Legal
Privacy Policy
Last updated: 2026-06-17
This Policy applies to the Spawk app and website worldwide. Region-specific rights for the European Union / EEA / United Kingdom, Brazil, and the United States are in Section 11.
1. Controller and contacts
Liberty Chain Inc. (“Spawk,” “we”), a Delaware corporation in Orlando, Florida, USA, is the controller (controlador) of personal data processed via the Service.
- Privacy / data-protection contact: privacy@spawk.app
- Brazil — Encarregado (DPO) under the LGPD: dpo@spawk.app [appoint & name the encarregado before BR launch]
- EU/EEA & UK — Article 27 representative: [appoint an EU and a UK representative and list name/address before EU/UK launch]
2. Data we collect
- Account data: name, email, phone (optional), password hash, Google/Apple identifier, profile photo.
- Pet & content data: pet name, breed, size, and the photos/videos/captions you upload.
- Booking & payment data: appointment details and reviews; for payments, Stripe returns only the payment-intent id, status, and amount — full card data never reaches our servers.
- Approximate (IP-based) location: coarse country/region/city from your IP, to tailor regional features and meet legal requirements; not precise, not shared with other users.
- Tracking-device location: if you activate a Spawk collar/tag — its position fixes, battery, and signal data, tied to your account (via LoRa/Helium, the Spawk Network, or Apple Find My).
- Precise / background device location:if you opt in to the Spawk Network — your device’s approximate location when it detects a nearby Spawk collar, including while the app runs in the background or is closed.
- Bluetooth detection data: when the Spawk Network is on — the rotating identifiers your phone observes from nearby Spawk collars and their signal strength. We do not scan for or identify people and do not access your contacts or other devices.
- Device & usage telemetry: user agent, IP, and event logs (page/screen views, clicks) for analytics and security.
- Custodial wallet: a Solana public key tied to your account; the private key is encrypted at rest (AES-256-GCM) and never sent to clients.
3. The Spawk Network — privacy by design
The Spawk Network lets participating phones help locate lost pets by relaying nearby collars, built to minimize personal data:
- Opt-in and off by default; turn it off in Settings or revoke permissions anytime.
- Collars broadcast rotating, non-identifying identifiers(not a stable id), so a collar can’t be tracked over time by third parties and a relaying phone can’t correlate detections to a pet.
- Detections are matched to a pet only on our servers; the relaying user is never told whose petthey detected, the owner is never told who relayed, and we do not attach the relayer’s identity to the stored location.
- We use the device’s last-known location rather than forcing a fresh GPS fix, and collect only an approximate location plus the observed identifier.
4. How we use data (purposes)
Provide and secure the Service (authentication, feeds, bookings, payments, emails/reminders); operate pet tracking and the Spawk Network to show locations and help reunite lost pets; prevent fraud and abuse; analyze and improve features; and comply with legal obligations.
5. Legal bases
EU/EEA/UK (GDPR / UK GDPR): performance of our contract with you (Art. 6(1)(b)); your consent for Bluetooth, precise and background location, and optional marketing (Art. 6(1)(a)), which you may withdraw anytime; our legitimate interests in operating, securing, and improving the Service (Art. 6(1)(f)); and legal obligations (Art. 6(1)(c)). Brazil (LGPD): execution of a contract (Art. 7, V), your consent (Art. 7, I) for location/Bluetooth and marketing, legitimate interests (Art. 7, IX), and legal/regulatory compliance (Art. 7, II). We rely on consent for precise geolocation and treat it as sensitive where applicable.
6. Sharing and processors
We do not sell personal data and do not share your precise location with other users. We use vetted processors/sub-processors under data-protection agreements: Stripe (payments, Connect KYC), Uploadthing (media CDN), MongoDB Atlas (database), Vercel (hosting), Sentry (error monitoring), Resend (transactional email), Twilio (SMS — opt-in), PostHog and Vercel Analytics (product analytics), Pusher (realtime updates), Apple (only if you enable Apple Find My), LoRa/Helium network operators (relaying encrypted device uplinks), and Anthropic / Google (only if you use AI features). We also disclose data where required by law or to protect rights and safety.
