Privacy Policy

Welcome to Entangled (Pte. Ltd.).

Entangled (Pte. Ltd.) (‘ENTANGLED’, ‘we’, ‘us’, ‘our’) are committed to protecting and respecting your personal data privacy and complying with data protection principles and provisions under applicable laws.

We may collect, process, use and disclose your information when you use this website and/or the Sparks App (together, Sparks Platform’) and the services offered by Entangled or the third-party operators (the ‘Merchants’) through Sparks Platform (the ‘Services’) as described in this Privacy Policy. ‘You’ and ‘your’ when used in this Privacy Policy includes any person who accesses Sparks Platform or use the Services.

This Privacy Policy sets out the basis and terms upon which Entangled collects, processes, uses and/or discloses your information that is obtained from you when you access Sparks Platform and/or use the Services. Such information may include personal information relating to or linked to a specific individual such as name, telephone number, email address, date of birth, or any such information we have requested, and you have provided through Sparks Platform (‘Personal Information’).

Please read this Privacy Policy carefully. By visiting Sparks Platform, you are consenting to the collection, processing, usage, and disclosure of your Personal Information as set out in this Privacy Policy.

Scope of Terms

  • Entangled reserves the right to update, amend or modify the terms of this Privacy Policy or any part of it without prior notice, and your continued access of Sparks Platform or use of the Services signifies your acceptance of the updated, amended, or modified Privacy Policy, unless if the changes reduce your rights in which case we will ask for your consent. If you do not agree to all the terms and conditions in this Privacy Policy and/or any subsequent updates, amendments, or modifications thereto, you must stop accessing or otherwise using Sparks Platform and the Services.
  • Accordingly, please visit this page if you wish to access and view the current version of this Privacy Policy.

Collection of Information

We may collect Personal Information about you that you provide to us while using Sparks Platform and information about how you use
Sparks Platform including when you open your user account (‘User Account’), visit Sparks Platform, or make reservations and/or bookings for any intended Services or using the Services. Providing your Personal Information to Entangled is always on a voluntary basis. However, we might not be able to provide you with certain Services if you choose not to give us your Personal Information.
For example, we cannot open your user account or make reservations and/or bookings for you if we do not collect your name and contact details.

  1. Opening Your User Account: When you open with us a User Account or amend any information of your User Account, we may collect your Personal Information, such as your Name, Email Address, Phone Number, Precise Location, Emails or Text Messages, Photos or Videos, Customer Support, User ID, Device ID, Product Interaction, Crash Data. The rationale for collecting these information are as follows:
    • Name
      • Used for App Functionality, and Product Personalization
      • Linked to the user’s identity.
    • Email Address
      • Used for Developer’s Advertising or Marketing, Analytics, Product Personalization, and App Functionality
      • Linked to the user’s identity.
    • Phone Number
      • Used for App Functionality, and Product Personalization
      • Linked to the user’s identity.
    • Precise Location
      • Used for App Functionality, and Product Personalization
    • Emails or Text Messages
      • Used for App Functionality, Product Personalization, and Developer’s Advertising or Marketing
      • Linked to the user’s identity.
    • Photos or Videos
      • Used for App Functionality
      • Linked to the user’s identity.
    • Customer Support
      • Used for Product Personalization, and App Functionality
      • Linked to the user’s identity.
    • User ID
      • Used for Product Personalization, Analytics, Developer’s Advertising or Marketing, and App Functionality
      • Linked to the user’s identity.
    • Device ID
      • Used for Product Personalization, Analytics, and App Functionality
      • Linked to the user’s identity.
    • Product Interaction
      • Used for Product Personalization, Developer’s Advertising or Marketing, App Functionality, and Analytics
      • Linked to the user’s identity.
    • Diagnostics
      • Used for Analytics, and App Functionality
  2. Visit Sparks Platform, Making Reservations, and/or Bookings for the Services or using the Services:

o   When you visit Sparks Platform (even when you have not registered a User Account or logged in), to make reservations, and/or bookings for any intended Services or use the Services, we may collect and process certain information (which may contain your Personal Information or may contain non-personally identifiable information but nevertheless linked to your Personal Information) including but not limited to those set out below: 

    1. Copies of correspondence (whether by e-mail, instant or personal messaging or otherwise) between you and us, and between you and the Merchants; Information necessary to fulfil your reservations, and/or bookings
    2. with us and our Merchants (including but not limited to information, age, and date of birth);
    3. Details of your usage of Sparks Platform (including traffic data, location data and length of user sessions);
    4. Feedback on and responses to surveys conducted by Entangled relating to the  Services and newsletters which may be published, circulated or distributed by Entangled;
    5. Information automatically collected and stored in our server or the server of our third party services provider by using or accessing to Sparks Platform (including the log-in name and password for your User Account, your computers Internet Protocol (IP) address, browser type, browser information, device information (including unique device identifier), pages visited, previous or subsequent sites visited).

3. When you use your mobile devices to visit Sparks Platform, we may collect information about you and your mobile device as stated above. This can include location information if you have consented and configured your mobile device to send us such information or upload photos with location information to Sparks Platform. Such location information will be used in the ways and for the purposes as stated in this Privacy Policy. For example, we may use your location to suggest nearby Services or provide personalised content. You can change your mobile device’s privacy settings at any time to deactivate the function of sharing location information. Please note some features of Sparks Platform may be affected if you turn off such location sharing function. Should you have any enquiries about your mobile devices’ privacy settings, we recommend you contacting your mobile services provider or the manufacturer of your device.

If you make reservations, and/or bookings for other individuals through the Sparks Platform, we may request personal information about such individual. You must obtain all requisite consent of such individuals and ensure they are aware of, understand and accept this Privacy Policy prior to providing their personal data to Entangled.

