Sparklets Privacy Policy.

Sparklets.ai is operated by Avant Digital Inc. References to Sparklets, Sparklets.ai, Emma, we, us, or our mean Avant Digital Inc and the Sparklets services we provide.

Sparklets is an AI assistant platform that helps users delegate tasks, process information, connect services, coordinate communications, make or receive calls, manage schedules, remember preferences, and complete real-world follow-through across web, mobile, voice, messaging, email, calendar, files, and related channels.

We collect information directly from you, from accounts and powers you connect, from device permissions you enable, from assistant actions you request, from support and billing flows, and from automated service activity needed to operate Sparklets.

We use information to provide, secure, support, and improve Sparklets. This includes:

• Understanding requests, creating tasks, using approved tools, drafting communications, making calls, and producing outputs.
• Searching or acting through connected powers that you authorize, such as email, calendar, contacts, files, phone, messaging, and browser tools.
• Personalizing Emma through preferences, memories, task context, communication style, and connected-service labels.
• Operating billing, metering Sparks, providing support, troubleshooting errors, preventing abuse, enforcing our Terms, and protecting the service.
• Complying with law, responding to lawful requests, resolving disputes, and protecting users, third parties, and Avant Digital Inc.

Sparklets uses third-party AI, speech, infrastructure, communication, search, browser, billing, authentication, and connected-service providers to operate the assistant. Depending on your request and enabled powers, we may send your messages, instructions, preferences, memories, connected email/calendar/contact/file content, call audio or transcripts, documents, location or address context, and related task context to those providers.

Sparklets uses paid, commercial, or production API routes for core AI model processing where available. For those routes, we use provider data-processing terms, contracts, or equivalent safeguards and configure no-training or limited-retention controls where the provider and production tier support them. We do not claim that every provider has the same retention rules or that providers never retain data for security, abuse monitoring, legal, or service-operation purposes.

We require providers that receive user data to protect it under data-processing terms, contracts, technical controls, or equivalent safeguards consistent with this Privacy Policy and applicable App Store privacy requirements.

More detail is available in our AI Processing Notice and Subprocessors page.

When Sparklets uses Google Maps Platform services, that use is also subject to the Google Terms of Service and Google's Privacy Policy.

Money Privacy Addendum — Version 2026-10-04.1, effective October 4, 2026.

If you choose to use Money, Sparklets uses Plaid to connect financial accounts that you select. Depending on the institution and account, Sparklets receives, stores, and processes institution and account identifiers, masked account numbers (such as the last four digits), account names and types, balances, transaction history, amounts, dates, pending status, merchants, counterparties, categories, and transaction-location information, including addresses and coordinates where provided. If you connect credit card, investment, retirement, health savings, or loan accounts, Sparklets also receives, stores, and processes holdings (the securities held, with their names, ticker symbols, types, sectors, quantities, prices, values and, where your institution provides it, cost basis), investment activity (such as purchases, sales, dividends, interest, fees, contributions, and transfers, with their dates, quantities, prices, and amounts), and card, loan, and payment details (such as a card’s interest rate, credit limit, statement balance and date, minimum payment, and due date; and a loan’s interest rate, payment amounts and due dates, terms, balances, original amount, payoff date, and the interest and principal paid). If you enter a loan’s details yourself, such as its balance, interest rate, and payment, Sparklets stores what you enter.

Plaid may also send Sparklets information that Money does not use, such as full account and loan numbers, a mortgage’s property address, a loan servicer’s address, guarantor information, loan names, repayment plans and statuses, and securities identifiers such as CUSIP or ISIN. Sparklets discards this information when it is received and does not store it in its application data, logs, exports, or backups, or share it with other service providers. Sparklets keeps only masked account numbers so that you can recognize your accounts.

Sparklets uses this information to display connected accounts and transactions; calculate balances, cash flow, net worth, investment holdings, allocation, performance and income, budgets, bills and payments due, and insights; show how a loan payment divides between principal, interest, and other charges; categorize activity; maintain synchronization; identify connection problems; and help you understand where a transaction occurred, including through a future map or map link.

