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Last Updated: June 17, 2025
This Policy describes SPARKLO policies and procedures oncollecting, processing, transferring, and storing information when you use the Service and tells you about privacy rights and how the law of Qatar protects Your Personal Data.
The Service and the Website use your Personal Data provided by you to provide and improve SPARKLO’s Services. By using the Services, you agree to collect and use information following this Policy.
By using our Application, you automatically agree with this Policy and all terms and conditions of this Policy and agree to share your personal data with us for further collecting and processing purposes, as it is described in this Policy.
Interpretation
The words in which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.
Definitions
"Application" means the application provided by SPARKLO and is available for downloading via AppStore and Google Play Market. The Application shall be used with the purpose of to get and use bonuses from Sparkomat using.
"Device" means any device where the Application can be downloaded.
"SPARKLO", "we", "our", and"us" means the company that is an owner of the Application. The name of the company: SPARKLO General Purpose Machinery Parts Manufacturing LLC, registered in accordance with the legislation of UAE, with its principal place of business at WIZN4-02 Shed No. N4 Al Hamra Industrial Zone-NFZ RAK, United Arab Emirates, license № 26000623.
"GDPR" means general data protection rules relating to the protection of natural persons about the processing of personal data and rules relating to the free movement of Personal Data.
"Personal Data" means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, location data, an online identifier, etc.
"Processing" means any operation or set of operations that are performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization,structuring, storage, adaptation or alteration, retrieval, consultation, use ,disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
«Sharing» data means the transferring Data (in full or partial), in original or processed form to third party (business partners, clients, etc) on the conditions defined by Sparklo , including cross-border data transfer (not limited by the country of person residency), to other countries where Sparklo operates or planning to operate the business.
"Usage Data" refers to data collected automatically, either generated using the Application’s infrastructure itself (for example, the duration of a visit, website usage, and the number of users).
"User", "you", and "your"means any individual or legal entity who is using the Application from SPARKLO.
Controller (the Sparklo itself) is a producer of cutting-edge AI-powered reverse vending machines (RVMs or the ”Equipment”), the unique operational system integration thereto, mobile application and unrivalled motivational award system that the Controller has successfully invented, designed and developed. The Controller directs its activities to promote waste management practices and effective use of resources and believe that development of large-scale RVM network will enable the world to achieve sustainability goals and make a long-lasting positive impact on the future to achieve the following goals:
The Controller operates under license no. 26000623.
Controller shall develop internal systems for the effective management of Personal Data, and report any breach of measures aiming at the protection thereof, also the key processing categories requiring a DPIA include systematic monitoring of data subjects upon the Qatar law.
Personal Data:
While using the Application, you may provide certain personally identifiable information that can be used to contact or identify you. Personal Data that we collect may include, but is not limited to:
Full name and surname;
Email;
Contact phone number;
Country of residence;
Mailing address and legal address;
SPARKLO has the right, at any time, at its sole discretion,to request that you confirm your personal information or any other information related to using the Application.
Rights of Your Data Subjects:
As a data subject, you as a natural person has several rights concerning your personal data. We are committed to respecting and facilitating these rights in accordance with applicable data protection laws. Below are your main privacy rights and how you can exercise them:
To exercise any of these rights, please contact us at support@sparklo.com. We will respond to your request within a reasonable timeframe and in accordance with applicable laws.
Usage Data is collected automatically when using theApplication and filling out the forms on SPARKLO’s Application from time to time.
Usage Data may include information, type of the Device, your visit pages, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data and diagnostic data of your account information.
When you visit the Application, SPARKLO has the right to collect, process and transfer the following data:
- the type of Device that is used;
- Device operating system which you used;
- The type of internet browser that is used for using the Application;
- Unique Device identifiers and other diagnostic data of the Device you used for access to our Application;
and SPARKLO has the right to check and control the Application using to keep the functionality and protect it from any infringements by third parties.
We Share personal information for the purposes set out in this Privacy Statement and with the following categories of recipients:
SPARKLO may use Personal Data for the following purposes:
To provide and maintain the Application, including monitoring the Application usage.
