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SPARKLO DISTRIBUTION LLC COMPANY LIMITED,
Registered and operating under the laws of Vietnam.
Sparklo is committed to safeguarding your privacy. This Privacy Policy describes Sparklo’s policies and procedures regarding the collection, processing, transfer, and storage of personal data in accordance with Vietnamese legislation, including Decree No. 13/2023/NĐ-CP.
By using our Application, you automatically agree to this Privacy Policy. If you do not agree with any part of this Privacy Policy, you should not use the Application.
1.1. Interpretation
The words with initial capital letters have meanings defined under the following conditions.
The same definitions apply regardless of whether they appear in singular or plural.
1.2. Definitions
• “Application” means the Sparklo mobile application, available for download via the App Store and Google Play Market.
• “Device” means any device (e.g., smartphone or tablet) on which the Application can be installed.
• “SPARKLO,” “we,” “our,” “us” means SPARKLO DISTRIBUTION LLC
COMPANY LIMITED, registered under Vietnamese law, operating at the address stated above, and the owner of the Application.
• “Personal Data” means any information relating to an identified or identifiable natural person as defined by Vietnamese law, including but not limited to name, phone number, email, country of residence, mailing and/or legal address, device information, etc.
• “Processing” refers to any operation or set of operations performed on Personal Data, whether automated or manual, such as collection, storage, usage, transfer, and destruction.
• “Sharing” means transferring Personal Data (in full or in part) in its original or modified form to a third party (business partners, clients, etc.) under the conditions defined by Sparklo, including cross-border data transfers to other countries where Sparklo operates or plans to operate.
• “User,” “you,” “your” refers to any individual or legal entity using the Sparklo Application.
• “Usage Data” refers to data collected automatically when using the Application or visiting Sparklo’s website, such as pages visited, session duration, Device type, and other diagnostic information.
2.1. Personal Data
While using the Application, you may voluntarily provide Personal Data, including (but not limited to):
• Full name
• Email address
• Contact phone number
• Country of residence
• Mailing and/or legal address
If you refuse to provide certain Personal Data, Sparklo may be unable to grant access to certain features or functionalities of the Application (including registration and bonuses).
Sparklo reserves the right to request additional information to verify your identity or ensure compliance with Vietnamese regulations.
2.2. Usage Data
We may collect Usage Data automatically when you use the Application. This can include:
• The type/model of your Device
• Device operating system
• Browser type (if accessing any web-based sections)
• Date, time, and duration of Application usage
• Unique device identifiers and other diagnostic information
Sparklo may use this Usage Data to maintain and improve the Application’s functionality and protect it from infringements by third parties.
In accordance with Decree No. 13/2023/NĐ-CP, you have the right to:
• Access your Personal Data.
• Correct inaccurate or incomplete Personal Data.
• Withdraw consent to Processing at any time.
• Object to the Processing of your Personal Data.
• Request deletion of your Personal Data under certain conditions.
• Lodge complaints with the Ministry of Public Security (Department of Cybersecurity and Hi-Tech Crime Prevention) if you believe your data protection rights have been infringed.
To exercise these rights, please contact us at:
Email: support@sparklo.com
We may use cookies and similar tracking technologies to collect information about your interactions with the Application or website in order to:
• Streamline User experience and functionality.
• Analyze usage patterns.
• Provide personalized content or offers.
You can manage cookie preferences at any time in your Device or browser settings. If you disable cookies, somefeatures of the Application may not function correctly.
Sparklo may use your Personal Data for the following purposes:
1. To Provide and Maintain the Application:
Monitor, analyze, and improve our services.
2. To Communicate with You:
Provide updates, respond to inquiries, notify you of promotions, events, or policy changes, unless you opt out.
3. To Manage Your Requests:
Process and respond to your specific requests related to the Application’s features.
4. For Business Transfers:
Evaluate or complete mergers, restructuring, or acquisitions, during which User Personal Data may be transferred to the new entity, subject to confidentiality and legal requirements.
5. With Affiliates: SPARKLO has the right to Share your Personal Data with SPARKLO affiliates, in which case SPARKLO will require those affiliates to honour this Privacy Policy. Affiliates include SPARKLO’s parent company and any other subsidiaries, joint venture partners or other companies that SPARKLO controls or are under common control with SPARKLO.