You authenticate with your financial institution through Plaid. Sparklets does not receive or store your online-banking password. Plaid and your financial institution process information under their own terms and privacy notices.

Transaction-location information describes the transaction or merchant location supplied by Plaid; it is not your device location or a record of where you were.

Current Money features do not intentionally send linked financial data to Sparklets’ AI model providers and do not include it in assistant prompts, task context, memories, or agent tools. Money summaries and insights currently use deterministic application calculations and rules. Before introducing an AI-powered financial feature, Sparklets will update its disclosures and obtain any additional consent that is appropriate.

Disconnecting an institution stops future synchronization but does not automatically delete imported history. The separate Delete Money data control removes Sparklets-held imported account, balance, transaction, holding, investment-activity, card, loan, and payment detail, merchant or counterparty, category, and transaction-location data, and loan details you entered. Sparklets may retain limited deletion and disconnection evidence, security and fraud-prevention records, legally required records, and billing or audit records under its documented retention practices.

Review Plaid's End User Privacy Policy.

Sparklets only accesses connected services when you connect or authorize a power, grant permissions, or instruct Emma to use that service. Examples include reading email, drafting or sending messages, reading or writing calendar events, importing files, using contacts, placing calls, opening browser sessions, or preparing posts.

You can disconnect powers or revoke provider permissions at any time. Disconnection may stop future access, but task history, logs, outputs, files, and records created before disconnection may remain until deleted under our retention practices or account deletion process.

Voice, phone, and meeting features may process phone numbers, call metadata, audio, recordings, transcripts, speaker labels, summaries, and action items. These features may use providers such as Twilio, LiveKit, Deepgram, Cartesia, and other feature-specific speech or voice providers.

You are responsible for using recording, transcription, and call features lawfully, including obtaining any consent required by your organization, jurisdiction, meeting platform, or participants.

Sparklets SMS is currently operating only as a limited, controlled pilot for authorized members and recipients in the consent flow. It is not generally available. Within the pilot, Sparklets SMS is limited to one-to-one, non-marketing personal operations and logistics coordination messages for a named member within the recipient's active consent program. The member directs the message through Sparklets; wording may be natural and is not limited to fixed templates or listed coordination categories. Sparklets does not use this program for bulk messaging, marketing, promotions, fundraising, lead generation, or campaigns. Sparklets blocks card and CVV data, Social Security and routing numbers, passwords and passcodes, and API or authentication tokens before transport. The member is responsible for the remaining content they direct Sparklets to send and for using SMS lawfully and appropriately. Legacy external-recipient and legacy member-notification consent programs will send no more than 20 member-funded task or notification messages to the same recipient number in any rolling 7-day period across those programs. The separately accepted variable-frequency external-recipient successor permits messages as personal coordination requires, and the separately versioned unified member written opt-in below uses variable frequency based on account activity, support requests, and assistant conversations. Existing capped grants are not automatically upgraded or reinterpreted as either variable-frequency permission.

Unified Member SMS Addendum — Version unified-member-sms-2026-10-03.3, effective October 3, 2026.

Sparklets offers one optional own-number written SMS opt-in during authenticated onboarding, on a later authenticated sign-in if no current qualifying v2 receipt exists, or in Settings and Notifications. The unchecked checkbox carries the exact disclosure below with adjacent Terms and SMS Privacy links. Sparklets records the number, exact disclosure and version, time, account identity, and capture surface. This permission covers recurring automated, non-marketing account, support and applicable waitlist messages, assistant conversations or coordination the person initiates, including non-sensitive urgent task-status or fallback updates about work the person has asked their assistant to handle. Message frequency varies based on these activities. Public waitlist enrollment remains on its separate capped consent program; a public waitlist receipt is not promoted into this account consent. A legacy receipt does not count as v2. Once v2 is accepted for the same account and current phone identity, later entry points do not render another consent checkbox. Existing trusted current-number binding is required before private owner-channel activation. The receipt is reused across eligible assistant senders, but each exact sender retains its own introduction and activation evidence; retrying the same introduction does not create another send. Accepting receive consent does not enable proactive alerts, and turning proactive alerts off does not withdraw consent or disable owner conversations. Publishing this disclosure does not enroll anyone or expand an older receipt. STOP remains brand-wide. This receive consent does not authorize texting other people; external-recipient consent and member sending/spending authorization remain separate.

