Privacy Policy

Effective Date: January 1st 2020

Last Updated: March 11, 2020

This Privacy Policy applies to your use of the Spark 718 Inc. service and any associated mobile applications, websites, or programs (together, the “Service”) provided by Spark 718 Inc. (“Company,” “we,” “us” or “our”). Its purpose is to describe the collection, use and disclosure of personal information collected through the Service. By using the Service, you acknowledge you have read and understood the terms and conditions of this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, please do not use the Service.

Your use of the Service is also governed by our Terms and Conditions https://www.conservativesociety.org/terms-of-use/.

PLEASE NOTE THE ARBITRATION PROVISION SET FORTH BELOW, WHICH, EXCEPT WHERE AND TO THE EXTENT PROHIBITED BY LAW, REQUIRES YOU TO ARBITRATE ANY CLAIMS YOU MAY HAVE AGAINST COMPANY ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE CAPACITY.

1. Collection of Information

We collect “personal information,” which we define as any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or can reasonably be linked, directly or indirectly, to an individual, household, or device. We have collected the following personal information from users of our Service in the last 12 months:

Category of personal information

Source(s)

Purpose(s)

Disclosure to third parties

Identifiers, e.g., name, postal address, online identifier, Internet Protocol address, email address or account name Directly from you

Indirectly from you (e.g., from observing your actions on our Service)

From third party service providers, such as a data analytics provider or lead generation providers

To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry, process your order or request Sale to: advertising networks and lead purchasers

Disclosure for business purposes to: internet service providers, payment processors, lead vendors

Private, non-public personal information contained in customer records, e.g., name, address, telephone number, bank account number, credit card number, debit card number, or any other payment and financial information Directly from you

Indirectly from you (e.g., from observing your actions on our Service)

From third party service providers, such as a data analytics provider or lead generation providers

To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry or process your order or inquiry Disclosure for business purposes to: internet service providers, payment processors, lead vendors
Protected classification information, e.g., race, political affiliations, etc. Directly from you

From third party service providers, such as a data analytics provider or lead generation providers

To fulfill or meet the reason you provided the information, e.g., to provide targeted advertising Sale to: advertising networks
Employment information, e.g. employment history, background check information, etc. Directly from you To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry or process your order or inquiry Sale to: advertising networks, lead vendors
Commercial information, e.g., records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies Directly from you

From third party service providers, such as a data analytics provider or lead generation providers

To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry or process your order Disclosure for business purposes to: payment processors, lead vendors
Internet or other similar network activity, e.g., browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement Indirectly from you (e.g., from observing your actions on our Service)

From third party service providers, such as a data analytics provider

To fulfill or meet the reason you provided the information, e.g., to provide targeted advertising Sale to: advertising networks, lead vendors

Disclosure for business purposes to: internet service providers, payment processors

Geolocation data, e.g., physical location or movements Directly from you

From third party service providers, such as data analytics providers

To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry, process your order, or provide targeted advertising Sale to: advertising networks, lead vendors

Disclosure for business purposes to: internet service providers, payment processors

Inferences drawn from other personal information, e.g., profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes Directly from you

Indirectly from you (e.g., from observing your actions on our Service)

From third party service providers, such as a data analytics provider or lead generation providers

To fulfill or meet the reason you provided the information, e.g., to respond to an inquiry, process your order or request Sale to: advertising networks and lead purchasers

Disclosure for business purposes to: internet service providers, payment processors, lead vendors

Examples of specific pieces of personal information we may collect include:

  • Name

  • Email

  • Other personal information voluntarily disclosed by you

  • Online identifiers, such as username and IP address
  • Interactions with our partners’ websites, e.g., what you are viewing, your interactions with certain campaigns, etc.

2. Use of Information

We use the personal information we collect for the following purposes:

  • To provide our Service, e.g., to provide you with information regarding other third party service providers and or to share your information to facilitate your request.

  • To send you marketing communications.

  • To respond to your requests and inquiries.

  • To improve user experiences by making our Service easier to use and navigate.

  • For other legitimate business purposes.

3. Sharing and Disclosure of Information

We may disclose your personal information to a third-party for a business purpose or sell your personal information (subject to your right to opt-out of those sales if you are a California consumer; see below in Section 11). We may also sell your personal information to third parties that may themselves re-sell your personal information. We may share or disclose your information to the following categories of third parties and for the following reasons:

  • To our partners, whose advertisements you view and click on.

