SparkToro, LLC ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website https://sparktoro.com/ (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
It does not apply to information collected by:
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed acceptance of those changes, so please check the policy periodically for updates.
Notice to EU individuals: this Privacy Policy is intended to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of the European Union 27 April 2016 (the "General Data Protection Regulation" or "GDPR") and provide appropriate protection and care with respect to the treatment of your user information in accordance with the GDPR.
Notice to California residents: this Privacy Policy is intended to comply with the California Consumer Privacy Act ("CCPA") and other applicable California law. Please contact us as provided below.
Notice to Nevada consumers: this Privacy Policy is intended to comply with Nevada Senate Bill 220. Please contact us as provided below.
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 18, please contact us at [email protected].
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.
Personal data, or personal information, means any information about an individual from which such person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows ("personal information"):
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We use different methods to collect data from and about you including through:
The information we collect on or through our Website may include:
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
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). Click here for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
Some content or applications on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins and applications (such as Disqus) and are not responsible for their privacy statements. When you leave our website or use third party plug-ins and applications on our Website, we encourage you to read the privacy policy first.
We use information that we collect about you or that you provide to us, including any personal information, in the following circumstances:
We may also use your information to contact you about our own products and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form) or adjust your user preferences in your account or email us at [email protected]. For more information, see Choices About How We Use and Disclose Your Information.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
We may also disclose your personal information:
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI’s website.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Nevada residents who wish to exercise their rights pursuant to Nevada Senate Bill 220, please submit a request to [email protected].
You can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an email at [email protected] to request access to, correct or delete any personal information that you have provided to us. Sometimes we cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms and Conditions.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. We prepare this section to comply with the CCPA in particular and any terms defined in the CCPA have the same meaning when used in this section.
Although the information we collect is described in detail in Information We Collect About You above, the categories of personal information that we have collected in the past 12 months – as described by the CCPA – are as follows:
For more detail on the information we collect and when, including the sources we receive information from, please review How We Collect Information About You above. In the past 12 months, we have collected and used information from all of the above categories for the business purposes described in the How We Use Your Information section, including to manage our Website and provide products and services on the Website. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We do not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities as a “sale” and to include processing and sharing publicly available personal information from social media platforms and other websites as a “sale,” we will comply with applicable law as to such activity. And such “sale” activity we engage is restricted to sharing the abovementioned categories of information with our registered users who run searches with our products.
California residents have the right to delete the personal information we have collected from you and the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:
To exercise any of these rights, please submit a request to [email protected]. In the request, please specify which right you are seeking to exercise and the scope of the request. Please also provide sufficient information that allows us to verify that you are the person about whom we collected personal information or an authorized representative in the request. We will only use personal information you provide in a request to verify your identity or authority to make the request.
We may require further information from you to help us verify your identity and process your request. If we are unable to verify your identity or your authority to make the request, we may deny your requests to know or delete. We may also deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We will confirm receipt of your request to know or delete within 14 days.
We endeavor to respond to a request within forty-five (45) days after we can reasonably verify your identity and authority to make the request. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to the email address from which you send us the request or the email address on your account (if you have registered an account with us).
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For any request to know, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information.
We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
To the extent we sell your personal information as the term "sell" is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by emailing [email protected] or submit a request to us by visiting the following Interest Web page link: Do Not Sell My Personal Information. If you change your mind, you may opt back in any time by emailing [email protected].
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to re-authorize any personal information sales.
You can designate an authorized agent to submit requests on your behalf. You may also act as an agent and make a verifiable request on behalf of your minor child. However, we will require written proof of the agent’s permission to do so and will verify your identity (or your minor child’s identity) directly.
You have the right not to receive discriminatory treatment by us for the exercise of any your rights under CCPA.
The website is not intent for minors under the age of 16. And we do not knowingly collect or sell personal information of minors under 16 years old, however, to the extent we knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents, we either obtain prior affirmative authorization from such minor who is at least 13 and opt-in to the sale of the minor’s personal information or obtain affirmative authorization from the minor’s parent or guardian. A minor, or parent/guardian, who has opted in to the sale of the minor’s personal information has the right to opt-out at any time. To exercise your right to opt-out, see Right to Opt-Out and Opt-In for more information.
California’s “Shine the Light” law (Civil Code Section§1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
We may share personal information as defined by "Shine the Light" with third parties and/or our affiliates for their direct marketing purposes. If this law applies to you and you wish to obtain further information about our sharing, please send an email to [email protected].
If you use our Website outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. If applicable, you may have a right to claim compensation for damages caused by a breach of relevant data protection laws.
If you are a resident of the EEA or Switzerland, the following information applies.
As explained above, we process personal data in various ways depending upon your use of our Website. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new user |
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Performance of a contract with you |
To process and deliver your order including:
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To manage our relationship with you which will include:
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| To enable you to partake in a prize draw, competition or complete a survey |
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| To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
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| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
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| To make suggestions and recommendations to you about products or services that may be of interest to you |
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We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
| Cookie Name | Purpose | More information |
|---|---|---|
| "user_session" | This cookie is associated with customizing your experience on the Website. | Expire in 1 year |
| "notFirstVisit" | This cookie is set on the user’s first visit to the Website trending section in order to customize future visits. | Expire in 10 years |
| "curator" | This cookie is set when a user becomes a Sparktoro trending curator. | Expire in 10 years |
| "__cfduid" | This cookie is associated with CloudFlare and is used to speed up page load times. | Expire in 30 days |
| "__stripe_mid" | This cookie is associated with the payment via Stripe on the Website. It is required by Stripe to use such cookie to remember who the user is and to enable the Website to process payments without storing any credit card information on its own servers. | Expire in 1 year |
| "_fbp" | This cookie is used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. | Expire in 3 months |
| "_ga" | This Google Analytics cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. | Expire in 2 years |
| "_gat_UA-107834206-1" | This Google Analytics cookie is used to throttle request rate. | Expire in 24 hours |
| "_gid" | This Google Analytics cookie stores and updates a unique value for each page visited. | Expire in 48 hours |
Please note that the following third parties may also use cookies, over which we have no control: Facebook, Pingdom, Google Analytics, Stripe and Twitter etc. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies. To deactivate the use of third party advertising cookies, see Choices About How We Use and Disclose Your Information.
The server of our Website is based in the US and the data we collect would be stored in the US. This will involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
The Company is the controller and responsible for your personal data. We have appointed a data protection officer (the "DPO") who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy or our privacy practices, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Full name of legal entity: SparkToro, LLC
Email address: [email protected]
Postal address: 17300 SE 270th PL #7866 Covington, WA 98042
You have the right to make a complaint at any time to the supervisory authority for data protection issues in your jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.