Privacy Policy
Effective Date: June 1, 2026 · Last Updated: June 1, 2026
1. Introduction
Welcome to AI-Spark ("we," "us," "our," or "the Service"). AI-Spark is a SaaS platform that provides AI-powered analysis of Fortnite gameplay videos. We are committed to protecting your privacy and handling your personal data transparently and lawfully.
This Privacy Policy explains what personal data we collect, how we use it, who we share it with, and what rights you have. It applies to all users of AI-Spark, including visitors to ai-spark-web.vercel.app and registered users. AI-Spark is operated by a private individual ("the Service operator"). For any privacy-related inquiries, contact us at aispark.help@gmail.com.
This policy is designed to comply with the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), and other applicable data protection laws.
2. Data Controller
For the purposes of the GDPR, the data controller is AI-Spark (operated by a private individual). Contact: aispark.help@gmail.com · Telegram Support: @spark_supp0rt_bot.
3. What Personal Data We Collect
3.1 Account Information
Email address; display name (when provided via Google, Discord, or Epic Games OAuth); user ID (internal identifier).
3.2 User-Generated Content
Gameplay video clips you upload for analysis; AI analysis results generated from your videos; chat history with the AI coach.
3.3 Transaction Data
Subscription plan (Free, Pro, or Elite); payment history and transaction identifiers. We do not store credit card numbers, CVVs, or full payment card details — these are handled exclusively by our payment processor, Lava.top.
3.4 Technical and Usage Data
IP address; browser type and version; device type and operating system; pages visited and features used; referring URLs; session duration; cookies and similar technologies (see Section 10).
4. How We Use Your Data
| Purpose | Legal Basis (GDPR Art. 6) |
|---|---|
| Providing the Service (account creation, video analysis, AI coaching) | Performance of a contract — Art. 6(1)(b) |
| Processing payments and managing subscriptions | Performance of a contract — Art. 6(1)(b) |
| Sending transactional emails (confirmations, password resets) | Performance of a contract — Art. 6(1)(b) |
| Improving the Service, fixing bugs, developing features | Legitimate interest — Art. 6(1)(f) |
| Product and web analytics (aggregated) | Legitimate interest — Art. 6(1)(f) |
| Ensuring security and preventing fraud | Legitimate interest — Art. 6(1)(f) |
| Compliance with legal obligations | Legal obligation — Art. 6(1)(c) |
| Marketing communications (only with explicit consent) | Consent — Art. 6(1)(a) |
We do not use your uploaded video clips or personal data to train AI models. Your videos are processed solely to provide you with gameplay analysis results.
5. Third Parties and Data Processors
We share your personal data with the following third-party service providers ("data processors") who process data on our behalf:
| Service Provider | Purpose | Region |
|---|---|---|
| Google LLC (Firebase) | User authentication, account database, data storage | United States |
| Google LLC (Gemini AI) | Processing uploaded videos to generate AI analysis | United States |
| Cloudinary | Storage of uploaded video files | United States / EU |
| Lava.top | Payment processing (we do not store card data) | International |
| PostHog | Product analytics (EU-hosted instance) | European Union |
| Google Analytics 4 | Anonymized web analytics | United States |
| Vercel | Website hosting and Vercel Analytics | United States |
We require all data processors to handle your data in accordance with applicable data protection laws. We do not sell your personal data to any third party.
6. International Data Transfers
Your personal data may be transferred to and processed in the United States and other countries outside the European Economic Area (EEA) and the United Kingdom. When such transfers occur, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission (as incorporated into our providers' data processing terms), adequacy decisions where applicable (e.g., the EU-U.S. Data Privacy Framework), and other appropriate safeguards required by law. You may request further information by contacting aispark.help@gmail.com.
7. Data Retention
| Data Category | Retention Period |
|---|---|
| Account information | Duration of account + 30 days after deletion |
| Uploaded video clips | Until you delete them, or account deletion + 30 days |
| AI analysis results and chat history | Duration of account + 30 days after deletion |
| Transaction records | Up to 6 years (tax and legal compliance) |
| Technical logs (IP, browser data) | Up to 12 months |
| Analytics data (aggregated) | Up to 26 months |
After the applicable retention period, data is permanently deleted or irreversibly anonymized.
8. Your Rights Under the GDPR
If you are located in the EEA, the UK, or Switzerland, you have the following rights:
- Right of Access (Art. 15) — request a copy of the personal data we hold about you.
- Right to Rectification (Art. 16) — ask us to correct inaccurate or incomplete data.
- Right to Erasure ("Right to Be Forgotten") (Art. 17) — request deletion of your data, subject to legal retention obligations.
- Right to Restriction (Art. 18) — ask us to limit processing in certain circumstances.
- Right to Data Portability (Art. 20) — request your data in a structured, machine-readable format.
- Right to Object (Art. 21) — object to processing based on legitimate interests or direct marketing.
- Right to Withdraw Consent (Art. 7(3)) — withdraw consent at any time without affecting prior lawful processing.
- Right to Lodge a Complaint — with a supervisory authority in your country of residence.
To exercise any of these rights, contact aispark.help@gmail.com. We will respond within 30 days. If the request is complex, we may extend this period by up to two additional months and will inform you.
9. Your Rights Under the CCPA / CPRA (California Residents)
If you are a California resident, you have the following rights:
- Right to Know — the categories and specific pieces of personal information we collect, the sources, the purposes, and the third parties we share it with.
- Right to Delete — request deletion of personal information we collected, subject to certain exceptions.
- Right to Correct — request correction of inaccurate personal information.
- Right to Opt-Out of Sale or Sharing — We do NOT sell or share your personal information as defined under the CCPA/CPRA.
- Right to Non-Discrimination — we will not discriminate against you for exercising your rights.
To exercise your rights, contact aispark.help@gmail.com. We will verify your identity and respond within 45 days. We do not collect sensitive personal information as defined by the CCPA/CPRA (e.g., SSNs, precise geolocation, biometric, or health data).
10. Cookies and Tracking Technologies
| Cookie Type | Purpose | Examples |
|---|---|---|
| Strictly Necessary | Essential for the Service to function (auth, security) | Firebase auth session tokens |
| Functional | Remember your preferences and settings | Language, theme |
| Analytics | Understand how users interact (aggregated) | Google Analytics 4, PostHog, Vercel |
You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair the Service. We do not use cookies for advertising or cross-site tracking.
11. Children's Privacy
AI-Spark is intended for users who are 16 years of age or older. We do not knowingly collect personal data from children under 16 in the EU/EEA/UK, or under 13 in the United States (COPPA). If we become aware that we have collected data from a child below the applicable minimum age, we will delete it as soon as reasonably possible. Parents or guardians may contact aispark.help@gmail.com.
12. Data Security
We implement appropriate technical and organizational measures to protect your data, including encrypted transmission (HTTPS/TLS), secure authentication via Firebase, access controls, and regular security reviews. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
13. Automated Decision-Making
AI-Spark uses artificial intelligence (Google Gemini) to analyze gameplay videos and generate recommendations. This processing is automated but advisory in nature only — it does not produce legal or similarly significant effects on you.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will post the updated policy with a new "Last Updated" date and, for material changes, notify you via email or an in-app notice. Your continued use of the Service constitutes acceptance.
15. Contact Us
Email: aispark.help@gmail.com · Telegram Support: @spark_supp0rt_bot · Website: ai-spark-web.vercel.app. We aim to respond within 30 days.