Privacy Policy

Services Covered and User Types

We provide several categories of services:

• Platform Services — Make, Eddy, Play, and associated mobile applications (iOS and Android): tools for creating, editing, and publishing audio and video content, playing and distributing podcasts, generating transcripts and captions, and managing media. The Headliner Dashboard is available to users across all service tiers, providing analytics, reporting, and management capabilities for Platform, Discovery, and Promotion Services.
• Discovery Services — Embedded Disco widgets deployed on third-party publisher websites.
• Promotion Services — Podcast Promo and related advertising and distribution tools.

This Policy applies to all user types:

• Account Users: Individuals or organizations who register for an account to access any of the Services.
• Publishers: Organizations or individuals who embed Disco widgets on their own websites.
• Visitors / End Users: Individuals who interact with embedded Disco widgets on Publisher websites, typically without creating a Headliner account.
• Advertisers: Individuals or organizations that promote podcasts through Podcast Promo.

Data Processing Roles

Customers and publishers may request a Data Processing Agreement (DPA) by contacting us at info@sparemin.com.

• Platform & Promotion Services: Sparemin acts as the data controller for personal information collected directly to provide and operate these Services.
• Discovery Services (Embedded Widgets): Sparemin acts as a service provider or data processor on behalf of the Publisher, who is the data controller in that context.

Information We Collect

3a. Account & Identity Information

When you create an account or contact us, we collect:

• Name, email address, and organization name.
• Login credentials (managed securely; we do not store plaintext passwords).
• Authentication information if you use single sign-on services (e.g., Google Sign-In or Apple Sign-In).
• Billing identifiers — payments are processed via Stripe. We receive a Stripe customer ID but do not store your full credit card number or payment details.

3b. Content Data

When you use Platform Services, we collect:

• Audio, video, images, transcripts, captions, and project metadata that you upload to or create within the Services.
• Software usage data, including mouse movements, clicks, and keyboard interactions, to improve the editing experience.

3c. Technical & Usage Data

We automatically collect technical information including:

• IP address, device type, operating system, and browser type and language.
• Referring and exit pages, URLs, access timestamps, and session duration.
• Feature usage data, widget impression and click data, and log files.

3d. Approximate Location

We derive a general geographic location (country or region) from your IP address to provide region-specific features and to comply with applicable laws. For certain mobile features, we may request more precise geolocation with your consent.

3e. Social Media & Third-Party Account Information

If you connect to the Services using a third-party social media account (e.g., Facebook, X, Instagram, YouTube, Threads, or Bluesky) or link a third-party service (e.g., Google Drive, YouTube, Zoom, Dropbox), we may collect:

• Authentication tokens and profile information made available by that service.
• For Google Drive: file titles, descriptions, and the ability to see and download files you select.
• For YouTube: ability to upload videos on your behalf. Use of YouTube API Services is subject to the YouTube Terms of Service and Google's Privacy Policy. You may revoke the Service's access at any time via Google's security settings page.

3f. Voluntary Information

You may voluntarily provide additional information such as your professional role, organization type, or product preferences.

How We Use Your Information

• To provide, operate, and maintain the Services.
• To process transactions and fulfill contractual obligations to you.
• To authenticate your identity and manage your account.
• To improve the Services through usage analysis, product development, and quality assurance.
• To send you service-related notices and transactional emails. These communications cannot be opted out of while your account is active.
• To communicate with you about optional features, renewals, or promotional offers only where you have authorized us to do so.
• To recommend podcasts and personalize your experience within Discovery Services, using your on-platform click behavior only.
• To analyze aggregated, de-identified data to understand usage patterns.
• To comply with applicable legal obligations and to protect the rights, property, and safety of Sparemin, our users, and the public.

How We Share Your Information

• Service Providers: Trusted third-party companies performing functions on our behalf. They access your information only as necessary and are contractually obligated to protect it.
• Third-Party Analytics & Monitoring: Google Analytics, Mixpanel, and Sentry help us understand usage and monitor service health. We do not share your information with these services for marketing purposes.
• Business Transfers: In the event of a corporate sale, merger, or similar event, your information may be part of the transferred assets. We will notify you as required by applicable law.
• Affiliates: Parent companies, subsidiaries, or entities under common control, for the purposes described in this Policy.
• Legal Requirements: When required by law or when we reasonably believe disclosure is necessary to protect rights, property, or safety.
• With Your Consent: When we have your explicit consent to share with third parties.
• Aggregated or De-identified Data: Information that cannot reasonably identify you, for lawful purposes.

