Privacy Policy

At Spark Vision, we deeply respect your privacy and appreciate the trust you place in us. That’s why we handle your personal data with the utmost care and responsibility whenever you use our mobile application (the “App” or the “Application”).

Through this Privacy Policy (the “Policy”), we aim to clearly explain what personal data we collect when you use the App, why we collect it, and what rights you have regarding your information. Our commitment is to keep you fully informed and confident that your data is handled securely and transparently.

About the App

This mobile application is designed to work with smart glasses for visually impaired users. It uses artificial intelligence to recognize objects, scenes, and text from the surrounding environment and converts the results into spoken descriptions delivered to the user in real time.

  1. PERSONAL DATA CONTROLLER

The controller responsible for your personal data, as outlined in this Privacy Policy, is Spark Vision IS OOD, UIC 206677712, with its seat and management address at 1, Krum Popov Str., Sofia, Bulgaria (referred to as “Spark Vision”, the “Company,” “Administrator,” “we,” or “our,” as applicable).

If you have any questions or concerns regarding how we process your personal data, you are welcome to contact us directly by sending an email to customer.support@sparkvision.tech or by mail to: 1, Krum Popov Str., Sofia, Bulgaria.

  1. PERSONAL DATA

What is personal data?

Personal data is any information relating to an identified or identifiable natural person. Various pieces of information, put together that can lead to the identification of a specific individual, also constitute personal data.

What personal data do we collect?

  1. Data associated with your account

When you register and connect your smart glasses with the mobile application, we collect and store certain personal information necessary to identify and associate the device with your account. This includes:

  • Full name – used to identify the registered user of the device;
  • Email address – used for account management, authentication, and communication regarding your device or services;
  • Phone number – used for account verification, technical support, and important notifications.

This information allows us to securely link the smart glasses to a specific user profile and ensure that personalized features and services are delivered correctly.

  1. Data collected when using your device

In addition to standard data (such as profile information, settings, and technical data), the application may, at the user’s discretion, process the following types of content:

  • Images and video frames captured by the smart glasses or the phone camera when the user activates a recognition or description function. These images may incidentally contain faces, objects, texts, or other personal data. They are transmitted in encrypted form to Google servers (Vertex AI, Gemini) solely for automated processing (e.g., OCR, scene description) and are not stored by us after the results are returned.
  • Text strings generated by the application (for example, recognition results or scene descriptions), which are sent to Google Cloud Text-to-Speech for voice synthesis.
    Such text may contain short descriptions of objects or scenes but no personal data, unless it was present in the original image.
  • Data provided through our contact and/or support form, which can be both written and by telephone
  • First and last name
  • Email address
  • Phone number
  • Any other information you provide to us through the contact and/or support form
  • Other Data
  • Diagnostic and technical data (device type, errors, OS version), used to improve performance and stability.
  1. PURPOSES AND BASIS FOR PROCESSING. RETENTION PERIODS

To the extent permitted by law, we use your personal data for the following purposes:

  • Providing and Supporting the Core Functionality of the Smart Glasses and the App

This primary purpose includes:

  • establishing and maintaining the connection between the smart glasses and the user’s profile within the mobile application;
  • creating and managing user accounts and device registrations;
  • enabling and managing accessibility features, such as image and text recognition, voice feedback, and personalized settings;
  • ensuring the proper operation of the application and the AI-based services that support it (e.g., processing requests via Google Vertex AI, Gemini, and Google Cloud Text-to-Speech);
  • resolving technical issues related to the smart glasses and the App;
  • providing customer support and assistance, including responses to your technical or service-related inquiries.

Grounds: performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering a contract (Art. 6(1)(b) GDPR); compliance with legal obligations, including tax and accounting laws (Art. 6(1)(c) GDPR).

Retention periods:

  • Data processed based on Art. 6(1)(b) GDPR – retained for 6 years from the termination of the contractual relationship;
  • Data containing tax or financial information – retained for 10 years, starting from January 1 of the year following the year of issuance or occurrence.
  • Responding to Your Requests and Inquiries

When you contact us (e.g., via email, phone, or in-app forms), we process your personal data solely for the purpose of responding to your inquiries or providing the requested assistance.

