Privacy Statement - Spark to Perspective

This policy describes our privacy practices – what Personal Information we collect about our Users, what we do with it, how we share it, and your rights regarding that Personal Information.
By accessing or using any of our Services, you acknowledge that you have read this Privacy Policy.

Sparktoperspective.com/ cares deeply about the privacy of its visitors and users. To that end, this Privacy Policy (“Privacy Policy”) describes how Sparktoperspective.com/ ( “we”, “our”, or “us”), collect, use, and share your Personal Information, as well as an explanation of the data rights you may have in that Personal Information. This Privacy Policy applies to all our users, including unregistered visitors, registered users, and premium users (collectively, “Users”, “you”, or “your”), and to all our services, including our website (collectively, the “Services”). This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you may have under other applicable data privacy laws.

Prior to accessing or using our Services, please read this policy and make sure you fully understand our practices in relation to your Personal Information. If you read and fully understand this Privacy Policy, and remain opposed to our practices, you must immediately leave and discontinue all use of any of our Services. If you have any questions or concerns regarding this policy, please contact us at http://sparktoperspective.com/

User Information:

To provide you the Services, we must collect Personal Information relating to an identified or identifiable natural person (“Personal Information”). We collect Personal Information you provide us, from your use of the Services, and from other sources. Here are the types of Personal Information we collect about you:

Information you provide us. When you register for our Services, purchase and/or use any of our Services; and/or when you contact us directly by any communication channel (e.g., emails), you may provide us Personal Information, such as name, email address, phone number, payment Personal Information (for Users with Paid Services), Personal Information you include in your communications with us, and Personal Information contained in scanned identification documents (such as an ID card, driver’s license, passport, or official company registration documents).
Information we collect when you use the Services. When you visit, download, and/or use any of our Services, we may collect aggregated usage Personal Information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying Personal Information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc
Information we collect from other sources. We may receive Personal Information about you from third-party sources, such as i) security providers , fraud detection and prevention providers for example to help us screen out users associated with fraud, ii) social media platforms, when you log-in or sign-up using your social media account, we may receive Personal Information from that service (e.g., your username, basic profile Personal Information) and in some cases, we may collect Personal Information from lead enhancement companies which help us to improve our service offering; iii) advertising and marketing partners in order to monitor, manage and measure our ad campaigns.

How do we collect such information?

We use your Personal Information for the following purposes:

To provide and operate the Services;
.To further develop, customize, expand, and improve our Services, based on Users’common or personal preferences, experiences and difficulties;

To provide our Users with ongoing customer assistance and technical support;
To be able to contact our Users with general or personalized service-related noticesand promotional messages.
To help us to update, expand and analyze our records to identify new customers;
To facilitate, sponsor, and offer certain contests, events, and promotions, determineparticipants’ eligibility, monitor performance, contact winners, and grant prizes and
benefits;
To create aggregated statistical data and other aggregated and/or inferred PersonalInformation, which we or our business partners may use to provide and improve our
respective services;
To provide you with professional assistance , only upon your request;
To enhance our data security and fraud prevention capabilities; and
To comply with any applicable laws and regulations.

We use your Personal Information for the purposes set out above where:

Our use of your Personal Information is necessary to perform a contract or to take stepsto enter into a contract with you (e.g. to provide you with our customer assistance and
technical support);
Our use of your Personal Information is necessary to comply with a relevant legal orregulatory obligation that we have; or
Our use of your Personal Information is necessary to support legitimate interests andbusiness purposes (for example, to maintain and improve our Services), provided it is conducted in a way that is proportionate and that respects your privacy rights.

We use the Personal Information we collect about you to provide our services and make them better.

We also collect and use Personal Information in order to contact Users and to comply with the laws applicable to us.

How we share your Personal Information

We may share your Personal Information with service providers and others (or otherwise allow them access to it) in the following manners and instances:

Third Party Service Providers: These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service Provider(s)”).

