IMPORTANT: This Privacy Policy explains how Sparrow Coach collects, uses, shares, and protects your personal information when you use our mobile application. Please read this policy carefully before using our Services. By using Sparrow Coach, you consent to the practices described in this Privacy Policy.

1. INTRODUCTION
Sparrow Vision, Inc. (“Sparrow Vision,” “Sparrow,” “Company,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use the Sparrow Coach application, our website, and related services (collectively, the “Services”).

The Services are offered only to users located in the United States at this time.

This Privacy Policy is incorporated into and subject to our Terms of Use/Terms of Service. Capitalized terms not defined in this Privacy Policy have the meanings given to them in our Terms.
If you do not agree with the terms of this Privacy Policy, please do not access or use the Services.

Apple App Store “App Privacy” Disclosure: Apple also requires a separate “App Privacy” disclosure (sometimes called a “privacy nutrition label”) completed in App Store Connect for each app. That disclosure is separate from this Privacy Policy and should be consistent with the practices described here.

2. INFORMATION WE COLLECT
We collect information in several ways when you use our Services.

2.1 Information You Provide Directly
Account Information: When you create an account, we collect information such as your email address, username, and password. We may also collect additional account information you provide, such as your name, mobile phone number, mailing address, and date of birth.

Profile Information: Any additional information you choose to add to your profile, such as preferences, interests, or demographic information (for example, gender), as well as coaching or training preferences you select within the App.

User Content (Video/Audio): Video and audio content you record, upload, or otherwise submit through the Services. This may include videos captured through the App for training analysis and coaching features.

Performance Statistics: Performance statistics and training-related information generated through your use of the Services (for example, session metrics, progress tracking, coaching-related statistics, and leaderboard-related data, where applicable).

Contacts (Optional): If you choose to upload or sync phone contacts (where available), we may collect contact information to help you find people you know, invite friends, and enable social features. Contact syncing is not required to use core features of the App, and you can disable contact access at any time in your device settings.

Third-Party Account Information: If you choose to sign in using a third-party account (such as Apple, Google, or Facebook), we may collect information made available by that account (for example, your name, third-party account ID, profile picture/URL, and other information you choose to share through that third party).

Communications: Information you provide when contacting our support team, responding to surveys, or otherwise communicating with us (including the content of messages and any attachments you provide).

2.2 Information Collected Automatically
When you use our Services, we automatically collect certain information, including:

Device Information: Device type, operating system and version, app version, language settings, mobile network information, and unique device identifiers or similar identifiers used to operate the Services (including identifiers used for analytics, crash reporting, push notifications, subscription management, and attribution/measurement).

Usage Data: Information about how you use the Services, including session duration, features accessed, interaction patterns, timestamps, and frequency of use.

Log Data and Diagnostics: Server logs that may record information such as your IP address, access times, pages/screens viewed, referring URLs (where applicable), and app crashes or performance events.

Location Information (IP-Based): General location information inferred from your IP address (for example, your general geographic region). We do not collect precise geolocation data unless you explicitly grant permission (see Section 2.3).

2.3 Location Information (Device Permissions)
If you enable location services for Sparrow Coach, we may collect precise or approximate location information (depending on your device settings) to provide location-based features such as location-based performance statistics and leaderboards.

Location access is controlled by your device permissions. You can disable location access at any time in your device settings; if you disable location, certain features may be limited.

2.4 Information from Third Parties
We may receive information about you from third parties, including:

Social Media / Identity Platforms: If you choose to link or sign in using a third-party account (such as Apple, Google, or Facebook), we may receive information from that platform in accordance with your privacy settings.

Analytics / Attribution Providers: We work with analytics and attribution providers that help us understand how users engage with our Services and measure installations and performance (see Section 5.1).

2.5 Cookies and Similar Technologies
We use cookies, pixels, and similar tracking technologies primarily on our website and in email communications (for example, to understand website usage or whether an email was opened or clicked). For more information, please see Section 9 (Cookies and Tracking Technologies).