Grounds: your explicit consent to be contacted (Art. 6(1)(a) GDPR).
Retention period:

  • If personal data is collected only to establish contact, it is retained until the communication is concluded, unless a longer period is required by law;
  • If communication relates to a specific account or device registration, data is retained for no less than 5 years from the date of termination of the corresponding agreement.
  • Improving and Personalizing Our Services

We strive to ensure the best possible experience for users of the smart glasses and the mobile App. For this purpose, we may process certain information about how you interact with the App — such as usage statistics, feature activation, and feedback submitted through support channels.
We may also invite you to participate in optional user satisfaction or usability surveys, conducted by us or trusted partners, to enhance the quality and accessibility of our services.
Additionally, we may send non-promotional educational messages that help you get the most out of the device and the App (e.g., usage tips, accessibility features, or troubleshooting instructions).

Grounds: legitimate interest (Art. 6(1)(f) GDPR) in improving our services and ensuring a high-quality and inclusive user experience, while always respecting your rights and freedoms.
Retention period: 12 months.

  • Protecting our legitimate interests

There may be times when we use or share information to protect our rights and business. These may include:

  • measures to protect the App and the App’s users against cyber-attacks;
  • measures to prevent and detect fraud attempts, including the transmission of information to competent public authorities;
  • measures to manage various other risks.

Grounds: The primary legal basis for these types of processing is our legitimate interest in safeguarding our commercial activities. We always ensure that any measures we take maintain a fair balance between our interests and your fundamental rights and freedoms.

In certain cases, our processing may also be based on legal obligations, such as statutory requirements related to the protection of property and assets, as outlined in the applicable legislation.

Retention period: according to the relevant legal provisions.

  1. SENSITIVE DATA

The Company does not process any sensitive personal data of users of the App. We kindly ask that you do not send or disclose any sensitive information — such as data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, health status, criminal records, or trade union membership — via the Application or through any other means of communication with us.

  • DATA OF MINORS AND PERSONS UNDER GUARDIANSHIP

Our App and services may, in certain cases, be used by or on behalf of individuals under the age of 18 or persons under guardianship, for accessibility and assistive purposes.
In such cases, the registration and management of the account in the App must be carried out by a parent, legal guardian, or other authorized representative, who acts as the controller of the user’s profile and provides consent for the processing of personal data.

We do not knowingly allow minors or persons under guardianship to independently create accounts or provide personal data without verified authorization from their parent or guardian.
If we become aware that personal information has been provided without such consent, we will take appropriate steps to suspend or delete the related data as soon as possible.

Parents, legal guardians, or authorized representatives are encouraged to contact us immediately if they believe that data of a minor or a person under guardianship has been submitted without proper consent or supervision.

  • HOW WE MAY DISCLOSE YOUR PERSONAL DATA

Except as expressly described in this Policy, we do not intentionally disclose any personal data collected or stored through the App to third parties without the explicit consent of the individual concerned.

However, to the extent permitted by applicable law and strictly for the purposes for which the data was originally collected, your personal data may be disclosed to the following categories of recipients:

  • third-party service providers – we may share your personal data with trusted third-party providers that enable, host, or support the operation of the smart glasses and the mobile App. These partners help us perform essential technical processes, including data processing, artificial intelligence–based recognition, and text-to-speech synthesis.

These third parties process your data solely on our behalf, under strict contractual and confidentiality obligations, and in full compliance with applicable data protection laws.

The main service providers we rely on include:

  • Google Cloud / Vertex AI / Gemini – for automated processing of images or video frames sent by the user for scene description, text recognition (OCR), and other AI-based analyses;
  • Google Cloud Text-to-Speech – for converting text strings (generated by the App) into spoken audio output returned to the device;
  • Google Cloud Platform (infrastructure services) – for secure hosting and data transmission related to the App’s AI functions;
  • Other IT infrastructure or communication partners – for hosting, encryption, and technical maintenance, where necessary.

