Sparks

Sparks Privacy Notice

Last updated: 11 October 2026

This notice explains how Sparks handles personal data about people who use bysparks.com: beta applicants, account holders, editors, and anyone who contacts us. It does not cover visitors to sites our customers publish on <slug>.bysparks.net: each of those sites has its own privacy notice, because the site's owner decides how their visitors' data is used, and we only host it for them (see section 4).

1. Who we are

Nir Ninio, a registered business in Israel (Osek Murshe no. 034134452), trading as "Sparks", runs Sparks and is the controller of the data described here. If a company is formed to run Sparks, it will take over this role and we'll update this notice. We work by email; a postal address is available on request.

2. What we collect, and why

WhatExamplesWhy we use itLegal basis (GDPR / UK GDPR)
Waitlist applicationFirst and last name, email, LinkedIn URL, your answers on the "Join the private beta" form (your type of work, whether you have a website and its address, your country, how you'd use Sparks and start with it, whether you'd give feedback, whether you'd pay), how you heard about us (including which Sparks site referred you, if you came from a site's badge)To choose and invite beta testersLegitimate interests (running a selective beta)
"Sparks news" opt-in (optional)Your email and that you ticked the boxTo send you news about SparksConsent (unsubscribe at any time)
Account dataName, email, sign-in method (email code or Google), invite code, plan, role on each siteTo create and run your accountContract
Your materialLinks you paste, text you type (such as your bio), files you upload (e.g. a LinkedIn PDF), your existing website's pages (up to 12), your answers in the build, photosTo build and maintain your site, which is the service you asked forContract; plus your AI consent at sign-up (section 3)
Free website auditThe website address you ask us to check, and the resultTo show you the auditLegitimate interests
Your site's contentThe text, facts, photos and posts on your site, including AI edits and their originalsTo host and publish your siteContract
Consent recordsThat you agreed to the AI consent, when, and which text versionTo prove what you agreed toLegal obligation / legitimate interests
Security and login recordsLogins, failed logins, sign-outs, password resets, IP address, browser/device, timeTo keep accounts safe and investigate misuseLegitimate interests (security)
Usage and cost dataWhich features you use, AI and email usage, build jobsTo run the service within each account's budget and fix problemsLegitimate interests
Support emailsWhat you write to support@ and our repliesTo help youContract / legitimate interests
Service emailsDelivery and bounce data for the emails we send youTo send required notices (welcome, preview ready, beta ending, suspension and deletion warnings)Contract
Website analyticsPage views on bysparks.com, counted without cookies (section 9)To understand how the site is usedLegitimate interests
Abuse protectionYour IP address, held briefly in memory to limit how often a form can be sent; not storedTo stop spam and abuseLegitimate interests (security)
Billing (paid launch only; there are no payments in the beta)Plan, invoices, payment status. Card details go to Paddle, never to usTo bill youContract; legal obligation (tax records)

What we don't do: we don't sell personal data, we don't use it for advertising, we run no ad pixels, and we don't train AI models on it.

During the beta we don't search the web about you and don't use photos of you found online. If we switch this on later, we'll update this notice and ask for your consent first.

Giving us your account details and material is needed to provide the service; without them we can't build your site.

3. AI processing

4. Data about your site's visitors

When people use your site's contact form or newsletter sign-up, you are the controller of their data and Sparks is your processor: we store it and send emails only on your instructions. Our Data Processing Agreement governs this, and your site's own privacy notice tells visitors about it. Visitors who want to exercise their rights should contact the site's owner; we'll help the owner respond.

5. Who we share it with

Only with service providers that help us run Sparks (our sub-processors), under contracts that limit them to our instructions. The current list, with locations: bysparks.com/subprocessors (draft). In short: Vercel (hosting, analytics, AI gateway), Supabase (database, sign-in, storage), Resend (sign-in emails for bysparks.com), Amazon Web Services (email for sites, from Sweden), OpenAI and Anthropic (AI), Zoho (our business email, including support@ and privacy@), Better Stack (uptime monitoring; no customer personal data) and, from the paid launch, Paddle (payments, as merchant of record: Paddle is a separate controller for payment data).

If you sign in with Google, Google tells us your name and email address under its own privacy policy.

We may also disclose data if the law requires it, to protect rights and safety, or to a company that takes over Sparks (for example, a company the founder forms to run it).

