SPARKS Biometric Information Privacy Policy
Introduction
SPARKS is an application (the "Application") published by InMobi, its affiliate(s) and/or its group companies (collectively referred to as "InMobi," "we", "us" or "our"). SPARKS is a mobile rewards-and-entertainment application that allows users to play games and engage with advertising content, including video advertisements, in exchange for in-app rewards. Rewards accumulated through such engagement may be redeemed by eligible users for cash or cash-equivalent value, subject to the applicable terms and conditions governing redemption. Our affiliate PinSight Media Inc. is the primary operator of the Application and has taken the position of a controller for the personal information we process, unless otherwise stated. During the rewards redemption process, we and our trusted service provider collect biometric data. This Biometric Information Privacy Policy ("Policy") describes how SPARKS collects, uses, discloses, processes, stores, and destroys biometric data. When used in this Policy, "biometric data" means "biometric data," "biometric identifiers," "biometric information," and other similar terms, as such terms are defined under applicable laws.
What Biometric Data We Collect
During the rewards redemption flow, SPARKS through our trusted third-party service provider, captures a photograph/facial scan of the user. From this image, the following biometric data may be derived:
- Face geometry / facial scan: Mathematical measurements and spatial relationships of facial features derived from your photograph.
- Liveness detection signals: Indicators confirming that the captured image represents a live, present individual rather than a static photo or digital reproduction.
- Biometric template: A numeric representation of facial geometry points on the user's face.
Purpose of Collection of Biometric Data
SPARKS and our service provider collect biometric data for the following purposes:
Purpose | Description | Legal Basis |
|---|---|---|
Liveness Verification | To confirm that the individual initiating a cash redemption is a real, live person and not a bot or a static image, preventing fraudulent redemptions. | contractual necessity; legitimate interest; consent |
Fraud Prevention | To prevent fraud | contractual necessity; legitimate interest; consent |
Duplicate User/ Account Detection | To check whether the user's biometric template matches any existing account in our database, preventing a single individual from creating multiple accounts to abuse the rewards program. | contractual necessity; legitimate interest; consent |
How and When we Collect Biometric Data
Biometric data is collected during your first-ever rewards redemption within the SPARKS application. When you initiate your first cash redemption via payment service provider, SPARKS presents a clear and prominent biometric consent notice and requests your explicit opt-in consent before any biometric data collection occurs. Upon providing consent, the SPARKS application activates your device camera through the service provider SDK to capture a photograph and facial scan. Service provider processes the captured image to perform liveness detection and to generate a biometric data used solely for the purposes in this Policy. The result of this process comprises a liveness pass or fail determination and a match or no-match outcome for duplicate account detection are returned to Sparks. The personal data collected pursuant to this Policy is never disclosed to any third-party. By agreeing to this Policy or otherwise proceeding with your first cash redemption, you acknowledge that you have read, understand, and explicitly consent to the collection, use, processing, and storage of your biometric data as described in this Policy.
Retention of Biometric Data
Data Type | Retention Period |
|---|---|
Biometric data | 13 Months |
Prohibition on Sale or Profit from Biometric Data
SPARKS will never sell, lease, trade, or otherwise profit from the disclosure of your biometric data. Our service provider's use of your biometric data is solely for service provision to InMobi under a written data processing agreement, consistent with the purposes stated in Section 3.
Changes to this Policy
SPARKS may update this Policy from time to time to reflect changes in law, technology, or our practices. If we do, we'll let you know by posting the updated Privacy Policy on our application, and we may also send other communications.
Contact Us
For questions, concerns, please contact us at: support@sparks.ai