SparkToro Privacy Policy
Last Modified: April 19, 2020

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:

  • On this Website.
  • In email, text, and other electronic messages between you and us or this Website.
  • When you register to use our Website or any tools/applications/software available on/through our Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy, such as when you give feedbacks via third party tools such as TypeForm.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website, such as the comment system run by Disqus and integrated to our Website.

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.

Not for Use by Children

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.

Information We Collect About You

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"):

  • Identity Data includes first name, last name, username, Twitter user ID or similar identifier.
  • Contact Data includes billing address, email address and telephone numbers.
  • Financial Data We use third party online payment processing platform such as Stripe to process the payment. The third party online payment processing platform may collect and store your payment card details but our Website doesn’t collect or store such information.
  • Transaction Data We may access the transactional data through secured connection to the third party online payment processing platform but we don’t collect or store transaction data.
  • Technical Data includes your login data, browser type and version, time zone setting and location, language settings, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases made by you, your feedback and survey responses.
  • Usage Data includes information about how you use our Website as well as products and services available on/through our Website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

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.

How We Collect Information About You

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:
    • create an account on our website or on any tools/applications/software available on/through our Website;
    • subscribe to our email contents;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below. As we use publicly available data, especially data from social media platforms and websites including Twitter, Facebook, YouTube, Reddit, LinkedIn, Instagram and Pinterest, to power our products and services (that’s what our products and services are for – analyzing such data), we collect much information in this way. If you don’t want us to use your public data, you may go to https://sparktoro.com/policies/data-removal and send us a request anytime.
    • Technical Data from analytics providers such as Google based outside the EU;
    • Contact, Financial and Transaction Data from providers of technical and payment services such as Stripe based outside the EU.
    • Identity, Contact Data and other data from publicly available sources such as Facebook, Twitter, YouTube, Reddit, LinkedIn, Instagram and Printerest based outside the EU.
Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or features/tools/applications on our Website, subscribing to our service, subscribing to our email contents, or requesting further services. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out on our Website and of the fulfillment of your orders. You may be required to provide financial information before making any payment on our Website.
  • Your search queries on the Website or on the tools/applications/software available on/through the Website.
Information We Collect Automatically

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:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your operating system, browser type and language setting.

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:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

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.

Third-Party Use of Cookies and Other Tracking Technologies

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.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, in the following circumstances:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account and subscription, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide through it.
  • To allow you to participate in interactive features on our Website.
  • In any other way we may describe when you provide the information.
  • Where we need to perform the contract we are about to enter into or have entered into with you. Here, "performance of contract" means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Here, "legitimate interest" means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
  • Where we need to comply with a legal obligation. Here, "comply with a legal obligation" means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
  • For any other purpose with your consent.

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.

Disclosure of Your Information

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:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “get the posts via Email” feature of our Website, we will transmit the contents of that post to that email address.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your 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:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form). You can also always opt-out by sending us an email with your request to [email protected].
  • Promotional Offers from the Company. If you do not wish to have your email address or contact information used by us to promote our own products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, product service experience or other transactions.
  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an email stating your request to [email protected]. For this opt-out to function, you must have your browser set to accept all browser cookies.
  • Publicly available information on social media. If you don’t want us to use information that is posted in your social media accounts such as your Twitter account or Facebook account, you can ask us to remove your data by sending a request here or by sending us an email stating your request to [email protected].

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].

Accessing and Correcting Your Information

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.

Your California Privacy Rights

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.

Notice of Collection

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:

  • Identifiers, including first name, last name, alias, online identifier, account name, email address, Twitter username and Twitter ID.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including name, phone number, and email address.
  • Demographics, such as your age or gender. This category includes data that may qualify as protected classifications under other California or federal laws.
  • Commercial information, including purchases and engagement with the products and services available on the Website.
  • Internet activity, including your interactions with our Website, browsing history and search history.
  • Professional or employment-related information or non-public education information, such as job title information.

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.

Right to Know and Delete

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:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information was collected;
  • The categories of personal information about you we disclosed for a business purpose or sold;
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
  • The business or commercial purpose for collecting or selling the personal information; and
  • The specific pieces of personal information we have collected about you.

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:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Response Time and Format

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.

Right to Opt-Out and Opt-In

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.

Authorized Agent

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.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any your rights under CCPA.

Children

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.

Shine the Light

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].

Information for Users in Europe and Elsewhere Outside The U.S.

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
  1. Identity
  2. Contact
Performance of a contract with you
To process and deliver your order including:
  1. Manage payments, fees and charges
  2. Collect and recover money owed to us
  1. Identity
  2. Contact
  3. Financial
  4. Transaction
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
  1. Notifying you about changes to our terms or privacy policy
  2. Asking you to leave a review or take a survey
  1. Identity
  2. Contact
  3. Profile
  4. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  1. Performance of a contract with you
  2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  1. Identity
  2. Contact
  3. Technical
  1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
  2. Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical
  1. Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  1. Technical
  2. Usage
  1. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you
  1. Identity
  2. Contact
  3. Profile
  4. Usage
  5. Marketing and Communications
  6. Technical
  1. Necessary for our legitimate interests (to develop our products/services and grow our business)
Change of Purpose

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:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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.

More on Cookies Policies
  • Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognize you when you return to our Website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

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.

International Transfers

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.

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data Security

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.

Changes to Our Privacy Policy

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.

Controller & Contact Information

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: 5820 6th Avenue NW, Seattle, Washington 98107

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.