Spark Privacy Policy

We at Spark Educational Services Limited (“Spark”, “we” or “us”) are committed to protecting the privacy of our users.

This Privacy Policy applies to personal information collected (1) at Spark websites and other sites that we own or control that link to this policy (“Spark Web Sites”), (2) for or by Spark product of service offerings that are hosted by Spark or its service providers, and (3) for or by Spark consumer offerings. Please review this Privacy Policy to understand how the information you provide to us will be treated.

CONSENT TO SPARK PROCESSING INFORMATION ABOUT YOU

By providing any information to us or sharing information with others (including sensitive information), you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy and any applicable user agreement (including an end user license agreement or service agreement) that allows us to process information about you.

COLLECTION OF PERSONAL INFORMATION

Personal information is information that can be used to identify you personally or is associated with any such information, such as your name, email address, mailing address, and so forth. This Privacy Policy does not apply to information we collect in the aggregate. Aggregated information does not identify you as an individual.

We may collect personal information from you in the following ways:

1. Registration
   
   • In order to access some Spark offerings, you will be asked to create a user account, which requires you to provide us with information that may include your name, email address, and other personally identifiable information.
2. Information You Choose to Provide
   
   • Certain Spark offerings enable you to provide information about yourself or others. Providing additional information beyond what is required at registration is up to you, but providing additional information may enable you to derive more benefit from Spark offerings.
3. Customer Service and Support
   
   • We may collect information about you if you receive end-user support and you use that support; this information may include your name, email address or other personally identifiable information. We may also collect information about you if you contact us for email or other support.
4. Web Sites, eCommerce and Other Marketing Initiatives
   
   • At some Spark Web Sites, we ask you to provide information, such as your email address, name, employer name, home or work address, or telephone number. We may also collect demographic information, such as your postal code, gender, age, preferences, interests, and favorites.
   • We may collect personal information from you, such as your name, email address, telephone number, and organization information, when you sign up for webinars, product trials, newsletters, contests, or other marketing initiatives through the Spark Websites.
   • If you choose to make a purchase or sign up for a paid subscription service or product offering, we may ask for additional information, such as your credit card information, billing address, shipping address.Please note that the only card information that should be stored is the first four and/or last four digits of the credit card number.
   • When you subscribe to Spark Web Sites, we collect information such as your name, organization, and email address. You can also populate your user profiles with information beyond that provided during registration, such as photos or other personally identifiable information.
   • When you post information to one of our forums, blogs, message boards, or groups, you share your profile information, including your name and other information that you choose to share with other group members. When you post a comment on our forums, blogs, message boards, or groups, you may share information within your comment, along with the name you provide to the general public.
5.  Cookies and Web Beacons
   
   • Like most websites, we use technologies, such as cookies and web beacons, to collect information about the pages you view, the links you click, and other actions you take when using Spark offerings and Spark Websites.

USE OF PERSONAL INFORMATION

When you provide information, that information may reside on our or our service providers’ systems. In addition to providing you with the services or products that you have requested, we collect and use your information to operate and improve Spark offerings and Spark Web Sites. These uses include providing you with more effective customer service; making offerings easier to use by eliminating the need for you to enter the same information repeatedly; performing research and analysis aimed at improving Spark offerings and technologies and Spark Web Sites; and displaying content and advertising that are customized to your interests and preferences.

Some Spark offerings include interactive features such as chat rooms, forums, messaging, and other ways to share; it is your choice whether to use the available functionality.

Information collected through Spark offerings and Spark Web Sites may be stored and processed by us, our affiliates, or our service providers in Jamaica or elsewhere; the laws of the jurisdiction in which the information is stored and processed will apply to its storage and processing.

If you submit information through a Spark Website, the personal information you submit may be used to provide the services or products you requested and may also be used for related activities. Related activities may include sharing your information with sales or marketing personnel, who may contact you with further information that may interest you.

When you receive newsletters or promotional emails from us, we may use web beacons, customized links, or similar technologies to determine whether the email has been opened and which links you clicked in order to provide you with more focused e-mail communications or other information.

We may use your information to communicate with you. We may send certain service communications such as welcome letters, billing reminders, information on technical service issues, and security announcements. Some Spark offerings may send periodic member communications that are considered part of the service. We may also send you promotional information to inform you of other Spark offerings and promotions.

