by-case basis, ensuring compliance with applicable laws while considering the privacy rights of our users.

4.3 Third-Party Service Providers

• Payment Processing: Sparkle Services USA LLC partners with Stripe to process payment transactions securely. Only necessary identifiers such as customer IDs and payment method tokens are stored, and no sensitive payment information is retained on our servers.
• Authentication: The app utilizes Firebase for user authentication. This service does not retain user data beyond what is necessary for ongoing authentication processes.

4.4 No Data Sharing for Analytics or Advertising

• Internal Use Only: All data collected through the Sparkle app is used solely for internal organizational purposes to enhance service delivery. No data is shared with third-party analytics or advertising platforms.
• Custom Developed Platform: The Sparkle platform is custom developed and in-house, limiting the exposure of user data to external entities.

4.5 No Anonymized or Aggregated Data Sharing

• Privacy Commitment: There is no sharing of anonymized or aggregated data with any third parties, reaffirming our commitment to user privacy and data security.

4.6 User Control and Transparency

• No Optional Data Sharing: Given the absence of data sharing with third parties for analytics or advertising, there are no controls required or provided for users to manage data sharing preferences. Data collected is used exclusively as described and is not shared externally beyond the necessary operational processes detailed above.

5. User Rights and Controls

5.1 Direct Interaction

• Limited User Access: Users can view and interact with current property data and images directly through the app, which includes properties actively being serviced and associated tasks. However, certain data such as previously deleted properties, tasks, and historical images (both uploaded by the user and after-cleaning images uploaded by cleaners) are retained by Sparkle LLC for operational and compliance purposes and are not accessible to users.

5.2 Deletion of Properties and Images

• User Deletion Requests: Users may request the deletion of properties or images through the app. While these deletions remove the items from the user’s view and mark them as deleted in our systems, Sparkle Services USA LLC retains the actual data on our servers. The physical deletion of such data from storage, including images in Google Cloud, is conducted at the discretion of Sparkle Services USA LLC, based on the relevance and necessity for business operations and compliance with applicable laws.

5.3 Data Correction

• Editable Data: Users have the ability to update information related to active properties and tasks directly within the app. This includes updating property details, notes on properties, and changing task-specific images. However, critical identification information such as phone numbers and email addresses cannot be changed via the app interface. Users must contact Sparkle Services USA LLC support directly to ensure secure verification and modification of such sensitive data.

6. Data Retention

6.1 Overview

• General Policy: Sparkle Services USA LLC retains user data, including account details, property information, and images, based on the operational needs and strategic interests of the business. The retention period for different types of data varies depending on their relevance and the cost-effectiveness of storage.

6.2 Specific Retention Practices

• Property Details and Images: Data such as property details and images are retained as long as they serve a business or operational purpose. High-resolution images may be deleted when their storage becomes cost-prohibitive. Lower-resolution versions or essential data points may be retained longer for historical analysis and operational continuity.
• Job and Transaction Data: Data related to cleaning jobs, scheduling, and transactions are stored indefinitely. This information is crucial for internal market research, trend analysis, and maintaining records for strategic planning and quality control.

6.3 Legal and Regulatory Compliance

• Financial Records: While some data, such as transaction and scheduling information, inherently aligns with regulatory requirements for financial record-keeping (e.g., for tax purposes), Sparkle LLC generally retains this data indefinitely for business analysis and operational efficiency. There are no specific regulatory mandates that dictate a minimum retention period beyond standard business tax requirements, but all retained data is held in compliance with applicable laws.

6.4 User-Requested Deletion

• Handling Deletion Requests: Users can request the deletion of their data, such as specific property details or images. While Sparkle Services USA LLC will consider these requests, deletion is not automatic and is subject to business needs and operational relevance. If a user's data no longer serves any active business purpose or its storage is not cost-effective, it may be deleted at the company’s discretion.
• Lack of Legal Obligations for Retention: There are no legal requirements compelling Sparkle Services USA LLC to retain most user data for any fixed period. Therefore, data retention is primarily guided by its value to the company’s service delivery and internal operations.

7. Collection and Use of Device Identifiers and Technical Data

At Sparkle Services USA LLC, we utilize various third-party services to enhance the functionality and security of our app. These services may collect device identifiers and other technical information to ensure the integrity of the app's operations.

7.1 Device Identifiers

• Firebase Authentication: Used to manage secure logins, Firebase Authentication may collect device identifiers to help ensure the integrity of authentication processes and prevent fraudulent access attempts. This may include SafetyNet services on Android, which checks device integrity and authenticity.
• Firebase Realtime Database: Device identifiers, such as Firebase Instance IDs, may be collected to manage real-time data synchronization across devices, ensuring a smooth experience.
• Stripe: To process payments securely, Stripe may collect device identifiers such as Android IDs to prevent fraud and ensure transaction security.
• Expo Notifications: We use Expo Notifications to send push notifications to users. ExpoPushToken, a unique identifier for each device, is collected to target notifications specifically to each device.
• Expo Updates: During over-the-air (OTA) updates, Expo Updates may interact with system-level identifiers to ensure the correct device is targeted for updates.
• Expo Camera and Media Library: While these libraries do not explicitly collect device identifiers, their interactions with the device's camera and media storage may rely on system services that handle such identifiers indirectly.

7.2 Purpose of Collection

• App Functionality: To authenticate users, provide notifications, and process payments securely.
• Fraud Prevention and Security: To prevent unauthorized access and fraudulent transactions, ensuring the safety of your data and the security of our platform.
• Account Management: To manage user accounts, including login and authentication functionality.

