OnlySpark. Privacy policy

Before completing the Client's registration, you should tick the following box:

By clicking the “Accept” button, you confirm that you have acknowledged with and accept OnlySpark’s Terms of Use and Privacy Policy and give explicit consent to OnlySpark for the processing of your Personal Data, including the processing of your sexual orientation, as provided in this Privacy Policy.

OnlySpark uses cookies to analyze traffic, personalize content and ads and to provide social media features. You consent to provisions of our Privacy policy regarding the usage of cookies if you continue to use the App.

This Privacy Policy was last updated on 18 January 2024.

1. General information

1.1. References in this Privacy Policy to “OnlySpark”, “Service”, “Application”, “App” relate to the app, available at www.onlyspark.net, operated by Red Panda APP LLC, a limited liability company registered in the USA under EIN 92-1192475, having its address 9165 OTIS AVE STE 238 INDIANAPOLIS, IN 46216.

1.2. OnlySpark is the data controller regarding the Personal Data processed within the framework of this Privacy Policy.

1.3. An individual can only become a Client of OnlySpark and use its features if he/she is aged 18 or over or the age of majority in the country in which he/she resides if that happens to be greater than 18. OnlySpark does not knowingly collect any information (including Personal Data) or market its services to minors or users under the age of majority. OnlySpark will terminate any Client’s account upon discovery that respective account was created with violation of the provisions of this paragraph.

OnlySpark will terminate any Client’s account upon discovery that respective account was created with violation of the provisions of this paragraph.

1.4. OnlySpark is committed to protecting and respecting the privacy of its Clients and ensures their security when using the Service. This Privacy Policy is intended to help the Client to understand what data and for which purposes Service collects, how collected data is processed and protected.

1.5. OnlySpark reserves the right to amend this Privacy Policy; therefore it is recommended that the Client of the Service checks Privacy Policy on a regular basis. The service will send a notice or an email regarding such changes to the Client.

1.6. All the changes to this Privacy Policy are effective as of the “Last updated” date. The Client who continues to use the Service after the Last updated date it deemed to accept the changes made to it.

2. Contact us

2.1. OnlySpark has designated a Data Protection Officer (DPO) who could be reached by emailing to [email protected] or by post at the address provided above.

2.2. By registering with the Service, the Client consents to the processing of his/her Personal Data by the Service in accordance with the provisions set below.

2.3. By registering with the Service, the Client gives consent to OnlySpark to anonymize his/her Personal Data for the purposes of further use in anonymized form in order to improve the performance of the Service.

3. Collected data

3.1. When using the Services, the Client agrees to the processing of the following Personal Data:

3.1.1. Personal Data that the Client provides to the Service:

When creating an account, the Client provides the Service with at least his/her login credentials (including unique username and password combination for the Client’s account), as well as basic details necessary for the Service to work, such as the Client’s name, gender and age.
When completing his/her profile, the Client could provide additional information, such as details on his/her physical characteristics (including height, weight, body type and sexual preferences), background (including education, financial situation, housing situation and ownership of a vehicle), personality (including purpose of acquaintance, sociability and attitude towards children), lifestyle (including attitude towards alcohol and smoking), date of birth, interests and other details about the Client, as well as content, such as pictures and photos.

To add certain content, such as pictures and photos, the Client may need to separately allow the Service to access his/her camera or device’s photo album.

Some of the information provided by the Client may be referred to as belonging to Special categories of Personal Data, pursuant to legislation of certain jurisdictions within the USA, such as the Client’s racial or ethnic origin, sexual orientation, political opinions or religious or philosophical beliefs. By placing such information in his/her Client’s account, the Client consents to the processing of the information by the Service.

When contacting Support Service, available through a separate chat in the App: the information that the Client provides during the interaction. OnlySpark reserves the right to monitor or record interactions between the Client and the Support Service for training purposes and to ensure high quality of service.
When participation in Client verification procedures: Client’s Personal Data, as requested by the Service for the Client identification purposes.
When participating in surveys or focus groups: insights and evaluation of OnlySpark’s services, responses to the questions from the Service.
When communicating with other Clients through a chat in the App: the contents of the relevant chat (including cases when such contents include Personal Data);

3.1.2. Personal Data collected through the use of the Service:

When the Client is using OnlySpark, the Service may collect data regarding the device(s) the Client uses to access the Service (such as his/her IP address, device identifier (including unique advertising device identifiers, for example Google Advertiser ID and IDFA), technical and statistical data (including data about the Internet connection, cellular service provider and application usage data) and location data (upon a separate consent from the Client).

