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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, some features 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