DATA PRIVACY

Privacy Policy

As of 12 September 2023


Thank you for being interested in Sparks. It is an online-offline mobile application developed by BTSolve, Inc. We at BTSolve, Inc. (BTS) respect your privacy and want you to fully understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights regarding your personal data.

This Privacy Policy shall apply when you visit or use the Sparks websites, mobile applications, APIs, or any related services. It also applies to prospective customers of our business services and products.

By using the services above, you agree to the terms of this Privacy Policy. You shouldn’t use the services above if you do not agree with this Privacy Policy or any other agreement that governs your use of the services above.



Table of Contents


Data We Collect

Data You Provide that We Collect

Data We Collect Automatically

Data From Third-Parties

How We Collect Data

Cookies and Data Collection Tools

Other Data Collection Methods Used

Why We Use Data Collection Tools

What We Use Your Data For
Who We Share Data With

Data We Collect


We collect certain data from you directly, like information you enter yourself, data about your content consumption, and data from third-party platforms you connect with Sparks. We also collect some data automatically, like information about your device and what parts of our services you interact with or spec time using. All data listed below is subject to the following process activities: collecting, recording, structuring, storing, altering, retrieving, encrypting, pseudonymizing, erasing, combining, and transmitting.


Data You Provide that We Collect

We may collect different data from or about your depending on how you use our services, Below are some examples to help you better understand the data we collect.


When you create an account and use the services, including through a third-party platform, we collect any data you provide directly, including:


Personal Data Description

The data listed above is stored by us and associated with your account.


Data We Collect Automatically

When you access our services in Sparks, we collect certain data by automated means, including:

Personal Data Description

Data From Third-Parties

When you join teams within Sparks, we may collect data that are related to the teams that you have joined such as businesses and industry information.


How We Collect Data

We use tools like cookies, web beacons, and similar tracking technologies to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.


Other Data Collection Methods Used

Insert other data collection methods used


Why We Use Data Collection Tools

Sparks uses the following types of Data Collection Tools for the purposes described:

  • Strictly Necessary: These Data Collection Tools enable you to access the site, provide basic functionality (like logging in or accessing content), secure the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These are required for the Services to work properly, so if you disable them, parts of the site will break or be unavailable.
  • Functional: These Data Collection Tools remember data about your browser and your preferences, provide additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behavior of the Services (like your preferred language or volume level for video playback).
  • Performance: These Data Collection Tools help measure and improve the Services by providing usage and performance data, visit counts, traffic sources, or where an application was downloaded from.
  • Advertising: These Data Collection Tools are used to deliver relevant ads (on the site and/or other sites) based on things we know about you like your Usage and System Data (as detailed in Section 1), and things that the ad service providers know about you based on their tracking data. The ads can be based on your recent activity or activity over time and across other sites and services. To help deliver tailored advertising, we may provide these service providers with a hashed, anonymized version of your email address (in a non-human-readable form) and content that you share publicly on the Services.

You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional. To learn more about managing Data Collection Tools, refer to Section 6.1 (Your Choices About the Use of Your Data) below.


What We Use Your Data For

We use your data to do things like provide our services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our services, analyze how people use our services, personalized advertising, provide learning status to you and your team admins, and as required by law or necessary for safety and integrity. We retain your data for as long as it is needed to serve the purposes for which it was collected.


We use the data we collect through your use of the Services to:


  • Provide and administer our services, including to facilitate participation in learning content, display customized content, and facilitate communication with other users and team admins;
  • Process your requests for access to educational content, products, specific services, information, or features;
  • Communicate with you about your account by:
    • Responding to your questions and concerns;
    • Sending you administrative messages and information, including messages from team admins and other users; notifications about changes to our Service; and updates to our agreements;
    • Sending you information, such as by email or text messages, about your progress in courses and related content, rewards programs, new services, new features, promotions, newsletters, and other available team admin-created content (which you can opt out of at any time);
    • Sending push notifications to your wireless device to provide updates and other relevant messages (which you can manage from the options or settings page of the mobile app);
  • Manage your account and account preferences and personalize your experience;
  • Facilitate the Services’ technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse;
  • Verify the identity of team admins;
  • Solicit feedback from users;
  • Market products, services, surveys, and promotions;
  • Learn more about you by linking your data with additional data through third-party data providers and/or analyzing the data with the help of analytics service providers; Identify unique users across devices;
  • Tailor advertisements across devices;
  • Improve our services and develop new products, services, and features;
  • Analyze trends and traffic and track usage data;
  • As required or permitted by law; or
  • As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our services.

Who We Share Data With

We share certain data about you with team admins, other users, companies performing services for us, Sparks affiliates, our business partners and clients, analytics and data enrichment providers. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent.

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:


  • With Your Instructors/Trainers Identified By You: We share data that we have about you (except your email address) with instructors or teaching assistants for educational content you access or request information about, so they can improve their content for you and other students. This data may include things like your country, browser language, operating system, device settings, the site that brought you to Sparks, and certain activities on Sparks, like enrolled courses and course review. We will not share your email address with instructors or teaching assistants.
  • With Other Users and Instructors/Trainers: Depending on your settings, your shared content and profile data may be publicly viewable, including to other students and instructors. If you ask a question to an instructor or teaching assistant, your information (including your name) may also be publicly viewable.
  • With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
  • With Business Partners and Client: We have agreements with other websites and platforms to distribute our Services and drive traffic to Sparks. Depending on your location, we may share your data with these trusted partners. We may also enter or have entered agreements with Business Clients to distribute data under which you are part of their team.
  • With Analytics and Data Enrichment Services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services like ZoomInfo, we share certain contact information or de-identified data. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner.
  • To Power Social Media Features: The social media features in the Services (like the Facebook Like button) may allow the third-party social media provider to collect things like your IP address and which page of the Services you’re visiting, and to set a cookie to enable the feature. Your interactions with these features are governed by the third-party company’s privacy policy.
  • To Administer Promotions and Surveys: We may share your data as necessary to administer, market, or sponsor promotions and surveys you choose to participate in, as required by applicable law (like to provide a winners list or make required filings), or in accordance with the rules of the promotion or survey.
  • For Advertising: If we decide to use an advertising-supported revenue model in the future, we may use and share certain System Data and Usage Data with third-party advertisers and networks to show general demographic and preference information among our users. We may also allow advertisers to collect System Data through Data Collection Tools (as detailed in Section 2.1), to use this data to offer you targeted ad delivery to personalize your user experience (through behavioral advertising) and to undertake web analytics. Advertisers may also share with us the data they collect about you. To learn more or opt out from participating ad networks behavioral advertising, see Section 6.1 (Your Choices About the Use of Your Data) below. Note that if you opt out, you’ll continue to be served generic ads. (System Data)
  • For Security and Legal Compliance: We may disclose your data (all data categories) to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
    • Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
    • Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
    • Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
    • Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;
    • Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Sparks, our users, employees, members of the public, or our Services;
    • We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy; or
    • Required or permitted by law.
  • During a Change in Control: If Sparks undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
  • After Aggregation/De-identification: We may disclose or use aggregated or de-identified data for any purpose.
  • With Your Permission: With your consent, we may share data to third parties outside the scope of this Privacy Policy.

Security

We use appropriate security based on the type and sensitivity of data being stored. As with any internet-enabled system, there is always a risk of unauthorized access, so it’s important to protect your password and to contact us if you suspect any unauthorized access to your account.

Sparks and BTSolve, Inc. take appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and BTSolve, Inc., our services, or any information provided to us in connection with the data we collect through our services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact our Developer Team and / or Support Team with any concerns.


Your Rights

You have certain rights around the use of your data, including the ability to opt out of promotional emails, cookies, and collection of your data by certain third parties. You can update or terminate your account from within our services, and can also contact us for individual rights requests about your personal data.


Your Choices About the Use of Your Data

You can choose not to provide certain data to us, but you may not be able to use certain features of the Services.


  • The browser or device you use may allow you to control cookies and other types of local data storage. To learn more about managing cookies, visit https://cookiepedia.co.uk/how-to-manage-cookies. Your wireless device may also allow you to control whether location or other data is collected and shared.
  • To opt out of allowing Google Analytics, Mixpanel, ZoomInfo, or Clearbit to use your data for analytics or enrichment, see the Google Analytics Opt-out Browser Add-on, Mixpanel Opt-Out Cookie, ZoomInfo’s policy, and Clearbit data claiming mechanism.
  • Apple iOS, Android OS, and Microsoft Windows each provide their own instructions on how to control in-app tailored advertising. For other devices and operating systems, you should review your privacy settings on that platform.

Accessing, Updating, and Deleting Your Personal Data

You can access and update your personal data that Sparks collects and maintains as follows:

  • User can manage their own data from our Sparks portal/app

Updates & Contact Information

When we make a material change to this policy, we’ll notify users via email, in-product notice, or another mechanism required by law. Changes become effective the day they’re posted. Please contact us via email or postal mail with any questions, concerns, or disputes.


Modifications and Revisions to This Privacy Policy

From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on our services, or as required by applicable law. We will also include a summary of the key changes. Unless stated otherwise, modifications will become effective on the day they are posted.

As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.


Questions

If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact us through admin@btsolve.com.