 Storage of Information

The Personal Information and other data we collect from you may be transferred to, processed, and stored in our servers or the servers of our third-party services providers. Your Personal Information will be stored as long as is necessary to fulfil any of the purposes described in this Privacy Policy, or to comply with any (i) contractual requirement that are necessary for the provision of the Services,
and (ii) legal, tax or accounting requirement.

When it is no longer necessary for us to process your Personal Information, we will either delete or anonymise the data or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information.

We will endeavour to anonymise or aggregate your data if we intend to use it for analytical purposes or trend analysis.

Entangled will use reasonable endeavours to maintain appropriate physical, electronic and organisational procedures to ensure that your Personal Information and other data is treated securely and in accordance with this Privacy Policy, and to protect such data against unauthorized access or unauthorized alteration, disclosure or destruction of data.

Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. Entangled does not give any representation, warranty or undertaking that the Personal Information you provide to us will be secure at all times, and to the extent Entangled has fulfilled its obligations under no circumstances shall Entangled be responsible for any losses, damages, costs and expenses which you may suffer or incur arising from unauthorised access to or use of your Personal Information.

All payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using online encryption technology. We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

You are responsible for keeping your chosen password confidential and not to share your password with any third party.

Usage of Information

We process the Personal Information collected in as far as necessary for performance of the contract with and providing services to you. Besides, we process the other Personal Information collected on the basis of our legitimate interests, which are the further improvement of the services and for direct marketing purposes.

For example, Entangled will use Personal Information and other data collected through Sparks Platform or when making purchases for the Services to create your User Account, to fulfil your reservations, and/or bookings for the Services, to provide you with the Services, to continually improve Sparks Platform and the Services, and to contact you in relation to the Services. This includes using your Personal Information or such other data to achieve faster purchase requests, better customer support and to provide you with timely notice of new Services and special offers.

From time to time, we may also make use of your Personal Information to contact you for feedback on your use of Sparks Platform, to assist us in improving Sparks Platform, or to offer special savings or promotions to you, where you have indicated your consent to receiving such communications. If you would prefer not to receive notices of special savings or promotions, you may simply opt-out from receiving them.

Disclosure of Information

We may from time to time share and disclose your Personal Information and other data to third parties, some of whom may be located outside your home country. The circumstances under which such sharing and disclosure will take place may include without limitation, the following:

  1. To successfully complete your reservations, and/or bookings, or to otherwise implement our Terms of Use. We may share your information with Merchants or third parties (including but not limited to our activity providers, restaurants, shops, amusement parks, etc.), both within and outside your home country, who deliver or provide goods and services or otherwise act on our behalf.
  2. If you are a visitor, to the relevant Merchant in connection with a Services which you have made reservations, and/or bookings for or intend to make reservations, rentals, and/or bookings for.
  3. If you are a Merchant, to any visitor in connection with the Services you are offering.
  4. To our third-party service providers (including Google Analytics), which we engage amongst others for the performance of certain services on our behalf, such as web hosting services, data analysis, marketing, market research, and to otherwise provide you with customer service.
  5. If and to the extent required by any applicable law, order of court or requests by any governmental authority to make such disclosure.
  6. In case of a corporate transaction, in connection with the sale, merger, acquisition, or other corporate reorganization or restructuring of our corporation, your Personal Information may be disclosed, shared or transferred to the new controlling entity or its authorised third party for carrying on our business.
  7. To our advisors, agencies or other parties concerned in order to protect the rights and property of Entangled.
  8. In any other case, to any third parties with your prior written consent (and in which case we will make it possible for you to withdraw your consent as easily as it was to provide consent).

We may also share aggregate or anonymous information with relevant third parties, including our advertisers. Such information does not contain any Personal Information and will not identify you personally. However, on some occasions, these third parties may possess information about you or obtain your information from other sources. When they combine such information with our aggregate information, they may be able to identify you personally.

Your Personal Information may be transferred outside of your home country and outside of the European Union, for the above mentioned purposes. If such transfer takes place to a country that does not provide an adequate level of protection, Entangled will use reasonable endeavours to ensure that appropriate safeguards are in place. Such safeguards include but are not limited to (i) standard contractual clauses of the European Commission; (ii) the EU-US and Switzerland-US privacy shield; and/or (iii) any other appropriate cross-border transfer mechanisms.

There may be links present on Sparks Platform which could result in you leaving Sparks Platform and/or being taken to other third-party websites. You should note that any Personal Information that you provide to these third-party websites are not subject to this Privacy
Policy, and Entangled is not liable for any losses, damages, costs or expenses which you may suffer or incur in connection with you providing or making available Personal Information or other data to such third party websites.


Cookies are widely used in order to make websites work or work more efficiently. When you visit our Website, we collect some of your Personal Information transmitted to us by your browser via cookies. This enables you to access Sparks Platform and helps us to create better user experience for you.

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use or may use:

  1.       Session Cookies: We use Session Cookies to operate our Service.
  2.       Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
  3.       Security Cookies: We use Security Cookies for security purposes.
  4.      Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.



Your rights

You may at all times access, correct or erase your Personal Information through Sparks Platform via the user portal, under “My Account”. Alternatively, you may make your data access, correction or erasure request by sending your request by email at

Where mandatory under applicable legislation, you may also request restriction of processing of your Personal Information or object to processing by sending your request or objection by email at You may also request a copy of the information that we hold about you by sending your request by email at

Please contact us via the contact details mentioned below if you have a complaint regarding the processing of your Personal Information.

When handling any of these requests described above, we have the right to check the identity of the requester to ensure that he/she is the person entitled to make the request.


If you have any questions about this Privacy Policy, please contact us by email at

Last updated on: 03 May 2021.