This optional receive consent is independent of permission for your assistant to text other people. Where Sparklets charges for a member-funded assistant conversation or urgent alert, the applicable current member SMS Sparks rate and any required spending authorization apply. Consent, STOP, HELP, and other required compliance messages are platform-funded. Checking the consent box does not verify or bind a current owner number.

Written opt-in used when this option is presented: By checking this box, I confirm this is my mobile number and agree to receive recurring automated, non-marketing text messages from Sparklets. Messages may identify my Sparklets assistant and may concern my Sparklets account, support requests, waitlist status if applicable, and conversations or coordination I initiate with my assistant, including non-sensitive urgent task-status or fallback updates about a task, conversation, or coordination I have asked my assistant to handle. Message frequency varies based on these activities. Message and data rates may apply. Reply STOP to opt out and HELP for help. Consent is not a condition of purchase. Terms. SMS Privacy.

Variable-Frequency External-Recipient SMS Addendum — Version external-recipient-variable-sms-2026-10-01.3, effective October 1, 2026.

This separately versioned successor consent covers recurring, one-to-one, automated, non-marketing personal operations and logistics coordination involving one named Sparklets member. It includes task-related questions, responses, follow-ups, scheduling, arrival, availability, approved administrative coordination, and status updates. All messages in this program are sent only by Avant Digital Inc. d/b/a Sparklets. The named member and assistant identify the human relationship and service context; neither is a separate sender, brand, affiliate, or business. Message frequency varies with actual coordination activity; the examples do not restrict natural message wording or create permission for marketing, promotions, bulk messaging, lead generation, purchased-list traffic, or sensitive information. Consent binds the recipient's mobile number, the Sparklets sender and program, the named member and assistant, and this scope. It may be obtained through recipient-completed written consent on a shared assistant card, an independently necessary live Sparklets task call followed by handset YES, or a recipient-initiated inquiry followed by the complete disclosure and handset YES. This successor version may be activated only after the applicable carrier campaign is approved and the recipient accepts this exact variable-frequency disclosure. Publishing it does not enroll anyone, and no existing capped or narrower grant is reinterpreted as this consent.

Written opt-in used only after carrier approval when this successor option is presented: By checking this box, I agree to receive recurring automated, non-marketing text messages from Sparklets about personal operations and logistics coordination involving [Member Name], a Sparklets member, including task-related questions, responses, follow-ups, scheduling, arrival, availability, approved administrative coordination, and status updates. Messages may identify [Assistant Name] as the Sparklets AI assistant helping with this coordination, but Sparklets is the sole sender. Message frequency varies based on coordination activity. Message and data rates may apply. Reply STOP to opt out and HELP for help. Consent is not a condition of purchase. Terms. SMS Privacy.

Waitlist Operational SMS Addendum — Version waitlist-operational-sms-2026-08-31.1, effective August 31, 2026.

A prospective Sparklets member may optionally enroll their own number for recurring automated operational texts from Sparklets, including Amy, by checking the unchecked SMS consent box on the official Sparklets waitlist form. This first-party written opt-in is not required to join the waitlist or buy anything. It authorizes only waitlist-status and Sparklets account-support messages under the stated 20-message rolling 7-day cap. Sparklets records the exact form, disclosure, number, timestamp, and request evidence, then sends one generic introduction with Sparklets identity, message frequency, rates, STOP, HELP, Terms, and Privacy. Because the recipient gave written consent on the form for their own number, no handset YES reply is required. This program does not authorize marketing or messages for another person.

Written waitlist opt-in: By checking this box, I confirm this is my mobile number and agree to receive recurring automated text messages from Sparklets, including Amy, about my Sparklets waitlist status and account support. Message frequency varies, up to 20 messages in any rolling 7-day period. Message and data rates may apply. Reply STOP to opt out and HELP for help. Consent is not a condition of purchase. Terms. SMS Privacy. Terms. SMS Privacy.

