Privacy Policy
Sprk (“Sprk, we, us, or our”) respects your privacy and values the relationship we have with you. This Privacy Policy describes the types of personal information we collect, how we use the information, with whom we share it, and the choices available regarding our use of the information. We also describe the measures we take to protect the security of the information and how to contact us about our privacy practices.
Our Commitment to you:
Your privacy is a top priority. We value your data as much as we value our own. We design all our products and services with your privacy in mind. We appreciate that you put your trust in us when you give us your information and we want to earn that trust.
We are committed to being transparent in the way we process your data. We do not want our privacy policy to be either overly complicated with legalese or vague and unclear. We have intentionally written it to be easily accessible to all – we want you to understand our privacy practices.
We work hard to keep your information secure. We have teams committed to keeping your data safe and secure.
Information we collect
How we use information
How we collect information
How we share information
How long we retain your information
How we protect information
Your rights
Age restrictions
Links to or access from other sites
Privacy Policy changes
California Residents
How to contact us
1. Information We Collect
It goes without saying, we can’t help you develop meaningful connections without some information about you, such as basic profile details and the types of people you’d like to meet. We also collect information generated as you use our services, for example when you take our Relative Preference Rating Test during the initial account creation process or periodically as you engage in Sprk, access logins, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.
Information You Give Us
You choose to give us certain information when using our services. This includes:
When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your gender and date of birth as well as the rating information when you complete the Relative Preference Rating Test.
When you complete your profile, you can share with us additional information, such as details on your personality, lifestyle, interests and other details about you, as well as content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs. By choosing to provide this information, you consent to our processing of that information.
When you participate in surveys, focus groups or market studies, you give us your insights into our products and services, responses to our questions and testimonials.
If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.
Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.
Information We Receive From Others
In addition to the information you provide us directly, we receive information about you from others, including:
Other Users: Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.
Social Media: You may be able to use your social media account (such as Facebook Login) to create and log into your Sprk account. This saves you from having to remember yet another user name and password and allows you to share some information from your social media account with us.
Other Partners: We may receive information about you from our partners, for instance where Sprk ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).
Information Collected When You Use Our Services
When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:
Relative Preference Data
Inferences drawn from or created based on any of the information identified above.
Usage Information: We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches or search parameters, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive). We do not READ your messages unless there has been a report of inappropriate behavior!
Device information: We collect information from and about the device(s) you use to access our services, including: ·
hardware and software such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address); and
information on your wireless and mobile network connection, like your service provider and signal strength.
Other information with your consent: If you give us permission, we collect the following information:
your precise geolocation (latitude and longitude) in order to offer you features that make use of it. Such geolocation is collected through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. If you decline permission for us to collect your geolocation, we will not collect it.
we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).
payment information, such as your method of payment and payment card information (including payment card number, expiration date, delivery address and billing address).
2. How We Collect Information
We may obtain personal information about you from various sources. The categories of sources from which we collect personal information are:
Directly from you
We collect information from you directly when you take any of the following actions:
purchase on our website,
contact us with a question or complaint,
use one of our mobile applications,
create an account on our website,
respond to a survey,
participate in a promotion,
apply for employment, or
sign-up to receive marketing communications.
Cookies and automatic collection methods.
Currently we do not use cookies!
From social media platforms and networks,
such as Facebook, Twitter, Pinterest, and Instagram. For example, we may obtain your information from a social media platform or network if you interact with us on social media or choose to log-in to our website using your social media credentials.
Cross Border Data Collection
We may transfer the personal information we have about you to countries other than the country in which the information was originally collected and your personal information may be processed and stored outside of your country of residence. Those countries may not have the same data protection laws as your country of residence and your personal information will be subject to applicable foreign laws. When we transfer your information to other countries, we will protect that information in the manner described in this Privacy Policy.
3. How We Use Information
The main reason we use your information is to deliver and improve our services. Additionally, we use your information to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.
To administer your account and provide our services to you
Create and manage your account
Provide you with customer support and respond to your requests
Communicate with you about our services
To help you connect with other users
Analyze your Relative Preference responses, profile and usage behavior and that of other users to recommend meaningful connections. For more information on our profiling and automated decision-making, please see our FAQ
Show users’ profiles to one another
To ensure a consistent experience across your devices
Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them
To serve you relevant offers and ads
Develop, display and track content and advertising tailored to your interests on our services and other sites
Communicate with you by email, phone, social media or mobile device about products or services that we think may interest you
To improve our services and develop new ones
Administer focus groups and surveys
Conduct research and analysis of users’ behavior to improve our services and content
Develop new features and services
To prevent, detect and fight fraud or other illegal or unauthorized activities
Address ongoing or alleged misbehavior on and off-platform
Perform data analysis to better understand and design countermeasures against these activities
Retain data related to fraudulent activities to prevent against recurrences
To ensure legal compliance
Comply with legal requirements
Assist law enforcement
Enforce or exercise our rights, for example our Terms
To process your information as described above, we rely on the following legal bases:
Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.
Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.
We also may use the information in other ways for which we provide specific notice at the time of collection.
4. How We Share Your Information
Since our goal is to help you make meaningful connections, the main sharing of users' information is, of course, with other users. We also share some users' information with service providers and partners who assist us in operating the services. Read on for more details about how your information is shared with others.
With Other Users
You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you're comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it. See our Safety Tips for suggestions on how to protect your information.
With our service providers and partners
We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.
We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of such information.
When required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances.
Since our goal is to help you make meaningful connections, the main sharing of users’ information is, of course, with other people, as per your privacy settings. We also share some users’ information with service providers and partners who assist us in operating the services and, in some cases, legal authorities.
5. How We Protect Information
We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately by sending an email to privacy@sparkai.us.
6. How Long We Retain Your Information
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 4 and as permitted by applicable law).
In practice, we delete or anonymize your information upon deletion of your account or after two years of continuous inactivity, unless:
we must keep it to comply with applicable law;
we must keep it to evidence our compliance with applicable law;
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints.
7. Your Rights
We want you to be in control of your information, so we have provided you with the following tools:
Access / Update tools in the service
Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any questions on those tools and settings, please contact our customer care team by sending an email to privacy@sparkai.us.
Device permissions
Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or opt-out of the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
Deletion.
You can delete your account by using the corresponding functionality directly on the service.
We want you to be aware of your privacy rights. Here are a few key points to remember:
Reviewing your information
Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or something similar). You can request a copy of your personal information by putting in such a request and sending it to privacy@sparkai.us.
Updating your information
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and you want to request its rectification, deletion or object to its processing, please contact us by sending an email to privacy@sparkai.us.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from her/him/they through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.
Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.
Uninstall
You can stop all information collection on the app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
Accountability
You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.
8. Age Restrictions
Our services are not intended for or directed to people under the age of 18 and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service. If we become aware that a person under the age of eighteen has provided us with personal information, we will delete the information from our records.
9. Links To Or Access From Other
Our website or mobile applications may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.
10. Updates to our Privacy Policy
We may make changes to This Privacy Policy some changes are a response to finding new ways to help you make meaningful connections others are to increase the protection of your information. We will notify you before any material changes take effect so that you have time to review the changes. We will post a prominent notice on our website and mobile applications to notify you of any significant changes to our privacy practices and indicate at the top of the Privacy Policy when it was most recently updated.
11. California Residence
If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request as indicated below. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.
12. How To Contact Us
If you have any questions or comments about this Privacy Policy, please contact us by email at privacy@sparkai.us.