PRIVACY POLICY

Welcome to SPRK (“we” or “us”) website, social media page, or application (“Platforms”).  Read below to learn how we collect, protect, and use your data when you interact with us through this Platform.

We are committed to maintaining the accuracy, confidentiality, and security of your personally identifiable information (“Personal Information”). As part of this commitment, our privacy policy governs our actions as they relate to the collection, use, and disclosure of Personal Information.

Whenever you submit any information to us using one of our Platforms, you consent to our storage and processing of this information within the USA or in different countries where you may be using these services.  Please note these countries may have different laws and requirements about privacy and data use than where you live.

INTRODUCTION

We are responsible for maintaining and protecting the Personal Information under our control. We have designated individuals who are responsible for compliance with our privacy policy.

PURPOSES

We collect, use and disclose Personal Information to provide you with the product or service you have requested and to offer you additional products and services we believe you might be interested in. The purposes for which we collect Personal Information will be identified before or at the time we collect the information. In certain circumstances, the purposes for which information is collected may be clear, and consent may be implied, such as where your name, address, and payment information is provided as part of the order process.

PERSONAL INFORMATION WE COLLECT

We collect Personal Information (information which can be used to identify an individual) such as but not limited to:

Name | Email | Phone | Mailing Address

We may collect Personal Information when you choose to use our Platform, as well as through other sources, such as joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, and from other third parties.

OTHER INFORMATION WE COLLECT

We may collect information about your use of the Platform such as but not limited to:

• How you use the Platform
• IP address and information about the device you use to access the Platform, such as:
• your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Platform (such as the application) you are using.

Your location, if you are using a Platform capable of utilizing such technology.  You will be asked if you want us to collect your location information before we do so.  Please note your IP address is automatically saved whenever an order is processed.

We also collect or compile other information about you (such as products or services viewed, browsing time, final purchases made, cart inventory, etc.)  We may use or share any other information with third parties for any lawful purpose.

HOW WE USE PERSONAL INFORMATION

We primarily use this information to provide the Platform and related features to you and to:

• Fulfill your requests and respond to your questions
• Send administrative information to you, such as changes to our terms, conditions, and policies
• Administer promotions or contests in which you choose to participate
• Facilitate social sharing functionality
• Analyze and monitor Platform usage and to make improvements
• Help secure the Platform, prevent fraud and enforce our policies
• Personalize our Platforms for you
• Contact you about other SPRK services or products or those of third parties if you agree.
• Perform other activities with your consent
• Provide “send to friend” type functionality on the Platform
• Conduct data analysis, audits, develop new products, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

HOW WE SHARE PERSONAL INFORMATION

We will only share Personal Information collected through the Platform as described in this policy unless we provide you with choices.  Specifically, we may share your Personal Information:

With companies and vendors that help us to operate our business by providing services such as website hosting, data analysis, information technology, and related infrastructure provision, customer service, email delivery, auditing, and other similar services.

• With third parties sponsors of promotions or contests in which you choose to participate
• To comply with local laws or other legal obligations such as responding to subpoenas, including laws and other legal obligations outside your country of residence.
• To respond to requests from public and government authorities including public and government authorities outside your country of residence.
• To protect our rights, operations, operations or property, or that of our users.
• To investigate, prevent, or take action regarding potential or suspected illegal activities, fraud, threats to the personal safety of any person, or violations of the Platform’s terms and conditions.
• With other companies that are owned by SPRK as allowed by law. SPRK is the party responsible for the management of the jointly-used Personal Information.
• With a purchaser of SPRK (or the majority of its assets), a merger or internal acquisition
• With your Consent

Please note that any information you post to public areas of a Platform such as our social media pages may be seen by other visitors.

CHOICE AND CONSENT

Knowledge and consent are required for the collection, use or disclosure of Personal Information except where required or permitted by law. Providing us with your Personal Information is always your choice.  You can choose not to provide us Personal Information when you use the Platform.  However, your decision not to provide certain Personal Information may limit our ability to provide you with our products, services, or Platform use.

We will not require you to consent to the collection, use, or disclosure of information as a condition to the supply of a product or service, except as required to be able to supply the product or service.

You can opt out of receiving promotional emails from a Platform managed by SPRK by following the unsubscribe link in those email messages.

THIRD-PARTY TRACKING

We may use third parties to administer services, advertisements, or other information which we deem beneficial or of interest to you, based on information that it has collected about your use of our website and third-party websites.  To do so, these companies or services may place or recognize a unique on your browser (including through the use of pixel tags).  To learn more about this practice and your choices in connection with it, please visit http://www.aboutads.com/choices

You can configure your browser to reject cookies, or to notify you when a cookie is set.  However, if you reject cookies, the Platform may not operate properly.

LIMITING COLLECTION

The Personal Information collected will be limited to those details necessary for the purposes identified by us. With your consent, we may collect Personal Information from you in person, over the telephone or by corresponding with you via mail, facsimile, or the Internet.

LIMITING USE, DISCLOSURE AND RETENTION

Personal Information may only be used or disclosed for the purpose for which it was collected unless you have otherwise consented, or when it is required or permitted by law. Personal Information will be retained until a request is made its deletion, the closure of an account or as may be required by law.

ACCURACY

Personal Information will be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.

HOW YOU CAN ACCESS OR EDIT YOUR PERSONAL INFORMATION

Some of our Platforms allow you to review and edit Personal Information that you entered.  Otherwise, you may contact us at the email address at the bottom of this policy to request access to or that we update, or correct the Personal Information collected by our Platforms.  Please note, that consistent with local law, SPRK may retain your Personal Information for auditing purposes, to troubleshoot problems, assist with investigations, enforce our policies, or comply with legal requirements.  Please note that we are not responsible for permitting you to review, or for updating or deleting Personal Information that you provide to a third party, including any app, social media platform, or wireless service provider.

HOW WE PROTECT YOUR PERSONAL INFORMATION

SPRK uses security technologies including Secure Socket Layers (SSL) to help protect the Personal Information we collect from you through the Platform.  Our policies restrict access to Personal Information to those employees and service providers who need to know the information in order to provide you with the SPRK services that you use.  We maintain physical, electronic, and procedural safeguards to protect Personal Information.

LINKED SERVICES

This privacy policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site of service to which the Platform links.  The inclusion of a link on the Platform does not imply endorsement of the linked site or service by SPRK.  Therefore we suggest that you examine the privacy statements of those sites to learn how your information may be collected, used, shared and disclosed.

CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy at any time by posting an updated privacy policy.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by law.

USE OF THE PLATFORM BY MINORS

The Platform is not directed to individuals under the age of eighteen (18+) or older as required by local, state, and federal laws pertaining to legal smoking age and we request that these individuals do not provide Personal Information through the Platform.

SENSITIVE INFORMATION

We ask that you not send us, and you do not disclose, any sensitive Personal Information (e.g. social security numbers, information related to racial or ethnic origin, political opinions, religion, or other beliefs, health, criminal background or trade union membership, etc.) on or through the Platform.

CUSTOMER ACCESS

Upon request, you will be informed of the existence, use, and disclosure of your Personal Information, and will be given access to it. You may verify the accuracy and completeness of your Personal Information and may request that it be amended, if appropriate. However, in certain circumstances permitted by law, we will not disclose certain information to you. For example, we may not disclose information relating to you if other individuals are referenced or if there are legal, security or commercial proprietary restrictions.

HOW TO CONTACT SPRK REGARDING YOUR PRIVACY CONCERNS AND QUESTIONS

You may direct any questions, inquiries, or comments with respect to our privacy policy or our practices by contacting: [email protected]