Privacy Policy for Users in Ghana
This policy explains how personal data is collected and used when you visit sparkling.com.gh and when you use Sparkling. Last updated: 3 November 2026.
1. Who Is Responsible
The controller is Swarming Labs Ltd, Intershore Chambers, Road Town, Tortola, British Virgin Islands, which operates Sparkling, the trading app with an AI agent available in Telegram and on the web and presented on the Sparkling Ghana home page. This policy applies worldwide and is written with Ghana’s Data Protection Act, 2012 (Act 843) in mind for visitors in Ghana.
2. What We Collect
Information you give us
- Account details such as your Telegram ID, username and email address.
- Sign-in data such as one-time codes, which are not stored in a readable form.
- Identity verification data where required, such as an ID document, proof of address and date of birth, handled by a regulated verification partner.
- Messages, trade instructions and support requests.
- Preferences such as notification settings and language.
Information collected automatically
- Transaction data such as quotes, signed transactions and transaction hashes.
- Technical data such as device type, operating system, IP address and approximate region.
- Usage data such as feature use, error logs and session information.
- Website analytics on this site, such as pages viewed, referral source and approximate location.
Information from others
We may receive data from wallet, routing and settlement partners and from sanctions screening providers. Public blockchain data, such as addresses and amounts, may also be analysed.
3. Why We Use It
- To provide the service: routing and executing transactions you approve, showing balances and running the agent.
- To keep accounts secure and prevent fraud, market manipulation and account takeover.
- To communicate with you about transactions, support and important changes.
- To improve the service through aggregated analysis and testing.
- To meet legal obligations, including identity checks, sanctions screening and record keeping.
- To measure website use, with your consent where the law requires it.
We do not sell personal data. Marketing messages are sent only with your consent.
4. Who We Share It With
We share data with service providers such as hosting, email, analytics, identity verification and support tools, under written agreements; with integrated partners that route and settle your transactions, each under its own privacy policy; with authorities where the law requires it; and with a buyer in the event of a merger or acquisition, under comparable commitments.
5. International Transfers
Data may be processed outside Ghana, including in countries with different data protection laws. Where required, we use contractual and technical safeguards for these transfers.
6. How Long We Keep It
| Data | Retention |
|---|---|
| Account information | While the account is open, plus 12 months |
| Transaction records | 7 years from the transaction date |
| Identity verification data | 5 years after the account is closed |
| Support correspondence | 3 years from the last contact |
| Technical logs and IP addresses | 30 days, or 90 days for security investigations |
| Website analytics data | 14 months |
7. Your Rights
Depending on where you live, you can ask to access, correct or delete your data, restrict or object to its use, receive a copy in a portable format and withdraw consent. In Ghana you can also complain to the Data Protection Commission. Send requests by email with the address linked to your account; we reply within 30 days, or tell you if we need longer.
8. Security
We use encryption in transit and at rest, multi-factor authentication for internal systems, least-privilege access and regular security testing. No system is completely secure, so please protect your own devices and codes.
9. Children
Sparkling is not intended for anyone under 18. If we learn that we hold a child’s data, we delete it.
10. Automated Decisions
The agent proposes trades, but every trade needs your confirmation. Automated fraud and sanctions checks are reviewed by people before decisions with significant effects, and you can ask for human review.
11. Cookies
This site uses strictly necessary storage and, with your choice, analytics cookies. Details are in the Cookie Policy.
12. Changes and Contact
We will announce material changes in advance. For privacy questions, contact:
- General enquiries: [email protected]
- Legal questions: [email protected]
- Data protection: [email protected]
- Postal address: Swarming Labs Ltd, Intershore Chambers, Road Town, Tortola, British Virgin Islands
Updated: