Privacy Policy
last updated on July 4, 2024
last updated on July 4, 2024
Welcome to Spark Love!
We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) in the “spark” mobile application (“Mobile Application” or “Service”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.
This Policy is a legally binding agreement between you (“User”, “you” or “your”) and Spark (“Spark”, “we”, “us” or “our”). If you are entering into this Policy on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this Policy, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this Policy, you must not accept this Policy and may not access and use the Mobile Application and Services. By accessing and using the Mobile Application and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
For the purpose hereof, the following terms shall have the following meanings: (i) Controller, Processor, Personal Information, Data Processing and Data Breach as defined in the Data Protection Legislation. (ii) Data Protection Legislation: all applicable data protection and privacy legislation in force from time to time in the Kingdom of Thailand including without limitation to the Personal Data Protection Act B.E. 2562 (and regulations made thereunder), in the European Union including Regulation 2016/679 and any other European Union legislation (and regulations made thereunder), in the United Kingdom including the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (and regulations made thereunder), and any other applicable data protection laws in force from time to time.
Automatic collection of information
When you use the Mobile Application, our servers automatically record information that your device sends. This data may include information such as your device’s IP address and location, device name and version, operating system type and version, language preferences, information you search for in the Mobile Application, access times and dates, device ID, and other statistics.
Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage of the Mobile Application and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular User of the system.
Collection of personal information
You can access and use the Mobile Application and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered in the Mobile Application, you may be asked to provide certain Personal Information (for example, your name and e-mail address).
We receive and store any information you knowingly provide to us when you create an account, publish content, make a purchase, or fill any forms in the Mobile Application. When required, this information may include the following:
Account details (such as user name, unique user ID, password, etc)
Contact information (such as email address, phone number, etc)
Basic personal information (such as name, country of residence, etc)
Sensitive personal information (such as ethnicity, religious beliefs, mental health, etc)
Proof of identity (such as a photocopy of a government ID)
Payment information (such as credit card details, bank details, etc)
Geolocation data of your device (such as latitude and longitude)
Device ID
Any other materials you willingly submit to us (such as articles, images, feedback, etc)
Some of the information we collect is directly from you via the Mobile Application and Services. However, we may also collect Personal Information about you from other sources such as social media platforms, public databases, third-party data providers, and our joint partners. Personal Information we collect from other sources may include demographic information, such as age and gender, device information, such as IP addresses, location, such as city and state, and online behavioral data, such as information about your use of social media websites, page view information and search results and links.
You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features in the Mobile Application. Users who are uncertain about what information is mandatory are welcome to contact us.
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 20. If you are under the age of 20, please do not submit any Personal Information through the Mobile Application and Services. If you have reason to believe that a child under the age of 20 has provided Personal Information to us through the Mobile Application and Services, please contact us to request that we delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Mobile Application and Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
Use and processing of collected information
We act as a data controller and a data processor in terms of the Data Protection Legislation when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Mobile Application and Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information and we comply with data controllers’ obligations set forth in the Data Protection Legislation.
We act in the capacity of a data processor in situations when you submit Personal Information through the Mobile Application and Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller in terms of the Data Protection Legislation.
In order to make the Mobile Application and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services . Any of the information we collect from you may be used for the following purposes:
Create and manage user accounts
Deliver products or services
Improve products and services
Send administrative information
Send marketing and promotional communications
Send product and service updates
Respond to inquiries and offer support
Request user feedback
Improve user experience
Enforce terms and conditions and policies
Protect from abuse and malicious users
Respond to legal requests and prevent harm
Run and operate the Mobile Application and Services
Processing your Personal Information depends on how you interact with the Mobile Application and Services, where you are located in the world and if one of the following applies:
You have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to European data protection law.
Provision of information is necessary for the performance of this Policy with you and/or for any pre-contractual obligations thereof.
Processing is necessary for compliance with a legal obligation to which you are subject.
Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us
Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
We may also combine or aggregate some of your Personal Information in order to better serve you and to improve and update our Mobile Application and Services.
We rely on the following legal bases as defined in the Data Protection Legislation upon which we collect and process your Personal Information:
User’s consent
Performance of a contract
Compliance with the law and legal obligations
Legal claims and proceedings
Our own legitimate interests
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases above. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Payment processing
In case of Services requiring payment, you may need to provide your credit card details or other payment account information, which will be used solely for processing payments. We use third-party payment processors (“Payment Processors”) to assist us in processing your payment information securely.
Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private data exchange happens over a SSL secured communication channel and is encrypted and protected with digital signatures, and the Mobile Application and Services are also in compliance with strict vulnerability standards in order to create as secure of an environment as possible for Users. We will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.
Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments (e.g., your email address, address, credit card details, and bank account number) and handle all the steps in the payment process through their systems, including data collection and data processing. The Payment Processors’ use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.
Managing information
You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Mobile Application and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so on the settings page of your account in the Mobile Application.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our trusted subsidiaries and joint venture partners, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Mobile Application and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any information with unaffiliated third parties.
Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes. We will share and disclose your information only with the following categories of Service Providers:
Communication and collaboration services
Data analytics services
Data storage services
Payment processors
Product engineering and design services
User authentication services
We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and your Personal Information will likely be among the assets transferred.
Retention of information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, as long as your user account remains active, to enforce our Policy, resolve disputes, and unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
Transfer of information
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own, including Thailand and India. The transfer of your Personal Information to countries outside the European Union will be made only if you have explicitly consented to it or in the cases provided for by the Data Protection Legislation and will be processed in your interest.
You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this Policy or inquire with us using the information provided in the contact section.
Data protection rights under the Data Protection Legislation
You have certain data protection rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.
You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.
You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this Policy.
You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or defense of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest.
You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or defense of legal claims.
You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.
You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.
How to exercise your rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.
You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
Data analytics
Our Mobile Application and Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information. The information gathered is used to compile statistical reports on User activity such as how often Users visit our Mobile Application and Services, what pages they visit and for how long, etc. We use the information obtained from these analytics tools to monitor the performance and improve our Mobile Application and Services. We do not use third-party analytics tools to track or to collect any personally identifiable information of our Users and we will not associate any information gathered from the statistical reports with any individual User.
Advertisements
We may permit certain third-party companies to help us tailor advertising that we think may be of interest to Users and to collect and use other data about User activities in the Mobile Application. These companies may deliver ads that might place cookies and otherwise track User behavior.
Social media features
Our Mobile Application and Services may include social media features, such as the Facebook and Twitter buttons, Share This buttons, etc (collectively, “Social Media Features”). These Social Media Features may collect your IP address, what page you are visiting on our Mobile Application and Services, and may set a cookie to enable Social Media Features to function properly. Social Media Features are hosted either by their respective providers or directly on our Mobile Application and Services. Your interactions with these Social Media Features are governed by the privacy policy of their respective providers.
Email marketing
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.
Push notifications
We offer push notifications to which you may also voluntarily subscribe at any time. To make sure push notifications reach the correct devices, we rely on a device token unique to your device which is issued by the operating system of your device. While it is possible to access a list of device tokens, they will not reveal your identity, your unique device ID, or your contact information to us. We will maintain the information sent via e-mail in accordance with applicable laws and regulations. If, at any time, you wish to stop receiving push notifications, simply adjust your device settings accordingly.
Links to other resources
The Mobile Application and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Mobile Application and Services and to read the privacy statements of each and every resource that may collect Personal Information.
Information security
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that
There are security and privacy limitations of the Internet which are beyond our control.
The security, integrity, and privacy of any and all information and data exchanged between you and the Mobile Application and Services cannot be guaranteed.
Any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.
Data breach
In the event we become aware that the security of the Mobile Application and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice in the Mobile Application, send you an email.
