PRIVACY POLICY

SparkPlug (“SparkPlug”, “we,” “our” or “us”) is committed to protecting your privacy. We have prepared this privacy policy (“Privacy Policy”) to describe to you, or if you represent an entity or organization, that entity or organization, (in either case, “you”) our practices regarding the collection, use, and sharing of personal information from and on behalf of end users through the website located at sparkplug.app, my.sparkplug.app, or other websites operated by SparkPlug (each, a “Site”), whether accessing the Site directly or indirectly through a mobile or online application provided by SparkPlug (an “Application,” and together with the Site, the “Platform”). By using the Platform, you consent to our Privacy Policy.

We may periodically update this Privacy Policy to reflect material changes in how we collect, use, share or store your personal information. We encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current Privacy Policy. You consent to any changes we make to this Privacy Policy if you continue to use the Platform after receiving a notice of the change or upon our posting of the new Privacy Policy on this Platform.

Use of SparkPlug is not required, is voluntary and is to be used only during working hours.

This Privacy Policy informs you about:

  1. the personal information we collect and how we collect it;
  2. how we use and disclose the personal information;
  3. how we protect your personal information;
  4. our practices regarding the information of children;
  5. third party data practices;
  6. how you can access and change the personal information we store about you; and
  7. how you can contact us with any questions or concerns.

As used in this Privacy Policy, the term “personal information” is information that would allow someone to identify or contact you, including, for example, your full name, address, telephone number, or email address. Non-personal information is information that does not directly identify an individual. We collect both types of information about you. The following provides examples of the types of data that we collect from you and how we use the information.

 

COLLECTING INFORMATION

Like many websites, we gather information about how visitors use our Platform. In general, you can visit many of our web pages without telling us who you are or revealing any personal information about yourself. We may track your visit for trends and statistics, but you will remain anonymous unless you tell us who you are. Once you choose to give us your personal information, you are not anonymous to us.

The following are the types of information we collect:

Information you give us: We receive the personal information you provide to us when you register for, or otherwise use, the Platform such as your name, email address, phone number, address, gender, ethnicity, age, education, and any feedback, questions, or recommendations you provide. In some cases, the Platform allows you to submit questions and comments in public areas of the Platform, and such information may read, collected, and used by us and other users of the Platform. If you provide information directly to us in other ways, such as one or more of the following: sending us an email, completing a survey or other form, or entering into a contest, we may retain that information and add it with the other information we have collected from you. We may also collect personal information that is necessary for our legitimate interests, which will be disclosed to you at the time of collection. We will use this information for the purposes of which it was collected.

Information from third parties: We may receive information about you from other sources, such as our business partners or from individuals who refer you to us. We may add this information to other information we collect from you.

Social Media: To provide you with certain social features, we may collect information about your contacts or friends from third-party websites that provide access to this information, such as Facebook, LinkedIn, Twitter, or email services. We respect and follow the privacy policies of those third party services with regard to the data we collect from them.

Automatically collected information: We may receive and store certain types of information from you each time you use the Platform. For example we may automatically log your browser type, operating system, network, language preference, the date and time of your visit to the Platform, your time zone, your Internet Protocol (IP) address, and the website you visited before our Platform. In addition, we may receive and store information about your use of the Platform, for example, the pages you visited, the length of your session, or the time you take to complete a survey. We may also receive and store information about the device you used to access the Platform, including, for example, the device’s make, the device’s model, the device’s operating system, your carrier, and any mobile applications through which you interact with the Platform. The technologies we use for this automatic data collection may include:

  • Cookies. Cookies are small data files stored on your hard drive by a website. Among other things, cookies help us improve our Platform and improve your experience on our Platform by analyzing the way you use the Platform. You can set your browser to not accept cookies, but that may prevent us from providing you with the full range of Platform we offer. Also, please be aware that if you visit other websites you may be required to accept cookies. The use of cookies placed by third parties on other websites is not covered by this Privacy Policy. We do not have access or control over such cookies.
  • Web Beacons. Web beacons are electronic images that may be used on our Platform or in our emails. We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.
  • Other. We may also use clear gifs or other data files or identifiers to collect information for statistical purposes and to improve and develop the Platform we provide. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are placed on a hard drive, clear gifs are embedded invisibly on web pages.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). We do not respond to browser-based “do not track” signals. Some third party sites who push content to our Platform may keep track of your browsing activities over time and across different websites when they serve you content, which enables them to tailor what they present to you.

USING AND DISCLOSING INFORMATION

We use and disclose your personal information only as described in this Privacy Policy or as otherwise disclosed to you on our Platform. For example, we may use and/or disclose your personal information:

  • To operate and improve our Platform;
  • To fulfill your requests for certain products or services;
  • To better understand your needs and provide you with more customized service.
  • To communicate with you about the Platform or our products and services
  • To respond to any questions or concerns that you may have;
  • For market research, project planning, troubleshooting problems, detecting and protecting against errors, fraud, or other criminal activity;
  • To fulfil other legitimate purposes permitted by applicable law;
  • To third-party contractors that provide services to us and are contractually bound to safeguard your personal information (e.g., website hosting providers, payment processors, log monitoring analysts, forensic data scientists, user data analysts, marketing assistants, and other service providers for legitimate purposes permitted by applicable law);
  • To our wholly-owned companies and affiliates, which may be outside the United States;
  • To third parties in connection with any merger, acquisition, reorganization, change in capital structure or sale of all or part of the assets of the business or a sale or transfer of assets of SparkPlug;
  • To third parties designated by you with your express consent (exclusive of information obtained through the SMS short code);
  • When we have a good faith belief that disclosure is necessary to comply with law, protect or defend our rights or the rights of other users of our Platform or products or services, or act in an emergency to protect someone’s safety; or
  • Otherwise with your express consent.