  • To our partners when you ask us to find applicable servicers for you.

  • To third party service providers, agents or independent contractors who help us maintain our Services, provide other administrative services to us, and also provide relevant information to you.

  • We may share your personal information in the course of any reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.

  • We may disclose your personal information to law enforcement, government agencies, and other related third parties, in order to comply with the law, enforce our policies, or protect our or others’ rights, property or safety.

How We Use Cookies, Similar Technologies, and Third Party Advertisers

We and our service providers use cookies, web beacons, and other similar technologies in connection with the Service. The above technologies are used in analyzing trends, administering the Service, services and products, tracking users’ movements around the Service and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We, or third parties, may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device’s hard drive until you delete them or they expire. Different cookies are used to perform different functions, which we explain below:

  • Essential. Some cookies are essential in order to enable you to move around our website and mobile applications and use their features, such as accessing secure areas of the Services. Without these cookies, we cannot enable appropriate content based on the type of device you are using.

  • Browsing and Functionality. We use these cookies to remember choices you make on the Services, such as your preferred language and the country from which you are visiting, and to provide enhanced, more personalized features.

  • Performance and Analytics. We use third party cookies to see how you use our Services in order to improve their performance and develop them according to your preferences.

  • First Party Cookies. First-party cookies are hosted on our servers. We use cookies to remember users’ settings, market products and services to users, and for authentication purposes. To manage the cookies that are placed on your computer, you may configure your internet browser to refuse, accept or delete cookies from our website at any time. Some of the cookies we use may be more persistent in nature. These persistent cookies may not be deleted when other cookies are deleted.

  • Third Party Advertising Cookies. We receive audience based data (such as pixel traffic and conversion data) from social media platform providers. We may also use advertisers, third party ad networks, and other advertising companies to serve advertisements on the website. Depending on the particular advertising services they provide, these third party advertising companies may employ first-party cookies or third-party cookies. Please be advised that such advertising companies may gather information about your visit to the website or other sites (such as through cookies, web beacons and other technologies) to enable such advertising companies to market products or services to you, to monitor which ads have been served to your browser and which webpages you were viewing when such ads were delivered. We use Google Analytics, for example, to track website usage and activity. You can opt-out of the Google Analytics Advertising Features we use by indicating your preference using the interest-based opt-out link here. Google also provides a complete privacy policy and instructions on opting-out of Google Analytics here.

There are several ways to manage cookies. Please check your browser and browser settings to determine where these types of cookies are stored and whether and how they may be deleted. The help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable most cookies altogether. Please note that if cookies are disabled or removed, not all features of our Service will operate as intended.

4. Collection and Use of Information from Children

Our Services are not intended for children. We do not knowingly collect personal information from children, and our Services are not designed to attract children. In the event that we learn that a child under the age of 18 has provided personal information to us, we will delete such personal information as soon as possible.

5. Third Party Links

When you use our Service, there may be links and you may be directed to third party websites. We are not responsible for the privacy practices or content of such other sites. If you have any questions about how these other sites use your information, you should review their policies and contact them directly.

6. Security

We implement reasonable security measures to ensure the security of your personal information. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using our Service or otherwise providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Service. We may post a notice via our Service or website if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

7. International Data Transfers

If you choose to provide us with information, please understand that your personal information may be transferred to the US and that we may transfer that information to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. We put in place appropriate operational, procedural and technical measures in order to ensure the protection of your personal information. You acknowledge you understand that by providing your personal information: (i) your personal information will be used for the uses identified above in accordance with this Privacy Policy; and (ii) your personal information may be transferred to the US and other jurisdictions in accordance with applicable law.

8. Dispute Resolution and Agreement to Arbitrate

Except where and to the extent prohibited by law, by using the Services, you and Spark 718 Inc. agree that, if there is any controversy, claim, action, or dispute arising out of or related to your use of the Services or the breach, enforcement, interpretation, or validity of this Privacy Policy or any part of it (“Dispute”), both parties shall first try in good faith to settle such Dispute by providing written notice to the other party describing the facts and circumstances of the Dispute and allowing the receiving party 30 days in which to respond to or settle the Dispute. Notice shall be sent to:

  • Spark 718 Inc., PH Gran Plaza, Oficina C-1, Calle Andres Mojica, San Francisco, Ciudad de Panama, Republica de Panama, or
  • You, at the address we have on file for you.