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Mobile Application and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page, post a notification in the Mobile Application, send you an email to notify you. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Mobile Application and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Mobile Application and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Mobile Application and Services.
Your Rights Under the California Consumer Privacy Act (CCPA)
If you are a resident of California, you have the following rights under the CCPA:
You have the right to know what personal data is being collected about you.
You have the right to know whether your personal data is sold or disclosed and to whom.
You have the right to say no to the sale of your personal data.
You have the right to access your personal data.
You have the right to request the deletion of your personal data.
You have the right to equal service and price, even if you exercise your privacy rights.
To exercise your rights under the CCPA, please contact us using the information provided in the "Contacting Us" section.
Your Rights Under the Lei Geral de Proteção de Dados (LGPD)
If you are a resident of Brazil, you have the following rights under the LGPD:
You have the right to confirm the existence of processing.
You have the right to access your data.
You have the right to correct incomplete, inaccurate, or out-of-date data.
You have the right to anonymize, block, or delete unnecessary or excessive data or data processed in noncompliance with the provisions of the LGPD.
You have the right to data portability.
You have the right to delete personal data processed with your consent.
You have the right to information about public and private entities with which the controller has shared data.
You have the right to information about the possibility of denying consent and the consequences of such denial.
You have the right to revoke consent.
To exercise your rights under the LGPD, please contact us using the information provided in the "Contacting Us" section.
Your Rights Under the Virginia Consumer Data Protection Act (VCDPA)
If you are a resident of Virginia, you have the following rights under the VCDPA:
You have the right to confirm whether or not your personal data is being processed.
You have the right to access your personal data.
You have the right to correct inaccuracies in your personal data.
You have the right to delete personal data provided by or obtained about you.
You have the right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format.
You have the right to opt-out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise your rights under the VCDPA, please contact us using the information provided in the "Contacting Us" section.
Your Rights Regarding Data Sales and Sharing
We do not sell any of your personal data to third parties. If in the future we decide to sell personal data, we will update this Policy and provide you with a means to opt-out of the sale of your personal data.
You have the right to know whether your personal data is shared with any third parties. We will clearly disclose any sharing of personal data in this Policy. If you wish to opt-out of the sharing of your personal data, please contact us using the information provided in the "Contacting Us" section.
Data Protection Officer (DPO) Contact Information
Our Data Protection Officer (DPO) is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact our DPO using the details set out below:
Name: Sandeep Khurana
Email: sunny@spark.love
Address: 23 NEW INDUSTRIAL ROAD, #04-09, SOLSTICE BUSINESS CENTER, Singapore 536209
Contacting us
If you have any questions regarding the information we may hold about you or if you wish to exercise your rights, you may use the following data subject request form to submit your request:
If you have any other questions, concerns, or complaints regarding this Policy, we encourage you to contact us using the details below:
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.
Welcome to Spark Love!
We respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Policy”). This Policy describes the types of information we may collect from you or that you may provide (“Personal Information”) in the “spark” mobile application (“Mobile Application” or “Service”) and any of its related products and services (collectively, “Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that Personal Information. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update it.
This Policy is a legally binding agreement between you (“User”, “you” or “your”) and Spark (“Spark”, “we”, “us” or “our”). If you are entering into this Policy on behalf of a business or other legal entity, you represent that you have the authority to bind such entity to this Policy, in which case the terms “User”, “you” or “your” shall refer to such entity. If you do not have such authority, or if you do not agree with the terms of this Policy, you must not accept this Policy and may not access and use the Mobile Application and Services. By accessing and using the Mobile Application and Services, you acknowledge that you have read, understood, and agree to be bound by the terms of this Policy. This Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
For the purpose hereof, the following terms shall have the following meanings: (i) Controller, Processor, Personal Information, Data Processing and Data Breach as defined in the Data Protection Legislation. (ii) Data Protection Legislation: all applicable data protection and privacy legislation in force from time to time in the Kingdom of Thailand including without limitation to the Personal Data Protection Act B.E. 2562 (and regulations made thereunder), in the European Union including Regulation 2016/679 and any other European Union legislation (and regulations made thereunder), in the United Kingdom including the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (UK GDPR) and the Data Protection Act 2018 (and regulations made thereunder), and any other applicable data protection laws in force from time to time.