Sparktoperspective.com/ may share the following categories of Personal Information with Third Party Service Providers for a business purpose:

identifiers, including name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
commercial Personal Information, for example Personal Information regarding products or services purchased, obtained, or considered
Sparktoperspective.com/ is accountable for Personal Information it receives under the Privacy Shield and subsequently transfers to a third party as described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if Third Party Service Providers process Personal Information on its behalf in a manner inconsistent with the Principles, unless we prove that it is not responsible for the event giving rise to the damage.

We may share the Personal Information of our Users and Users-of-Users with various third parties, including certain service providers and law enforcement officials.

The Personal Information may be shared solely in accordance with this policy.

Law Enforcement, Legal Requests and Duties: We may disclose or otherwise allow access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings,

search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.

Protecting Rights and Safety: We may share your Personal Information if we believe in good faith that this will help protect the rights, property or personal safety of Sparktoperspective.com/, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.

Social Media Features and Framed Pages: Our Services include certain Social Media features, widgets, and single sign on features, such as the “Facebook Connect,” “Google Sign-in,” “Facebook Like”, or “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect certain Personal Information such as your IP address or which page you are visiting on our Website and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.

In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third-Party Service Providers or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing are governed by those third parties’ policies and not ours.

We encourage you to review any privacy policy accompanying a Third Party App and ask Third Party Developers for any clarifications you may need before deciding to install and use their Third Party App. Sparktoperspective.com/ does not control and is not responsible for the actions or policies of any Third Party Developers, and your use of any Third Party App is at your own risk.

You are solely responsible for notifying your Users-of-Users of the collection, processing and use of their Information and informing them that their Information will be transferred to and processed by us on your behalf.

Upon Your Further Direction: Sparktoperspective.com/ may also share your Personal Information with third parties for other purposes upon your further direction or with your explicit approval.

Where do we store your Personal Information?

Users’ and Users-of-Users’ Personal Information may be stored in data centers. We may use other jurisdictions as necessary for the proper delivery of our Services and/or as may be required by law.

Sparktoperspective.com/ is responsible for the processing of Personal Information it receives under the Privacy Shield Framework, and subsequent transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of Personal Information from the EU, including the onward transfer liability provisions.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our third-party dispute resolution provider at …………..

Under certain conditions, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Upon request Sparktoperspective.com/ will provide you with Personal Information about whether we hold any of your Personal Information. We will respond to your request within a timeframe imposed by local laws or a reasonable timeframe.

Our data storage providers are contractually committed to protect and secure your data.

Among other things, We adhere to local laws, the EU-US & to the Swiss-US Privacy Shield Principles, for further protecting and enhancing our users’ privacy.

Data Localization Obligations: If you reside in a jurisdiction that imposes “data localization” or “data residency” obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so.

You acknowledge that while doing so, we may continue to collect, store and use your Personal Information elsewhere, including in the United States of America, as explained above.

Some jurisdictions require us to maintain and store their residents’ Personal Information locally. We may also collect, process and use such Personal Information elsewhere, including in the USA.

Users-of-users’ Personal Information

Sparktoperspective.com/ may collect, store and process certain Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their email contacts from third-party services like Gmail, or otherwise collect and manage contacts via their User Website.

For such purposes,we shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation (“GDPR”)) of such Users-of-Users Information.

The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.

You are responsible for the security, integrity and authorized usage of Personal Information about Users-of-Users’, and for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such Personal Information.

Sparktoperspective.com/ cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites in accordance with any applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they understand and, to the extent required by applicable law, consent to them.

If you are a visitor, user or customer, please read the following: Sparktoperspective.com/ has no direct relationship with Users-of-Users whose Personal Information it processes.

Use of cookies and other third-party technologies

We and our Third Party Service Providers use cookies and other similar technologies (“Cookies”) in order for us to provide our Service and ensure that it performs properly, to analyze our performance and marketing activities, and to personalize your experience.

Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

We and certain third party services may use cookies and similar tracking technologies throughout our services.
These technologies are used mostly for stability, security, functionality, performance and advertising purposes.