Member Account-Support SMS Addendum: support-sms-written-v1-2026-09-30, effective September 30, 2026.

Rollout availability clarification — Version 2026-10-03.4. During rollout, a compatible earlier Sparklets release may continue to present the legacy account-support SMS prompt described below. Any consent under that prompt is governed only by its exact historical disclosure, sender, purpose, frequency or cap, and funding terms. It does not satisfy, expand into, or replace Unified Member SMS v2.

Sparklets members may optionally enroll their own mobile number for Sparklets account-support texts, including Amy, using an unchecked checkbox during onboarding or in Settings. Existing members without a qualifying grant may see a dismissible invitation in Sparklets. Consent is not required to access Sparklets or make a purchase. We retain the number, exact disclosure, version, time, and capture surface. A qualifying prior waitlist grant for the same number and purpose remains valid. The standard introduction identifies Sparklets and explains frequency, rates, STOP, HELP, Terms, and Privacy before the first substantive support text. Written enrollment does not require an additional handset YES reply. This permission does not cover marketing or another member's personal communications.

Legacy account-support written opt-in — original disclosure for compatible earlier releases: By checking this box, I confirm this is my mobile number and agree to receive recurring automated, non-marketing text messages from Sparklets, including Amy, about my Sparklets account, support requests, and waitlist status, if applicable. Message frequency varies, up to 20 messages in any rolling 7-day period. Message and data rates may apply. Reply STOP to opt out and HELP for help. Consent is not a condition of purchase. Terms. SMS Privacy.

Introductory message: Sparklets Hello - This is Amy from Sparklets. You are enrolled for account-support updates and, if applicable, waitlist-status updates. Msg frequency varies, up to 20/rolling 7 days. Msg & data rates may apply. STOP to opt out; HELP for help. Terms: sparklets.ai/terms Privacy: sparklets.ai/privacy#sms-communications

For a member's personal contact, the member's instruction, provision of a number, account consent, or attestation is not recipient consent. New external-recipient enrollment may use recipient-completed written consent on the shared assistant card, an independently necessary eligible live task call followed by handset YES, or an ordinary recipient-initiated inquiry followed by the disclosed invitation and handset YES. In the recipient-initiated path, Sparklets may answer only the exact signed inquiry before full consent; the first accepted answer identifies Sparklets and the named member and assistant, states the approved non-marketing coordination scope, the frequency policy of the consent path being offered, message-and-data rates, STOP and HELP, and links the Terms and Privacy notice. It then invites an exact YES for future coordination.

For live-call consent, Sparklets retains the exact adjacent request and recipient response with the call record. The live Voice model records a candidate decision, and a separate provider-distinct compliance model independently reviews the same sealed turns and required disclosures. Only matching affirmative decisions may create a pending record and exactly one non-task confirmation. SMS consent does not depend on a particular recording disclosure. Call recording and the configured Voice capture profile are governed separately under the Voice policy; SMS enrollment is available only when the required Voice operational checks are satisfied. For recipient-initiated consent, Sparklets retains the exact signed inbound message and permits only bounded contextual replies tied to that inbound turn before YES. Future proactive task messages require the correlated YES reply within 7 days. Sparklets initiates no cold consent text, reminder, consent-only call, or first-time START enrollment.

Each consent program binds the recipient's E.164 number, Sparklets sender/program, named member and assistant, approved scope, and recorded frequency policy. Consent for one named member cannot be used by another Sparklets member. Message wording may be natural and is not limited to fixed templates or listed coordination categories. The recorded frequency policy does not broaden consent or member authority. Read the SMS Consent Evidence, our Terms, and this SMS Communications disclosure.

Legacy Authenticated Member SMS Pilot Addendum — Version 2026-08-25, effective August 25, 2026.

