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This Policy describes Sparklo’s policies and procedures on collecting, processing, transferring, and storing information when you use the Service. It also informs you of your privacy rights under South African law, including the Protection of Personal Information Act (POPIA) and the Promotion of Access to Information Act (PAIA).
The Service and the Website use the Personal Data you provide to deliver and improve Sparklo’s Services. By using our Services, you agree to the collection and use of your information in accordance with this Policy.
By using our Application, you automatically agree to this Policy and all its terms and conditions, and you consent to share your Personal Data with us for the purposes outlined herein.
Interpretation
Words with an initial capital letter have meanings defined under this section. These definitions apply whether the terms appear in singular or plural form.
Definitions
Personal Data Collection
While using the Application, you may provide certain personally identifiable information that can be used to contact or identify you. This includes, but is not limited to:
Refusal of Data Provision:
If you choose not to provide the requested Personal Data (for example, during registration or bonus sign-up), please note that this may result in limitations or restrictions in accessing certain features of our Application. We encourage you to review the implications before declining to provide your data.
Sparklo reserves the right, at its sole discretion, to request that you confirm your Personal Data or any other information related to your use of the Application.
Sources of Data:
In addition to the data you provide directly via the Application, Personal Data may also be collected from other sources, such as Sparklomats or other channels available in South Africa. In such cases, we will inform you about these additional data collection methods.
Usage Data is collected automatically when you use the Application and fill out forms on Sparklo’s Application. Usage Data may include information such as:
This data helps us monitor Application performance, ensure security, and improve functionality.
We use cookies and other tracking technologies to enhance your experience. We may share Personal Data with:
Sparklo may use Personal Data for the following purposes:
Disclosure to Third Parties:
Sparklo may share your Personal Data in the following circumstances:
For greater transparency, a detailed list of third-party recipients and the categories of data shared is available on our official website.
Sparklo retains your Personal Data only as long as necessary for the purposes described in this Policy, to comply with legal obligations, resolve disputes, and enforce our policies. Usage Data is retained for a shorter period unless used for security or functionality purposes. We use PostgreSQL to store your data, ensuring robust and stable protection.
Your Personal Data may be processed and stored on servers located outside South Africa. By providing your Personal Data, you consent to its transfer to jurisdictions with different data protection laws. Sparklo will take all reasonable steps to ensure that your data is treated securely in accordance with this Policy, and no transfer will occur unless adequate controls are in place.
Business Transactions:
If Sparklo is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred to the new entity. We will notify you before such a transfer, where practicable.
Law Enforcement and Other Legal Requirements:
Sparklo may disclose your Personal Data if required by law or in response to valid requests from public authorities (e.g., a court or government agency).
Other Legal Requirements:
Sparklo may disclose your Personal Data in the good faith belief that such action is necessary to:
In compliance with POPIA and other relevant South African regulations, you have the following rights:
In accordance with the Promotion of Access to Information Act (PAIA), a separate PAIA Manual is published on our official website www.sparklo.com/legal-privacy-south-africa-paia. This manual provides detailed information on:
We encourage you to review the PAIA Manual for further details on accessing records and your additional rights.
Sparklo takes all reasonable measures to protect your Personal Data from accidental or unlawful destruction, loss, alteration, or unauthorized access. Our safeguards include physical, technical, and administrative measures as well as encryption technology. However, Sparklo is not liable for any losses or damages resulting from unauthorized access or technical issues.
Our Application may contain links to third-party websites or applications. Sparklo is not responsible for the content, privacy policies, or practices of these external sites. We encourage you to review their privacy policies before providing any Personal Data.
Sparklo reserves the right to update this Policy from time to time by posting a new version on our website. The updated Policy will be effective immediately upon posting. We recommend that you review this Policy periodically to stay informed about how we protect your Personal Data.
By using our Application, you agree to the terms of this updated Privacy Policy and acknowledge your rights under South African law (POPIA and PAIA). If you have any questions or require further clarification regarding this Policy or your rights, please contact us at support@sparklo.com.
This PAIA Manual is published in accordance with the Promotion of Access to Information Act (PAIA) to inform the public about the records held by Sparklo and the procedure to access those records. The Manual sets out the categories of records that are available without a formal request, the records available upon request, and the process for making a PAIA request.
For the purposes of PAIA, the following contact details relate to the head of the body at Sparklo:
The following categories of records are available for public inspection without the need to submit a formal PAIA request:
These records can be accessed by visiting our official website at [Insert URL] or by contacting our PAIA Representative.
Additional records that are not available for public inspection without a formal request include, but are not limited to:
These records will be provided in accordance with PAIA procedures, subject to any exemptions allowed by law.
If you wish to access records held by Sparklo, please follow the steps below:
Sparklo maintains records relating to, but not limited to, the following categories:
Sparklo is committed to ensuring that personal data is processed securely and in compliance with the Protection of Personal Information Act (POPIA). Measures include:
For further information or clarification regarding this PAIA Manual or the records held by Sparklo, please contact our PAIA Representative using the details provided in Section 2.
This PAIA Manual is provided for informational purposes and may be updated periodically. We recommend reviewing the latest version on our official website.
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.