Privacy Policy
Last updated: May 10, 2026 — Sparkle5, LLC
This Privacy Policy describes how Sparkle5, LLC (“Luvu”, “we”, “us”, or “our”) collects, uses, stores, and shares personal information when you use the Luvu platform at https://beta.fruitydate.com and our mobile applications (“Service”). Please read this policy carefully. If you have questions, contact us at support@sparkle5.com.
1. Who We Are / Data Controller
The data controller responsible for your personal data is:
Sparkle5, LLC30 N. Gould Street #10391, Sheridan, WY 82801, USA
E-mail: support@sparkle5.com
2. Data We Collect and Why
We only collect personal data that is necessary for the purposes described below. Where we rely on your consent as the legal basis, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
| Data category | Examples | Purpose | Legal basis (GDPR) |
|---|---|---|---|
| Account data | Email, display name, date of birth, gender | Account creation and authentication | Contract (Art. 6(1)(b)) |
| Profile data | Photos, bio, interests, location (city/region) | Providing matching and discovery features | Contract (Art. 6(1)(b)); Consent for special-category data (Art. 9(2)(a)) |
| Location data | Approximate GPS coordinates | Showing nearby members | Consent (Art. 6(1)(a)) |
| Payment data | Billing address, last 4 digits, transaction ID (full card data held by Stripe) | Processing subscriptions and purchases | Contract (Art. 6(1)(b)); Legal obligation (Art. 6(1)(c)) |
| Usage and device data | IP address, device type, OS version, session logs | Security, fraud prevention, service improvement | Legitimate interests (Art. 6(1)(f)) |
| Communications | Support emails, in-app messages | Customer support and dispute resolution | Contract / Legitimate interests (Art. 6(1)(b)(f)) |
Special-category data. A dating platform inherently involves information about your sexual orientation and preferences. We process this data only on the basis of your explicit consent (GDPR Art. 9(2)(a)), which you give when you voluntarily create a profile indicating your preferences. You may withdraw consent at any time by deleting your account.
3. How We Use Your Data
- To provide, personalise, and improve the Service.
- To verify your identity and enforce our Terms.
- To process payments and manage subscriptions.
- To send service-related communications (account verification, security alerts, subscription receipts). We will only send marketing emails with your separate opt-in consent.
- To detect and prevent fraud, abuse, and illegal activity.
- To comply with our legal obligations.
4. Cookies
We use cookies and similar technologies as described in our Cookie Policy.
5. Data Sharing
We do not sell your personal data. We share it only in the following circumstances:
- Service providers. We use carefully selected sub-processors (e.g., Stripe for payments, cloud hosting providers) who process data on our behalf under contractual data protection obligations.
- Legal requirements. We may disclose data to law enforcement, courts, or regulators when required by applicable law, a court order, or to protect our rights and the safety of our users.
- Business transfers. In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquirer, subject to the same level of data protection. We will notify you in advance.
6. Data Location and International Transfers
Server location. Your personal data is stored and processed on servers located within the European Union. We have specifically chosen EU-based infrastructure to keep your data within the EEA and minimise international transfers.
Sub-processors outside the EEA. We use a small number of third-party service providers whose infrastructure may be located outside the EEA:
- Stripe, Inc. (payment processing) — US-based, EU operations covered by Standard Contractual Clauses (SCCs). Privacy policy: stripe.com/privacy.
- SMTP2GO (transactional email, EU mail server) — email is routed through EU servers; subject to SMTP2GO’s data processing agreement.
Company headquarters. Sparkle5, LLC is incorporated in Wyoming, USA. As the data controller, our personnel may access EU-stored data for administrative and support purposes. Where such access constitutes a transfer of personal data to a third country, we rely on the EU Standard Contractual Clauses (Commission Decision 2021/914) as the appropriate safeguard. You may request a copy of the applicable SCCs by contacting us at support@sparkle5.com.
7. Data Retention
| Data type | Retention period |
|---|---|
| Account and profile data | Until account deletion, then erased within 30 days (except where legal hold applies) |
| Transaction records | 7 years for tax and accounting compliance |
| Server / access logs | Up to 12 months |
| Support communications | 3 years from last interaction |
| Blocked/banned account identifiers | Up to 5 years to prevent re-registration |
8. Your Rights
Depending on your jurisdiction, you may have the following rights. To exercise any of these rights, contact us at support@sparkle5.com. We will respond within 30 days (GDPR: within 1 calendar month).
- Access. Receive a copy of the personal data we hold about you.
- Rectification. Ask us to correct inaccurate or incomplete data.
- Erasure (“right to be forgotten”). Ask us to delete your personal data, subject to legal retention obligations.
- Restriction. Ask us to restrict processing of your data in certain circumstances.
- Data portability. Receive your data in a structured, machine-readable format.
- Objection. Object to processing based on legitimate interests or for direct marketing purposes.
- Withdrawal of consent. Withdraw any previously given consent at any time without affecting prior processing.
- Lodge a complaint. If you are in the EU/EEA, you have the right to lodge a complaint with your local data protection authority (e.g., the supervisory authority of your EU member state). A list of authorities is available at edpb.europa.eu.
9. Children’s Privacy
The Service is strictly for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we become aware that a minor has created an account, we will delete the account and associated data promptly. If you believe a minor is using the Service, please report it to support@sparkle5.com.
10. Security
We implement industry-standard technical and organisational measures to protect your personal data, including TLS encryption in transit, hashed passwords, role-based access controls, and regular security assessments. In the event of a data breach that poses a high risk to your rights, we will notify you and the relevant supervisory authority as required by law.
11. Automated Decision-Making
Our matching algorithm suggests profiles based on your stated preferences and location. This is not fully automated decision-making with legal or similarly significant effects; human interaction is central to the Service. You may contact us if you have concerns about how recommendations are generated.
12. Changes to This Policy
We may update this Privacy Policy periodically. Material changes will be communicated by email or prominent in-Service notice at least 30 days before they take effect. The “Last updated” date at the top of this page indicates when the most recent revision was made.
13. Contact and Data Protection Officer
For all privacy-related enquiries, requests to exercise your rights, or to reach our Data Protection Officer, contact:
Sparkle5, LLC — Privacy30 N. Gould Street #10391, Sheridan, WY 82801, USA
E-mail: support@sparkle5.com