All third-party providers act as data processors and are bound by written agreements that ensure your data is processed only as required to deliver the requested functionality, without independent use for their own purposes.

  • Business transfers and corporate transactions

Your personal data may be disclosed as part of a business reorganization, merger, acquisition, joint venture, sale, transfer, or other disposition of all or part of our business or assets. This includes situations involving bankruptcy or insolvency, to the extent permitted by applicable law.

  • Legal obligations and protection of rights

We may also disclose your personal data when required or appropriate under applicable law, including when we believe such disclosure is necessary to:

  • comply with legal or regulatory obligations, including those outside your country of residence;
  • respond to lawful requests and legal processes (such as subpoenas or court orders);
  • cooperate with public or governmental authorities, including law enforcement;
  • protect our operations, rights, property, safety, or that of our users or others;
  • enforce our terms of use and pursue available legal remedies; or
  • prevent or limit any potential damages or liability we may face.

In all cases, we ensure that any disclosure of personal data is made only to the extent strictly necessary, in accordance with data protection principles, and that all reasonable measures are taken to protect the confidentiality and integrity of your information.

DATA SUBJECTS RIGHTS

  • Access to your personal data

You have the right to access, correct, or delete the personal data we hold about you. To exercise any of these rights, please contact us at customer.support@sparkvision.tech.

We will respond to your request free of charge and within one month, in accordance with applicable data protection laws. However, if a request is manifestly unfounded, excessive, or repetitive, we reserve the right to charge a reasonable administrative fee or to refuse the request, as permitted by law.

  • Correction of personal data

If any of the information we hold about you is inaccurate or incomplete, you can ask us to correct or complete it at any time.

  • Your right to erasure or to be forgotten

You can ask us to delete your personal data, but only if:

  • It is no longer necessary for the purposes for which it was collected; or
  • you have withdrawn your consent (if the data processing is based solely on consent); or
  • you exercise a legitimate right to object; or
  • it has been unlawfully processed; or
  • there is a legal obligation in this regard.

We are not obliged to comply with your request to delete your personal data if the processing is required:

  • to comply with a legal obligation; or
  • to establish, exercise or defend a legal claim.

There are certain circumstances under applicable law where we may not be obligated to comply with your request to delete personal data. These situations are limited, but they represent the most common reasons why a deletion request might be lawfully denied.

If you wish to request the deletion of your personal data, please contact us at customer.support@sparkvision.tech, using the email address associated with your account or by otherwise verifying your identity.

Please note that deleting your data and your account within the App is a permanent and irreversible process, including the removal of all associated documents and records. Once deletion is complete, this information cannot be recovered, unless we are required to store it by law.

  • Restriction of data processing

You have the right to request that we restrict the processing of your personal data, but only in the following circumstances:

  • you contest the accuracy of the data, in which case processing will be restricted until we verify its accuracy (see the section on data correction);
  • the processing is unlawful, but you prefer restriction over deletion;
  • we no longer need the data for the purposes for which it was collected, but you require it for the establishment, exercise, or defence of legal claims;
  • you have objected to the processing and we are verifying whether our legitimate grounds override yours.

We may continue to process your personal data during the restriction period only:

  • if we have your explicit consent;
  • for the establishment, exercise, or defence of legal claims; or
  • to protect the rights of the Application owner or another individual or legal entity.
    • Data portability

You have the right to request that we provide your personal data in a structured, commonly used, and machine-readable format, or that we transmit it directly to another data controller, where technically feasible. This right applies only if:

  • the processing is based on your consent or on a contract with you; and
  • the processing is carried out by automated means (i.e., not manual processing).
    • Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data where such processing is based on our legitimate interests, if you believe that your fundamental rights and freedoms outweigh those interests.

  • Making automatic decisions

The controller does not carry out profiling or automated individual decision-making. In the event of a change, you will be expressly notified of this before the change takes effect.

  • Right to file a complaint with the local supervisory authority

If you believe that we are processing your personal data in an unlawful manner, you may contact us at customer.support@sparkvision.tech.