Automatic collection of information
When you use the Mobile Application, our servers automatically record information that your device sends. This data may include information such as your device’s IP address and location, device name and version, operating system type and version, language preferences, information you search for in the Mobile Application, access times and dates, device ID, and other statistics.
Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage of the Mobile Application and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular User of the system.
Collection of personal information
You can access and use the Mobile Application and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered in the Mobile Application, you may be asked to provide certain Personal Information (for example, your name and e-mail address).
We receive and store any information you knowingly provide to us when you create an account, publish content, make a purchase, or fill any forms in the Mobile Application. When required, this information may include the following:
Account details (such as user name, unique user ID, password, etc)
Contact information (such as email address, phone number, etc)
Basic personal information (such as name, country of residence, etc)
Sensitive personal information (such as ethnicity, religious beliefs, mental health, etc)
Proof of identity (such as a photocopy of a government ID)
Payment information (such as credit card details, bank details, etc)
Geolocation data of your device (such as latitude and longitude)
Device ID
Any other materials you willingly submit to us (such as articles, images, feedback, etc)
Some of the information we collect is directly from you via the Mobile Application and Services. However, we may also collect Personal Information about you from other sources such as social media platforms, public databases, third-party data providers, and our joint partners. Personal Information we collect from other sources may include demographic information, such as age and gender, device information, such as IP addresses, location, such as city and state, and online behavioral data, such as information about your use of social media websites, page view information and search results and links.
You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features in the Mobile Application. Users who are uncertain about what information is mandatory are welcome to contact us.
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 20. If you are under the age of 20, please do not submit any Personal Information through the Mobile Application and Services. If you have reason to believe that a child under the age of 20 has provided Personal Information to us through the Mobile Application and Services, please contact us to request that we delete that child’s Personal Information from our Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Mobile Application and Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed to never give out Personal Information when online without their permission.
Use and processing of collected information
We act as a data controller and a data processor in terms of the Data Protection Legislation when handling Personal Information, unless we have entered into a data processing agreement with you in which case you would be the data controller and we would be the data processor.
Our role may also differ depending on the specific situation involving Personal Information. We act in the capacity of a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Mobile Application and Services. In such instances, we are a data controller because we determine the purposes and means of the processing of Personal Information and we comply with data controllers’ obligations set forth in the Data Protection Legislation.
We act in the capacity of a data processor in situations when you submit Personal Information through the Mobile Application and Services. We do not own, control, or make decisions about the submitted Personal Information, and such Personal Information is processed only in accordance with your instructions. In such instances, the User providing Personal Information acts as a data controller in terms of the Data Protection Legislation.
In order to make the Mobile Application and Services available to you, or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services . Any of the information we collect from you may be used for the following purposes:
Create and manage user accounts
Deliver products or services
Improve products and services
Send administrative information
Send marketing and promotional communications
Send product and service updates
Respond to inquiries and offer support
Request user feedback
Improve user experience
Enforce terms and conditions and policies
Protect from abuse and malicious users
Respond to legal requests and prevent harm
Run and operate the Mobile Application and Services
Processing your Personal Information depends on how you interact with the Mobile Application and Services, where you are located in the world and if one of the following applies:
You have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to European data protection law.
Provision of information is necessary for the performance of this Policy with you and/or for any pre-contractual obligations thereof.
Processing is necessary for compliance with a legal obligation to which you are subject.
Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us
Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.
We may also combine or aggregate some of your Personal Information in order to better serve you and to improve and update our Mobile Application and Services.