6. International transfers

Sparks is run from Israel, which the European Commission and the UK recognise as giving adequate protection. Our providers process data in the United States and the EU: for example, bysparks.com's database is in the US (Oregon) and email for sites is sent from Sweden (Stockholm). For transfers out of the EU/UK we rely on the safeguards in each provider's data processing terms (such as the EU Standard Contractual Clauses with the UK Addendum, or the EU–US Data Privacy Framework where the provider is certified); we'll list each provider's safeguard on our sub-processor page before the paid launch. Ask us for a copy of the safeguards.

7. How long we keep it

DataKept
Account, material and site contentWhile your account is active. After a site is suspended (for example when the beta ends and you don't subscribe), 14 days, then deleted (30 days if it was on a paid plan). Deleting your account or site starts deletion at once
Source material in the AI build (bio, files, answers, pages read from your own site)Kept by our build system only while a build runs and deleted when it ends (at most about 30 minutes after the build starts). Uploaded files that no build uses are deleted within 48 hours
Files you upload to bysparks.comFor the life of your workspace, deleted with it. If you start signing up and never finish, they're deleted after 7 days
Free website auditThe request and its result: at most 24 hours
Build progress records30 days
A preview you never publishSuspended after 30 days, then deleted 14 days later
Data exports you requestAbout 7 days, then deleted
Login and security records12 months. If your account is deleted, your entries are pseudonymised (replaced with a one-way code)
"Used a free trial" recordKept after deletion, as one-way hashes (of your email and site/profile links), only to enforce one free trial per person
Erasure logKept, with no personal data (the site address, date and which systems confirmed)
Invoices and billing records (paid launch)As long as tax law requires (in Israel, 7 years). None exist during the free beta
Email suppression listAddresses that bounced or complained stay on our email provider's suppression list so we don't email them again
Support emails3 years after the last message
Waitlist applications not invitedDeleted when the beta ends (at the paid launch)
System run logs90 days; they contain no personal data
BackupsExpire on their own within 90 days. If we ever restore a backup, we delete again anything that was erased
Legal holdIf there's a legal reason (a dispute, a request from authorities), deletion is paused until it's resolved

A deleted site's address (<slug>.bysparks.net) is retired and never reused.

8. Your rights

Depending on where you live, you can ask us to:

How: email privacy@bysparks.com from your account's address. We reply within one month (sometimes longer for complex requests, and we'll tell you).

Complaints: you can complain to your data protection authority, for example the ICO (UK), the supervisory authority in your EU country, or Israel's Privacy Protection Authority. We'd appreciate the chance to sort it out first at privacy@bysparks.com.

Israel: we handle data in line with Israel's Protection of Privacy Law, 5741-1981, as amended by Amendment 13 (in force since August 2025), including your rights to review and correct data held about you.

US residents: we don't sell personal data or share it for cross-context behavioural advertising. You can ask us for access to or deletion of your data at privacy@bysparks.com, wherever you live.

9. Cookies

This section is published as bysparks.com/privacy#cookies.

We use only essential and functional cookies, so there's no cookie banner. There are no advertising or tracking cookies.

On bysparks.com

CookieWhat it doesHow long
sb-<project>-auth-tokenKeeps you signed in to your account (set by our sign-in provider, Supabase). The access token inside it lasts 1 hour and is refreshed while you use SparksUp to 400 days, unless you sign out
active_workspace_idRemembers which workspace you're inUntil you close your browser
sidebar_stateRemembers whether the sidebar is open7 days

On the sites we host and their editor (<name>.bysparks.net and /admin)

CookieWhat it doesHow long
payload-tokenKeeps the site's owner or editor signed in to the editor2 hours at a time; a session ends at most 7 days after sign-in
payload-tenantIn /admin only: remembers which site you're editing1 year
spn_previewLets the owner and editors preview a site that isn't published or is hidden24 hours (2 hours for Sparks staff)

Browser storage (not cookies)

ItemWhat it does
sparks:annOn a hosted site, remembers that you dismissed an announcement
spn-admin-remembered-emailRemembers your email on the /admin sign-in page

You can block or delete cookies in your browser; if you block the essential ones, you can't sign in.

10. Children

Sparks is for adults running a professional presence. It's not for anyone under 18, and we don't knowingly collect children's data. If you think a child has given us data, tell us and we'll delete it.

11. Security

Access to your data is limited to the founder and, later, staff who need it; every login and staff action is logged; data is encrypted in transit, and our main providers encrypt the data they store; sites that aren't public never send their content. No system is perfectly secure; if a breach affects you, we'll tell you as the law requires.

12. Changes

We'll post updates here and change the date at the top. For material changes we'll email account holders before they apply.

13. Contact

privacy@bysparks.com · support@bysparks.com · postal address on request