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Sparkinity Limited

Privacy Policy



Last Updated: 06 June 2022

Sparkinity understands you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our privacy practices. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and that we will collect, use, and share your information in the following ways.

Remember that your use of Sparkinity’s Services is subject to the Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.


What does this Privacy Policy Cover?

This Privacy Policy applies to Sparkinity.com, and all other websites, applications, widgets, products, services, and other offerings (collectively, the “Services”) owned and operated by Sparkinity Limited and our affiliates and subsidiaries (collectively, “Sparkinity”) that link to this Privacy Policy. This Policy covers our treatment of the personal information we gather through use of our Services. Sparkinity Limited a company incorporated and registered in England and Wales under company number 10958055, whose registered office address is 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ is the data controller for the personal information collected in connection with use of Sparkinity’s services.


What Information does Sparkinity Collect?

We collect information about your use of our Services. We also gather various types of personal information, as explained in more detail below.


Information You Provide to Us:

We receive and store any information you knowingly provide to us. If you create an account or place an order with us, we may collect personal information such as:


Retailers:

When you register as a Retailer with Sparkinity, we will collect your first and last name, email address, phone number, business address, website, store name, store address, years you have been in business, revenue, store type and projected sales figures.

If you place an order to purchase goods from Brands through Sparkinity, we will also collect information to facilitate that order, such as your shipping address, VAT number (or local equivalent), and payment information.

In some cases, we may request additional information to validate your business, such as photos of your store or your social media profiles. In some cases, we may request information such as your VAT number or local equivalent or financial or lease records to establish your account limits or extended terms such as Net 60.


Brands:

When you register as a Brand with Sparkinity, we will collect your first and last name, brand name, website, address, phone number, and information about your brand such as the primary category of products you provide, the countries you operate in, and your social media profiles.

If you are accepted as a Brand for Sparkinity, we may ask for additional information to build out your profile such as your profile photo, wholesale pricing and order requirements, years you have been established, number of stores your products are stocked at, margins and if your products are sold on Amazon.

When you receive an order through Sparkinity, we will collect information to facilitate that order, such as your VAT number (or local equivalent), tax class (or local equivalent), and bank account information or other related information so we can pay you. Optionally, you may choose to provide information about your existing retail customers to refer to Sparkinity, such as their name, store name, email address, and telephone number.


Using the Services

When you browse and use our Services, we collect information about the items you browse, show interest in, and buy. Some of our Services allow you to create audio-visual content, which will be streamed live to other Sparkinity users. These Services will access the camera and/or microphone on your device and record your image and voice.


Communication with Us

We collect personal information from you when you communicate with us, for example when you request information about our services, contact our Support team, apply for a job, or register for our newsletter.


Surveys, Sweepstakes, and Contests

We may ask you to participate in optional surveys, where you may be asked to provide personal information.

Additionally, we may conduct sweepstakes or contests where you may be asked to provide personal information. This information may be used to contact you about the sweepstakes or contest, and for other promotional and marketing purposes, as permitted by law. Additionally, note that some jurisdictions require us to publicly share information about sweepstakes and contest winners.


Forums and Social Media

Our Services may provide forums, blogs, social media pages, or other channels where individuals may review purchases, talk about their experience using our Services, or “like” or “share” content to social media. Note that content provided for and posted in these channels, including by you, is public and that the processing of your information might be subject to the policies and notices of third parties that make such channels available.


Information Collected Automatically

Whenever you interact with our Services, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, the type of browser and/or device you’re using to access our Services, and the page or feature you requested.

Additionally, we, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies to collect information automatically through our Services. These technologies are small data files that we transfer to your browser or device that allows us to provide and enhance our Services. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of these technologies, but this may prevent you from taking advantage of some of our features.

Sparkiniity uses strictly necessary, functional, performance and tracking cookies.

Strictly necessary cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

The functional cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Our performance cookies us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.

Our targeting cookies, web beacons, tags and scripts remember your browsing behaviour. This helps us in tailoring our website content to your interests and showing advertisements that fit your profile.

