SparkJam Co., Limited

Truthy Privacy Policy

Last updated July 1, 2026

This Privacy Policy describes how SparkJam Co., Limited (“Truthy”, “Company”, “we”, “us”, or “our”) collects, uses, shares, and protects information in connection with your use of the Truthy mobile application, website, and related services (collectively, the “Services”).

By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Policy, you must not use the Services.

1. Scope of This Policy

This Policy applies to your use of:

• The Truthy mobile application
• Any related websites operated by us
• Any services, features, or content provided through Truthy

It also applies when you interact with us through customer support, marketing communications, or participation in promotional activities.

2. Information We Collect

We collect information necessary to provide and improve the Services.

2.1 Information You Provide

When using Truthy, you may voluntarily provide:

• Name or partial name inputs
• Photos you choose to upload
• Social media links or profile references
• Location information (city, state, or country level)
• Additional contextual details you submit

This information is used solely for generating results and improving matching relevance within the Services.

2.2 Automatically Collected Information

When you use the Services, we automatically collect technical and usage-related information, including:

• Device type, model, and operating system
• IP address
• App interaction logs and usage patterns
• Crash reports and diagnostic data
• Language settings and system configuration

This information is used to ensure stability, security, and performance of the Services.

2.3 Subscription Information

If you purchase a subscription, we may collect:

• Subscription plan type
• Purchase status and renewal status
• Billing cycle information

All payments are processed by Apple. We do not collect or store payment card information.

3. How We Use Information

We use collected information to:

• Operate and provide core functionality of the Services
• Generate AI-based matching and information discovery results
• Build candidate results and structured reports
• Improve system accuracy, performance, and reliability
• Detect, prevent, and respond to fraud or misuse
• Provide customer support

We may also use aggregated or anonymized data for analytics and product improvement.

4. Photo Processing

When you upload a photo, it is processed through automated systems that analyze visual characteristics and return related publicly available results.

Photos are used only for processing the request and are not used for unrelated purposes such as advertising or profiling.

We do not:

• Store facial biometric templates
• Use photos to identify or verify identity
• Link uploaded photos to personal identity profiles
• Retain images after processing beyond operational necessity

Photo processing is transient and limited to service execution.

5. Public Data Sources

Truthy generates results using publicly available information from open web sources and publicly accessible digital platforms.

We do not access private accounts, private databases, or restricted content.

All results are informational and derived from publicly available data, which may be incomplete, outdated, or inaccurate.

6. Sharing of Information

We do not sell personal information.

We may share limited data with third-party service providers that support our operations, including:

• Cloud infrastructure providers
• Analytics and monitoring services
• Customer support systems
• Payment processing via Apple

We may also share information when required by law, regulation, or legal process.

In case of business restructuring, merger, or acquisition, user data may be transferred as part of the transaction under the same protections described in this Policy.

7. Data Retention

We retain information only for as long as necessary to provide the Services and fulfill operational or legal obligations.

When data is no longer required, it is securely deleted or anonymized.

Some limited technical logs may be retained temporarily for system stability and security purposes.

8. Data Security

We implement reasonable technical and organizational measures to protect information, including encryption, access control, and monitoring systems.

However, no system is completely secure, and we cannot guarantee absolute security of data transmitted or stored.

9. Your Rights

Depending on your jurisdiction, you may have rights to:

• Access your personal data
• Request correction or deletion
• Restrict or object to processing
• Withdraw consent where applicable
• Request data portability

You may exercise these rights by contacting us using the details provided below.

10. Children’s Privacy

The Services are intended for users aged 17 and above and are not directed to children.

We do not knowingly collect personal data from minors. If we become aware that such data has been collected, we will take steps to delete it.

Users are prohibited from uploading photos of minors.

11. International Data Transfers

Your information may be processed in countries outside your country of residence.

By using the Services, you consent to such transfers, subject to applicable data protection laws.

12. Prohibited Use of Data

You agree not to use the Services for:

• Surveillance or monitoring of individuals
• Harassment, stalking, or discrimination
• Fraud or identity misuse
• Employment, credit, or background evaluation decisions
• Any unlawful or harmful activity

We may restrict or terminate access if misuse is detected.

13. AI-Based Processing Disclaimer

Truthy uses automated systems and AI to generate results based on publicly available information.

As a result:

• Outputs may be incomplete or inaccurate
• Information is not verified or guaranteed
• Users are responsible for independent verification of results

14. Third-Party Services

Certain features rely on third-party service providers.

These providers process data under their own privacy policies. We are not responsible for their practices or outputs.

15. Legal Basis for Processing (GDPR)

Where applicable, we process personal data based on:

• User consent
• Contractual necessity
• Legitimate interests in operating and improving the Services
• Legal obligations

16. Updates to This Policy

We may update this Privacy Policy from time to time.

Updates will be posted within the application or website. Continued use of the Services constitutes acceptance of the updated Policy.

17. Contact Information

If you have questions about this Privacy Policy, please contact:

SparkJam Co., Limited
Email: customer-service@spark-jam.top

18. Apple End User License Agreement

Your use of the Services is also subject to Apple’s EULA:

https://www.apple.com/legal/internet-services/itunes/dev/stdeula