3.1.3. Personal Data collected from third parties:

The Client can connect his/her Client’s account to a social network (including but not limited to Facebook, Odnoklassniki, Vkontakte) by way of registering through the corresponding social network. After connecting his/her account in a social network, the Client would be able to add the personal information from his/her profile in corresponding social network to his/her profile in the Service. The following information could be received by the Client from the social network: the Client’s name, ID within the respective social network, photo, email address, IP address, phone number, age, gender, preferred language, country, information about the Client’s device, location, list of friends in the social network, data on the use of other networks (as contained in the respective social network). By connecting his/her Client’s account with OnlySpark to a social network, the Client gives an explicit consent to the processing of the Client’s Personal Data contained in his/her account in the respective social network.

3.2. By providing Personal Data to OnlySpark, the Client warrants that such data is true, accurate and up to date.

4. Use of User’s/Client’s personal data

4.1. OnlySpark collects, process and uses Personal Data of Clients of the Service based on the following grounds:

when such processing is performed in order to fulfil the contract between the Service and the Client;
based on legitimate interest of the Service;
upon explicit prior consent from the Client.

4.2. OnlySpark collects and processes Personal Data of the Service’s Clients in order to maintain the functionality of the Service and to ensure compliance with legal and business-related requirements.

The User’s/Client’s Personal Data is processed for the following purposes:

4.2.1. When processing of personal data is related to fulfilment of the contract between the Service and the Client:

to set up, operate and manage the Client’s account and, if necessary, to contact the respective Client through the means provided by the Client upon registration, in connection with the operation and management of the Client’s account;
to analyze the Client’s profile, activity on the Service, preferences and current location in order to recommend the Client’s profile to the other Client’s of the Service and to recommend the other Clients’ profiles to the Client;
to proceed and respond to the requests and enquiries received from the Client;
for administrative purposes, such as password reminders, service messages (including but not limited to the App’s maintenance messages, updates to the Service’s Privacy Policy and Terms of use);

4.3.2. Under legitimate interests of the Service:

to connect the Client’s account to a social network (including but not limited to Facebook, Odnoklassniki, Vkontakte);
for Client verification purposes, conducted in relation to an ongoing or alleged misbehavior, performed by the Client of the Service, in order to block accounts as part of the Services anti-spam procedures, to investigate possible fraud;
to evaluate the effectiveness of marketing and to perform market research and training.

4.3.3. Under an explicit consent from the Client:

to facilitate networking opportunities of the Client with the Service by way of allowing him/her to add additional information to the Client’s account (including information on the Client’s sexual orientation);
to process Personal Data from the Client’s account in a third party social network, connected to the Client’s account with OnlySpark;
to serve the Client with targeted in-App advertisements;
for remarketing purposes, allowing the Service to identify the Client who has previously visited the App and optimize advertising information according to the Client’s preferences. This feature is used by the Service through third-party services such as Google Advertising, myTarget and Facebook;
to prepare statistics regarding the use of the Services by the Client;
to identify possible technical malfunctions in the work of the Service, to assist internal research and development and to make improvements to the App.

5. Duration of the Сlient’s data retention

5.1. OnlySpark retains the Client’s Personal Data for the period of time necessary to carry out relevant activities, specified in section 4 of this Privacy Policy and as permitted by applicable law.

Personal Data, that the Client has communicated to the Service upon registration and subsequently through the use of the Service, will be retained by the Service as long as the Client remains the Client of the Service.

5.2. To protect the safety and security of the Clients of the Service, OnlySpark implements a safety retention window of 30 days following a Client’s account deletion.

5.3. OnlySpark reserves the right to store the Client’s Personal Data for a longer period of time than provided in paragraph 5.1., when it is performed in order to fulfill the legal obligations of the Service (including law enforcement requests, dispute resolution), ensure compliance with applicable law or when the relevant Personal Data is stored on the basis of the Service’s legitimate interests (including security reasons, prevention of fraud).

6. Disclosure of Personal Data

6.1. OnlySpark may share the Client’s Personal Data with third parties in the following cases:

Other Clients of OnlySpark:

The Client shares information with other Clients of OnlySpark by way of voluntarily disclosing information on the Service (including but not limited to information in his/her Client’s profile).

It is in the Client’s discretion to choose the information to be disclosed with the Service and OnlySpark rescinds from responsibility for the other Clients of the Service regarding the way they might use such information, disclosed by the Client.

