Privacy Policy

Version 1.0 · Effective Date: 19 July 2026 · Last Updated: 19 July 2026

1. Introduction

Welcome to Spark Rituals.

Your privacy is central to everything we build. Unlike many mobile applications, Spark Rituals has been designed using a privacy-first, local-first architecture, meaning that the personal information and memories you create remain under your control rather than being stored on our servers.

This Privacy Policy explains how Storm Advies B.V., trading as Spark Rituals, handles personal information when you use any Spark Rituals mobile application or related services.

Our current apps include:

Little Lines, a keepsake application that allows parents to preserve memorable things their children say.

Stay Close, an application that helps grandparents and their teenage grandchildren stay connected through small weekly exchanges.

Daily Talk, an application designed to encourage meaningful conversations between parents and children.

Additional applications released under the Spark Rituals brand will also be governed by this Privacy Policy unless a separate policy is expressly provided.

Because Spark Rituals is built differently from most apps, this Privacy Policy also explains an important distinction:

Information may be entered into the application by you.

That does not necessarily mean the information is collected by us.

In most cases, the information you enter never leaves your own Apple device or personal iCloud account. We cannot view it, access it, or use it.

Our goal is simple:

Your family's memories belong to your family—not to us.

This Privacy Policy is intended to comply with applicable privacy and consumer protection laws, including, where applicable:

the EU General Data Protection Regulation ("GDPR");

the UK GDPR (where applicable);

the Dutch General Data Protection Regulation Implementation Act (Uitvoeringswet AVG);

the United States Children's Online Privacy Protection Act ("COPPA"), where applicable;

Apple's App Store Review Guidelines; and

other applicable privacy laws.

2. Who We Are

Spark Rituals is a family of privacy-focused mobile applications developed for parents.

Spark Rituals is a trade name (handelsnaam) of Storm Advies B.V.; it is not a separate legal entity.

The legal operator of the Spark Rituals apps is:

Storm Advies B.V.

Registered with the Netherlands Chamber of Commerce (KVK): 78745128

Registered Office:

Heerlerweg 122

6367 AG Voerendaal

The Netherlands

Email:

legal@sparkrituals.com

Website:

https://sparkrituals.com

Throughout this Privacy Policy:

"Spark Rituals," "we," "our," and "us" refer to Storm Advies B.V.

"you" refers to the parent or other adult using one of our applications.

Although the applications are designed to help parents preserve memories involving their children, the applications are intended to be used by adults. Parents—not children—are the users and account holders.

3. Scope of this Privacy Policy

This Privacy Policy applies to:

all Spark Rituals mobile applications;

our websites that link to this Privacy Policy;

communications with our support team;

subscription services offered through Apple;

future Spark Rituals applications unless separate privacy policies are provided.

This Privacy Policy does not apply to:

Apple services, including iCloud, CloudKit, the App Store, or Apple In-App Purchases;

third-party websites or services that may be linked from our applications;

your personal Apple ID or iCloud account.

Those services are governed by Apple's own privacy policies and terms.

4. Our Privacy-First Philosophy

Most mobile applications collect user information by transmitting it to company-operated servers.

Spark Rituals was intentionally designed differently.

Our applications operate using a local-first architecture.

This means that the content you create remains under your control.

For example, information such as:

your child's first name;

your child's date of birth;

memorable quotes;

notes;

journal entries;

conversation history;

keepsakes; and

5. Information Entered Into the Applications

While using Spark Rituals, you may choose to enter information including:

your child's first name;

your child's date of birth;

memorable quotes;

conversations;

journal entries;

notes;

milestones;

family memories;

photographs (where supported);

custom categories;

reminders; and

other information you voluntarily choose to save.

It is important to understand that this information is entered into the application by you.

However, under the normal operation of Spark Rituals, this information is not transmitted to Storm Advies B.V.

Instead, it remains stored:

on your Apple device; and

if enabled by you, within your own personal iCloud account using Apple's CloudKit synchronisation services.

Because we never receive this information, we generally cannot:

access it;

retrieve it;

restore deleted content;

correct it;

share it;

analyse it;

sell it; or

provide copies of it.

You remain responsible for managing your own device, Apple ID, iCloud account, backups and exports.

If you delete information from your device or iCloud account, we generally cannot recover it.

6. Information We Actually Receive

Unlike the personal memories stored within the applications, there are limited situations where we do receive information directly from you.

6.1 Communications with Support

If you contact us for assistance, we may receive information that you voluntarily provide, including:

your name (if included);

your email address;

the contents of your message;

attachments you choose to send;

technical information necessary to investigate a reported issue.

We use this information solely for purposes such as:

responding to your enquiry;

providing customer support;

resolving technical problems;

improving customer service; and

complying with applicable legal obligations.