Rollout availability clarification — Version 2026-10-03.4

Unified Member SMS v2 is the current enrollment path in the updated release. During rollout, a compatible earlier Sparklets release may continue to display the original legacy member-notification prompt. Any consent under that prompt is governed only by its exact historical disclosure, sender, scope, frequency or cap, and funding terms. It does not create, satisfy, or expand into Unified Member SMS v2 or variable-frequency messaging. The historical enrollment required the signed-in member to accept the then-current member-SMS disclosures, request one confirmation message, and reply YES from that handset. Under the legacy member-notification program, and only within its exact historical disclosure and other recorded terms, a model-declared high-priority owner alert may initiate a member-funded urgent SMS alert when the assistant judges that immediate attention is needed before a possible phone call. Normal updates remain in Sparklets and its ordinary notification channels. The generic urgent alert does not include task details. Any ordinary message sent from the verified current account number to the enrolled number while the pilot is active is captured and may receive one fixed member-funded acknowledgement for that admitted message directing the member to Sparklets; it does not invoke the assistant or continue work by SMS. Urgent alerts and fixed reply acknowledgements share the accepted rate and rolling cap. Sparklets does not send legal, medical, financial, employment, family, credential, confidential, or other sensitive content in outbound member SMS. Do not send that information by SMS; use Sparklets instead. The same STOP and HELP controls and 20 member-funded message rolling 7-day cap apply. Read the member SMS program details.

STOP, STOPALL, UNSUBSCRIBE, CANCEL, END, or QUIT will immediately suppress future Sparklets messages except any legally required confirmation. HELP will identify Sparklets and return clear support information, including support@sparklets.ai and sparklets.ai, along with STOP, frequency, and rates disclosures. START or UNSTOP is available only after STOP to restore the same previously active exact program after provider and Sparklets checks succeed; it cannot enroll a new recipient or changed program. Sparklets retains consent, confirmation, HELP, opt-out, and re-enrollment evidence. Carriers are not liable for delayed or undelivered messages.

We do not sell or rent mobile numbers, SMS content, messaging consent, or opt-out data, and we do not share that information for advertising or for a third party's own marketing or promotional purposes. Service providers may process this information only as needed to provide Sparklets under contractual safeguards.

• We do not sell your personal information.
• We do not use your personal information for third-party advertising.
• We do not share your personal information with data brokers.
• We do not use your private content to train a Sparklets foundation model.
• For core AI model providers, we use production business/API routes and available controls designed to prevent your private content from being used to train general foundation models unless Sparklets expressly opts in.

We use layered technical and organizational safeguards, including encryption in transit, authentication and access controls, tenant isolation, production content-log minimization, field-level encryption for supported stored credentials, logging, monitoring, and operational security controls.

Before certain content is sent through AI model paths, Sparklets applies deterministic hard-secret masking designed to reduce exposure of payment card numbers, Social Security numbers, bank or routing numbers, passwords, and API tokens. Sparklets may still process working personal information, connected-service content, files, audio, transcripts, memories, and task context when needed to provide requested assistant features.

Sparklets also uses memory-governance controls designed to limit when sensitive or confidential memory content may enter assistant context. Users can review and manage saved memories and control which categories of memory Sparklets may use to personalize assistant responses. Confidential memory is handled with stricter controls and is not exposed as ordinary assistant context. No system is completely secure, and we cannot guarantee absolute security.

We retain information for as long as needed to provide Sparklets, maintain task history and memories you choose to keep, satisfy legal or business requirements, resolve disputes, secure the service, and enforce agreements. Provider retention periods vary by provider and feature.

Sparklets is designed so you decide what Emma can access, remember, and use. You can manage many of these choices from Sparklets Settings, your device settings, connected provider settings, or by contacting us at privacy@sparklets.ai.

Some assistant features may not work if you decline AI processing, disconnect powers, revoke permissions, or delete the context Emma needs to perform the requested task.

Sparklets is intended for adults and is not directed to individuals under 18. We do not knowingly collect personal information from children or from users who cannot legally consent to using an AI assistant service.

Information may be processed in the United States and other locations where we or our providers operate.

We may update this Privacy Policy from time to time. Material changes will be reflected by updating the effective date and, where appropriate, providing in-product notice or requiring renewed consent.

Privacy questions and requests can be sent to privacy@sparklets.ai. Legal notices can be sent to legal@sparklets.ai.