Privacy Policy

Leads Under Control LLC ("SparkBNB," "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 SparkBNB platform ("Platform").

1. Information We Collect

Information You Provide

• Account information: Name, email address, phone number, password
• Profile information: Profile photo, bio, languages spoken (Cleaners)
• Property information: Address, property type, size, access instructions, photos
• Payment information: Credit/debit card details (processed and stored by Stripe, not by us), bank account information for payouts (processed by Stripe Connect)
• Identity verification (Cleaners): Government-issued ID, selfie, proof of address, date of birth, and signed IRS Form W-9 (including Social Security Number or Employer Identification Number)
• Insurance verification (Cleaners): Certificate of Insurance (COI) showing liability coverage amount and expiry date
• Consents & acknowledgments: Terms of Service, Privacy Policy, Contractor Agreement, background-check consent, SMS/TCPA consent, W-9 tax certification, equipment acknowledgment, and cleaning-manual read acknowledgment — each recorded with a timestamp
• Communications: Messages between Hosts and Cleaners, support inquiries

Information Collected Automatically

• Device information: Device type, operating system, browser type, screen resolution
• Usage data: Pages visited, features used, time spent, clicks, interactions
• Location data: GPS coordinates (Cleaners, for check-in verification — only when the app is in use)
• IP address: For security, fraud prevention, and approximate geolocation
• Cookies: Session cookies, preference cookies, and analytics cookies

2. How We Use Your Information

We use collected information to:

• Provide the Platform: Match Hosts with Cleaners, process bookings, facilitate payments
• Verify identity: Background checks (via Checkr), identity verification, fraud prevention
• Process payments: Charge Hosts, pay Cleaners, process refunds (via Stripe)
• Communicate: Send booking confirmations, reminders, completion notifications via email, SMS, and push notifications
• Improve the Platform: Analyze usage patterns, fix bugs, develop new features
• Ensure safety: GPS check-in verification, completion photo documentation
• Resolve disputes: Review completion photos, messages, and booking details
• Comply with law: Respond to legal requests, enforce our Terms, report as required

3. Information Sharing

We share your information with:

We do NOT sell your personal information. We do not share your data with advertisers, data brokers, or any third party for marketing purposes.

4. Data Security

• All data transmitted to and from the Platform is encrypted using TLS 1.3
• Payment card information is processed by Stripe (PCI DSS Level 1 certified) and never touches our servers
• Passwords are hashed using industry-standard algorithms (bcrypt via Supabase Auth)
• Access to personal data is restricted to authorized personnel only and logged
• We conduct regular security reviews and vulnerability assessments
• Identity verification documents and signed W-9 forms are stored in a private, access-controlled bucket; only the uploading Cleaner and SparkBNB administrators with legitimate need may retrieve them
• Sensitive tax information (full SSN/EIN) is stored only within the signed W-9 PDF. The database retains only the last four digits of the tax identifier plus a type flag (SSN or EIN) for display purposes. Full identifiers are never shown in any user-facing screen, log, email, or support ticket

5. Data Retention

• Active accounts: Data is retained as long as your account is active
• Deleted accounts: Personal data is deleted within 30 days of account deletion, except as required by law or legitimate business need (see rows below)
• Tax records (Cleaners): Signed W-9 forms and 1099-NEC records are retained for 7 years as required by IRS regulations
• Booking and payment records: Retained for 3 years for dispute resolution, chargeback windows, and legal compliance
• Dispute and strike records: Retained for 2 years after resolution
• Completion photos: Retained for 90 days after job completion, then deleted
• Identity documents and COIs: Retained while account is active + 30 days after deletion
• Background-check results: Retained per Fair Credit Reporting Act (FCRA) requirements, minimum 5 years
• Audit logs (admin actions): Retained for 3 years for security and compliance

6. Your Rights

All Users

• Access: Request a copy of the personal data we hold about you
• Correction: Update or correct inaccurate information
• Deletion: Request deletion of your account and personal data
• Portability: Request your data in a machine-readable format
• Opt-out: Unsubscribe from marketing communications at any time

California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights:

• Right to know what personal information we collect and how it is used
• Right to delete your personal information
• Right to opt out of the sale of personal information (we do not sell your data)
• Right to non-discrimination for exercising your privacy rights
• Right to limit use of sensitive personal information

Florida Residents

Florida residents may have additional rights under the Florida Digital Bill of Rights (effective July 1, 2024), including the right to access, delete, and correct personal data.

7. Cookies and Tracking

We use cookies for:

• Essential cookies: Login sessions, security, preferences (cannot be disabled)
• Analytics cookies: Understanding how users interact with the Platform (can be disabled)

We do NOT use advertising cookies or cross-site tracking. You can manage cookie preferences through your browser settings.

8. Children's Privacy

The Platform is not intended for users under 18 years of age. We do not knowingly collect personal information from minors. If you believe we have collected information from a minor, please contact us immediately.

9. International Users

The Platform is operated from the United States. If you access the Platform from outside the US, your information will be transferred to and processed in the United States. By using the Platform, you consent to this transfer.

10. SMS Communications

By providing your phone number to SparkBNB, you consent to receive transactional SMS/MMS messages from us, including: account verification and security codes, booking confirmations, reminders, and status updates (cleaner on the way, check-in, completion, dispute, and payout notifications), and occasional operational updates about the service.

Message frequency: varies based on your activity — typically 2–8 messages per booking, and fewer than 20 messages per month for active users. Low-activity accounts may receive only 1–2 messages per month.

Message and data rates may apply depending on your mobile carrier and plan. SparkBNB does not charge for messages; your carrier may.

Opt-out: Reply STOP to any SparkBNB text to unsubscribe from non-critical messages. Reply HELP for help, or email hello@sparkbnb.com. Critical transactional notifications (e.g., account security, dispute resolution) may continue via email or in-app after an SMS opt-out.

Mobile information — including phone numbers, message content, and opt-in status — is never sold, rented, or shared with third parties for their marketing purposes. SparkBNB uses Telnyx as its messaging provider to deliver SMS on our behalf; Telnyx's handling of message traffic is governed by its own privacy policy.

No marketing or promotional SMS messages are sent without a separate, explicit opt-in outside of this transactional scope.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify registered users of material changes via email. The "Last updated" date at the top indicates the most recent revision.

12. Contact Us

For privacy inquiries, data requests, or concerns:

• Email: privacy@sparkbnb.com
• Leads Under Control LLC
• Pompano Beach, FL 33060

We will respond to privacy requests within 30 days.