We ask that you do not send sensitive information or your private family memories unless doing so is necessary to explain a technical problem.

6.2 Subscription Information

Subscriptions are purchased exclusively through Apple's App Store using Apple's In-App Purchase system (StoreKit).

Apple acts as the payment processor.

We do not receive or store:

your payment card details;

bank account information;

Apple Pay information; or

other financial payment credentials.

Apple may provide us with limited transaction information necessary to administer your subscription, such as confirmation that a subscription is active, renewal status, expiration dates, and similar purchase-related information.

The precise information shared is determined by Apple and is governed by Apple's own privacy practices.

6.3 Website Communications

If you contact us through our website, we may receive the information you voluntarily submit, such as your name, email address and the contents of your enquiry.

We use this information solely to respond to your request or otherwise communicate with you.

7. Information We Do Not Collect

One of the defining features of Spark Rituals is that we intentionally minimize the amount of information we collect.

Unless expressly stated in this Privacy Policy, we do not collect, receive, store or process the personal content you create within our apps.

In particular, we do not collect or have access to:

your child's name;

your child's date of birth;

quotes or conversations you save;

journal entries;

keepsakes;

photographs stored within the app;

notes or memories you create;

parenting history;

family information;

free-text content entered into the app; or

backups stored within your personal iCloud account.

At launch, we also do not collect:

analytics about how you use the apps;

advertising identifiers;

behavioural tracking information;

marketing profiles;

device identifiers for advertising purposes;

crash reporting data through third-party services;

location information;

contacts;

calendars;

microphones (except where a feature expressly requires your permission);

cameras (except where you choose to add photographs);

browsing history; or

information for targeted advertising.

We do not sell personal information.

We do not rent personal information.

We do not build advertising profiles.

We do not use your personal content to train artificial intelligence or machine-learning models.

Because we do not receive your personal memories, we cannot disclose them to advertisers, marketing companies or other third parties.

8. Apple CloudKit and Local Storage

Spark Rituals uses Apple's technologies to allow you to securely store and synchronise your information across your own Apple devices.

8.1 Local Storage

By default, the information you enter into the app is stored locally on your Apple device.

This information remains under your control and is not transmitted to us.

8.2 iCloud Synchronisation

If you enable iCloud synchronisation, your content is synchronised using Apple's CloudKit service under your own Apple ID.

Your information is stored within your personal iCloud account—not on servers operated or controlled by Storm Advies B.V.

We do not have administrative access to your iCloud account.

We cannot retrieve your data from iCloud.

We cannot restore deleted information from your iCloud account.

Apple acts as the provider of the iCloud and CloudKit services and processes information in accordance with its own terms, privacy policies and security practices.

For more information about Apple's handling of your information, please consult Apple's privacy documentation.

8.3 Data Exports

Certain Spark Rituals apps may allow you to export your own content, such as PDF files or archive files.

These exports are generated directly from information stored on your device or within your personal iCloud account.

We do not receive copies of exported files unless you intentionally send them to us, for example when requesting technical support.

9. Apple In-App Purchases and Subscriptions

Spark Rituals offers optional paid subscriptions through Apple's In-App Purchase system (StoreKit).

All subscription purchases are processed exclusively by Apple.

We do not process payments directly.

We do not receive your payment card information.

We do not receive your banking information.

We do not store your financial information.

Apple may provide us with limited subscription-related information necessary to manage access to premium features, including information such as:

subscription status;

product purchased;

renewal status;

expiration date; and

other limited purchase verification information.

Prices, billing periods, introductory offers and renewals are determined through Apple's App Store.

Subscriptions automatically renew unless cancelled through your Apple account before the applicable renewal date.

Questions concerning billing, refunds or payment disputes should generally be directed to Apple, as Apple is responsible for processing subscription payments.

10. Legal Bases for Processing Personal Information (GDPR)

To the extent that the General Data Protection Regulation ("GDPR") applies, we process the limited personal information that we actually receive on one or more of the following legal bases.

10.1 Performance of a Contract

We process certain information where necessary to provide the services you request, including:

responding to customer support enquiries;

administering subscriptions;

providing access to premium features; and

communicating with you regarding your use of the services.

10.2 Legitimate Interests

We may process limited personal information where necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms.

Examples include:

maintaining the security of our services;

responding to enquiries;

preventing fraud or misuse;

improving customer support; and

defending legal claims.

10.3 Compliance with Legal Obligations

We may process information where necessary to comply with applicable legal obligations, including tax, accounting, regulatory or judicial requirements.

10.4 Consent

Where we rely on your consent, you may withdraw that consent at any time.

Withdrawal of consent will not affect the lawfulness of processing carried out before the consent was withdrawn.