You have the right to file a complaint with your local supervisory authority regarding the processing of your personal data.

In Bulgaria, the contact details of the supervisory authority for personal data protection are as follows:

Personal Data Protection Commission

Bulgaria, Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd.

Phone: + 359 2 915 35 18

Email: kzld@cpdp.bg

  • OTHER INFORMATION

Other information we may collect

“Other information” is any information that does not reveal your specific identity, such as:

  • device information, operator, internet connection
  • server log information and App logs
  • information collected through cookies, pixel tags and other technologies
  • demographic information and other information provided by you
  • location information

We may use and disclose Other Information for any purpose, except as required to do otherwise by applicable law. If we are required to treat Other Information as personal data by applicable law, then we may use and disclose Other Information for all purposes for which we use and disclose personal data.

  1. DATA SECURITY METHODS

To protect user data from unauthorized or accidental disclosure, we implement reasonable and appropriate technical and organizational measures.

Technical measures: We employ technologies designed to prevent unauthorized third-party access to personal data. As part of our security protocols, we apply encryption to user and end-user data—this includes but is not limited to: communication within the App; all data stored on our servers.

Organizational measures: We have adopted internal policies and procedures that govern how our employees handle personal data. These are part of our internal regulations and are considered confidential for security reasons.

Where servers are hosted in data centres operated by third parties, we ensure that equivalent technical and organizational safeguards are in place and applied by those providers.

Data Storage Location: All personal data is stored on servers located within the European Union.

We currently engage the following data processors: Google.

  • TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY OR INTERNATIONAL ORGANIZATION

All personal data is stored exclusively on servers located within the European Union. In case of transfer to third countries, such transfers will be conducted in full compliance with Article 46 of the GDPR, based on:

  • the use of Standard Contractual Clauses (SCCs) adopted by the European Commission, and/or
  • certification under the EU–US Data Privacy Framework, where applicable.

These safeguards are in place to ensure that your data receives an adequate level of protection, even when processed outside the European Economic Area (EEA).

  • THIRD PARTY SITES

The App may contain links to websites, mobile applications, and other online services operated by third parties. Please note that this Privacy Policy does not apply to the privacy, data handling, or other practices of such third parties. We are not responsible for the content, security, or privacy practices of any third party, including those whose services are linked to or accessible from within the App. The inclusion of a link in the App should not be interpreted as an endorsement of the linked website or service by us.

We are also not responsible for the data collection, use, or disclosure practices (including data security measures) of other organizations or platforms—such as Apple, Google, Microsoft, or any other application developers, service providers, social media platforms, operating system providers, wireless service providers, or device manufacturers. This includes any personal data you choose to share with such organizations through or in connection with our presence on social media or third-party platforms.

  • COOKIE POLICY
  • What are cookies?

Cookies are small text files that are stored on your computer or mobile device. They are widely used to make websites work or work better and more efficiently. They can do this because websites can read and write these files, allowing them to recognize you and remember important information that will make your use of the website more convenient (for example, by remembering your preference settings).

The application automatically identifies the user’s IP address. An IP address is a number that is automatically assigned to the user’s computer after connecting to the Internet. All such information is recorded in an activity file by the server, which allows subsequent data processing.

  • What are scripts?

A script is a piece of programming code that is used to make our Application function properly and interactively. This code runs on our server or on your device.

  • What is a “web beacon”?

A web beacon (or “pixel tag”) is a small, invisible piece of text or image on a website that is used to monitor website traffic. To do this, various data about you is stored using web beacons.

  • What cookies do we use?

The App does not currently use cookies, scripts and/or web beacons.

  • CHANGES TO THE PRIVACY POLICY

We may update or modify this Privacy Policy at any time. The most current version will always be available within the App.

If we make any material changes to the way we process your personal data, we will notify you by displaying a prominent notice within the App before the changes take effect. We confirm that such changes will not apply retroactively.

We encourage you to review this Privacy Policy periodically while using the App, so that you remain informed about how your data is being protected.

Last updated on: 3.02.2026

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