Privacy Policy

Last Updated: February 3, 2026

This Privacy Policy describes how LUMINO STRATEGIES LIMITED ("we," "us," or "our") collects, uses, and discloses your personal information when you visit or use quickspark.club (the "Platform" or "Service"). We operate in strict accordance with the General Data Protection Regulation (GDPR), the UK Data Protection Act 2018 (UK GDPR), and the California Consumer Privacy Act (CCPA/CPRA).

Entertainment Disclosure: This Platform is for entertainment purposes. You are interacting with fictitious, simulated profiles. Data processed during these interactions is used to maintain the simulated environment and improve the entertainment experience. Physical meetings with these profiles are not possible.

1. Who we are

The company responsible for the Service is LUMINO STRATEGIES LIMITED, registered in England and Wales under registration number: 16657374.

Registered Office: Suite Ra01, 195-197 Wood Street, London, United Kingdom, E17 3NU
Data Controller: LUMINO STRATEGIES LIMITED
Email: [email protected]

2. Definitions

Account: a registration on the Service, which enables Visitors to establish contact with fictional Profiles;
Controller: the natural or legal person which determines the purposes and means of the processing of personal data;
Device: a computer, mobile, or other internet enabled device used to access the Service;
Member: an end user of the Service who has completed registration;
Personal Data: any information relating to an identified or identifiable natural person;
Profile: a description of a Member, including personal details, pictures, and chat history;
Processing: any operation performed on personal data, such as collection, storage, or use;
Special Categories of Personal Data: data revealing racial/ethnic origin, religious beliefs, health data, or data concerning a person's sex life/sexual orientation.

3. Information We Collect

We collect information you provide directly and information generated automatically during your use of the Service:

Account Data: Username, email address, password (stored in hashed format), age, and gender.
Profile Content: Bio details, interests, physical attributes, and any photos you choose to upload.
Transaction Data: Payment amount, date, and method. We do not store full credit card numbers; these are handled by PCI-DSS compliant processors.
Technical Data: IP address, device type, operating system, browser version, and ISP details.
Communication Data: Full logs of your chats and interactions with simulated profiles.

4. Legal Bases for Processing

Under GDPR and UK GDPR, we only process data with a valid legal basis:

Contractual Necessity: To provide the service, manage your account, and facilitate the chat environment.
Consent: Specifically for processing Special Categories of Data (if provided in your profile) or for marketing communications.
Legal Obligation: To verify your age (18+) and comply with anti-fraud or tax regulations.
Legitimate Interests: To improve our platform, ensure network security, and prevent abuse of our terms.

5. Data Retention

Active Accounts: We store your data as long as your account remains active.
Inactivity: Accounts inactive for 90 days are flagged for deletion.
Payment Logs: Retained for 7 years to comply with UK and EU tax and accounting laws.
Chargeback Evidence: Specific transaction data is kept for 121 days to handle potential disputes.

6. Notice for California Residents (CCPA/CPRA)

If you are a resident of California, you have specific rights regarding your "Personal Information" (PI):

Right to Know: You can request disclosure of what PI we collect, the sources, and how we use it.
Right to Delete: You can request the deletion of your PI, subject to legal exceptions (like tax or fraud records).
Right to Opt-Out: We do not sell your PI for monetary value. We only share data with service providers to operate the site.
Right to Correct: You can ask us to rectify inaccurate personal information.
Limit Use of Sensitive PI: You can restrict our use of sensitive data to only what is necessary to provide the Service.

To exercise these rights, email [email protected] with the subject "CCPA Request".

7. International Data Transfers

Our servers and service providers (including Google Cloud) may be located outside of your country of residence. When we transfer data outside the UK or EEA, we ensure protection through:

Standard Contractual Clauses (SCCs) approved by the European Commission and the UK ICO.
Technical encryption and strict access controls.

8. Security Measures

We implement robust security to protect your data:

Encryption: SSL/TLS encryption for all data in transit.
Hashing: Use of Bcrypt for all user passwords (making them unreadable).
Access Control: Two-factor authentication (2FA) for internal administrative access.
Infrastructure: Firewalls and regular automated backups.

9. Your Rights (Europe & UK)

You have the following rights regarding your Personal Data:

Access: Request a copy of the data we hold about you.
Rectification: Correct inaccurate or incomplete information.
Erasure: The "Right to be Forgotten" — requesting deletion of your account and data.
Portability: Receive your data in a structured, machine-readable format.
Restriction: Limit how we process your data in certain circumstances.

10. Children’s Privacy

QuickSpark is strictly for adults (18+). We do not knowingly collect data from anyone under the age of 18. If we discover an account belongs to a minor, it will be terminated immediately and all associated data deleted.

11. Contact & DPO

For any questions regarding this policy or to exercise your privacy rights, please contact our Data Protection Officer:

LUMINO STRATEGIES LIMITED
Suite Ra01, 195-197 Wood Street,
London, United Kingdom, E17 3NU
Email: [email protected]