7.3 Data Sharing and Security

• Data Sharing: We share device identifiers with trusted third-party services such as Firebase and Stripe for the purposes of authentication, notification delivery, and payment processing. These services comply with industry standards for security and privacy.
• Data Security: All device identifiers are transmitted securely using HTTPS and other encryption protocols. No device identifiers are publicly exposed or shared with advertising networks or analytics services.

8. SMS Communications and Consent

8.1 Purpose of SMS Communications

• Transactional Messages: SMS messages are used to send essential service-related updates, such as appointment confirmations, reminders, and notifications about the status of cleaning services.
• Marketing Messages: Marketing and promotional messages are sent only to customers who explicitly opt-in to receive them. By default, customers will not receive any marketing communications unless they opt-in.

8.2 Consent for SMS Communications

• Opt-In Requirement: Consent for SMS communications is obtained during account creation or by explicitly opting in through the app or customer support. By agreeing to the Terms of Service during account creation, customers provide consent to receive transactional SMS messages as part of the service.
• Explicit Opt-In for Marketing: Customers must provide explicit consent to receive marketing messages. This can be done by contacting Sparkle Services USA LLC or using the app’s settings.
• Consent Language: Customers agree to receive SMS messages by accepting the following statement: "I consent to receive SMS messages from Sparkle Services USA LLC. Reply STOP to opt-out; Message and data rates may apply."

8.3 Opt-Out Options

• STOP Keyword: Customers can opt-out of receiving SMS messages at any time by replying with the keyword "STOP" to any message they receive. Upon opting out, they will no longer receive SMS communications.
• Re-Opt-In: Customers can re-enable SMS communications by replying with the keyword "START."
• Global Opt-Out: Replying "STOP" will opt-out the customer from all SMS communications, including both transactional and marketing messages.

8.4 Message and Data Rates

• Standard message and data rates may apply to all SMS messages sent or received. These charges are determined by the customer’s mobile carrier and are not the responsibility of Sparkle Services USA LLC.

8.5 SMS Compliance

• All SMS communications adhere to the requirements outlined by carriers and applicable laws, including opt-in and opt-out functionality and clear communication of messaging purposes.
• Sparkle Services USA LLC does not share or sell phone numbers or SMS data to third parties.
• Each SMS includes clear instructions on how to opt-out and how to contact customer support for assistance.

8.6 Contact Information for SMS Assistance

• For assistance, customers can contact Sparkle Services USA LLC directly at +1 (864) 520-5018 or email us at contact@sparkleservicesusa.com.

9. Google Analytics and Cookies

9.1 Use of Google Analytics

• Sparkle Services USA LLC uses Google Analytics to collect and analyze data about how users interact with our website and services. This helps us improve the functionality and effectiveness of our offerings.
• Google Analytics collects data such as page views, time spent on the site, referral sources, and device/browser information. However, it does not collect personally identifiable information (PII).

9.2 Cookie Usage

• Google Analytics uses cookies to track user interactions on our website. Cookies are small text files stored on your device that help us understand user behavior and enhance the overall experience.
• By using our website, you consent to the use of cookies for the purposes described in this section. You may disable cookies in your browser settings if you prefer, but this could affect the functionality of the site.

9.3 Third-Party Data Processing

• Data collected through Google Analytics may be processed by Google according to their Privacy Policy. Sparkle Services USA LLC does not share this data with any other third parties.

9.4 User Opt-Out

• To opt-out of Google Analytics tracking, users can install the Google Analytics Opt-Out Browser Add-on, which prevents the collection of data during website visits.

10. Use of Contact Information

10.1 Referral Contact Access

• Sparkle accesses your contacts solely to allow you to select individuals to refer for cleaning services.

10.2 Data Collected

• Only the first name, last name, and phone number of contacts you explicitly select and message through the app are collected.

10.3 Storage and Security

• This contact data is securely stored in our backend database using MySQL with industry-standard encryption and access control practices.

10.4 Limited Use

• The stored contact information is used solely to track referral relationships for earnings purposes. Sparkle does not use this data to contact referrals directly.

10.5 User-Driven Outreach

• All communication with potential referrals is initiated by you. Sparkle does not send promotional or outreach messages to your contacts without your explicit action.

11. Changes to the Privacy Policy

11.1 Notification of Changes

• Sparkle Services USA LLC reserves the right to update or modify this privacy policy at any time to reflect changes in our business practices, legal requirements, or the way we manage user data. Changes to the privacy policy will be communicated to users via notifications within the Sparkle app.

11.2 Accessing the Updated Policy

• Upon notification, users can access the updated privacy policy directly within the Sparkle app, located under the "Terms of Service" section. The most current version of the privacy policy will always be available in this designated area, ensuring that users can review it at any time to understand how their personal information is handled.

11.3 Acknowledgment of Changes

• Continued use of the Sparkle app after changes to the privacy policy have been notified will be regarded as acknowledgment and acceptance of the updated policy. By accessing and using the Sparkle services, users are accepting the practices described in the privacy policy at that time.

11.4 Frequency and History of Changes

• Updates to the privacy policy are expected to be infrequent and will occur as needed based on changes in business operations or legal requirements. Sparkle Services USA LLC does not provide access to historical versions of the privacy policy as only the current policy is relevant to the users' ongoing use of our services.