3. HOW WE USE YOUR INFORMATION
We use the information we collect for the following purposes:

3.1 To Provide and Operate the Services
- Create and manage your account.
- Provide Sparrow Coach functionality, including coaching features, video -capture/upload, and performance statistics.
- Provide leaderboards and other social features, where enabled.
- Process transactions and manage subscriptions (including in-app purchases).
- Provide customer support and respond to your inquiries.
- Personalize your experience based on your preferences and usage patterns.

3.2 To Improve and Develop the Services
- Analyze usage patterns and trends to understand how users interact with the Services.
- Identify and fix bugs, errors, and technical issues.
- Improve performance, reliability, and user experience.
- Develop new features, products, and services.

3.3 Video and Performance Verification / Improvement
We may use videos and related data to help verify the accuracy of performance statistics generated by the Services (including real-time statistics, where applicable) and to improve our Services and related products.

3.4 Safety and Security
- Detect, prevent, and address fraud, abuse, security risks, and technical issues.
- Enforce our Terms of Service and other policies.
- Protect the safety of our users and the integrity of the Services.
- Comply with legal obligations and respond to lawful requests.

3.5 Communications
- Send you service-related communications, such as account verification, technical notices, updates, and security alerts.
- Send you promotional communications about new features, products, or offers (with your consent where required by law).
- Respond to your comments, questions, and requests.

3.6 Legal Compliance
Comply with applicable laws, regulations, and legal processes; respond to lawful requests from public authorities (including law enforcement); and protect our legal rights and interests.

4. HOW WE SHARE YOUR INFORMATION
We may share your information in the following circumstances:

4.1 Service Providers and SDKs
We share information with third-party vendors and service providers who perform services on our behalf, such as cloud hosting, data storage, subscription management, payment processing, analytics, crash reporting, push notifications, customer support, and email delivery. These providers are contractually obligated to protect your information and may only use it to provide services to us.

SDK Disclosure: The App may include third-party software development kits (“SDKs”) that collect information to provide functionality such as analytics, crash reporting, push notifications, subscriptions/in-app purchases, and attribution/measurement. Our SDKs may include:

- Analytics: Amplitude, Firebase Analytics, AppsFlyer, Facebook
- Crash Reporting: Firebase Crashlytics
- Push Notifications: OneSignal
- In-App Purchases / Subscriptions: RevenueCat
- Attribution / Measurement: AppsFlyer, Facebook SDK

4.2 Social and Public Sharing (Based on Your Settings)
Depending on your privacy settings and how you use the Services, information and data about you and your performance statistics—including when and where you use the Services and any videos you create—may be visible to other users and/or the public. Other users may be able to download or export content you make available to them and share it outside the Services, and such sharing may or may not respect your privacy settings.

4.3 School / End User Accounts (If Applicable)
If you are using an End User Account as defined in a “Service Subscription Agreement for Schools” between your school and us, certain information and data about you, your performance statistics, and related content (including videos) may be accessed, amended, or deleted by the school. The school may also be able to change your privacy settings to restrict disclosure of such information and data.

4.4 Business Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of company assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your personal information as required by law.

4.5 Legal Requirements
We may disclose your information if required to do so by law or in response to valid legal requests, including:
- Complying with a subpoena, court order, warrant, or other legal process.
- Responding to requests from government or law enforcement authorities.
- Protecting our rights, property, or safety, or that of our users or others.
- Investigating potential violations of our Terms of Service.

4.6 With Your Consent
We may share your information for other purposes with your explicit consent.

4.7 Aggregated or De-Identified Information
We may share aggregated or de-identified information that cannot reasonably be used to identify you. This information may be used for industry analysis, research, marketing, or other business purposes.

5. DATA RETENTION
We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Retention periods vary depending on the type of information and how it is used.

Account Information: Retained for the duration of your account and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements.

Videos and Performance Data: Retained as necessary to provide the Services (including generating and verifying performance statistics), maintain the integrity of the Services, and comply with legal obligations. You may be able to delete certain content through the Services or by contacting us (see Section 8).

Usage Data and Diagnostics: Generally retained in identifiable form for a limited period and may be retained in aggregated or de-identified form for longer to improve the Services.

