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[Draft — subject to change]

Privacy Policy

Version 2026-10-26-draft · Last updated October 26, 2026

1. Who we are

This policy explains how goSparkor, operated by VerifyLocal LLC ("goSparkor", "we", "us"), 1111B S. Governors Ave. #41709, Dover, DE 19904, handles personal information when you use gosparkor.com and the goSparkor app (the "Service"). It covers venue owners, creators, and visitors to our website. Contact: [email protected].

2. Information we collect

CategoryExamplesSource
Pilot sign-upBusiness name, your name, email, phone, city, number of locations, POS used, how you heard about us, contact consentYou, through our website form
AccountName, email, phone, role, sign-in credentials (passkeys)You
Business profileVenue name, address, cuisine, hours, ordering links, logoYou
PaymentCard details and bank account details, processed and stored by Stripe; we keep the last digits, account type and payment statusYou, Stripe
POS sales data (if you connect)Menu items, categories, sales and order totals by product, day and hour, discounts, refunds, location IDsSquare, Clover, through VerifyLocal LLC's POS analytics service (Section 6)
MediaPhotos, footage, videos you upload or creators deliverYou, creators
Advertising resultsImpressions, reach, clicks, spend, ad statusTikTok, Meta
Ordering-link clicksTime, campaign, device type, approximate location from IP, bot signalsOur redirect service
Existing collab postsPost links, creator handles, ad codes and their expiry, likes and comment counts shown with the post, and who entered themVenues, creators, TikTok and Meta
Creator profileHandle, public profile, niche, audience size range, portfolio, location as listedTikTok and Instagram creator marketplaces, you
CommunicationsMessages, creator work details, support requests, notification preferences, SMS consent recordsYou
UsagePages viewed, actions, device and browser, IP address, cookiesAutomatically

We aim to collect aggregate POS data and avoid customer-identifying transaction details. We never collect payment card data from your POS.

3. How we use it

  • To provide the Service: accounts, campaigns, ad buying, video generation and editing, creator connections, reports and recommendations.
  • To bill you and verify payment methods.
  • To create and run your ads on TikTok and Meta, and to build advertising audiences as described in Section 5.
  • To generate rules-based and AI-assisted recommendations from your ad results and POS data.
  • To communicate with you, including service emails and, with your consent, text messages.
  • To keep the Service secure, prevent fraud and abuse, and comply with law.
  • To describe and verify businesses and their locations (for example name, address, hours and whether they are open), including through products and APIs offered to third parties, as set out in the Venue Terms.
  • To improve the Service using de-identified or aggregate data.

We do not sell personal information, and we do not share it for cross-context behavioral advertising except as described in Section 5. [Counsel to confirm the Section 5 audiences are characterized correctly under state laws.]

4. Who we share it with

  • TikTok and Meta, to create, run and measure ads, and to show creator listings.
  • Stripe, to process card payments and bank debits and verify bank accounts.
  • Square and Clover, when you connect your POS.
  • Our AI video-generation provider, which receives your venue profile and uploaded assets to make flyer videos.
  • Our external video-editing company, bound by confidentiality, which receives only the assets, video and instructions for a job and deletes them when it closes.
  • AI language-model providers, which process data to produce recommendation text, under terms that prohibit using it to train their models. [Confirm zero-retention terms.]
  • Email and SMS providers, to deliver notifications.
  • Hosting, storage and analytics providers that operate the Service for us.
  • Venues and creators, as needed for creator work: a creator sees the venue's name, contact details and the agreed work; a venue sees the creator's profile and deliveries.
  • Directories, maps, search and AI services, which may receive business information and verification records about venues (not owners' personal contact details) to describe and verify those businesses.
  • Our affiliates and successors, including VerifyLocal LLC and any successor to the goSparkor business, which may use information under this policy.
  • Professional advisers, authorities and successors, where required by law, to protect rights, or in a merger or sale.

5. Advertising audiences

5.1 When we run ads, TikTok and Meta record who views and engages with them. We ask the platforms to group those people into two kinds of advertising audience: for each venue, the people who engaged with that venue's ads (a venue audience); and for each market, the people who engaged with goSparkor's own regional content and ads (the local pool). Engagement with a venue's ads is never added to the local pool or to another venue's audience. These audiences are held by TikTok and Meta. We do not receive the names or identities of the people in them.

5.2 A venue audience is used only to show that venue's ads. The local pool is used to show ads for goSparkor venues near those people. Audience membership is governed by each platform's data policy; people can manage their ad preferences in their TikTok and Meta settings.

5.3 We do not upload customer lists from venues' POS data to build audiences.

6. POS analytics

goSparkor's POS insights and recommendations are produced by the POS analytics service of VerifyLocal LLC, which processes connected POS data on our behalf and only for providing the Service to you.

7. Creator network

If you are a creator and keep the opt-in checked when accepting our Creator Terms, we keep your profile in the goSparkor creator network to invite you to future work. You can opt out at any time; we then stop using your profile for that purpose and delete it unless needed for work in progress or legal reasons.

8. How long we keep it

DataRetention
Account and profileWhile the account is open, then [X] days
Billing, payment and tax recordsAs long as tax law requires, typically 7 years
POS dataWhile connected and for [X] months after disconnection, unless you ask us to delete it sooner
Media and videosWhile the account is open, then [X] days
Ad results and campaign dataWhile the account is open, then [X] years in aggregate form
Existing collab posts (links, handles, ad codes)While the account is open; expired or revoked ad codes deleted after [X] days
Editing-vendor copiesDeleted when the job closes
Logs and click data[X] months

9. Security

We use encryption in transit and at rest, encrypted storage for access tokens, role-based access, tenant isolation, and audit logs. No system is perfectly secure; tell us at [email protected] if you suspect a problem.

10. Your choices and rights

  • Update your information and notification settings in the Service.
  • Disconnect your POS at any time.
  • Opt out of text messages by replying STOP; unsubscribe from marketing emails by the link in each email.
  • Request access, correction, deletion or a copy of your personal information at [email protected] (see Section 11 for deletion). Depending on where you live (for example Connecticut, California or other US states, or Canada), you may have additional rights, including to appeal a decision. We will not discriminate against you for exercising them.
  • We will verify your identity before acting on a request.

11. Deleting your data

You can ask us to delete your personal information at any time; instructions are also at gosparkor.com/data-deletion. Email [email protected] from the address on your account, say who you are (venue owner, creator, or someone whose Instagram or TikTok handle is used with goSparkor, with that handle) and what you want deleted. We confirm your identity, then delete or de-identify your information within [30] days, except records the law requires us to keep (such as billing and tax records) and information needed to resolve a dispute or prevent fraud. Deleting your goSparkor data does not delete data that TikTok, Meta, Stripe or your POS provider hold under their own policies; we will tell you how to contact them.

12. Cookies

We use necessary cookies to run the Service and [analytics cookies] to understand usage. [Cookie banner and opt-out — counsel to confirm requirements.] Our websites do not currently place advertising pixels from TikTok or Meta. [Confirm before launch.]

13. Children

The Service is for businesses and adults. We do not knowingly collect information from anyone under 18.

14. International users

We operate in the United States. If you use the Service from Canada or elsewhere, your information is processed in the United States. [Canadian privacy (PIPEDA) and anti-spam (CASL) notices — counsel to add.]

15. Changes

We will post updates here and notify you of material changes by email or in the Service before they take effect.