SPARKED GOVERN PRIVACY POLICY

POSTED: SEPTEMBER 14, 2016

We at Schenley Systems, LLC, a Delaware limited liability company doing business as Sparked (“Sparked”, “us” or “we”) are committed to protecting your privacy. This Privacy Policy describes how we, collect, store, use and disclose personal information collected, and applies to all individuals who use Sparked Govern (collectively, the “Services”). If you are using Sparked Insights or Sparked Admin please refer to our Student-friendly Privacy Policy here.  If you do not agree with our privacy practices as described in this Privacy Policy, or do not agree with or are not willing to comply with any portion our Terms of Service, do not use the Service.

Collection of Information

We collect and use the following information to provide, improve and protect our Services:

Account. We collect, and associate with your account, information like your name, email address, phone number(s), and physical address. We may also collect, directly or through a third party processor, payment information from you. However, any payment information we collect will not be permanently stored on our servers.

Services. When you use our Services, we store, process and transmit your files (including things like your photos, structured data and emails) and information related to them (for example, location tags in photos). If you give us access to your contacts, we'll store those contacts on our servers for you to use. This will make it easy for you to do things like share your stuff, send emails, and invite others to use the Services.

Usage. We may collect information from and about the devices you use to access the Services. This includes things like IP addresses, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services.

Cookies and other technologies. We may use technologies like cookies and pixel tags to provide, improve, protect, and promote our Services. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Services, and improving them based on that information. Cookies may also enable us to collect anonymous location and browsing data from your computer or device. You can set your browser to not accept cookies, but this may limit your ability to use the Services.

Device Information: If you use the Services on a mobile device, Sparked may collect the following device information that is generated by your use of the Services; (a) operating system, device type and wireless carrier for your mobile device (“Device Information”), and (b) date, time and duration for each use of the Service application (“Usage Information”). If Sparked collects information about your device, Sparked will use such information to improve the Services, and to make software updates, provide product support and other services more relevant to its users. Additionally, we may link information we automatically collect with personal information, such as information you give us at registration or check out.

How Sparked Uses the Information

In addition to the disclosures described in the Section entitled “Collection of Information”, we may also use your information as follows. Generally, we collect, store, disclose, and use information to enable us to provide the Services, identify you as a user, respond to your inquiries and emails, improve the Services, and process your orders. The information may also be used to send you administrative and service related communications, newsletters, surveys, offers, and other promotional materials.

Sparked may create anonymous information from Personal Information by excluding information (such as your phone number) that makes the data personally identifiable to you. We may use anonymous information to analyze request and usage patterns so that we may improve to the Services, and enhance the content of our cloud-based platform, mobile applications, or other products.

How Sparked Shares the Information

We may share information as discussed below, but we won't sell it to advertisers or other third-parties.

Other users. Our Services may display information like your name and email address to other users in places like your user profile and sharing notifications. Certain features may let you make additional information available to other users.

Administrators. If you have been granted access to the Services in connection with your job, through an organization, or from a person who acts as an administrator, your administrator may have the ability to access and control your Sparked account. Please refer to your organization's internal policies if you have questions about this.

Data Protection. Stewardship of your data is critical to us and a responsibility that we embrace. Accordingly, below we have listed some of the safeguards we employ to ensure your data remains protected:

  • We use SSL SHA-256 with RSA Encryption,
  • Our servers are physically located in Amazon’s secure data centers,
  • We proactively and routinely update our servers and software to use up to date secure versions and bug fixes as they are released or a potential security threat is found,
  • User passwords are stored using strong AES-256-CBC and a secure encrypted salt,
  • User password requirements are in place to help prevent overly simple and common passwords

Law & Order.

Our servers are located in the United States, and as such, your Device Information and Usage Information (collectively, “Data”) may be available to the U.S. government or its agencies under a lawful order made in the U.S irrespective of the safeguards we have put in place for the protection of your Data. We may disclose your Data to a third party without your consent: (a) if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of our products or websites, or anyone else (including the rights or property of anyone else) that could be harmed by such activities; (b) in connection with any legal investigation; and/or (c) when we believe in good faith that such disclosure is required by and in accordance with the law or to respond to subpoenas, warrants, production orders, litigation requests or similar documents served on Carnegie.

Others Working for Sparked. From time to time we may employ third parties to help operate our business and the Service. Examples of such service providers include vendors and suppliers that provide us with technology, services and/or content for analyzing data, research, providing advertising and marketing assistance, processing payments (including credit card payments), and providing customer service. Access to your Data by each of these service providers is limited to the information reasonably necessary to perform its limited function and these service providers may only use your Data to provide services on our behalf.

We may disclose Information in some other limited circumstances, but we will specifically describe them to you when we collect the information, such as in a separate consent for a new service.

We may also disclose your Data in connection with a corporate reorganization, a merger or acquisition with another entity, or a sale of all or a substantial portion of our assets or stock provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information. In the unlikely event of an insolvency, bankruptcy or receivership, your Data may also be transferred as a business asset. We may share some or all of your Data with a parent company, any subsidiaries, joint ventures, or other companies under common control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

Your Choice Regarding Your Information

If you wish to stop all collection of information by the Services you should stop using the Services. If you are using the Services through a mobile application, you may use the standard uninstall process as may be available as part of your Device or via the appropriate mobile application marketplace or network.

Our Commitment To Data Security

The security of your Data is important to us. We use commercially reasonable efforts to store and maintain your Data in a secure environment and have implemented commercially reasonable procedures designed to limit loss, theft or unauthorized access, use, modification, copying or disclosure of your Data. Despite these measures, you should know that Sparked cannot fully eliminate security risks associated with your Data. You are also responsible for helping to protect the security of your Data.

Our Privacy Policy for Children

Sparked does not knowingly collect personally identifying information from anyone who is under the age of 13 unless we first obtain permission from the child’s parent or legal guardian. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@sparked-tech.com.  We will delete such information from our files within a reasonable time.

Other Countries

Your Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of your Data may be less stringent than the laws in your country.

Changes and updates to this Privacy Notice

Sparked may amend the terms of this Privacy Policy periodically without specific notice to you. We will provide notice of any changes to our Privacy Policy by posting a new privacy policy, and its effective date, at http://www.sparked-tech.com.

Contact Us

If you have any questions about, or complaints that concern, this Policy, please call us at Carnegie or email us at privacy@sparked-tech.com. If you prefer, you also may write us at Office of Privacy -Legal Department, Sparked, 8522 Broadway, Suite 209, San Antonio, Texas 78217.