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Legal and privacy

Privacy Policy

This policy applies to the Sparkdemy website, enquiry forms, and the optional Facebook Messenger and Instagram messaging integrations enabled by our clients.

Last updated: 20 October 2026

01

Data we collect

  • Enquiry data: your name, company, role, industry, company size, email, phone or WhatsApp number, and the message you submit.
  • Meta connection data: Facebook Page or Instagram professional account IDs, names, usernames, permissions, connection status and access tokens.
  • Customer-service conversation data: customer IDs, message content, attachments or related links, timestamps, processing status, drafts and sent replies.
  • Technical data: necessary security logs, request times, IP address, browser information, and website analytics or Meta Pixel event data.
  • Name card data: the name, company, job title, email, phone and website on a name card you gave us at an event, and which event we met at.
  • Email activity: whether an email we sent you was opened, which of its links were clicked, and unsubscribe requests.

02

Where data comes from

  • Information you submit directly through an enquiry form or service configuration.
  • Facebook Pages, Instagram professional accounts and Meta webhooks that you authorise us to connect.
  • People who message a connected business account.

03

How we use data

  • To answer enquiries, provide the service, authenticate authorised business accounts and handle support requests.
  • To receive and route customer messages and generate drafts or replies from client-approved knowledge and rules.
  • To enforce human approval, messaging windows, escalation rules and duplicate-reply protection.
  • To secure accounts and systems and investigate faults, misuse or unauthorised access.
  • To understand website and service usage. We do not sell personal data.

04

Disclosures and processors

  • Meta Platforms processes Facebook, Messenger, Instagram, login, permissions and message delivery.
  • Cloudflare and our cloud-hosting providers process website, network, security, backup and service-operation data.
  • Resend sends email on our behalf and tells us whether it was delivered or bounced.
  • The AI model provider selected for a client processes the minimum conversation content needed to generate a customer-service draft or reply.
  • Authorised Sparkdemy personnel and administrators of the relevant client company access data only as needed for operations, support, approval or compliance.

05

Retention and deletion

  • We retain data only as long as needed for its collection purpose, service delivery, disputes, legal obligations or security.
  • Disconnecting a Meta account deletes its active access token and live connection record and stops new events from being collected.
  • Conversation events, drafts and operational records are cleared according to operational need; verified full-deletion requests are normally completed within 30 days.
  • Copies in backups are removed through the normal backup rotation, except for limited records required by law or a security investigation.
  • Deleting Sparkdemy data does not automatically delete the original messages held by Meta, Facebook, Messenger or Instagram.

06

Security

  • Meta access tokens are encrypted at rest and network traffic uses HTTPS.
  • Webhooks are checked against Meta signatures, and each client uses separate signed authentication with the central service.
  • Access is limited by operational role, and each client's data is separated from other clients.
  • No system is risk-free. If an incident occurs, we will contain and investigate it and provide notices where applicable.

07

Website browsing records

  • When you browse sparkdemy.ai we record which pages you view, when, which site sent you, and the source tags on ad links. Records are tied only to a random browser ID cookie, kept for 90 days.
  • We do not record search terms or other parameters in the address, page content or your full IP address.
  • If you send our enquiry form or click a link in one of our emails, your earlier browsing records are linked to your contact details so we understand what you are interested in.
  • Records we cannot link to anyone are deleted after 30 days, linked records after 90 days. Browsers with Global Privacy Control switched on are never recorded.
  • You can stop recording and clear this browser's records at any time with the button below. This does not change email subscriptions; to unsubscribe, use the link at the bottom of any email.

08

Your rights and choices

  • You can disconnect Facebook or Instagram to stop new processing.
  • You can ask whether we hold your personal data and request access, correction or deletion.
  • We verify authority over the relevant Page, account or data before acting, to prevent unauthorised deletion.
  • You can also revoke Sparkdemy's permissions in your Facebook or Instagram settings.
  • You can unsubscribe with the link at the bottom of any email we send, and you will not get that kind of email again.

09

International processing, children and updates

  • Service providers may process data outside Hong Kong. We require them to process it only for the service purpose and with appropriate safeguards.
  • The service is for business users and is not directed to anyone under 18.
  • If this policy changes materially, we will update the date on this page and notify connected clients where appropriate.