To provide you with news, special offers and general information about services and events that SPARKLO offers, like those you have already used unless you have opted not to receive such information.
To manage your requests: To attend to and manage your requests to the Application.
For business transfers: SPARKLO may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or another sale or transfer of some or all SPARKLO assets, whetheras a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by SPARKLO about the Application’s users is among the assets transferred.
For other purposes: SPARKLO may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of the Application’s promotional campaigns, evaluating and improving the Application, products, and services, marketing, and your experience.
SPARKLO may Share your Personal Data in the following situations:
SPARKLO will retain your Personal Data only as long as necessary for the purposes set out in this Privacy Policy.
SPARKLO will retain and use your Personal Data to the extent necessary to comply with SPARKLO’s legal obligations (for example, if we are required to retain SPARKLO’s Personal Data to comply with applicable laws),resolve disputes, and enforce our legal agreements and policies.
SPARKLO will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this Personal Data is used to strengthen the security or improve the Website's and/or the Service’s functionality, or SPARKLO is legally obligated to retain this data for more extended periods.
SPARKLO will retain your personal data with PostgreSQL database service providing the safest and most stable data protection as it is possible.
Your information, including Personal Data, processing by SPARKLO’s operating offices and in any other places where the parties involvedin the processing are located. This information may be transferred to — and maintained on — computers outside your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
Your consent to this Privacy Policy, followed by submission of such information, represents your agreement to that transfer.
SPARKLO will take all steps reasonably necessary to ensure that your Personal Data is treated securely and following this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your Personal Data and other personal information.
Business Transactions
If SPARKLO is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. SPARKLO will provide notice before your Personal Data is transferred and becomes subject to a different PrivacyPolicy.
Law enforcement
Under certain circumstances, SPARKLO may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
SPARKLO may disclose your Personal Data in the good faith belief that such action is necessary to:
SPARKLO’s Application does not address anyone under 18 (eighteen). SPARKLO does not knowingly collect personally identifiable information from anyone under 18 (eighteen). If you are a parent or guardian and are aware that the child has provided SPARKLO with Personal Data, please contact us immediately.
If SPARKLO becomes aware that we have collected Personal Data from anyone under 18 (eighteen) without verification of parental consent, SPARKLO takes steps to remove that Personal Data from our servers or/and any storage used by SPARKLO.
If SPARKLO needs to rely on consent as a legal basis for processing your information and your country requires consent from a parent, SPARKLO may require your parent’s consent before SPARKLO collects and use that information.
By using our Application, you automatically agree with this Policy and guarantee us that you are under 18 (eighteen) years old or you have your parental or guardian consent to share your personal data with us.
SPARKLO takes all reasonable steps to protect information that is received from you from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. SPARKLO has put in place appropriate physical, technical, and administrative measures to safeguard and secure your information, and SPARKLO makes use of privacy-enhancing technologies such as encryption. If you have any questions about the security of your personal information, you can contact us VIA email support@sparklo.com.
SPARKLO, in any case, is not responsible for losses and/or disclosures of your Personal Data or any damages related to losses and/or disclosure of the Privacy Data as a result of any unauthorised or technical problem.
We take the security of your personal data seriously and react promptly to any breaches. Our procedures for handling data breaches are as follows:
Response to data breaches. Upon identifying a breach of personal data, we will act promptly to contain and mitigate the impact of the breach. This includes taking reasonable measures to prevent further dissemination of the data.
Notification to data subjects and regulatory authorities. We are obliged to notify both the affected data subjects and the relevant regulatory authorities of any data breach. If the breach is likely to result in a high risk to your rights and freedoms, we will inform you without undue delay.
Details of notification. In the event of a data breach, we will provide:
A description of the nature of the breach.
The categories and approximate number of data subjects and data records concerned.
The likely consequences of the breach.
The measures we have taken or propose to take to address the breach and mitigate its effects.
Serious damage notification. If the breach may cause serious damage to personal data or individual privacy, we will immediately inform both the individual and the regulatory authority of the occurrence and the measures taken to prevent further damage.