We rely on the following legal bases as defined in the Data Protection Legislation upon which we collect and process your Personal Information:
User’s consent
Performance of a contract
Compliance with the law and legal obligations
Legal claims and proceedings
Our own legitimate interests
Note that under some legislations we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases above. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Payment processing
In case of Services requiring payment, you may need to provide your credit card details or other payment account information, which will be used solely for processing payments. We use third-party payment processors (“Payment Processors”) to assist us in processing your payment information securely.
Payment Processors adhere to the latest security standards as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. Sensitive and private data exchange happens over a SSL secured communication channel and is encrypted and protected with digital signatures, and the Mobile Application and Services are also in compliance with strict vulnerability standards in order to create as secure of an environment as possible for Users. We will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds.
Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments (e.g., your email address, address, credit card details, and bank account number) and handle all the steps in the payment process through their systems, including data collection and data processing. The Payment Processors’ use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.
Managing information
You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Mobile Application and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so on the settings page of your account in the Mobile Application.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our trusted subsidiaries and joint venture partners, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Mobile Application and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. We will not share any information with unaffiliated third parties.
Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are given the information they need only in order to perform their designated functions, and we do not authorize them to use or disclose any of the provided information for their own marketing or other purposes. We will share and disclose your information only with the following categories of Service Providers:
Communication and collaboration services
Data analytics services
Data storage services
Payment processors
Product engineering and design services
User authentication services
We may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and your Personal Information will likely be among the assets transferred.
Retention of information
We will retain and use your Personal Information for the period necessary to comply with our legal obligations, as long as your user account remains active, to enforce our Policy, resolve disputes, and unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
Transfer of information
Depending on your location, data transfers may involve transferring and storing your information in a country other than your own, including Thailand and India. The transfer of your Personal Information to countries outside the European Union will be made only if you have explicitly consented to it or in the cases provided for by the Data Protection Legislation and will be processed in your interest.
You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this Policy or inquire with us using the information provided in the contact section.
Data protection rights under the Data Protection Legislation
You have certain data protection rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
You have the right to withdraw consent where you have previously given your consent to the processing of your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You have the right to learn if your Personal Information is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.
You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete.
You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection. You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn whether we are processing Personal Information for direct marketing purposes, you may refer to the relevant sections of this Policy.
You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include: the accuracy of your Personal Information is contested by you and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or defense of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest.
You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure such as where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, to exercise or defense of legal claims.
You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.
You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.
How to exercise your rights
Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.
You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
Data analytics
Our Mobile Application and Services may use third-party analytics tools that use cookies, web beacons, or other similar information-gathering technologies to collect standard internet activity and usage information. The information gathered is used to compile statistical reports on User activity such as how often Users visit our Mobile Application and Services, what pages they visit and for how long, etc. We use the information obtained from these analytics tools to monitor the performance and improve our Mobile Application and Services. We do not use third-party analytics tools to track or to collect any personally identifiable information of our Users and we will not associate any information gathered from the statistical reports with any individual User.
Advertisements
We may permit certain third-party companies to help us tailor advertising that we think may be of interest to Users and to collect and use other data about User activities in the Mobile Application. These companies may deliver ads that might place cookies and otherwise track User behavior.
Social media features
Our Mobile Application and Services may include social media features, such as the Facebook and Twitter buttons, Share This buttons, etc (collectively, “Social Media Features”). These Social Media Features may collect your IP address, what page you are visiting on our Mobile Application and Services, and may set a cookie to enable Social Media Features to function properly. Social Media Features are hosted either by their respective providers or directly on our Mobile Application and Services. Your interactions with these Social Media Features are governed by the privacy policy of their respective providers.
Email marketing
We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.
In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on how to contact the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.
Push notifications
We offer push notifications to which you may also voluntarily subscribe at any time. To make sure push notifications reach the correct devices, we rely on a device token unique to your device which is issued by the operating system of your device. While it is possible to access a list of device tokens, they will not reveal your identity, your unique device ID, or your contact information to us. We will maintain the information sent via e-mail in accordance with applicable laws and regulations. If, at any time, you wish to stop receiving push notifications, simply adjust your device settings accordingly.
