Privacy Policy

This Privacy Policy explains how SPARK VISION IS OOD processes personal data when you use SparkVision websites, applications, devices, support channels, and related services. We process personal data lawfully, transparently, and only for the purposes described below.

Last updated: 26 May 2026

I. Personal Data Controller

The personal data controller is SPARK VISION IS OOD, UIC 206677712, Krum Popov 1, 1164 Sofia, Bulgaria.

For privacy requests, contact us at customer.support@sparkvision.tech.

For customer service and warranty handling in Romania, SparkVision uses SPARK VISION IS ROMANIA SRL, CUI 54581719, Trade Register No. J2026028294009, Str. Verzisori 6, Bl. D, Ap. B118, 040301, Sector 4, Bucharest, Romania. Privacy requests should still be sent to customer.support@sparkvision.tech.

II. Personal Data We Process

Depending on the product or feature used, we process:

Account and contact data: name, email address, phone number, account identifiers, authentication data, language settings, service settings, and support messages.
Device and technical data: device identifiers, product model, serial or product identifiers where available, app version, operating system, diagnostics, error logs, update status, and security logs.
Assistive-function content: images, video frames, audio, recognized text, OCR results, scene descriptions, AI prompts and outputs, translation content, documents opened or created in the workstation software, and other content you submit to use a requested function.
Location and route-related data: location, route, heading, transit, and map-related information when a location, navigation, transit, assistant-call, or similar feature is enabled.
Face-recognition data: person labels, face images used for setup or recognition, and facial embeddings where you enable face-recognition features. Face embeddings are stored for the feature and can be deleted by the user through available account or app controls, or by contacting support.
Assistant-call data: call metadata, assistant mapping, signalling data, and, during an active user-initiated call, camera, audio, and location data if the relevant permissions are enabled.
Support, warranty, and service data: purchase or warranty information, repair status, correspondence, and information needed to handle customer support.

We do not ask you to provide unnecessary sensitive data. Because SparkVision products are assistive products and because some features process images, audio, location, and facial embeddings, the data you provide or generate can reveal information about disability, health, surroundings, identity, or other sensitive matters. Where GDPR requires an Article 9 basis, we rely on explicit consent or another applicable legal basis.

III. Purposes, Legal Bases, and Retention

We process personal data for these purposes:

Providing the service: account creation, authentication, device association, assistive functions, AI/OCR/text-to-speech features, assistant calls, updates, and user settings. Legal basis: contract performance or steps before entering a contract.
Support and warranty: responding to requests, troubleshooting, customer service, warranty handling, repair coordination, and service communication. Legal basis: contract performance, legitimate interest, or legal obligation.
Safety, security, and service improvement: diagnostics, abuse prevention, system monitoring, quality improvement, testing, and troubleshooting. Legal basis: legitimate interest, with safeguards appropriate to the data involved.
Legal and compliance obligations: accounting, tax, product compliance, regulatory requests, dispute handling, and legal claims. Legal basis: legal obligation or legitimate interest.
Optional features and communications: optional surveys, non-promotional service messages, and optional functions that require additional permissions. Legal basis: consent or legitimate interest, depending on the feature.

Account data and feature data are retained while the user account remains active and for as long as needed to provide the service. If an account is inactive for 6 months, SparkVision deletes the account and related personal data, unless applicable law requires or permits longer retention. Users can request deletion of their data at any time at customer.support@sparkvision.tech.

Some records are retained for longer where required or permitted by law, including accounting, tax, warranty, security, dispute, and legal-claim records. Technical logs, call/session metadata, diagnostics, and temporary processing data are retained for limited periods appropriate to security, troubleshooting, and service operation.

IV. Processors and Recipients

We use trusted providers to operate the services. Depending on the feature, these can include providers for hosting, databases, authentication, email, push notifications, AI processing, OCR, text-to-speech, speech-to-text, maps/routes, storage, security, diagnostics, and communication services.

These providers process personal data on our behalf under contractual confidentiality and data-protection obligations. We can also disclose data where required by law, by a competent authority, by court order, or where necessary to protect rights, safety, property, security, or legitimate interests.

V. International Transfers

Personal data is stored or processed in the European Union where possible and according to the architecture of the relevant service. Some providers or sub-processors can process data outside the European Economic Area. Where this happens, transfers are made under an adequacy decision, Standard Contractual Clauses, the EU-US Data Privacy Framework where applicable, or another lawful GDPR transfer mechanism.

VI. Minors and Persons Under Legal Protection

Where SparkVision services are used by or for a minor or a person under guardianship or similar legal protection, purchase, setup, account administration, and consent must be handled by a parent, legal guardian, or authorised representative as required by applicable law.

VII. Automated Processing and AI Features

SparkVision services use AI-supported processing to provide functions such as OCR, scene description, recognition, translation, voice assistant features, transit information, and other assistive outputs. These outputs are informational and can be incorrect, incomplete, delayed, or unavailable.

SparkVision does not use these AI outputs to make legal, financial, employment, healthcare, insurance, or similarly significant automated decisions about users.

VIII. Your GDPR Rights

Subject to GDPR conditions, you have the right to request access, rectification, erasure, restriction, portability, and objection. Where processing is based on consent, you can withdraw consent at any time without affecting prior lawful processing.

To exercise your rights, contact customer.support@sparkvision.tech. We respond within one month unless GDPR allows an extension. We can request information needed to verify your identity.

You can also lodge a complaint with a competent data-protection authority. In Bulgaria, the supervisory authority is the Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria, email kzld@cpdp.bg, phone +359 2 915 35 18.

IX. Security

We apply reasonable technical and organisational measures to protect personal data against unauthorised access, loss, disclosure, alteration, or misuse. These measures include access controls, encryption where appropriate, internal procedures, provider safeguards, monitoring, and data minimisation.

No online service can guarantee absolute security. Users should protect their account credentials, keep devices updated, and contact SparkVision if they suspect unauthorised access.

X. Website Storage, Cookies, and Third-Party Links

The SparkVision website does not currently use advertising or analytics cookies in this codebase. The website accessibility tools store accessibility preferences in the user's browser local storage so the selected settings can remain active between visits.

The website, app, or documentation can link to third-party websites or services. Their privacy, security, accessibility, and data practices are controlled by those third parties, not by SparkVision.

XI. Changes to This Policy

We can update this Privacy Policy when our services, providers, legal obligations, or processing activities change. The current version is published on the website or in the app. For material changes affecting personal-data processing, we will provide a visible notice before the change takes effect where required by law.