For any concerns or to report a data breach, please contactus at support@sparklo.com. We are committed to safeguarding your personal data and ensuring prompt and transparent communication in the event of any security issues.
SPARKLO’s Application may contain links to other websites or applications not operated by us. If you click on a third-party link, you will be directed to that third-party’s website or application. SPARKLO strongly advises you to review the Privacy Policy of every site that you visit.
SPARKLO has no control over and assumes no responsibilityfor any third-party sites or services' content, privacy policies or practices.
SPARKLO may update the Policy from time to time. SPARKLO is not obliged to notify you and any other third parties of any changes by posting the new Policy on this page.
SPARKLO has the right to update the Policy. SPARKLO will let you and any other third parties know via updating the “Last Updated” date at the top of this Policy.
You and any other third parties are advised to review this Policy periodically for any changes. Changes to this Privacy Policy are effective when posted on this page.
Sparklo, Organizer of the Bonus Program – SPARKLO GENERAL PURPOSE MACHINERY PARTS MANUFACTURING LLC, having its principal office at Al Hamra Industrial Zone-NFZ, WIZN4-02, Ras Al Khaimah, United Arab Emirates
Bonus – a virtual conditional unit within the Bonus Program, credited to a participant upon submission of Empty Containers via Sparklo reverse vending machines (RVMs), in accordance with this Offer.
Bonus Program – a program to incentivize the submission of Empty Containers for recycling by accruing and using Bonuses, organized by Sparklo.
Personal Account – the Bonus Program Participant’s account in the Sparklo Mobile Application or on the website.
Official Bonus Program Website: sparklo.com
Bonus Program Partners – legal entities and/or individual entrepreneurs that provide discounts on their goods and/or services in exchange for Bonuses. The current list of Bonus Program Partners is published on the official website and in the App.
Empty Container – used plastic and/or aluminum containers or other similar recyclable items.
Bonus Program Participant (Participant) –an individual who has reached the age of 18 and confirmed their consent to participate in the Bonus Program by registering via Sparklo RVMs or in the App.
Sparklo RVM – equipment manufactured by Sparklo for the collection of empty containers and participation in the Bonus Program.
Participant Bonus Account – a conditional account opened by the Organizer in its information system in the name of the Participant in their Personal Account in the App, where Bonuses are credited for each unit of submitted Empty Container (according to the calculation formula provided in Section 5.1 of the Offer).
Offer – this document, which is a public offer by the Organizer addressed to any natural or legal person to conclude an agreementon the terms specified in the offer, including all its annexes.
Acceptance – full and unconditional acceptance by a person of the terms of the offer and their willingness to become a Participant in the Bonus Program.
Sparklo Mobile Application – software used by individuals on mobile phones, smartphones, or computers (including tablets) connected to the Internet to access the Organizer’s automated systems for earning bonuses, purchasing goods, or obtaining services.
This document is an official offer (public offer) within the Bonus Program organized by Sparklo, aimed at incentivizing the submission of Empty Containers for recycling in the United Arab Emirates, and includes all essential terms of service provision (hereinafter referred to as the"Offer"). This Offer is published in the Sparklo Mobile Application and on the website: sparklo.com
In accordance with applicable UAE law, by accepting the conditions outlined below, a legal or natural person who accepts this Offer becomes and is hereinafter referred to as a "Bonus Program Participant." Acceptance of the offer is equivalent to entering into a contract under the terms outlined in the offer.
The moment of full and unconditional acceptance of the Organizer’s proposal (the moment of acceptance of the Offer) is considered the Participant’s registration in the Bonus Program via Sparklo RVMs or the Sparklo Mobile Application.
By accepting the Offer as defined in clause 2.3 of theAgreement, the Participant confirms that they have read, agree with, and fully and unconditionally accept all terms of the contract as outlined in the text of the Offer, including its annexes, which are an integral part thereof.
The Offer remains in effect until withdrawn by the Organizer.