COMMUNICATIONS WE SEND

We may communicate with you through email or other means available through a Spark offering. We may send emails that help inform you about features of Spark offerings, and we may also send you service messages related to the function of Spark offerings. We may send you messages with promotional information directly or on behalf of our partners.

If you sign up for webinars, product trials, newsletters, contests, or other marketing initiatives through the Spark Websites, Spark employees may contact you with information about Spark offerings and promotions that may interest you.

SHARING YOUR INFORMATION WITH THIRD PARTIES

We may share your information with third parties who are not our partners or service providers only in the following situations: We have your consent through an opt-in option provided to you, or We have a good faith belief that access, use, preservation or disclosure of your personal information is reasonably necessary to

1. satisfy any applicable law, regulation, legal process, or enforceable governmental request,
2. enforce applicable terms and conditions of this Privacy Policy or any applicable user agreement, including investigation of potential violations thereof,
3. detect, prevent, or otherwise address fraud, security or technical issues, or
4. protect against harm to the rights, property, or safety of One-One-One, our users, or the public as required or permitted by law.

Except as part of the sale of all or substantially all of our assets and undertaking, we will not sell, trade, or rent your personal information to third parties who are not our partners or service providers unless we have your consent.

INFORMATION YOU SHARE WITH OTHER USERS

Spark offerings may enable you to share information with or send communications to other users or the general public. You may select the other users with whom you share or to whom you send this information. Once you share information with or send information to other users, however, those other users may share your information at their discretion. If you join a Spark community, forum, blog or group, other members of that Spark community can view your profile information once you provide it.

YOUR OPTIONS FOR YOUR PERSONAL INFORMATION

1. Accessing and Correcting Your Personal Information

We offer users the ability to access or correct information we collect during registration or that they have provided in using Spark offerings. Users may correct this information anytime and as often as necessary by using the features provided within the applicable Spark offering. To access or correct personal information collected by us that is not available through a Spark offering, please contact us at the address listed below. We will respond within a reasonable timeframe of receiving your request or as law requires.

We may decline to provide you with access to, or to change, your personal information if (a) your request is not provided in writing, (b) your request does not provide us with sufficient detail to identify the personal information you seek to access or change, (c) we are unable to verify your identity to our satisfaction or (d) we deem, in our sole discretion, that it would be unreasonable in the circumstances to provide you with access to or to correct your personal information.

2.  User Opt-Out Option and Retention of Your Information

You may opt out of receiving promotional information from us by following the unsubscribe procedures indicated in the promotional information you receive. We will retain your information for so long as you maintain an active account or user profile or as needed to provide you with the applicable Spark offering. If you wish to close an account with us, you may contact us at hello@ spark-education.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce this Privacy Policy and any applicable user agreements. We will take steps to ensure that your personal information is destroyed, erased, or made anonymous as soon as the purpose for which it was collected is no longer relevant or as required by law.

Please be aware that, as long as you have access to Spark offerings, you cannot opt out of receiving service messages from us. Also, if we send communications to you via the carrier service with which you have a mobile communications subscription or otherwise have access, you understand you will pay any service fees associated with your receipt of messages on your mobile device (including text messaging charges). You may opt out of receiving promotional information from us by following the unsubscribe procedures indicated in the promotional information you receive.

3. Information Security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include internal reviews of our data collection, storage, and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to Spark employees, contractors and agents who have a need to know that information in order to process it on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, as well as civil action and criminal prosecution, if they fail to meet these obligations.

We do not guarantee that we will eliminate all risks of misuse of your personal information. There is no such thing as perfect security, and we cannot guarantee or warrant the security of any data (including personal information) that we receive and store on our or our service providers’ systems.

You are responsible for keeping any passwords secret to prevent unauthorized access to and use of any offerings to which you have access.

4. Transaction Security

Our website has a 128-bit encryption standard, making transactions more secure.

5. Protection of Children’s Personal Information

We do not knowingly collect any personal information from individuals under the age of 18 through Spark offerings or Spark Web Sites. The Spark Web Sites are general audience Web sites.

HOW TO CONTACT US

We commit to the resolution of complaints about your privacy and our collection or use of your personal information. Our Privacy Officer is responsible for ensuring our compliance with this Privacy Policy and all relevant privacy laws.

If you have any comments, questions, or concerns about this Privacy Policy, the data that we collect from you, or how that data is being used, or to report suspected misuse of your information, please contact us at [email protected]