Because Spark Rituals is designed not to receive most user information, consent is generally required only for specific interactions, such as when you voluntarily contact us.

11. Data Security

Protecting your family's privacy is fundamental to the design of Spark Rituals.

Rather than relying primarily on contractual promises about privacy, we have designed our applications so that we generally never receive your personal memories in the first place.

We implement reasonable technical and organisational measures appropriate to the limited information we process.

These measures include, where appropriate:

secure communication channels;

restricted administrative access;

authentication and access controls;

regular software maintenance;

encryption provided by Apple for supported services;

careful management of support communications; and

procedures designed to minimise the information we receive.

However, no method of electronic storage or internet transmission can be guaranteed to be completely secure.

Accordingly, while we take reasonable steps to safeguard the information we receive, we cannot guarantee absolute security.

You are also responsible for protecting your own Apple device, Apple ID credentials, passcodes, backups and iCloud account.

12. Data Retention

Because we generally do not receive your personal memories, we also do not retain them.

The limited information that we do receive is retained only for as long as reasonably necessary for the purpose for which it was collected, unless a longer retention period is required or permitted by law.

For example:

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<w:tcPr><w:tcW w:w="0" w:type="auto"/><w:vAlign w:val="center"/><w:hideMark/></w:tcPr><w:p w14:paraId="2012B39B" w14:textId="77777777" w:rsidR="000A359C" w:rsidRPr="000A359C" w:rsidRDefault="000A359C" w:rsidP="000A359C"><w:pPr><w:rPr><w:rFonts w:ascii="Times New Roman" w:hAnsi="Times New Roman" w:cs="Times New Roman"/><w:sz w:val="24"/><w:szCs w:val="24"/><w:lang/></w:rPr></w:pPr><w:r w:rsidRPr="000A359C"><w:rPr><w:rFonts w:ascii="Times New Roman" w:hAnsi="Times New Roman" w:cs="Times New Roman"/><w:sz w:val="24"/><w:szCs w:val="24"/><w:lang/></w:rPr><w:t>For the duration of the subscription and any applicable legal retention period

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Information stored on your Apple device or within your personal iCloud account remains under your control.

You may delete such information at any time using the tools provided by Apple or within the applicable Spark Rituals app.

Because we do not possess this information, deleting it from your device or iCloud account generally removes our ability to assist with its recovery.

13. Children's Privacy

Spark Rituals develops applications for parents and caregivers—not for children to use independently.

Our apps are designed to help adults record memories, conversations and milestones relating to their children. Parents remain the users of the applications and decide what information, if any, they choose to enter.

13.1 Information About Children

Parents may voluntarily enter information relating to their children, including:

first names;

dates of birth;

memorable quotes;

conversations;

milestones;

photographs (where supported); and

other family memories.

However, this information remains stored on the user's own Apple device and, if enabled, within the user's personal iCloud account.

Storm Advies B.V. does not receive or store this information on its own systems under the normal operation of the apps.

13.2 COPPA

The United States Children's Online Privacy Protection Act ("COPPA") applies to operators that collect personal information online from children under 13 years of age.

Spark Rituals is designed so that:

children are not the intended users of the apps;

parents are the users and decision-makers;

child-related information entered into the apps remains under the parent's control;

we do not knowingly collect personal information directly from children through our own servers.

Because our architecture is local-first and we do not receive users' child-related content, our data handling practices differ significantly from traditional online services that collect and store children's information.

If our services or technical architecture change in the future in a manner that results in our collection of children's personal information, we will review our obligations under COPPA and update this Privacy Policy and our practices as necessary.

13.3 Children's Data under the GDPR

For users in the European Union, the processing of children's personal data in relation to information society services is governed by Article 8 of the General Data Protection Regulation ("GDPR"). In the Netherlands, the age at which a child may generally provide their own consent for such services is 16 years.

Spark Rituals has been designed so that parents or other adult caregivers—not children—are the intended users of the apps. Parents decide what information, if any, they choose to enter about their children, such as a child's first name, date of birth, memorable quotes or family notes.

Importantly, this information remains stored on the parent's own Apple device and, where the parent enables synchronisation, within the parent's personal iCloud account through Apple's CloudKit services. Under the normal operation of the apps, Storm Advies B.V. does not receive, access or store this child-related content on its own systems.

Accordingly, Spark Rituals does not rely on a child's consent under Article 8 GDPR for the operation of its services. Instead, the apps function as tools used by parents to manage information that remains under their own control. If the architecture or functionality of the apps changes in the future such that Storm Advies B.V. begins collecting or otherwise processing child-related personal data on its own systems, we will review our obligations under the GDPR, including Article 8 where applicable, and update this Privacy Policy and our practices accordingly.

