Last Updated: March 2025
This Privacy Policy applies to the Spark website located at https://spark.re/ (the “Website”) and all sub-domains maintained by Spark RE Technologies Inc. (dba Spark) (“Spark”, “we”, “us” or “our”). By accessing and using this Website, you shall be deemed to have accepted and agreed to the terms hereafter set forth (the “Privacy Terms”). If you do not agree to these Privacy Terms, please do not use the Website.
These Privacy Terms were last revised as of the date that appears at the top of this page. These Privacy Terms may be changed from time to time. Changes will be posted on this page and your use of this Website after such changes have been posted will constitute your agreement to the modified Privacy Terms and all of the changes.
What this Privacy Statement Covers
Consent and Information Collection
Our Use of Personal Information
Aggregated Data
Sharing of Personal Information
Integrations
Rights to Your Information
Links
Cookies and Log Files
Google Analytics
Opting Out of Marketing Communications
Retention, Storage, and International Transfer of Personal Information
Security
Contact Us
For the purposes of these Privacy Terms, “personal information" means information about an identifiable individual, as described under applicable privacy laws. In some locations, personal information excludes the name, position name or title, business telephone number, business address, business e-mail, and business fax number of an individual.
By providing personal information to us, you consent to the collection, use and disclosure of such personal information as specified in these Privacy Terms. Without limiting the foregoing, we may on occasion ask you to consent when we collect, use, or disclose your personal information in specific circumstances. Sometimes your consent will be implied through your conduct with us if the purpose of the collection, use or disclosure is obvious and you voluntarily provide the information.
Please note that Spark’s customers may provide your personal information to Spark while using the Website or Spark services. The customer controls your information processed within the Spark services, including your contact information, billing details and other records. Please contact the relevant customer for any questions about your personal information.
We may collect, use, and disclose different types of personal information, depending on our relationship with you. Generally, we collect the following types of personal information (not all of which may apply to you):
You may provide personal information to be published or displayed on public areas of the Website or transmitted to other users of the Website or third parties (collectively, "Member Contributions"). Your Member Contributions are published or displayed on the Website and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your Member Contributions. Therefore, we cannot and do not guarantee that your Member Contributions will not be viewed by unauthorized persons.
We may use your personal or account information for the following purposes:
We may also use your personal information and Website usage statistics to generate Aggregated Data for internal use and for sharing with others on a selective basis. “Aggregated Data” means records which have been stripped of information potentially identifying customers or users, and which have been manipulated or combined to provide generalized, anonymous information. Your identity and personal information will be kept anonymous in Aggregated Data.
Google Integration
By using the ‘Gmail Integration’ with the Subscription Service you will grant the Subscription Service access to information associated with your account, including emails, subject lines, and URLs of tracked links from your email, if you use the email sync functionality. In addition, the Subscription Service will be able to read, modify, create, and send emails from your connected Gmail account. The Subscription Service will scan the content of your emails to identify which emails you have elected to track in order to provide you with the notifications feature. The Subscription Service will store replies, outgoing mail, email headers, subject line, distribution lists, aliases, time sent, and Email bodies. Your email may contain sensitive information, such as names of your contacts, your private communications, or financial or medical information. You understand that the correspondences you track will be visible to other users on your Subscription team.
Additional Limits on Use of Your Google user Data:
Notwithstanding anything else in this Product Privacy Policy, if you provide Spark with access to your Gmail data using the Gmail Integration, our use of that data will be subject to these additional restrictions:
We expect you to supply us with updates to your personal information, when required. We will not routinely update your personal information unless such a process is necessary.
You may make a request to review any personal information about you that we have collected, used, or disclosed, and we will provide you with any such personal information to the extent required by applicable laws.
You may also challenge the accuracy or completeness of your personal information in our records. If you demonstrate that your personal information in our records is inaccurate, incomplete or equivocal, we will amend or delete your personal information as required. Where appropriate, we will transmit the amended information to third parties to whom we have disclosed your personal information.
We may require that you provide sufficient identification to fulfill your request to access or correct your personal information. Any such identifying information will be used only for this purpose. We will not charge you any fees to access your personal information in our records without first providing you with an estimate of the approximate fees, if any.
If you object to how we handle your request, you may have the right to make a complaint to the Privacy Commissioner of Canada or the applicable provincial privacy commissioner.
The Website may contain links to other websites. These Privacy Terms do not apply to other websites, and we are not responsible for the privacy practices or the content of such websites. We encourage you to read the privacy policy of linked websites prior to providing them with personal information. Their privacy policies and practices may differ significantly from our policies and practices.
Our website utilizes Google Analytics, a service from Google that uses cookies. The information collected by the cookies (which includes your IP address) is transferred to Google who stores and processes the information in the United States. Google uses the information to provide us with an analysis of your use of our website, overall use of and traffic on our website. You can opt out of Google Analytics by downloading and utilizing the Google Analytics Opt-out Browser Add-on. By using our website, you understand and acknowledge our use of Google Analytics.
If you no longer want to receive marketing-related e-mails from us, you may opt out of receiving marketing-related e-mails by clicking the “unsubscribe” link at the bottom of any e-mail you receive from us. You may also opt out by contacting us directly using the contact information in the “Contact Us” section below.
Please note that if you opt out from receiving marketing-related e-mails, we may still need to send you communications about your use of our products or services, or other matters.
We will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, and as permitted or required by law.
We may transfer your personal information outside of Canada to fulfil the purpose for which we collected it, including for processing and storage by service providers. While your personal information is outside of Canada, it is subject to the laws of the country in which it is located, which may have different data protection laws than Canada. Those laws may require disclosure of your personal information to authorities in that country. For more information about our policies and practices regarding service providers outside of Canada, contact us using the contact information in the “Contact Us” section below.
We will strive to prevent unauthorized access to your personal information, however, no data transmission over the Internet, by wireless device or over the air, is guaranteed to be 100% secure. We will continue to enhance security procedures as new technologies and procedures become available. Please remember that you control what personal information you provide while using the Website. Ultimately, you are responsible for maintaining the secrecy of any personal information provided in connection with the use of the Website. Always be careful and responsible regarding your personal information. We are not responsible for, and cannot control, the use by others of any information which you provide to them, and you should use caution in selecting the personal information you provide to others through the Website. Similarly, we cannot assume any responsibility for the content of any personal information or other information which you receive from other users through the Website, and you release us from any and all liability in connection with the contents of any personal information or other information which you may receive using the Website. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the personal information or other information provided by any third party. You release us from any and all liability in connection with the use of such personal information or other information of others.
If you have any questions or suggestions regarding our Privacy Policy, you may contact Spark by email at privacy@spark.re.