Spark Growth Inc. Privacy Policy

The Spark Growth website and proprietary software platform (the “Service”) is owned and operated by Spark Growth Inc. (“Spark Growth”) and made available to our registered users. This Privacy Policy describes:


We encourage you to read this Privacy Policy and our Terms of Use (www.spark.app/terms-of-use) carefully. Capitalized terms used but not defined in this Privacy Policy have the meaning given them in the Terms of Use. We will post notices of all changes that materially affect the way in which your personally identifiable information may be used or shared in updates to our Privacy Policy.

This policy does not apply to the practices of those third-party plug-ins, exchanges, networks or websites that Spark Growth has a relationship with (the “Third Party Services”) or of our third party payment processor or other companies or individuals that Spark Growth does not own, employ, manage or control.

If you have any questions about this Privacy Policy, please feel free to contact us through our Service or write to us at Spark Growth Inc., [ADDRESS].

Information We Collect

The information we learn from users helps us not only provide the Service but also to continually improve each company’s experience with the Service. Here are the types of information we gather:

Information You Give Us

Personal Information: When you create an account with Spark Growth, we may ask you for certain limited personally identifiable information such as your name, company name and email address, which we will use to contact or identify you. You can choose not to provide us with any or all of the information we specify or request, but then you may not be able to register with us or to take advantage of some or all of our features.

User-generated Content: The content you upload to or create on the Service, such as text or image files or other media (“Content”), may when applicable be displayed to us and other authorized users along with associated metadata such as date, location and time created. Any Content that you make publicly available on the Services will be visible to the public. As with any profile information, you should exercise caution when uploading or creating Content that will be available to the public.

Automatic Information Collected

Like many other websites, we also collect information through cookies and other automated means. Information of this sort includes:

Technical information about your browser and mobile device: This information is used in the aggregate to help us optimize the Service for common browsers and devices.

Usage information, such as the features and emails from Spark Growth that you interact with: We collect and use this behavioral information and may use it in anonymized and aggregate forms to generate statistics about users and how the Services are being used and to facilitate targeted communications and advertisements but the information is not shared in any form that could be used to identify you personally. Please see “How we use and share the information we collect,” below, for further information and choices about sharing information with third parties.

IP address and log file information, web beacons, cookies, tokens and device identifiers: These are alphanumeric identifiers that help us to distinguish between unique browsers and devices in order to avoid showing you the same information twice, keep you logged into Spark Growth, prevent duplicate actions, prevent duplicate coupon redemptions and improve your experience. The information we collect from cookies may include your IP address, browser and device characteristics, referring URLs, and a record of your interactions with our Service. By using the Service, you are consenting to such use of cookies. Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. We will respect your choices relating to on-line tracking, whether you choose to reject individual cookies or set your web browser to reject cookies and other tracking technology. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Service or certain areas or features of the Service.

Crashes and error reports: If you encounter a crash or error while using our Service, we may generate a crash report that includes technical, usage and, if you are logged in, your account information so that we can diagnose and potentially prevent the problem in the future.

Information Collected from other Sources. We may also periodically obtain both personal and non-personal information about you from third parties that you have authorized us to access (for example, we may collect information from the Third Party Services to help integrate content and services). These parties may install tracking scripts and cookies when you integrate them with the Service. This policy only covers the use of cookies by Spark Growth. Cookies placed by third party services are governed by the third party terms and privacy policies applicable to those services (which we encourage you to read).

Lawful Basis to Information Processing

We process your personal data only when we have a lawful basis. Presently, we have a legitimate interest and, in some cases, your consent as the lawful basis for processing. Our legitimate interest is to deliver the Service to you. We have determined that our processing of your personal data is necessary to deliver the Service to you, and that there is no less intrusive means of delivering you the Service. Finally, we believe that our processing of personal data will not cause unjustified harm in a way that would override our legitimate interest basis as provided under the EU’s General Data Protection Regulations.

In some cases, we may use consent as our lawful basis for collecting and processing certain types of personal information. In such cases, you have a right to withdraw the consent at any time.

