Version updated September 18, 2019


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. This policy applies to our customers, end users, applications users, and website users in the United States. This policy also describes privacy rights you have under certain laws. A separate policy applies to the collection of personal data outside of the United States.


Information We Collect

We collect personal information from our customers, employees, application users, end users, and employment candidates. The personal data collected may include name, address, telephone number, email address, company name, job title, tax identification number, driver license, other forms of identification, device identification, IP addresses, site usage information, reason for contacting us, 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.

If we have collected and processed your personal data with your consent, you can withdraw your consent at any time. This may mean your access to certain services is restricted or denied as a result. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

How We COLLECT 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 you 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.

When you contact us we may monitor or record that conversation to keep a record of the transaction or for training purposes. We may use automated systems to better direct your calls or inquires. If you communicate with us through the use of third party software or systems your communication will also be governed by these companies’ privacy policies.

When you establish an online account or register on our sites or apps, we may collect information about your user identification, password and secret questions and answers. We use this information to authenticate you when you sign in.

We are interested in your views, and we value feedback, and we may therefore set up notice boards, newsgroups, community feedback sites, email systems, forum facilities and/or chat rooms on our sites. Any information that you disclose via such facilities will be used in accordance with the terms of service for the particular forum and in the absence of such terms of service, this Policy. However, we can of course not control and be responsible for other parties’ use of the personal data which you make available to them through such facilities and otherwise on our sites. We encourage you to be careful about what personal data you share in this way.

How We Use Information About You

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 law 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 We Share With Third PartIes

Except as explained in this privacy policy for specific services to our customers and end users, we do not sell, license or share information with companies that are not working on our behalf without the consent of the person whose information will be shared.

We may disclose information that identifies our customers or end users under certain circumstances such as:

  • To comply with a valid legal process including subpoenas, court orders, or search warrants, and as otherwise authorized by law.
  • To protect you against fraud
  • To protect our property and rights
  • To defend against complaints or legal claims in court
  • To parties you have authorized to verify your account information
  • With your consent

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 us 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 or to the disclosure of customers, and user’s 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

Or 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.



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