13.4 If You Believe Information Has Been Sent to Us

If you believe that child-related personal information has inadvertently been transmitted to us, please contact us promptly using the details provided below.

Where appropriate, we will investigate the matter and take reasonable steps to delete information within our possession, subject to applicable legal obligations.

14. Your Privacy Rights

Depending on your country of residence, you may have certain rights regarding the limited personal information that we process.

Because Spark Rituals generally does not receive the content you create within the apps, some of these rights apply only to the limited information that we actually possess, such as support communications.

Subject to applicable law, you may have the right to:

request access to your personal information;

request correction of inaccurate information;

request deletion of information we hold about you;

request restriction of processing;

object to certain processing activities;

request data portability where applicable;

withdraw consent where processing is based on consent; and

lodge a complaint with a competent supervisory authority.

These rights do not extend to information that remains solely on your own device or within your own iCloud account, as we do not possess or control that information.

15. Exercising Your Rights

If you wish to exercise any applicable privacy rights, please contact us using the contact details below.

To protect your privacy and the security of our users, we may request reasonable information to verify your identity before responding to your request.

We will respond within the timeframes required by applicable law.

If we are unable to comply with a request, we will explain the reasons, subject to any legal restrictions.

16. International Users

Spark Rituals is operated by Storm Advies B.V., a company established in the Netherlands.

Our apps may be downloaded and used by individuals located in many countries.

Because we generally do not receive or store the content created within the apps, international transfers of user-generated content by Storm Advies B.V. ordinarily do not occur.

Where we receive limited personal information, such as support enquiries, that information may be processed in accordance with applicable law.

If, in the future, we engage service providers located outside the European Economic Area ("EEA"), we will ensure that appropriate safeguards are implemented where required by the GDPR, including the use of adequacy decisions, the European Commission's Standard Contractual Clauses or other lawful transfer mechanisms.

17. Future Features and Third-Party Services

At launch, Spark Rituals does not use third-party analytics, advertising platforms, attribution tools, crash-reporting services or subscription management platforms.

As our services evolve, we may introduce carefully selected third-party services that improve the functionality, reliability or security of our apps.

Examples could include:

privacy-respecting analytics;

crash reporting tools;

subscription management services;

customer support platforms; or

other technical infrastructure providers.

If we introduce any such services, we will:

evaluate their privacy practices;

limit the information shared to what is reasonably necessary;

avoid transmitting child-related content, quotes or free-text entries wherever reasonably possible;

update this Privacy Policy before or at the time such services are introduced; and

comply with applicable privacy laws.

Our commitment to a privacy-first design will continue to guide our decisions regarding any future third-party integrations.

18. Third-Party Websites and Services

Our apps or website may contain links to third-party websites or services for your convenience.

We do not control those third-party websites or services and are not responsible for their privacy practices, security or content.

We encourage you to review the privacy policies of any third-party services you choose to use.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect:

changes in applicable laws;

new features or services;

improvements to our products;

changes to our business operations; or

changes to our privacy practices.

When we make material changes, we will update the "Last Updated" date at the beginning of this Privacy Policy.

Where required by applicable law, we will provide additional notice or obtain any necessary consent.

Your continued use of the Spark Rituals apps after an updated Privacy Policy becomes effective constitutes your acknowledgement of the revised Privacy Policy, except where applicable law requires a different form of consent.

20. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us:

Storm Advies B.V.

Trading as Spark Rituals

Heerlerweg 122

6367 AG Voerendaal

The Netherlands

Email: legal@sparkrituals.com

Website: https://sparkrituals.com

If you contact us regarding a privacy matter, please provide sufficient information for us to understand and respond to your enquiry.

21. Governing Law

This Privacy Policy shall be governed by and interpreted in accordance with the laws of the Netherlands, without regard to its conflict of law principles.

Nothing in this Privacy Policy limits any mandatory consumer rights that may apply under the laws of your country of residence.

22. Apple-Specific Notice

Spark Rituals applications are distributed through Apple's App Store.

Apple Inc. and its affiliated companies provide certain services used by the apps, including:

the App Store;

Apple In-App Purchases (StoreKit);

iCloud; and

Apple CloudKit.

These services are governed by Apple's own terms, conditions and privacy policies.

Nothing in this Privacy Policy modifies or replaces Apple's own legal terms.

23. Questions About Privacy

We believe privacy should be easy to understand.

If anything in this Privacy Policy is unclear, or if you have questions about how Spark Rituals protects your information, we encourage you to contact us.

We are committed to responding openly, transparently and in accordance with applicable privacy laws.

Thank you for trusting Spark Rituals with your family's memories.

Our goal is to help you preserve life's meaningful moments while ensuring that those moments remain yours—and yours alone.