Privacy Policy

Last Updated: July 25, 2025

This Privacy Policy describes how your personal data is collected, used, and shared when you use the Spark services ("Service"), and informs you about your privacy rights and how the law protects you.

We use your personal data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

Account: A unique account created for you to access our Service or parts of our Service.
Application: The mobile applications Spark – Master Math and Spark for Schools, developed and operated by Spark Bilgisayar Yazılım Teknoloji Ticaret Limited Şirketi.
Company ("We", "Us", or "Our"): Spark Bilgisayar Yazılım Teknoloji Ticaret Limited Şirketi
- MERSİS No: 0781112876600001
- Address: GÖKTÜRK MERKEZ MAH. 2. KAYIN SK. NO:1 İÇ KAPI NO:11 EYÜPSULTAN / İSTANBUL
Country: Turkey
Device: Any device that can access the Service such as a computer, a cellphone, or a digital tablet.
Personal Data: Any information that relates to an identified or identifiable individual.
Service: The Spark applications and all related products and services.
Service Provider: Any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, or to assist the Company in analyzing how the Service is used.
Usage Data: Data automatically collected through your use of the Service or generated by the Service’s technical infrastructure (such as diagnostic logs or crash reports).
You: The individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Personal Data We Collect and How We Use It

Data You Provide to Us Directly:

We may ask you to provide us with the following information during registration or communication:

First and Last Name
Email Address
Your in-app preferences and interactions

Usage Data (Automatically Collected Data):

The following data may be collected automatically when you access the Service:

IP address, device type, operating system, and browser information
Screens you visit and the time spent on those screens
Mobile device information: device model, mobile operating system, unique device identifiers
Technical diagnostic data

Purposes and Legal Bases for Processing Personal Data

The Company processes your Personal Data for the following purposes and based on the following legal grounds:

Purpose	Legal Basis
To provide and maintain our Service	Performance of a contract
To manage your Account and user-related operations	Performance of a contract
To contact you (transactional notifications, technical support)	Legitimate interest and Performance of a contract
To improve the quality of our Service, perform analysis, and reporting	Legitimate interest
To improve user experience and product development	Legitimate interest
To send marketing communications and announce campaigns	Explicit Consent

Data Retention Period

Personal Data is stored only for the period necessary to fulfill the purposes outlined in this Policy. Data may be retained for longer periods to comply with legal obligations, protect contractual rights, and resolve disputes. Usage Data is generally retained for a shorter period, though this may be extended if the data is used to strengthen the security or to improve the functionality of our Service.

Transfer of Personal Data

Your Personal Data may be transferred to service provider systems located abroad as part of the execution of the Service. We use Google Firebase for database infrastructure and analytics services, and your data is transmitted to the servers where these systems are located. This data transfer is a requirement of the technical infrastructure of the Service we provide and is therefore necessary for the performance of the contract between you and us.

The Company takes all necessary technical and administrative measures to ensure the security of your personal data and establishes appropriate privacy and protection arrangements with third parties to whom data is transferred. Your consent to this Privacy Policy signifies your understanding and acceptance of this necessary data transfer.

Selling of Personal Data

We do not sell or rent your personal data to third parties under any circumstances.

Children's Privacy

Our Service is primarily designed for students, including children under the age of 18, and we are committed to protecting their personal data.

Age and Parental Consent: We recognize that the age of digital consent varies by jurisdiction (e.g., 13 in the U.S. under COPPA, 13-16 in the EU under GDPR, while Turkish law provides protections for all minors under 18). To ensure a high standard of protection for all our users, we require verifiable consent from a parent or legal guardian for any user under the age of 16. Our Company takes the necessary steps to confirm this consent has been obtained.
Data Minimization: We do not request more personal data from children than is strictly necessary to provide the Service.
Parental Rights: Parents and legal guardians have the right to access, correct, or request the deletion of their child's personal data. For such requests, you can contact us at support@sparkmastermath.com.

Your Data Protection Rights (Under KVKK Article 11)

As a data subject under the Turkish Law on the Protection of Personal Data No. 6698 ("KVKK"), you have the following rights:

To learn whether your personal data is being processed.
To request information if your personal data has been processed.
To learn the purpose of the processing and whether it is used in line with that purpose.
To know the third parties to whom your personal data has been transferred, both at home and abroad.
To request the correction of your personal data if it is incomplete or incorrectly processed.
To request the deletion or destruction of your personal data.
To request that these correction and deletion operations be notified to third parties to whom your data has been transferred.
To object to outcomes against you that arise from the analysis of your data exclusively through automated systems.
To demand compensation for damages arising from the unlawful processing of your personal data.

Data Deletion and Account Management

Users can update or delete their data through their in-app account settings. You can also send requests for access, correction, or deletion by emailing support@sparkmastermath.com. The Company may retain certain data in cases of legal obligation or legitimate interest.

Tracking Technologies and SDK Policy

Our mobile applications do not use traditional cookies as found on websites. However, to perform the essential functions of our Service, analyze performance, diagnose errors, and improve the user experience, we use SDKs (Software Development Kits) and similar tracking technologies provided by third-party service providers like Google Firebase.

These technologies enable us to collect the Usage Data described in the "Usage Data (Automatically Collected Data)" section of this policy. The collection of this data is within our legitimate interest to provide you with a better and more secure Service.

Contact Information

If you have any questions or requests regarding this Privacy Policy, you can contact us:
📧 Email: support@sparkmastermath.com