Sparkling Privacy Policy
This policy describes how personal information is handled on sparkling-card.org and in the Sparkling app, with specific notes for people in Canada and in Quebec. Last updated: 27 October 2026.
1. Scope and Responsibility
Swarming Labs Ltd, of Intershore Chambers, Road Town, Tortola, British Virgin Islands, operates Sparkling, non-custodial trading software with an AI assistant that people use through Telegram or a browser. Swarming Labs is accountable for the personal information described here. For people in Canada, this policy is written with the Personal Information Protection and Electronic Documents Act (PIPEDA) in mind, as well as Quebec’s Act respecting the protection of personal information in the private sector as amended by Law 25, and the private-sector privacy laws of Alberta and British Columbia where they apply.
2. Personal Information We Handle
| Category | Examples | Source |
|---|---|---|
| Account | Email address, Telegram user ID and username, language and notification settings | You |
| Sign-in | One-time codes, stored only in a form that cannot be read back | You |
| Verification | Name, date of birth, identity document and address, if a check is required | You, through a verification provider |
| Trading | Requests to the agent, quotes, signed transactions, wallet addresses and transaction hashes | You and the app |
| Device and usage | IP address, device and browser type, approximate region, crash reports and feature use | Collected automatically |
| Website | Pages visited, referring site and approximate location on sparkling-card.org | Collected automatically, with consent where required |
| Third parties | Sanctions screening results and data from routing and settlement partners | Service providers |
Public blockchain records, such as addresses and amounts, can be read by anyone and may be analysed for security and compliance.
3. Purposes
Personal information is used only for purposes a reasonable person would consider appropriate in the circumstances:
- to run your account and prepare, route and record the trades you confirm;
- to protect accounts and detect fraud, account takeover and market abuse;
- to answer support requests and tell you about significant changes;
- to understand how the service and this website are used, mostly in aggregated form;
- to comply with the law, including sanctions screening and record-keeping duties.
Personal information is never sold. Promotional messages are sent only if you have agreed to receive them, and every message includes a way to unsubscribe, in line with Canada’s Anti-Spam Legislation.
4. Consent
We rely on your consent, express or implied depending on the sensitivity of the information. Identity documents and other sensitive information are collected only with express consent. You can withdraw consent at any time, subject to legal or contractual limits; if you do, we will explain what that means for the service.
5. Disclosure to Others
We disclose personal information to service providers that host, secure, analyse or support the service, under contracts that require equivalent protection; to wallet, liquidity and settlement partners and trading venues that process the transactions you approve, which apply their own privacy terms; to authorities when the law requires it; and to a successor in a merger or sale, under the same commitments.
6. Processing Outside Canada
Our service providers and partners may store or process information outside Canada, including in the United States and the European Union. Information held abroad may be accessible to courts, law enforcement and national security authorities of those countries. For people in Quebec, we assess the privacy impact before information is communicated outside the province.
7. Retention
| Information | How long we keep it |
|---|---|
| Account details | Until the account closes, plus one year |
| Transaction records | Seven years from the trade date |
| Verification records | Five years from account closure |
| Support messages | 3 years after the last exchange |
| Security logs | 30 days, or up to 90 days during an investigation |
| Website analytics | 14 months |
When information is no longer needed, it is deleted or anonymised.
8. Safeguards and Breaches
Safeguards include encrypted storage and connections, two-step login for staff, access limited to people who need it and regular security testing. If a breach creates a real risk of significant harm, we will notify the affected people and the Office of the Privacy Commissioner of Canada and, for Quebec residents, the Commission d’accès à l’information, as the law requires.
9. Your Rights
You may ask to access the personal information we hold about you, to correct it, and to withdraw consent. People in Quebec may also ask for de-indexing, for information in a structured, commonly used format and for information about automated decisions. We reply within 30 days. Please write from your account email, which lets us verify that the request is yours.
If you are not satisfied with our answer, you can complain to the Office of the Privacy Commissioner of Canada, the Commission d’accès à l’information du Québec or the privacy commissioner of your province.
10. The Agent and Automated Processing
The AI agent prepares trade proposals from your requests, but nothing is sent to a market until you approve it. Automated screening for fraud or sanctions may flag an account; a person reviews any flag before a decision with significant effects, and you may ask for that review and present your view.
11. Minors
Sparkling is meant only for adults who have reached the age of majority in their province or territory. We do not knowingly collect information from minors and delete it if we learn that we have.
12. Updates and Privacy Officer
Material changes to this policy will be announced before they take effect. Our privacy officer is responsible for compliance and can be reached at:
- Privacy officer: [email protected]
- Legal matters: [email protected]
- Everything else: [email protected]
- By post: Swarming Labs Ltd, Intershore Chambers, Road Town, Tortola, British Virgin Islands
Updated: