SparksLife Worldwide OÜ

We ask you to read this Policy thoroughly. When we use “We”, “Us”, “Our”, “Sparks Life” in the text of this Policy we mean SparksLife Worldwide OÜ, a company registered in Estonia at Tuukri 19-315, Tallinn, Estonia, registration number 14549959, which is the developer and the owner of the products and services offered in the Sparks Life’s official application, located at App Store and Google Play(the “Application”).

SparksLife Worldwide OÜ is the controller of the personal data of Users, which use Sparks Life Services (hereinafter referred to as the "Users"). The controller of the personal data is the person or entity who determines the purposes and means of the processing of personal data.

We have prepared this new Policy, taking into account the latest changes in the legislation regulating the protection of personal data, in particular, taking into account the requirements of the General Data Protection Regulation (GDPR).

Sparks Life is committed to transparency in the collection and use of your personal information. We recognize the right of all our Usersfor confidentiality. Protection of personal data of our Users is our top priority.

This Policy sets forth a description of how we collect, store, use and protect personal information, and the circumstances under which we may share this information. This Policy also describes your data protection rights, including your right to object to some of the processing which We carry out. More information about your data protection rights and how to exercise them is set out below. This Policy applies to all users of the Application.

This Policy describes procedures of Sparks Life (created by SparksLife Worldwide OÜ) pertaining to the collection, use, and disclosure of your personal information and products we offer (the “Services”).

COLLECTING OF YOUR PERSONAL INFORMATION

We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities in the Application or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Application, the choices you make and the products and features you use. The personal information we collect can include the following:

a) Personal information you give us by phone, email, and via our Application, in writing or otherwise. This includes but is not limited to information you give us when you request quotations, register for email alerts, signup for newsletters or information that you provide while using our Application. The information you give us can include your name, address, email address and other contact information. It can also include your financial and debit card information, bank account number and other personal details such as your National Insurance number, identification details (e.g., Passport number, National ID number), National tax ID or details about your education and career.

b) Personal data for contract, service provision we have entered with you or data collected in order to take certain steps prior to entering into a contract with you. We will use your personal data to provide you with our Services. These may include but is not limited to name, position, residential address, identification details (e.g., passport) postal address, business address, mobile number, email address, proof of source of income etc.

c) Publicly available information. Sparks Life may also process personal data from public sources including from databases for compliance checks or sources such as e.g., LinkedIn.

d) Compliance with a legal obligation Sparks Life might be required to comply with certain legal and regulatory obligations, which may involve the processing of personal data. (e.g., employment records, company records, tax reporting obligations). Sparks Life may also need to provide information to a public body or law enforcement agency when we are so required.

Further to all the above, the most common types of information that We collect include names, email addresses, IP addresses, other contact details, profession, qualifications, survey responses, dietary requirements, photos, credit card information, tax information, copies of Passport or ID, quotes, etc. The information may be used to process your registration, gain feedback. This information may be used for future contact, only with your consent, in order to market the Sparks Life Services to you. This information will be held by Us until you choose to unsubscribe/withdraw your consent, in accordance with article 7(3) of the General Data Protection Regulation (Regulation EU 2016/679).

USE OF COOKIES

Sparks Life makes available a comprehensive Cookie Notice that describes the cookies used in our Application and provides information on how users can accept or reject them.

SECURITY OF YOUR PERSONAL INFORMATION

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. Please note that transmission of data or information (including communications by email) over the Internet or other publicly accessible networks may not always be secure, and may be subject to possible loss, interception, or alteration while in transit. Accordingly, Sparks Life does not assume any liability, without limitation, for any loss or damage you may experience or costs you may incur as a result of any transmissions over the Internet or other publicly accessible networks, containing your personal information. While Sparks Life will take commercially reasonable efforts to safeguard the privacy of the information you provide to us and will treat such information in accordance with the Policy contained herein, in no event will the information you provide to us be deemed to be confidential, create any fiduciary obligations for Sparks Life, or result in any liability for Sparks Life in the event that such information is accessed by third parties without our consent.

STORAGE OF YOUR PERSONAL INFORMATION

Sparks Life is based in Estonia. Your data will be processed in this country. The personal information we collect from you may also be stored in one or more databases hosted by third parties located in Europe.

We store your personal data only when it is necessary for you or Sparks Life for the purposes indicated in this Policy. If we don't need certain information about you and don't need to store information about you in accordance with the requirements of the law, we will delete it or will store it in an anonymized way.

DISCLOSURE OF PERSONAL INFORMATION

We do not transfer, sell, rent, trade or otherwise disclose your personal information, except as described in this Policy.

We may transfer or disclose your personal information as follows:

1. Service Providers: Your personal information may be disclosed, stored and / or transferred (or otherwise made available) to our affiliates, subsidiaries, third parties who provide services such as hosting; to third parties – processors, namely, companies, which help Sparks Life collect, record, store, analyze, structure and process information or perform other actions according to Sparks Life instructions. Abovementioned persons adhere to confidentiality rules with regard to your information to the same extent as Sparks Life according to this Policy.

2. Legal and Compliance: Sparks Life may share your personal information with law enforcement, data protection authorities, government officials, and other authorities if (i) compelled by subpoena, court order, or other legal procedure, (ii) disclosure is necessary to prevent physical harm or financial loss, (iii) necessary to report suspected illegal activity, or (iv) disclosure is necessary to investigate violations of Users’ obligations or potential violations of law.

3. Sale of Business: Your personal information may be provided to third parties in the case of carrying out mergers and acquisitions operations, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.

4. International Transfer: The data of the Users from the EU can be transferred to third countries outside the EU and the European Economic Area. If such data is transferred outside the countries of the EU and the European Economic Area to third countries, we will use appropriate measures to ensure that such a transfer is legal. The measures might include the standard contract clauses approved by the European Commission.

RIGHT TO ACCESS TO PERSONAL DATA

If you want to find out an exhaustive list of data, which Sparks Life has about you, you may use your right to access information about yourself. To exercise this right, please send a request to the following email address: company@a-sparks.com. We may ask you to carry out additional verification procedures to ensure that the information is provided to the right User.

THE RIGHT TO BE FORGOTTEN

In certain cases, i.e. if you withdraw your prior consent or if you object to processing of your personal data based on legitimate interest and we do not have any interest that prevails over your rights, freedoms and interests, you have the right to ask us to remove the data that we have about you. To exercise this right, please contact us at the following email address: company@a-sparks.com. We may ask you to perform additional verification procedures to make sure that the appropriate User has contacted it. There are certain cases in which the above described right cannot be exercised. We will inform you if they occur.

CHANGES TO THE POLICY

In the event of changes made to this Policy, the modified version will be immediately published in the Application. You should regularly review this Policy. If the changes in this Policy are significant, we will do our best to inform you about the changes and to make such changes clearly introduced to you. If changes to this Policy are not significant, we will notify you of such changes by posting the updated Policy in our Application.

CONTACT US

You understand and agree that all communication with you will be via email.

Please contact us if:

you have any questions, inquiries or comments about this Policy; or
you wish to access, update, and/or correct inaccuracies in your personal information; or
you otherwise have a question or complaint about the manner in which we or our service providers treat your personal information.

You may contact us by E-mail at company@a-sparks.com.

MISCELLANEOUS

This Privacy Policy comes into force on May 1, 2023.