6. With business partners: SPARKLO has the right to Share your Personal Data with business partners to offer you certain products, services, or promotions.
7. With your Consent: SPARKLO has the right to disclose your Personal Data for any other purpose only with your advance consent, except in situations under request from government authorities and under the court resolutions where we are not eligible to notify you.
8. Compliance and Legal Obligations:
Fulfill legal requirements, respond to governmental or regulatory requests, and safeguard Sparklo’s legal interests.
9. Other Purposes:
Use data for analytics, identifying usage trends, evaluating our marketing and promotional campaigns, and improving overall user experience.
Sparklo will retain your Personal Data only for as long as is necessary to:
• Fulfill the purposes outlined in this Policy.
• Comply with legal obligations.
• Resolve disputes.
• Enforce policies and legal agreements.
We store Personal Data in a secure PostgreSQL database environment or equivalent secure storage.
1. Transfer Requirements
• As Sparklo operates internationally, your Personal Data may be transferred to servers or third parties in different jurisdictions.
• We will ensure adequate protection standards are met, including Data Transfer Impact Assessments (DTIA) where required by Vietnamese law.
2. Opt-Out
• You have the right to be informed of any cross-border data transfer and may opt out if you do not consent, subject to legal and contractual constraints.
In the event of a data breach involving your Personal Data, Sparklo will:
• Notify the Ministry of Public Security within 72 hours after identifying the breach.
• Inform affected users promptly about the risks and recommended preventive measures.
Sparklo will:
• Send marketing messages only with your explicit consent.
• Label all advertising messages with [QC] or [AD] in line with local rules.
• Provide a simple mechanism to opt out of receiving further marketing communications.
• Refrain from sending advertising to individuals listed on Vietnam’s Do Not Call registry.
Our Application is not intended for anyone under 18 years of age. Sparklo does not knowingly collect Personal Data from children under 18. If you are a parent or guardian who becomes aware that your child has provided Sparklo with Personal Data, please contact us immediately. If we discover we have inadvertently gathered such data without verified parental consent, we will promptly delete it.
Sparklo’s Application is not intended for individuals under 18 years of age. We do not knowingly collect personal data from minors. If we discover that a minor has provided us with Personal Data without verified parental/guardian consent, we will promptly delete such data.
We implement robust physical, technical, and administrative measures to safeguard your
Personal Data from unauthorized access, disclosure, alteration, or destruction, including:
• Encryption of data at rest or in transit.
• Access controls and authentication protocols.
• Regular security audits and vulnerability assessments.
Despite these measures, no security system is impenetrable. Sparklo is not liable for unauthorized access or disclosures arising from technology failures, malicious attacks, or user negligence.
Sparklo may disclose Personal Data in good faith if necessary to:
• Comply with legal obligations or lawful requests by authorities.
• Protect Sparklo’s rights, assets, or operations.
• Prevent or investigate possible wrongdoing in connection with the Service.
• Enforce Sparklo’s legal agreements or policies.
If Sparklo undergoes a merger, acquisition, or asset sale, your Personal Data may be transferred to the new ownership entity.
Sparklo may update this Privacy Policy periodically. We are not obligated to provide direct notice of changes but will post the updated version, reflecting the “Last Updated” date at the top or bottom of this document. Your continued use of the Application after any modifications constitute your acknowledgment of the updated terms.
For any questions, comments, or concerns regarding this Privacy Policy or the Processing of your Personal Data, please contact us at:
• Sparklo Vietnam Office:
L633OT10, 33rd floor, L6 Building, 02 Ton Duc Thang, Ben Nghe Ward, District 1,
Ho Chi Minh City, Vietnam
• Email: support@sparklo.com
Last Updated: 24 March 2025
Sparklo, Organizer of the Bonus Program – SPARKLO DISTRIBUTION COMPANY LIMITED, registered and operating under the laws of Vietnam, having its registered address at: L633OT10, 33rd floor, L6 Building, 02 Ton Duc Thang, Ben Nghe Ward, District 1, Ho Chi Minh City, Vietnam.
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 Vietnam 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 Vietnam 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 Vietnam 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 Vietnamese 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.