Links to other resources
The Mobile Application and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Mobile Application and Services and to read the privacy statements of each and every resource that may collect Personal Information.
Information security
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no data transmission over the Internet or wireless network can be guaranteed.
Therefore, while we strive to protect your Personal Information, you acknowledge that
There are security and privacy limitations of the Internet which are beyond our control.
The security, integrity, and privacy of any and all information and data exchanged between you and the Mobile Application and Services cannot be guaranteed.
Any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.
As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.
Data breach
In the event we become aware that the security of the Mobile Application and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the User as a result of the breach or if notice is otherwise required by law. When we do, we will post a notice in the Mobile Application, send you an email.
Changes and amendments
We reserve the right to modify this Policy or its terms related to the Mobile Application and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page, post a notification in the Mobile Application, send you an email to notify you. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided.
An updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Mobile Application and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.
Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Mobile Application and Services and submitting your information you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Mobile Application and Services.
Your Rights Under the California Consumer Privacy Act (CCPA)
If you are a resident of California, you have the following rights under the CCPA:
You have the right to know what personal data is being collected about you.
You have the right to know whether your personal data is sold or disclosed and to whom.
You have the right to say no to the sale of your personal data.
You have the right to access your personal data.
You have the right to request the deletion of your personal data.
You have the right to equal service and price, even if you exercise your privacy rights.
To exercise your rights under the CCPA, please contact us using the information provided in the "Contacting Us" section.
Your Rights Under the Lei Geral de Proteção de Dados (LGPD)
If you are a resident of Brazil, you have the following rights under the LGPD:
You have the right to confirm the existence of processing.
You have the right to access your data.
You have the right to correct incomplete, inaccurate, or out-of-date data.
You have the right to anonymize, block, or delete unnecessary or excessive data or data processed in noncompliance with the provisions of the LGPD.
You have the right to data portability.
You have the right to delete personal data processed with your consent.
You have the right to information about public and private entities with which the controller has shared data.
You have the right to information about the possibility of denying consent and the consequences of such denial.
You have the right to revoke consent.
To exercise your rights under the LGPD, please contact us using the information provided in the "Contacting Us" section.
Your Rights Under the Virginia Consumer Data Protection Act (VCDPA)
If you are a resident of Virginia, you have the following rights under the VCDPA:
You have the right to confirm whether or not your personal data is being processed.
You have the right to access your personal data.
You have the right to correct inaccuracies in your personal data.
You have the right to delete personal data provided by or obtained about you.
You have the right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format.
You have the right to opt-out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise your rights under the VCDPA, please contact us using the information provided in the "Contacting Us" section.
Your Rights Regarding Data Sales and Sharing
We do not sell any of your personal data to third parties. If in the future we decide to sell personal data, we will update this Policy and provide you with a means to opt-out of the sale of your personal data.
You have the right to know whether your personal data is shared with any third parties. We will clearly disclose any sharing of personal data in this Policy. If you wish to opt-out of the sharing of your personal data, please contact us using the information provided in the "Contacting Us" section.
Data Protection Officer (DPO) Contact Information
Our Data Protection Officer (DPO) is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact our DPO using the details set out below:
Name: Sandeep Khurana
Email: sunny@spark.love
Address: 23 NEW INDUSTRIAL ROAD, #04-09, SOLSTICE BUSINESS CENTER, Singapore 536209
Contacting us
If you have any questions regarding the information we may hold about you or if you wish to exercise your rights, you may use the following data subject request form to submit your request:
If you have any other questions, concerns, or complaints regarding this Policy, we encourage you to contact us using the details below:
We will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by applicable data protection laws.
© 2024 – Club Spark Pte Ltd
© 2024 – Club Spark Pte Ltd
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© 2024 – Club Spark Pte Ltd