7. International transfers
We operate from the United States, so data is processed in the US and may be processed in the EU and elsewhere by our processors. For transfers from the EU/EEA/UK we rely on the European Commission’s Standard Contractual Clauses (and the UK Addendum), and for transfers from Brazil we rely on the LGPD’s international-transfer bases (including contractual safeguards and your consent where applicable), with supplementary measures as needed.
8. Retention
Account data is kept while your account is active; after deletion, identifying data is removed within 30 days (anonymized analytics may be kept). Tracking position history powers your map and can be deleted from the device page anytime. Spawk Network detection records are kept only as long as needed to operate the network and are not linked to the relaying user. Booking and payment records are retained as required by tax law (currently up to 7 years).
9. Security
TLS in transit; encryption at rest for sensitive secrets (custodial-wallet keys and tracking-device key material via AES-256-GCM, never returned to clients); rate limiting on wallet, AI, and ingestion endpoints; and an append-only administrative audit log with delete permission revoked in production.
10. Children
The Service is not directed to children under 13 (US), under 16 in the EU/EEA/UK (or the lower age set by your member state, minimum 13), or to children below the applicable age in Brazil, in each case without verified parental/guardian consent. We do not knowingly collect their data, including via the Spawk Network. If you believe a child provided data, contact
privacy@spawk.app.
11. Your rights
EU / EEA / UK (GDPR / UK GDPR). You may request access, rectification, erasure, restriction, portability, and object to processing based on legitimate interests; withdraw consent at any time; and not be subject to solely automated decisions with legal effects. You may lodge a complaint with your local supervisory authority (in the UK, the ICO). We respond within one month.
Brazil (LGPD). You may obtain confirmation of processing and access; correct incomplete or outdated data; request anonymization, blocking, or deletion of unnecessary or excessively processed data; request portability and deletion of data processed under consent; obtain information about sharing; and withdraw consent. You may contact our encarregado (dpo@spawk.app) and the Autoridade Nacional de Proteção de Dados (ANPD).
United States (California & other states). Subject to your state’s law (e.g., CCPA/CPRA, Virginia, Colorado, Connecticut, Utah, Texas), you may request to know, access, delete, and correct personal information, and to limit the use of sensitive personal information (which includes precise geolocation — used only to provide the features you enable, not to infer characteristics). We do not “sell” personal information or share it for cross-context behavioral advertising. You may use an authorized agent and appeal a denial. We will not discriminate against you for exercising these rights.
To exercise any right, email privacy@spawk.app (we verify identity first), or use in-app controls: delete your account in settings, turn off the Spawk Network and tracking, and revoke Bluetooth/location permissions in your device settings.
12. Bluetooth and background location disclosure
The Spawk Network and live tracking collect location data — including in the background and when the app is closed or not in use — and use Bluetooth to detect nearby Spawk collars, to relay their location and help reunite lost pets. These features are opt-in, are not used for advertising, and can be disabled at any time in Settings or via your operating-system permissions. On Android, Bluetooth scanning is used to derive device location for this purpose; on iOS, background scanning and (where you enable it) the Apple Find My network are used.
13. Cookies and similar technologies
On the website we use first-party cookies for authentication sessions and basic preferences, and limited analytics. We do not use cross-site advertising cookies. Where required (EU/UK), non-essential cookies/analytics load only with your consent via our cookie banner. The mobile app uses local storage and SDKs (analytics, crash reporting) as described above.
14. Changes
We may update this Policy. Material changes are announced via email or in-app banner at least 14 days before taking effect.
15. Contact
Liberty Chain Inc., Orlando, FL, USA —
privacy@spawk.app. See Section 1 for our Brazilian encarregado and EU/UK representative.