Both you and Spark 718 Inc. agree that this dispute resolution procedure is a condition precedent that must be satisfied before initiating any litigation or filing any claim against the other party. IF ANY DISPUTE CANNOT BE RESOLVED BY THE ABOVE DISPUTE RESOLUTION PROCEDURE, YOU AGREE THAT THE SOLE AND EXCLUSIVE JURISDICTION FOR SUCH DISPUTE WILL BE DECIDED BY BINDING ARBITRATION ON AN INDIVIDUAL BASIS. ARBITRATION ON AN INDIVIDUAL BASIS MEANS THAT YOU WILL NOT HAVE, AND YOU WAIVE, THE RIGHT FOR A JUDGE OR JURY TO DECIDE YOUR CLAIMS, AND THAT YOU MAY NOT PROCEED IN A CLASS OR CONSOLIDATED CAPACITY. Other rights that you and we would otherwise have in court will not be available or will be more limited in arbitration, including discovery and appeal rights. All such disputes shall be exclusively submitted to JAMS (www.jamsadr.com) for binding arbitration under its rules then in effect, before one arbitrator to be mutually agreed upon by both parties.

The arbitrator, and not any federal, state, or local court or agency, shall have exclusive authority to resolve any dispute arising under or relating to the interpretation, applicability, enforceability, or formation of this Privacy Policy, including any claim that all or any part of this Privacy Policy is void or voidable.

9. Choice of Law

This Privacy Policy has been made in and shall be construed in accordance with the laws of California, without giving effect to any conflict of law principles. Any disputes or claims not subject to the arbitration provision discussed above shall be resolved by a court located in California and you agree and submit to the exercise of personal jurisdiction of such courts for the purpose of litigating any such claim or action.

10. Assignment

In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal information collected via the Service.

11. Your California Privacy Rights

California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us using the contact information provided below and put “Shine the Light” in the subject line of your request.

From January 1, 2020, many California consumers now have the following rights:

  • Right to know

You have the right to request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share such information.

You also have the right to request information about our sale or disclosure for business purposes of your personal information to third parties in the preceding 12 months.

You may also request a copy of the personal information we have collected, and upon request, we will provide this information to you in electronic form.

  • Right to delete

You have the right to request the deletion of your personal information, subject to certain exceptions.

  • Right to opt-out of sale

You have the right to opt out of the sale of your personal information to third parties. Note that some of the third parties to whom we sell your personal information may also sell the personal information that they receive from us. You can exercise this right through the webform “Do Not Sell My Personal Information” link in the footer of our websites. We do not sell the personal information of minors under the age of 16 without affirmative authorization.

  • Right to non-discrimination

You have the right to not be discriminated against for exercising any of these rights.

If you would like to exercise one or more of the rights above, please contact us using the contact information provided below. If you are emailing, please write “Data Subject Request” as your subject line, and explicitly state which right you are exercising in the body of the email. If using the webform, then explicitly state which right you are exercising within the body of the description section. You may designate an authorized agent to make a request on your behalf. Such authorized agent must be registered with the California Secretary of State. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

When submitting a request, we may need to take certain steps to ensure that we are receiving a verifiable consumer request before completing your request, and, for example, may ask for you to confirm data points we already have about you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Whenever feasible for verification, we will match the identifying information provided by you to the personal information already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information.

12. How We Respond to Do Not Track Signals

We do not support “Do Not Track” browser settings and do not currently participate in any Do Not Track frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your personal information.

13. Changes to This Privacy Policy

We reserve the right to change this Privacy Policy from time to time. When we do, we will also revise the “Last Updated” date at the top. If we make material changes, we will notify you by placing a prominent notice on our Service or emailing you at the email address we have on file for you. We encourage you to periodically review this Privacy Policy to keep up to date on how we are handling your personal information.

14. Contact Us

If you have any questions, comments or concerns about our privacy practices or this Privacy Policy, or to exercise any of your rights, please contact us at:

Spark 718 Inc., PH Gran Plaza, Oficina C-1, Calle Andres Mojica, San Francisco, Ciudad de Panama, Republica de Panama

contact@spark718.com

833 222 9655