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

How We Use and Share the Information We Collect

Use

We use the information we collect for things like:

Share

We will share your Content with designated Third Party Services only when you tell us to. When you share Content, whether directly or through the Service, your Content becomes subject to the terms of use and privacy policies of the applicable Third Party Services, which we encourage you to review and understand. The use of this profile and usage information by the Third Party Services, as well as any personal information you directly provide to such Third Party Services, is governed by the internal policies of the Third Party Services and is not subject to our control.

In the normal course of business Spark Growth may also share your information with individuals (such as employees, contractors and lawyers) and companies (such as consultants and providers such as a push notification delivery service) to perform tasks on our behalf and may need to share certain information with them in order to provide products or services to you. However, our agents do not have any right to use the information we share with them beyond what is necessary to assist us in providing the service to you as described in this Privacy Policy.

Sometimes we may be required to share your information in response to a regulation, court order or subpoena. We may also share information when we believe it's necessary to comply with the law. We also may share information to respond to a government request or when we believe disclosure is necessary or appropriate to protect the rights, property or safety of Spark Growth, our customers, or others; to prevent harm or loss; or in connection with an investigation of suspected or actual unlawful activity.

We may also share your information in the event of a corporate sale, merger, acquisition, dissolution or similar event.

How We Store and Protect the Information We Collect

Spark Growth uses reasonable security measures to store and protect the information under our control and appropriately limit access to it. However, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk.

We use a variety of information security measures to protect your online transactions with us. The Service uses encryption technology, such as Secure Sockets Layer (SSL), to protect your sensitive personal information during data transport.

We want you to feel confident using the Services. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, Content, or other communications will always remain secure. We will notify you by email if we have reason to believe that your personal information has been compromised due to a security breach or used in an unauthorized manner, but by using this Service, you agree to release us from any and all claims arising out of unauthorized use of your information.

Your Rights Regarding the Information We Collect

You have the right to:

To do any of these, simply notify us of this decision by one of these methods:

Data Retention

We will retain your profile information and Content for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. If you close your account, we may still retain certain information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, collect any fees owed, enforce our terms and conditions, take actions we deem necessary to protect the integrity of our web site or our users, or take other actions otherwise permitted by law. Deactivating your account does not automatically delete your account or Content from our database, but regardless of any retention policy we will make reasonable efforts to enable you to delete your profile information from our database upon request. However, if certain information has already been provided to third parties, retention of that information will be subject to those third parties' policies. Additionally, if you have provided your information to Third Party Services or otherwise made it available to the public, you may not be able to remove or edit your information from some internet databases.

Third Party Services and Links to Other Websites

Our website may contain links to other websites including those of our payment processor and certain Third Party Services, many of which have their own privacy policies. Be sure to review the privacy policy on any site you are visiting or uploading Content to, whether directly or through the Service.

Additionally, we may integrate third party services in to our Service in order to personalize your experience. This policy only covers the use of cookies by Spark Growth. Cookies placed by third party services are governed by the third party terms and privacy policies applicable to those services (which we encourage you to read).

Children's privacy

We restrict use of the Service to individuals age 18 and above, and do not knowingly seek or collect personal information from anyone under the age of 18.

Using the Services from outside the United States

This Privacy Policy is intended to cover collection of information from residents of the United States and is not intended for users located outside the United States. The hosting facilities, servers and central database for the Service are located in the United States. If you are accessing the Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States by us as data controller and as data processor. By signing up for and using the Service you agree to this transfer. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected.

Changes to this Privacy Policy

Please note that this Privacy Policy may change from time to time. We will post any Privacy Policy changes on this page and, if the changes are significant or involve changes to the way we use personal information, we will notify you by delivering an announcement via our Service or your account email. If you opt out of communications from Spark Growth, you may not receive these notifications, however they will still govern your use of the Service, and you are responsible for proactively checking for any changes. If you continue to use the Service after changes have been posted, you agree to abide by and be bound by the modified privacy policy. Each version of this Privacy Policy will be identified by its effective date found at the bottom of this page.

If you have any additional questions or concerns about this Privacy Policy, please feel free to contact us any time through this Service, or email us at hello@spark.app.


Last updated August 5th, 2018