Effective Date: May 25, 2018
YOUR PRIVACY IS IMPORTANT TO US
We respect privacy and your rights to control your personal data. Our principle guidelines are simple:
- We will be clear about the data we collect and why.
- We do not and will not sell your data to third parties.
The text that follows elaborates on these two guiding principles.
Below you will find the answers to these questions:
- Is Information About Me Secure?
- What Information Do We Collect?
- How, and With Whom, Is My Information Shared?
- What are Your Rights to Access and Deleting of Your Data?
- How What Information of Mine Can I Access My Information?
- How Can I Delete My Account?
- What Happens When There are Changes to the Policy?
Any Service provided by Spark Collaboration is purely voluntary. You are not required to provide any personal information to us unless you choose to access features of the Service that require such information. If you do not agree with the terms of this policy or Spark Collaboration’s Terms of Service, then please do not provide us with personal information, exit the applications immediately, and refrain from using the Service.
LEGITIMATE BASIS OF PROCESSING
Spark Collaboration’s uses of your data for the purposes described above is based on the following legitimate basis:
Why do we need your data?
Spark Collaboration is a service which Organizers use to introduce groups (communities) of stakeholders to each other on an one-on-one basis and users use our services to meet others in their respective communities. We use data provided by the organizers and the users to provide this service. This data is collected at the point of registration, from feedback surveys, and other means of communication (phone and email directed to us) with the Organizers and Users.
As a core service of Spark Collaboration is introducing you to other people associated with your organization, communication may occur between you and other users following that introduction that is out of our control, and it is your responsibility to take the necessary precautions.
We rely on our legitimate interest to provide our service, analyze and improve our Services and the content on our websites and apps, to send you notifications about software updates or information about Services or to use your personal information for administrative, fraud detection or legal purposes.
In addition, we are entitled by law to use your data for direct marketing purposes, in order to send you commercial communications related with Spark Collaboration products or services which are similar to the Services, since legislation on data privacy recognizes direct marketing to clients as a legitimate interest of use of personal data, and legislation on information society services expressly allows Spark Collaboration to send you commercial communications by electronic means, provided that they are related with products or services which are similar to the Services. In any case, you are entitled to ask us, now or at any moment, not to send you any commercial communications. If you don’t want us to send you commercial communications, you can do it, now or at any moment, by changing the communication preferences in your account settings page. Additionally, all commercial communications you might receive in the future, will include an easy and free-of-charge way for you to ask us not to send further commercial communications.
When legally required, strictly necessary for the performance of the services or to protect our rights, or the rights of our affiliates or users, we disclose your personal information to law enforcement authorities, investigative organizations, our affiliates or in legal proceedings.
Where we process your personal information based on our legitimate interest and no opt-out mechanism is immediately available to you (e.g. in your Account settings), you may exercise your right to object by sending an email to firstname.lastname@example.org.
Is Information About Me Secure?
We are committed to protecting the security of your personal information. However, while we take reasonable precautions to guard the personal information we collect, no security system is impenetrable.
We use a variety of appropriate technical and organizational measures and industry standards to protect your personal information and help prevent information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account. To protect the confidentiality of your personal information, you must keep your password confidential and not disclose it to any other person.
Please alert us immediately if you believe your password has been misused. We we will never ask you to disclose your password.
What Information Do We Collect?
When you create an Account, you will provide information that could be Personal Information, such as your name, password and email address. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous.
Other information we collect include the following:
- Account information
- User Content
- Email Communication
- Device and Application Data
- IP Address Information
The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information.
Spark Collaboration does not target and is not intended to attract children under eighteen. Although visitors of all ages may navigate through our websites or use our app, we do not knowingly collect or request personal information from those under the age of eighteen without parental consent. If, following a notification by a parent or guardian or discovery by other means, a child under eighteen has been improperly registered on our site by using false information, we will cancel the child’s account and delete the child’s personal information from our records.
Information collected directly from the User
When you create an Account, you will provide information that could be Personal Information, such as your name, password, description, profile picture, social media handles and email address. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you allow others, including us, Organizers, and those we introduce you to as part of this service, to identify you and therefore you may not be anonymous.
You may unsubscribe from these messages by emailing email@example.com.
Some features of the Services may allow you to provide content to the Services, such as written comments via email communications or feedback surveys, and other related content that will help improve the service.
We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service and ensure the proper delivery of the system generated emails.
Information we collect indirectly or passively when interacting with the Service
Device and Application Data:
Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.
IP Address Information:
We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on).
Information Collected Using Cookies:
Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways.
We use data to develop aggregate analysis and business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of our business. This processing is necessary to serve our legitimate interest.
How, and With Whom, Is My Information Shared?
Spark Collaboration does not and will not sell personal information about our customers.
We only disclose your data as described in this Statement. We may share information with the following types of third parties.
Third Party Vendors
Spark Collaboration uses a variety of third-party vendors to carry out services like websites management and hosting, and email communications. We only share your personal data as necessary, such as to complete a transaction or to provide a Product or Service you have requested or authorized and only with vendors or agents working on our behalf for the purposes described in this Statement.
In this case, it is our legitimate interest to share your your personal information with these agents or contractors but only for the purpose of performing services on behalf and under instructions of Spark Collaboration and in accordance with this Statement.
For questions about third-party vendors, please send an email to firstname.lastname@example.org.
User Profile Information:
User profile information including your name and other information you enter may be displayed to other users, including organizers, such as if you submit a written response to a survey, or via email communications. We will only directly reveal user email addresses to users that you are matched with from communities that you have registered for through Spark Collaboration.
What are Your Rights to Access and Deleting of Your Data?
Where we are using your personal information on the basis of your consent, you are entitled to withdraw that consent at any time. Moreover, where we process your personal information based on legitimate interest you have the right to object at any time to that use of your personal information.
We rely on you to ensure that your personal information is complete, accurate and current. Please inform us promptly of any changes to, or inaccuracies of, your personal information by contacting email@example.com.
You have the right to access, rectification, opposition, erasure (“right to be forgotten”), and right to restriction of processing of your personal data by directing any such requests to Spark Collaboration.
To help make it easier for you, and without prejudice to the legal requirements Spark Collaboration must comply with under the laws, Spark Collaboration allows you to exercise the above-mentioned rights by sending an email to firstname.lastname@example.org
We will respond to your request as soon as possible, but certainly within 30 days.
How What Information of Mine Can I Access My Information?
If you are a registered user, you can access information associated with your Account by logging into the Services. Or alternatively you can email email@example.com and we will provide it to you. Registered and unregistered users can access and delete cookies through their web browser settings.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 409 Joyce Kilmer Ave. Suite 316 New Brunswick, NJ 08901
How Can I Delete My Account?
Should you ever decide to delete your Account, you may do so by emailing firstname.lastname@example.org
What Happens When There are Changes to the Policy?