Payment and Subscription Records: Retained as required by tax, accounting, and other legal obligations.

When we no longer need your information, we will securely delete or anonymize it in accordance with our retention policies and applicable law.

6. DATA SECURITY
We implement appropriate technical and organizational security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures may include access controls, encryption in transit, and operational security procedures.

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials.

7. COOKIES AND TRACKING TECHNOLOGIES

7.1 Types of Cookies We Use (Website/Email)
- Essential Cookies: Required for the website to function properly.
- Analytics Cookies: Help us understand how users interact with our website and communications.
- Functionality Cookies: Remember preferences and settings on the website.

7.2 Your Cookie Choices
You can manage cookie preferences through:
- Your browser settings (note: disabling cookies may affect website functionality); and/or
- Any cookie consent tools we provide on the website (where applicable).

7.3 Do Not Track
Our website does not currently respond to “Do Not Track” signals.

7.4 App Tracking Transparency (Apple ATT)
We do not “track” you as Apple defines tracking unless we explicitly disclose otherwise and, where required, request your permission through Apple’s App Tracking Transparency framework. If we engage in activities that require ATT permission, we will present the ATT prompt and honor your choice.

8. YOUR PRIVACY RIGHTS
Depending on your location, you may have certain rights regarding your personal information.

8.1 Rights for All Users
- Access: Request access to the personal information we hold about you.
- Correction: Request correction of inaccurate or incomplete personal information.
- Deletion: Request deletion of your personal information, subject to certain exceptions.
- Account Deletion: Request deletion of your account through the app settings (if available) or by contacting us.
- Marketing Opt-Out: Opt out of marketing communications by clicking “unsubscribe” in emails or adjusting your notification settings where available.

8.2 Exercising Your Rights
To exercise your rights, please contact us at:
Privacy/Support Email: coach@sparrowup.com

We will respond within the timeframe required by applicable law and may need to verify your identity before processing your request.

9. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)
If you are a California resident, you may have additional rights under the CCPA/CPRA, including:
- Right to know (categories and specific pieces of personal information collected).
- Right to delete (subject to exceptions).
- Right to correct.
- Right to opt out of sale/sharing (as defined by California law, where applicable).
- Non-discrimination for exercising your rights.
- Sparrow does not sell your personal information and does not share personal information for cross-context behavioral advertising as defined by the CCPA/CPRA, except to the extent such definitions may apply to certain third-party SDK configurations used for analytics or attribution/measurement.

To exercise your California privacy rights, contact us at coach@sparrowup.com.

10. OTHER STATE PRIVACY RIGHTS
Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have similar rights to those described for California residents. Please contact us to exercise your rights under applicable state law.

11. CHILDREN’S PRIVACY
Protecting the privacy of young children is especially important.

11.1
The Services are a general-audience service not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13 unless:

(a) it is through Minor Accounts as defined in a “Service Subscription Agreement for Schools” between a school and us, in which case we rely on the school’s consent (on behalf of, or in lieu of, parents where applicable) to enable us to deliver services to these users in accordance with the Children’s Online Privacy Protection Act (COPPA); or

(b) a parent has given us express consent in accordance with COPPA, in which case any information we collect from these users under 13 will be used for internal purposes only.

11.2
If a school or parent wishes to access, amend, or delete information we have collected from a user under 13, or exercise consent choices, they may contact us at coach@sparrowup.com.

12. THIRD-PARTY LINKS AND SERVICES
The Services may contain links to third-party websites, applications, or services. This Privacy Policy does not apply to any third-party services. We are not responsible for the privacy practices of third parties. We encourage you to read the privacy policies of any third-party services you visit.

13. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. When we make material changes, we will notify you by updating the “Last Updated” date at the top of this policy and, where required by law, by providing additional notice (such as email notification or in-app notification). Your continued use of the Services after any changes constitutes your acceptance of the updated Privacy Policy.
We encourage you to review this Privacy Policy periodically to stay informed about our data practices.

14. CONTACT US
If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:
Sparrow Vision, Inc.
Email: coach@sparrowup.com
Mailing Address: 64 Beaver Street, Suite 203, New York, NY 10004