Third-party advertising services. OnlySpark uses the following services (list of services is provided alongside with privacy policies of the relevant services):

Facebook - https://www.facebook.com/policy.php

Google Advertising / Play Market - https://policies.google.com/privacy

AppLovin - https://www.applovin.com/privacy/

Appmetrica - https://metrica.yandex.com/about/info/privacy-policy - users from countries other than the Russian Federation

MyTarget - https://target.my.com/optout/

AppsFlyer - https://www.appsflyer.com/services-privacy-policy

Twitter, Inc. - https://www.mopub.com/en/legal/privacy

Cloud services providers:

Amazon (Amazon’s privacy policy could be found on https://aws.amazon.com/privacy/)

Providing Client’s data by law:

OnlySpark may disclose Client’s Personal Data when such disclosure is required by law and is reasonably necessary:

in order to establish, exercise, defend or enforce legal rights of the Service;
to comply with a legal process such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements;
to assist in the prevention or detection of crime (subject in each case to applicable law);
to protect the safety or vital interests of an individual.

6.2. OnlySpark ensures appropriate contractual control over third parties assisting the Service in processing the Client’s Personal Data, securing that rights of Clients of the Service are upheld, their Personal Data is secure, appropriate security and privacy arrangements are in place.

6.3. In the event of change in the corporate structure of the Service, resulting in transfer of the Client’s Personal Data to a third party, all the Clients of the Service would be notified of such changes via email and through a notice posted on the Service’s website. Respective notice would explain the identity of the new data controller and the Client’s options regarding disposal of their Personal Data.

7. Client’s rights

7.1. Every Client of the Service is a data subject and thus has ultimate rights over his/her Personal Data.

7.2. The rights of data subject over his/her Personal Data are as follows:

Client’s right	Description
Access	A right to know whether Personal Data concerning the Client is being processed by the Service, right to get information regarding processing of Personal data, right to request a copy of Personal Data being processed.
Rectification	A right to ask the Service to correct Client’s Personal Data in a situation when such data available to the Service or disclosed to third parties is inaccurate or incomplete.
Erasure	A right to request ‘to be forgotten’, meaning deletion of the Client’s Personal Data from the database of the Service so that the Service is not able to continue processing and storing of such data, with exceptions, provided by applicable law.
Restrict processing	Right to introduce the restriction regime on the processing of the Client’s Personal Data, so that in each case the data may be processed only upon separate consent from the Client.
Data portability	Right to request for the Personal Data provided to the Service to be given in a machine-readable format so that it could be transferred to another service provider or transfer directly to a third party designated by the Client.
Object	Right to object to processing his/her Personal Data in a case when the corresponding processing is not performed on the basis of the Client’s consent.
Withdraw consent	Right to withdraw consent to processing of his/her Personal Data by OnlySpark and/or third party processors of Personal Data. The Client should note that withdrawal of consent to the processing of his/her will result in the deletion of his/her profile with the Service and the termination of his/her use of the Service.

7.3. The abovementioned rights are not absolute. In order to exercise some of the rights, the Client should meet certain conditions and requirements, specified by the law.

7.4. For more information regarding his/her rights over Personal Data, the Client/User of the Service should contact [email protected]. In order to exercise his/her rights, the Client should submit a request to [email protected].

7.5 The Client/User of the Service should also be acknowledged of his/her right to complain to a data protection regulator in his/her jurisdiction.

8. Protection measures

8.1. When using the App, Client’s personal data is transferred by the Service as follows:

for the Clients, residing in Russian Federation: to the domain www.onlyspark.net, which belongs to OnlySpark;
for the Clients, residing in other countries than Russian Federation: to the Amazon Cloud Services server (more information could be found on this link: https://aws.amazon.com/).

8.2. OnlySpark works hard to protect its Clients from unauthorized access to or alteration, disclosure or destruction of their Personal Data. Yet, as any other technology companies, although OnlySpark takes steps to secure Clients’ information, it could not be promised or guaranteed, that unauthorised access, hacking, data loss, or other breaches will never occur.

OnlySpark reserves the right to suspend the Client’s account without notice if there is a reasonable suspicion of breach of security or unauthorised access to such account. If you believe that your account or information is no longer secure, please notify OnlySpark immediately by sending a message to [email protected].

8.3. The Client should take reasonable steps in order to keep his/her Personal Data (including the account’s password) safe. It is recommended that the Client does not share account’s password with anyone.

