Effective Date: 10/03/2025

1) Who We Are

Spark Leads, LLC (“Spark Leads,” “we,” “us”) provides luxury client acquisition through short‑form video, automated Instagram funnels, concierge nurture, and attribution/reporting systems for med spas, salons, clinics, and other premium service providers. Spark Leads is a subsidiary of Monarch Bay Capital, LLC, a Wyoming holding company.

This Privacy Policy explains how we collect, use, share, and protect information in connection with our Services, websites, and operations.

2) What Information We Collect

We collect the following types of information:

Client Business Data — names, emails, phone numbers, billing info, business performance data (revenue, CAC, LTV), booking calendars, and social media handles.

Platform & Technical Data — login tokens, access permissions, analytics dashboards, cookies, IP addresses, device/browser info, and logs.

Leads/End‑Customer Data (on behalf of Client) — names, booking times, service interests, and contact details collected via Instagram DM flows, booking links, or Spark phone lines.

Booking Metadata — unique booking event identifiers, Arrived Tap logs (timestamp, device/IP), credit issuance/redemption, and disputes recorded in the Spark Ledger.

Deposit Status — confirmation of deposit payments processed through Client’s approved processor (Stripe, Square, etc.), tied to booking identifiers. Spark Leads does not store card numbers or funds.

Sensitive Data — we do not want or collect protected health information (PHI) or other sensitive categories as defined under HIPAA, GDPR, or similar.

3) How We Use Information

We use information to:

• Deliver and improve Services, including content production, booking funnels, DM automation, and reporting.

• Verify deposits, validate Shows, and enforce attribution and anti‑gaming rules.

• Issue and track Client Credits and Brand Credits.

• Communicate with Clients regarding Services, billing, updates, and support.

• Prevent fraud, enforce edit locks, and conduct audits.

• Market and promote Spark Leads, including using non‑confidential Client results in portfolios or case studies.

4) Sharing & Disclosure

We do not sell personal information. We may share limited data with:

• Vendors/Service Providers — processors, hosting, analytics, SMS/email platforms.

• Platforms — Instagram, Meta, TikTok, YouTube, etc., to execute campaigns.

• Legal/Regulatory — when required by law or subpoena.

• Affiliates — Monarch Bay Capital, LLC and related controlled entities.

All third parties are contractually limited to authorized use only.

5) Data Security & Account Protection

We use commercially reasonable safeguards, but no system is 100% secure. Clients are responsible for securing their accounts (MFA, password rotation, limiting admin access, revoking staff access). If accounts are hacked, Spark Leads is not liable (see §14A of our Terms).

6) Data Retention

• Booking metadata, credit records, and Spark Ledger reports are retained for audit, dispute, and billing purposes.

• Deposits are verified via integrations but not stored by Spark Leads.

• Client data may be deleted upon written request, subject to legal or contractual obligations.

7) Rights & Choices

Depending on your location, you may have rights to:

• Access, correct, or delete personal data we hold.

• Opt‑out of certain processing or marketing.

• Request portability of your data.

Requests can be made to support@sparkleads.agency. Verification may be required.

8) Cookies & Tracking

Our sites use cookies and pixels for analytics, booking flow optimization, and campaign measurement. You may disable cookies in your browser, though some features may not function properly.

9) Children’s Privacy

We do not knowingly collect information from anyone under 18. If we discover we have, it will be deleted.

10) International Transfers

If you access Services outside the U.S., your data may be processed in the U.S. where laws differ. Safeguards are applied consistent with applicable law.

11) Audit & Compliance Rights

• Spark Leads retains read‑only access to appointment metadata for validation.

• We may perform spot audits or POS/calendar cross‑checks to confirm Shows and credit eligibility.

• Clients must cooperate with onboarding requirements, quarterly refreshes, and dispute timelines.

12) Updates to This Policy

We may update this Privacy Policy periodically. Updates will show a new Effective Date. Continued use of our Services after updates constitutes acceptance.

13) Contact Us

Spark Leads, LLC Email: support@sparkleads.agency