Privacy Policy

Last Updated: May 31st, 2022

This Privacy Policy applies to the Spark website located at https://spark.re/ and related websites (collectively, 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 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.

Consent and Information Collection and Use

When you visit the Website, use the functionality contained therein and/or communicate with us via email, social media or feedback or contact forms located on the Website, we may ask for personal information that will be used for purposes set out in these Privacy Terms. Some information is also automatically collected, such as your Internet Protocol ("IP") address, your operating system, the browser type, the address of a referring website, your user preferences and your activity on the Website. We treat this information as personal information if we combine it with or link it to any of the identifying personal information mentioned above.For the purposes of these Privacy Terms, “personal information" means information about an identifiable individual, as further defined under British Columbia's Personal Information Protection Act or other applicable laws. Personal information excludes the name, position name or title, business telephone number, business address, business e-mail, and business fax number of an individual, as well as any publicly available information as designated under applicable laws, such as information available from a public telephone directory or from a public registry.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. We do not knowingly collect the personal information from anyone under the major age of consent in the jurisdiction of residence of the individual or determined based on the address of such individual. We may store and process personal information in Canada and other countries.

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.

You also 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.

Sharing of Personal Information

We may share your personal information with certain service providers, 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.

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.

Rights to Your Information

We strive to ensure that any personal information we retain and use is accurate, complete and up-to-date as necessary for the purposes for which we will use it. If our records regarding your personal information are inaccurate or incomplete, we will amend that information at your request.

Aggregated Data

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.

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.
Spark will retain Gmail data for up to 90 days after authorization is revoked to allow seamless reactivation. After this period, the data is deleted securely unless required by law.
Spark will delete Gmail data securely upon user request. Users may request data deletion at any time by contacting support@spark.re.

Links

We may use cookies and log files to track user information. Cookies are small amounts of data that are transferred to your web browser by a web server and are stored on your computer’s hard drive. We use cookies to track which page variant a visitor has seen, to track if a visitor has clicked on a page variant, to monitor traffic patterns and to gauge popularity of website pages and options. We will use this information to deliver relevant content and services to you.

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or functionality of our Website.

Change of Ownership or Business Transition

In the event of a change of ownership or other business transition, such as a merger, acquisition or sale of our assets, your information may be transferred in accordance with applicable privacy laws.

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 support@spark.re.