The Organizer of the Bonus Program, via the use of Sparklo RVMs, offers individuals participation in a recycling program for plastic and aluminum packaging waste, during which individuals submit Empty Containers (plastic bottles and aluminum cans) in Sparklo RVMs in exchange for participation in a loyalty program entitling them to Bonuses.
The Organizer does not verify the accuracy of personal data provided by the Participant and does not control its relevance. The Organizer assumes that the Participant provides accurate and current personal information. The Participant is solely responsible for providing inaccurate or outdated personal data.
To register via Sparklo RVMs, the Participant must enter their phone number in the specified field on the RVM screen. By entering their phone number, the Participant accepts this Offer and agrees to receive Bonuses for submitted containers.
To register via the Sparklo Mobile Application, the Participant downloads and installs the app, enters their phone number, and confirms it using a verification code sent via SMS. Acceptance of this Offer is confirmed by entering the code in the app, thereby confirming participation. By doing so, the Participant agrees to receive notifications via SMS.
For each Empty Container submitted via a Sparklo RVM, the Participant is entitled to receive 10 Bonuses to their Bonus Account in the Personal Account of the Sparklo App.
Bonuses do not have monetary value and cannot be exchanged for cash or any other form of compensation.
To receive Bonuses, the Participant must enter a correct phone number that matches the number provided during registration.
Bonuses are credited to the Participant’s Bonus Account immediately after the submission process is completed.
Bonuses can be redeemed through the Personal Account by obtaining discounts from Bonus Program Partners, according to the terms outlined in the App.
If due to technical reasons the redemption of Bonuses is not possible, the Organizer reserves the right to deny the operation.
Bonuses do not expire and remain valid indefinitely once credited.
If for technical reasons the accrual of Bonuses is not possible, the Organizer reserves the right to deny the operation until the issue is resolved.
Participants may not transfer Bonuses to other users.
The Organizer only accepts Empty Containers suitable for further recycling via Sparklo RVMs. The Organizer reserves the right to determine the type and form of Empty Containers accepted via Sparklo RVMs.
Bonuses provide the Participant with the right to exchange them for discounts on goods and services from Partners or to participate in social programs, according to the terms outlined in the App. Bonuses are non-refundable in case of product returns.
The Organizer reserves the right to change the accrual and usage conditions of Bonuses by publishing relevant information in the App.
The Organizer is not liable for losses or damages incurred by the Participant due to suspension, amendment, or termination of the Bonus Program unless otherwise required by applicable UAE law.
The Organizer is not responsible for the quality of goods and/or services provided by Partners, nor for any losses incurred due to their use.
The Participant agrees not to: a) misuse the Sparklo MobileApplication; b) misuse Sparklo RVMs; c) interfere with software or hardware components; d) provide false information; e) violate container acceptance rules; f) exploit technical or software malfunctions for bonus accrual or unauthorized access; g) engage in fraud; h) violate the Offer or UAE law.
In case of any such violations, the Organizer may terminate the Participant's access and void or block their Bonus Account without explanation.
The Organizer may amend this Offer at any time by publishing the new version in the App or on the website at least one day prior to its effective date.
Participants are responsible for monitoring any changes to the Offer.
The Organizer may suspend or terminate the Bonus Program at any time, publishing relevant information in the App or on the website at least 30 days prior.
Upon termination of the Bonus Program, Bonuses in Participant Accounts will be voided without compensation.
If the Organizer suspects fraud, it may exclude the Participant from the Program. The results of an internal investigation will serve as sufficient grounds for exclusion.
The Organizer reserves the right to adjust bonus accrual timelines due to technical issues and may notify Participants accordingly.
By accepting the Offer, the Participant consents to the collection, processing, updating, use, and storage of personal data for registration and participation purposes.
The Organizer undertakes not to disclose information received from the Participant. The Participant consents to data processing according to the Privacy Policy available during App registration. The Organizer processes personal data in accordance with UAE data protection laws.
The Participant may delete the App and terminate their account at any time. Further use of the Personal Account will be unavailable.
The Organizer is not responsible for the Participant’s lack of awareness regarding the rules in this document.