We may offer you services through the Platform in conjunction with other third parties who will be identified to you at the time of collection of your personal information. For example, we may provide the Platform for and on behalf your employer (e.g. a retail store). In such case, your personal information may be shared with that third party. Except as expressly stated in this Privacy Policy, this Privacy Policy does not apply to the information that is collected by, used by, disclosed by, or disclosed to your employer. For more information about your employer’s privacy practices, please contact your employer directly.

We may create non-personally identifying anonymous or aggregate data from the information we collect. We may use that anonymous or aggregate data for our own purposes or disclose it to third parties in our own discretion.

Data obtained through SparkPlug's SMS short code program will never be shared with third parties for their marketing purposes.

PROTECTING YOUR INFORMATION

We take reasonable steps to help protect your personal information in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration and destruction. We follow reasonable standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure and we do not guarantee its absolute security. Please contact us if you have any questions about security of our Platform.

PROCEDURES REGARDING CHILDREN

Our Platform is not intended for children under 13 years of age. No one under age 13 may provide any information to us using the Platform. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Platform. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at hello@sparkplug.app.

THIRD PARTIES

Advertisements and Links to Other Websites: The Platform may contain links, content, and advertisements from third parties. Such links, content, and advertisements are not endorsements, authorizations or representations of our affiliation with that third party. We are not responsible for the privacy practices or the content of third parties, and we encourage you to carefully review the privacy policy of any website you visit.

Advertising agencies, advertising networks, and other companies who may place advertisements on our Platform may use their own cookies, pixel tags, web beacons, web bugs and other technology to collect information about you. We do not control these companies’ use of such technology and we have no responsibility for the use of such technology by these companies to gather information about you.

HOW TO REVIEW, MODIFY OR DELETE YOUR INFORMATION

We want to communicate with you only if you want to hear from us. If you prefer not to receive information from us or would like to update or change your personal information or preferences, follow the instructions below to review, modify or delete your personal information.

  • To modify the information you have provided during registration, please login and update your personal settings on the Platform.
  • To unsubscribe from a promotional email, please follow the instructions in any email you receive. If you decide not to receive promotional emails, we may still send you transactional communications, such as those about your account, to fulfill orders you have made, to ask you to rate a product you purchased, or event you attended.

If you request your registration information be deleted or if you unsubscribe from communications, we may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations, or to complete any transactions that you began prior to requesting such change or access. When updating or deleting your personal information, we may ask you to verify your identity before we can act on your request. We will comply with your request as soon as reasonably practicable and in accordance with applicable law.

RETENTION OF PERSONAL INFORMATION

SparkPlug retains your personal information:

  • For so long as your account is active or as needed to provide you with access to the Platform or to fulfill our contractual obligations;
  • As necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; and
  • For so long as is necessary for the purposes for which we collected such personal information.

QUESTIONS AND FEEDBACK

We welcome your questions, comments, and concerns about privacy. Please contact us by email at: hello@sparkplug.app. If SparkPlug needs, or is required, to contact you concerning any event that involves information about you, we may do so by email, telephone, or mail.

COMPLAINTS

If you have a data privacy complaint, please contact us by email at: hello@sparkplug.app.

We are committed to working with you to obtain a fair resolution of any privacy concern.

CALIFORNIA VISITORS

Residents of the State of California may request a list of all third parties to which SparkPlug has disclosed certain information collected in connection with this Platform during the preceding year for the third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at hello@sparkplug.app. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request and include the name of this Platform, as well as your name, street address, city, state, and zip code. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

EUROPEAN ECONOMIC AREA VISITORS

In accordance with applicable laws, you may have the right to request access to, rectification, and erasure of your personal information; restriction of processing of personal information; objecting to certain processing of personal information; and the right to data portability. Where any processing of personal information is solely dependent upon your consent, you have the right to withdraw such consent at any time (For example, we suggest by using the unsubscribe link contained in an applicable marketing message or emailing us at hello@sparkplug.app). Where you believe that we have not processed your personal information in accordance with applicable laws, you may lodge a complaint with the respective supervisory authority or data protection regulator. The provision of personal information by you will be for contractual, marketing, analytical purposes, or other purposes as referred to in this Privacy Policy. When we receive your request, we may ask you to verify your identity before we can act on your request. We may withhold information where we are required by law to do so or if the search for that information would require disproportionate effort or have a disproportionate effect to, for example, the cost of providing the information, the time it would take to retrieve the data, or how difficult it may be to obtain the information requested.

INTERNATIONAL OPERATIONS

SparkPlug is based, and the Platform is hosted, in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein. Where we transfer your personal information from the European Economic Area to recipients located outside the European Economic Area who are not in a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection to receive personal information, we do so on the basis of standard contractual clauses. You may request a copy of the relevant standard contractual clauses by emailing us at hello@sparkplug.app.