When you first visited our website we informed you about our use of cookies and requested your consent. You can easily remove or block cookies and trackers in your browser. For more information please visit http://www.whatarecookies.com/delete.asp

Please also refer to the section ‘Automatic Collection Technologies.’ for more information on how we use these technologies when providing our Services.


Analytics

We may use analytics service providers, including Google Analytics, to collect information regarding visitors to our Services, such as their behaviour on our Services or information about their demographic. For more information about Google Analytics, see https://www.google.com/policies/privacy/partners/. To opt out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout.


Do-Not-Track

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioural advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. At this time, we do not respond to nor honour Do-Not-Track signals from web browsers.


Information Collected from Third Parties

We may collect information about you through a referral program, such as when a Sparkinity Retailer or Brand refers one of their existing customers, leads, or partners to Sparkinity. If you have been referred to Sparkinity but wish to opt out of emails from us, please contact us as explained below.

If you access our Services through a third party or social networking site, we may collect information about you from that third-party application if that information has been made public via your privacy settings with that third party. For example, if you register for Sparkinity with Facebook, we may collect your name, profile ID, location, gender, profile picture, and list of your friends.

We may receive information about you from other sources, including to supplement the information we have collected about you. In some circumstances, we may receive payment performance information to evaluate your eligibility for extended payment terms (such as Net 60).

We may offer third-party integrations. If you choose to integrate third-party applications with Sparkinity, we will collect personal information as part of that integration. Because each third-party service you may choose to integrate collects different personal information, the detail on which information will be collected will be explained during the integration setup process. For more information on integrations, please contact us as described below.


How Does Sparkinity Use the Personal Information It Collects?

We use the information we collect about you for various business purposes as described below.


To provide you with our Services

  • Enter into a contract with you

  • Allow you to set up a user account and profile

  • Fulfil your requests for products and services

  • Allow you to create and share content with others

  • Communicate with you about your account and updates to our Services

  • Determine your order or account limits and eligibility for extended payment terms

  • Process applications, transactions, and payments

  • Allow you to register for events

  • Facilitate communications between you and other users


For our legitimate business interests

  • Enter into a contract with you

  • Analyse how you use the Services

  • Understand user interest and engagement on the Services

  • Engage in marketing or sales outreach

  • Provide customised content, offers, or Services, including marketing content via email, postal mail, social media, SMS, or other channels, subject to applicable laws

  • Research and develop Services

  • Improve and streamline our Services

  • Verify your identity and prevent fraud

  • Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity

  • Ensure quality control

  • Debug to identify and repair errors

  • Enforce our Terms and policies

  • Audit or other compliance activities


To comply with our legal obligations

We retain and use your information in connection with potential legal claims, and for compliance, regulatory and auditing purposes. For example, we retain information where we are required by law, or if we are compelled to do so by a court order or regulatory body. Also, when you exercise any applicable legal rights you have to access, amend or delete your personal information, we may request identification and verification documents from you for the purpose of confirming your identity.


With your consent

Sparkinity may collect and use personal information based with your consent. You can revoke your consent at any time (either through our Services directly or by contacting us via support@sparkinity.com), though note that you might not be able to use any service or feature that requires collection or use of that personal information.

In exceptional cases we may further process your personal information to protect your vital interests or as further required for the public good.


De-Identified and Aggregated Information

We use personal information to create de-identified, aggregated information such as: information about demographics, de-identified location information, information about devices used to access our Services, and de-identified, aggregate information on transactions on our Services that help our users understand and optimise sales.


Automatic Collection Technologies

Our use of automatic collection technologies such as cookies, pixel tags, and local storage objects (together “Cookies”) fall into the following general categories:

  • Strictly Necessary: Technologies that allow you to access our Services and use our features, and tools that help us identify irregular site behaviour and prevent fraudulent activity or improve security.

  • Personalisation: Technologies that help us personalise advertising and content for you, such as by making inferences about your interests based on the content you interact with on our Services, which informs future selections of content or advertising.

  • Measurement: Technologies that collect information about your use of our Services, including measuring, understanding, and reporting on your usage of the Services.

  • Information Storage and Access: Technologies that store information or provide access to information that is already stored on your device, such as your shopping cart.