Artificial Intelligence (AI) Features

• Paid Users: Content uploaded by paid subscribers is not used to train machine learning models.
• Free-Tier Users: Content may be used in aggregated or de-identified form to improve machine learning systems and product features.
• Third-Party AI Processors: We may use providers such as OpenAI and AssemblyAI to process content. These providers may not use your content to train their own models beyond what is permitted under data processing agreements.
• Accuracy Disclaimer: AI-generated outputs may contain inaccuracies. You are responsible for reviewing and verifying AI-generated content before publishing or distributing it.

Cookies, Tracking, and Do Not Track

7a. Cookies

Platform Services use session and persistent cookies for authentication, security, and session management. If you disable cookies, some features may not function properly.

7b. Discovery Services Tracking

7c. Social Plug-ins

Your interactions with social plug-ins are governed by that platform's privacy policy: Facebook, Instagram, X, LinkedIn, TikTok, YouTube, Threads, and Bluesky.

7d. Do Not Track

We do not track users across third-party websites for targeted advertising and therefore do not respond to browser "Do Not Track" signals.

Data Retention

• Account Information: Retained for the duration of your account and a limited period afterward for legal, operational, or dispute-resolution purposes.
• Content Data: Retained while your account is active. Following account deletion, content data may be retained for up to 24 months before permanent deletion, unless you request earlier deletion.
• Logs & Analytics Data: Retained for up to 24 months for security and operations, or in de-identified form for ongoing product improvement.
• Legal Holds: We may retain data longer if required by law or in connection with actual or anticipated litigation.

To request earlier deletion of your data, please contact us at info@sparemin.com.

How We Protect Your Information

We implement technical and organizational safeguards including encryption in transit and at rest, access controls, and regular security reviews. No security system is impenetrable; we cannot guarantee absolute security.

In the event of a data breach likely to result in a high risk to your rights and freedoms, we will notify affected users and relevant authorities as required by applicable law.

International Transfers of Data

Sparemin's Services and servers are operated in the United States. If you are located outside the United States, your information may be transferred to, processed, and stored in the United States or other jurisdictions where our service providers operate.

For users in the European Economic Area (EEA), United Kingdom, or Switzerland, we rely on appropriate safeguards including Standard Contractual Clauses approved by the European Commission, where required.

Your Privacy Rights

11a. General Rights (All Users)

Depending on your location, you may have the right to access, correct, delete, or restrict the processing of your personal information. To exercise any of these rights, please contact us at info@sparemin.com.

11b. California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights:

• Right to Know: Request disclosure of categories and specific pieces of personal information collected about you in the past 12 months.
• Right to Delete: Request deletion of personal information we collected, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt-Out: We do not "sell" or "share" personal information for cross-context behavioral advertising. No opt-out request is needed.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

Submit a verifiable consumer request to info@sparemin.com. We will respond within 45 days (up to 90 with notice). No fee for reasonable requests.

11d. EEA, UK, and Swiss Residents (GDPR)

We process your personal data based on: Contract (performing our Services), Legitimate Interests (analytics, security, fraud prevention), Consent (optional marketing, geolocation), and Legal Obligation.

You have the right to access, correct, erase, restrict, or port your personal data, and to withdraw consent at any time. You also have the right to lodge a complaint with your local data protection authority.

Accessing, Correcting, and Managing Your Information

You may access, update, or delete your personal information by logging into your account or by contacting us at info@sparemin.com. To opt out of marketing emails, click the "unsubscribe" link in any Headliner marketing email. You will continue to receive essential service-related communications.

Children's Privacy

Our Services are not directed to children. We do not knowingly collect personal information from children under the age of 13 (or under 16 in certain jurisdictions, including EEA member states). If you believe a child has provided us with personal information, please contact us at info@sparemin.com.

Links to External Services

The Services may contain links to or integrations with third-party services. Sparemin has no control over the privacy practices of those services. You should review the applicable privacy policy before using those services.

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 posting the updated Policy on the Services and, where appropriate, sending a notification via email or in-app notice. Your continued use of the Services constitutes acceptance of the revised Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us: