Privacy Policy

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

Our Use of Personal Information

We may use your personal or account information for the following purposes:

to administer and fulfill contests, loyalty programs, and other promotions and programs in which you participate;
to help us address problems with and improve the Website, and/or our products and services;
to request feedback and otherwise contact you about your use of the Website and/or our products and services;
to notify you about important changes to our Website and/or our products and services;
for our internal business purposes, such as to analyze trends and statistics, for audits, to develop new products, to enhance our websites, to improve our products and services, to identify usage trends and to determine the effectiveness of our promotional campaigns;
to protect the security or integrity of our websites, our products and services and our business;
to prevent, detect and investigate activity and transactions that are suspicious, fraudulent, or violate our Website Terms and Conditions;
to contact you if necessary regarding your transactions with us, changes to our terms, conditions, and policies and/or for other administrative purposes;
to respond to your requests for support or customer service;
in an emergency situation to protect your personal safety or that of site visitors or any third party;
in connection with, or during negotiations of, any merger, sale of Spark's assets, financing or acquisition, or in any other situation involving the transfer of all or part of the business assets of Spark;
with your consent when required, to communicate with you and to send you information by email, postal mail, telephone, text message, or other means about our products, services, contests, and promotions; or
as required or authorized by law.

Aggregated Data

Sharing of Personal Information

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.We may share your personal information with certain service providers to provide our Services and to operate our business, including without limitation outside shipping companies, vendors, consultants and credit card or payment processing companies ("Service Providers"). When we engage Service Providers who manage customer information on our behalf and/or perform services on our behalf, such as conducting surveys, sending communications or helping prevent fraudulent transactions, we may share your personal information with such Service Providers under the requirement that such personal information is used only to provide services to us.

If we transfer your personal information to a service provider, we require that they maintain the confidentiality of your personal information and keep it secure. We also require that our service providers comply with applicable privacy laws and only use your personal information for the limited purposes for which it is provided.

We are not responsible for the actions of any independent third parties you may choose to engage with directly, nor are we responsible for any additional information you provide directly to any third parties, and we encourage you to become familiar with their privacy practices before disclosing information directly to any such parties.

Additionally, we may share your information when we believe such sharing is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our operations or those of any of our affiliates or subsidiaries; (f) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your personal information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

If we otherwise intend to disclose your personal information to a third party, we will identify that third party and the purpose for the disclosure and obtain your consent.

Integrations

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:

Spark will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and to enhance the email experience for productivity purposes.
Spark will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
Spark will not use this Gmail data for serving advertisements.
Spark will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for Spark's internal operations when the data have been aggregated and anonymized.
Spark's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Rights to Your Information

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.

Links

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.

Cookies and Log Files

A “cookie” is a small text file that contains information and is stored on your computer. We use cookies and similar tracking technologies, such as web beacons and pixels, to automatically collect information about your use of our website and your interaction with our emails. Information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, internet service provider and/or mobile carrier, pages and files viewed, searches, operating system and system configuration information, and date/time stamps associated with your usage.

We use this information to facilitate the use of our website, for our business or analytical purposes (including to assess website traffic and track search criteria), and to personalize web pages according to your choices and interests.

We may also use this information to engage in interest-based advertising (also known as targeted or behavioral advertising) in connection with your use of our website, and across third-party websites or service offerings when you leave our website. Interest-based advertising means that your preferences and interests are collected through cookies or similar technologies and then used to provide you with advertising and marketing materials that are relevant to you, based on those preferences and interests.

If you do not wish to accept cookies, you can adjust your web browser settings so that you automatically deny the storage of cookies or are informed each time a website requests to store a cookie. Previously stored cookies can also be deleted through your web browser. Please refer to your web browser’s help pages for more information. Some areas or features of our website rely on cookies and may not work if you delete or decline cookies. For more information about cookies generally please visit www.allaboutcookies.org.

Google Analytics

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.

Opting Out of Marketing Communications

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.

Retention, Storage, and International Transfer of Personal Information

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.

Security

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.

Contact Us

If you have any questions or suggestions regarding our Privacy Policy, you may contact Spark by email at privacy@spark.re.