  • Content Selection, Delivery, and Reporting: Technologies that select and deliver content for you, and measure the effectiveness of that content, including information about what content was shown, how often or how long it was shown, when and where it was shown, and what actions, if any, you took on the content.

  • Ad Selection, Delivery, and Reporting: Technologies that select and deliver advertisements for you, and measure the effectiveness of those advertisements, including information about what advertisements were shown, how often or how long they were shown, when and where they were shown, and what actions, if any, you took on the advertisements.


Third-Party Websites

We may offer links to third-party websites or Services, including those from the Retailers and Brands registered on our platform. These are not controlled by us and not subject to the protections laid out in this Privacy Policy. We do not endorse nor approve any third-party website and we encourage our users to read the Privacy Policy of each service they interact with.


APIs and SDKs

We may use third-party APIs and software development kits (“SDKs”), which may allow third parties to collect personal information about you for various purposes, such as to conduct analytics, verify your business when you register with Sparkinity as a Retailer or Brand, provide customised content, or otherwise streamline the Services. For more information about our use of APIs and SDKs, contact us as described below.


Will Sparkinity Share Any of Your Personal Information With Third Parties?

We do not sell your personal data to third parties.

We will only share it with third parties if this is necessary for us to perform specific obligations under our agreement with you, if we have a legal obligation or if you have given us your explicit consent.

We will enter into a data processing agreement with each company that processes your personal data on our behalf to ensure that this company adheres to at least the same level of security and confidentiality.

We may share information about you, including your financial history, with 3rd parties in order to evaluate your eligibility for extended payment terms (such as Net 60).

Sparkinity may share specific data of its users relating to such user’s identity and its activities on the platform with other users on the platform.

We may collect information about you through a referral program, such as when a Sparkinity Retailer or Brand refers one of their existing customers, leads, or partners to Sparkinity. If you have been referred to Sparkinitiy but wish to opt out of emails from us, please contact us as explained below.


Children’s Information

As noted in the Terms of Service, we do not knowingly collect nor solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us with personal information, please contact us as described below.


Is Personal Information About Me Secure?

You must prevent unauthorised access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We treat your Personal Data as private, confidential and we strive to ensure that Personal Data under our control, regardless of format, is protected and kept secure at all times. Please be aware, however, that no method of transmitting information over the Internet or of storing information is 100% secure. Accordingly, we cannot absolutely guarantee the protection of any information shared with us.


What Are Your Rights In Relation to Your Personal Data?

Since your personal data belongs to you, you also have rights in relation to your personal data:

  • Right to access, rectify and transfer. This means that we can give you an overview of all personal data that we are processing in relation to you and make any changes if it is not correct.

  • Right to object to further processing. This means that we will stop the processing of your personal data if we are processing your data on the basis of legitimate interest or your consent.

  • Right to erasure and restriction of processing. This means that we can delete any personal data of you if we no longer have a good reason to process it. You can also ask us to (temporarily) stop any use of your personal data if the use is unlawful or if there is a disagreement on the correctness of your personal data.

Please let us know you wish to invoke your rights, by sending an email to the address at the bottom of this policy. We may ask for additional information to verify your identity.


Data Storage

Sparkinity is a UK registered business and we intend and prefer to store all your personal data within relevant regulatory requirements. However, based on the subcontractors we use your data may be stored elsewhere. In that case we will make sure that this subcontractor uses an adequate level of protection of this data that is at least as good as the level we are required to have in compliance with UK laws and regulatory requirements.


Data Retention

We keep your Personal Data for as long as we have a valid and lawful reason to use it. After that we will destroy it or anonymize it so the data is no longer traceable back to you.


Will Sparkinity Change this Privacy Policy?

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to material changes by placing a notice on the http://www.whatarecookies.com/delete.asp website, by sending you an email, and/or by some other means. By using the Services after any changes to the Privacy Policy have been posted, you agree to the new Privacy Policy.


What if I have questions about this policy?

If you have any questions or suggestions regarding the way we deal with privacy and personal data, please let us know via support@sparkinity.com or by regular mail at:

Sparkinity Limited
71-75 Shelton Street
Covent Garden
London
England
WC2H 9JQ