Sharing personal information with third parties

Sparktoperspective.com/ may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:

Promotional Messages

We may use your Personal Information to send you promotional content and messages by email, text messages, notifications within our platform, marketing calls and similar forms of communication from our partners (acting on our behalf) through such means.

If you do not wish to receive such promotional messages or calls, you may notify us at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.

We may send you promotional messages and content.
You can easily opt-out of receiving promotional messages by contacting us or unsubscribing.

Service and Billing Messages

We may also contact you with important Personal Information regarding our Services, or your use thereof. For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your User Website; or notify you of material changes in our Services.

We may also contact you with service and billing-related messages and content. You will not be able to opt-out of receiving such messages.

Your rights in relation to your Personal Information

Sparktoperspective.com/ agrees that it is imperative that you have control over your Personal Information. Pursuant to privacy regulations worldwide, We will be taking steps to enable you to request access to, receive a copy of, update, amend, delete, or limit the use of your Personal Information.

Before fulfilling your request, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee where permitted by law (e.g. if your request is unfounded or excessive).

You have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).

Questions and Complaints

If you have any questions or concerns about our collection, use or disclosure of Personal Information, or if you believe that we have not complied with this Privacy Policy or applicable data protection laws, please contact us – our details are set out at the end of this Privacy Policy. We take every privacy complaint seriously and will make all reasonable efforts to resolve your complaint promptly and in accordance with applicable law.

You can file a complaint with your local supervisory authority for data protection at any time, however we recommend that you contact us first so we can try to resolve it.

You can file a complaint with your local supervisory authority for data protection at any time. Please contact us first so we can try to resolve your concerns.

Data Retention

We may retain your Personal Information (as well as your Users-of-Users’ Personal Information) for as long as your User Account is active, as indicated in this Privacy Policy, or as otherwise needed to provide you with our Services.

We may continue to retain your Personal Information after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal

obligations, to resolve disputes regarding our Users or their Users-of-Users, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.

We maintain a data retention policy which we apply to Personal Information in our care.

We may keep your Personal Information for as long as your account is active, and longer as needed (for example, if we are legally obligated to keep it longer, or need it to protect our interests).

Security

Sparktoperspective.com/ has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services; the transmission of sensitive payment information (such as a credit card number) through our designated purchase forms is protected by an industry standard SSL/TLS encrypted connection. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.

If you have any questions regarding the security of our Services, you are welcome to contact us at info@sparktoperspective.com.

Sparktoperspective.com/ values the security of our customers’ Personal Information and we do everything in our power to protect it.
However, as we can’t guarantee absolute protection – we encourage you to be careful, set a strong password for your account, and avoid submitting any sensitive information which, if exposed, could cause you major harm.

Third-Party Websites

Our Services may contain links to other websites or services. We are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave our Services and to read the privacy statements of each and every website and service you visit before providing your Personal Information. This Privacy Policy does not apply to such linked third party websites and services.

Public forums and user content

Our Services offer publicly accessible blogs, communities and support forums. Please be aware that any Personal Information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us at: info@sparktoperspective.com. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you must login into such application or contact its provider if you want to remove the Personal Information you posted on that platform.

In any event, we advise against posting any Personal Information (via any means) you don’t wish to publicize.

Updates and interpretation

We may update this Privacy Policy as required by applicable law, and to reflect changes to our Personal Information collection, usage and storage practices. If we make any changes that we deem as “material” (in our sole good faith discretion), we will notify you prior to the change becoming effective. In relation to any updated Privacy Policy, we will, as required by applicable law, notify you, seek your consent and/or take any other measures. We encourage you to periodically review this page for the latest Personal Information on our privacy practices.

This Privacy Policy was written in English, and may be translated into other languages for your convenience. You may access and view other language versions by changing your Website language settings. If a translated (non-English) version of this Privacy Policy conflicts in any way with its English version, the provisions of the English version shall prevail.

We may change this policy at any time. We will notify you of changes as required by applicable law.

Contacting us

If you have any questions about this Privacy Policy or wish to exercise any of your rights as described, feel free to contact us. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.

You can contact us by mail at: info@sparktoperspective.com.