Privacy Policy — Spark
Effective date: May 28, 2026
Last updated: May 28, 2026
1. Who we are
This app, Spark — Reflective Planner for Managers (the "App"), is published by Hanieh Mohammadi and Mohammad Naghavi, doing business as Gift for Managers. We can be reached at hello@giftformanagers.com.
Our address: 63 chemin de la Pointe-Sud, Verdun, QC H3E 1Z9, Canada.
## 2. What this policy covers
This policy tells you what personal information Spark collects, why we collect it, where we keep it, who else can see it, and what choices you have about it. It applies to the Spark mobile app, the Spark web app at app.giftformanagers.com, and the printed planner sold at giftformanagers.com.
3. The reflections you write
The heart of Spark is the writing you do — daily insights, weekly priorities, weekly reflections, habit data, leadership scores, and answers to the weekly question.
Where it lives: When you use Spark offline or before signing in, your writing stays on your device only. We do not see it.
If you sign in to sync across devices, your writing is stored in our hosted database (provided by Supabase, Inc.) so it can appear on your other devices. It is encrypted in transit and at rest. Only you — using your sign-in — can read it. We do not look at your reflections, sell them, use them to train models, or share them with anyone, ever.
If you connect a third-party AI account (Anthropic, OpenAI, Google, Mistral, or OpenRouter) to generate insights, then and only then the text you choose to summarize is sent directly from your device to that provider, using the API key you supplied. Your API key stays on your device, encrypted. Spark never sees it.
4. Information that identifies you
Email address — used to sign you in, recover your account, and send you essential service emails (trial reminders, receipts, subscription changes).
Name (optional) — for greeting you in the app.
Country / language — detected from your device.
5. Subscriptions and billing
When you subscribe, your payment is handled by Apple (iOS App Store), Google (Play Store), or Stripe (web). Each has its own privacy policy. We never see your full card number or bank details. We receive only the information needed to recognise an active subscription — a transaction ID, the plan you chose, when it renews, and whether it's been cancelled. Subscriptions are managed by RevenueCat, Inc., which is our subscription processor.
6. Technical data
When the App runs, we collect a small amount of technical information to keep the service working: device type, operating system version, app version, crash reports, and error logs. This is anonymised — it is not tied to your reflections or your identity. We use it to fix bugs and decide which features to improve.
We do not use third-party advertising, analytics, or tracking SDKs (no Google Analytics, no Facebook Pixel, no AppsFlyer, no Amplitude). Spark does not profile you and does not run ads.
7. Reminders and notifications
If you turn on reminders, Spark schedules a notification on your device (e.g. "What did you learn today?"). The text of those notifications is generated on your device. The scheduled time is stored on your device.
If we ever need to email you about your trial ending or your subscription, that email is sent through a transactional email provider (planned: SendGrid by Twilio, Inc.) using only your email address and the message itself.
8. Who can see your data
We share your data only with the service providers who help us run Spark, and only as much as they need:
| Provider | What they see | Why |
|---|---|---|
| Supabase, Inc. (US, EU regions) | Your encrypted reflections + account info | Database hosting and authentication |
| Apple, Google, Stripe | Your payment + transaction info | Processing your subscription |
| RevenueCat, Inc. (US) | Your subscription status | Telling the App whether you're subscribed |
| Sentry (US, optional, planned) | Anonymous crash reports | Fixing bugs |
| Twilio / SendGrid (US, planned) | Your email address + message body | Sending trial reminders and receipts |
| Anthropic, OpenAI, Google, Mistral, or OpenRouter | Only the text you choose to summarize, only when you've connected an AI account | Generating AI insights |
We do not sell, rent, or trade your personal information. Ever.
9. Where your data lives
We use Supabase as our backend. Depending on your region at the time you sign up, your data may be stored in the United States or the European Union. By using Spark, you consent to this transfer.
10. How long we keep your data
Reflections, habits, scores, weekly answers: kept as long as your account is active. If you delete your account, all of this is permanently removed within 30 days.
Email and account info: kept while your account is active; removed when you delete the account.
Subscription records: kept for 7 years to comply with tax and accounting laws, even after you cancel.
Crash logs: kept for 90 days.
11. Your rights
Regardless of where you live, you can:
See the data we hold about you — write to hello@giftformanagers.com.
Correct anything that's wrong.
Delete your account and all your reflections at any time, from Settings → Account → Delete account. Or write to us and we'll do it.
Export your reflections as a plain text or CSV file — write to us and we'll send it within 30 days.
Object to how we use your data, or restrict processing.
Withdraw consent at any time — by deleting the app, or contacting us.
If you live in the European Union, the United Kingdom, or Switzerland, you have these rights under the GDPR/UK-GDPR. Our legal basis for processing is your consent (you sign up and use the App), the performance of our contract with you (the subscription), and our legitimate interest in keeping Spark working (technical logs). You can complain to your local data protection authority if you think we've mishandled your data.
If you live in California, you have similar rights under the CCPA. We do not sell your data, including under the broad CCPA definition of "sell."
If you live in Canada, your rights under PIPEDA also apply. You can complain to the Office of the Privacy Commissioner of Canada.
12. Children
Spark is built for working managers. It is not directed at children under 16, and we do not knowingly collect data from children. If you believe a child has signed up, write to us and we'll delete the account.
13. Security
We protect your data with industry-standard practices: TLS in transit, encryption at rest, strict authentication, and least-privilege access for our own systems. No system is perfectly secure, but we take this seriously. If we discover a breach affecting your data, we will notify you and the relevant authorities within 72 hours, as required by law.
14. Changes to this policy
If we materially change this policy, we will email you and post a notice in the App at least 14 days before the change takes effect. The "Last updated" date at the top will show when we last revised it.
15. Contact
For any privacy question, write to hello@giftformanagers.com. If you'd prefer paper mail, our address is 63 chemin de la Pointe-Sud, Verdun, QC H3E 1Z9, Canada.