INTERNATIONAL PRIVACY POLICY

Introduction

This policy is to explain how SparX Works Inc., SparX Works, sparxworks.com (which we collectively refer to in this policy as “we”, “our”, or “us”) collect and use your personal data. Privacy laws around the world require us to provide you with information related to our collection of your personal data. You may also receive additional information as to how we use your personal data based on how you interact with us.

Information We Collect

We collect personal data from our publishers, employees, application users, end users, and employment candidates. The personal data collected may include name, address, telephone number, email address, company name, job title, device identification, IP addresses, site usage information, billing and transaction information, and credit card or other financial information. The exact information we collect will depend upon the products or services you use.

How We Obtain Personal Data

We may obtain data in a variety of ways including from registration, from publishing content using our services (via internet, form, telephone, mail, application, or a contract), from products, apps, our websites, and from vendors and contractors, or applicants as applicable.

We may use “cookies” and similar technologies to obtain information about visits to our sites or your responses via phone, text, or email. Cookies are used to enable our sites to function or may provide information to third parties. This information might be about you, your preferences, or your device. The information does not directly identify you, but it can give you a more personalized experience. We use these technologies to help us improve the user experience with our products and services, personalize your experience, facilitate access to content and user experience, or to automate entry into password protected features on our sites, apps or products so that you would not need to re-enter your password and user name each time you visit or use one of our products or services.

How We Use Personal Data We Collect

We use your personal data for various purposes, including providing our services, enabling your account, billing, technical support, product development, and payment application.

We may also use your personal data to contact you regarding our products and services, including survey requests. We will use your personal data for marketing or other purposes unrelated to your specific service only when this is in accordance with applicable data protection or privacy laws and any preferences you express.

If you choose to use our referral service to tell a friend about a product, experience, or page on one of our websites or mobile applications, you will be asked to submit an email, text, or notification to your friend directly. Please do so only if you have the permission of your friend. If your friends refer you to us directly, we may in certain geographic locations use the contact information provided in order to market to you, in accordance with applicable law. In some of our geographic locations, and to the extent permitted by applicable law, we may monitor or record your telephone conversations with us for quality control, training, and security purposes.

Under the local laws in some countries, we must be able to describe the legal basis on which we rely to process your personal data. In most cases, we will process your personal data for our legitimate business interests (for example, to enable us to understand how our services are used and to derive knowledge that enables us to develop new services), when it is necessary for purposes of a contract, or when it is necessary for us to do so to meet our legal obligations. When we process your personal data for our legitimate business interests, we put in place safeguards to make sure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

In some cases and where required by law we will ask for your consent to collect your personal data. You may withdraw your consent at any time by contacting us. See contact information below.

When Do We Share Personal Data?

We share analytics and location based information with our publishers and partners, with your consent, and otherwise where we have a legal basis to do so under applicable law.

We may also share personal data when it is (i) required or permitted to do so by law or regulatory obligation; (ii) necessary to identify, contact or bring legal action against individuals who may be endangering public safety or interfering with our property or services including as part of any procedure necessary to collect a customer debt, or our customers’ or others’ use of them; or (iii) in connection with any proposed or actual sale or other transfer of some or all of our assets. Such disclosures occur only in accordance with applicable laws.

Some of our products and services may include social network or other party’s plugins that may provide information to their associated networks.

Information from Children Under 13 (16 in the EU)

We do not knowingly market to or collect information from children under 13 years of age in the United States, or 16 years of age in the EU. We will promptly delete any information later determined to be from such a young person, unless we have received consent to collect such personal data from the child’s parent or guardian. If you think your child has provided his/her personal information to us and you wish that data to be removed or corrected please contact us as indicated below.

Transfer of Personal Data

We do not transfer personal data to any entities.

Data Protection Rights

We take your security and confidentiality seriously. We have procedural and technical safeguards in place to protect against unauthorized access to use or disclose customer information we store. Our personnel are trained on the importance of protecting privacy and proper access to use of or to the disclosure of customers’ and users’ information. Under our policies access to personally identifiable information is authorized only for those who have a business need for such access. Personal or sensitive information is only kept as long as needed for legal, business, tax, or administrative purposes and we abide by applicable laws.

It is important to know that no software program or system is 100% secure and we cannot guarantee that our processes and technology will prevent every unauthorized attempt to access information.

Contact details

For questions regarding this policy or your data protection rights, please contact us via email at userprotection@sparxworks.com SparX Works Inc. C/O Legal Department 212 N. Juanita Ave. # 2 Redondo Beach, CA 90277

Policy Updates

We reserve the right to make changes to this privacy policy, so please check back periodically for changes. You will be able to see that changes have been made by checking to see the effective date posted at the end of the policy. If we decide to use or disclose your personal data in a manner that is materially different from that stated in our policy at the time we collected that information from you, we will give you a choice regarding such use or disclosure by appropriate means, which may include use of an opt out mechanism.

Affiliates

NorthSouth Studios Peru S.A.C. Prepared September 18, 2019