9. Cookies

9.1. In order to guarantee an optimal level of usability and performance and to ensure relevance of promoted services, OnlySpark uses cookies and similar technologies in order to track the interaction of Clients with the App. This section explains the different types of cookies that may be set when the Client uses the App, helping to understand and manage them as he/she wishes.

9.2. A cookie is a small file that is stored locally at the Client’s technical device as soon as the App is being visited. Cookies function by saving particular sets of data, such as, for example, the Client’s language selection. Should the Client open the App again later, a cookie will transmit this data back to the App. The App’s cookies don't store personal information like the Client’s name or address.

9.3. Types of Cookies

OnlySpark uses different types of cookies:

Session cookies only last only while the Client is visiting the App and help OnlySpark to learn more about Client’s use of the App during a single session and to help the Client to use the App more efficiently.
Persistent cookies have a longer lifespan and aren't automatically deleted when the Client closes the App. These cookies are primarily used to help the Client to sign-in into the App again quickly, for security and analytical purposes. OnlySpark does not use any information whilst the Client is logged off the App.
OnlySpark uses first-party cookies that is when the cookies are placed on the Client’s device directly by the Service. For example, first-party cookies are used to adapt the App to the language preferences and analyze user experience of the Client.
Third-party cookies are placed on the Client’s device by OnlySpark’s partners and service providers.

9.4. The Client can at any time change or withdraw his/her consent to the use of cookies in the App.

There are several cookie management options available to the Client. The Client should note that changes that he/she makes regarding cookie preferences may limit the features offered by OnlySpark.

In some cases, the Client may find himself/herself unable to use all or part of the App.

The Client could adjust use of cookies on his/her device by way of changing his/her browser and device settings (device identifiers on mobile phone) in order to block cookies on the device (for information on cookie management on an android device see: https://html.com/resources/cookies-ultimate-guide/#Controlling_Cookies_on_an_Android_Device,

on an IOS device see: https://support.apple.com/en-us/HT201265).

9.5. Below is information about how OnlySpark uses Clients’ cookies in the App:

Necessary cookies

These cookies are strictly necessary to provide the Client OnlySpark’s services.

Authentication cookies

These persistent cookies help the Service to identify the Clients so that the Client could log into the App automatically.

Analytics cookies

These cookies help the Service to understand how the App is being used, and help us customize and improve the Service.

Cookie provider	Link to the provider’s privacy policy
Google analytics	https://marketingplatform.google.com/about/analytics/terms/us/, part 7, Privacy
AppMetrica	https://metrica.yandex.com/about/info/privacy-policy
AppsFlyer	https://www.appsflyer.com/services-privacy-policy

Advertising cookies

These cookies are used to make advertising messages more relevant to the Client. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on the Client’s interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad.

Cookie provider	Link to opt-out /link to the provider’s privacy policy

Google Advertising	https://policies.google.com/privacy www.google.com/settings/ads to opt out from the Google Ads
AppLovin	https://www.applovin.com/privacy/
Appmetrica (only for the Clients from countries other than the Russian Federation	https://metrica.yandex.com/about/info/privacy-policy
MyTarget	https://target.my.com/optout/
Mopub	https://www.mopub.com/legal/privacy/
IronSource	https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
Vungle	https://vungle.com/privacy/
Inmobi	https://www.inmobi.com/privacy-policy/
Tapjoy	https://www.tapjoy.com/legal/advertisers/#privacy-policy
AdColony	https://www.adcolony.com/privacy-policy/

Social networking cookies

These cookies are used to enable the Client to connect the Client’s account to third party social networks.

Cookie provider	Link to the provider’s privacy policy
Facebook	https://www.facebook.com/policy.php
Vkontakte	https://vk.com/privacy
Ok.ru	https://ok.ru/res/privacypolicy.html

9.6. Below is information about how OnlySpark uses Clients’ cookies on the onlyspark.net website:

Necessary

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Name	Provider	Purpose	Expiry	Type
__cfduid	www.onlyspark.net	Used by the content network, Cloudflare, to identify trusted web traffic.	29 days	HTTP Cookie
CookieConsent	www.onlyspark.net	Stores the user's cookie consent state for the current domain.	1 year	HTTP Cookie

10. Cross-border data transfer

10.1. Disclosure of OnlySpark’s Clients’ Personal Data, as provided in section 6 of these Terms of Use sometimes involves cross-border data transfers, for instance to the United States of America, Russian Federation and other jurisdictions. OnlySpark uses standard contract clauses or other suitable safeguard to permit data transfers from the USA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of Client’s Personal Data.