Spark Schools Inc and its affiliates (collectively, "SPARK", "we", "us”) is a global organization offering software tools used by schools, teachers, guardians, students for ed-tech purposes.
- Information We May Collect
- Use of Information
- Sharing of Information
- Cookies and Similar Technologies
- Data Retention
- Choices and Opt-Out
- Cross-Device Tracking
- Employment Opportunities
- Third Party Sites
- International Data Transfers
- California Privacy Rights
- Questions, Complaints and Disputes
USE OF INFORMATION
Spark Services may use the information, including personal information, collected in connection with the Spark Services for the purpose of providing the Services to our customers, as well as for supporting our business functions, such as fraud prevention, marketing, analytics and legal functions and other legitimate purposes.
To the extent permitted by applicable law and, for customer data, as permitted by our customer agreements, we may use information collected in connection with our Services:
- To operate the Spark Services and provide support.
- To fulfill customer requests, such as to create a Spark Services account or complete customer purchases.
- To communicate with our customers; to inform customers and users of products, programs, services and promotions.
- To send customers information regarding the Spark Services and issues specifically affecting Spark Services.
- To respond to reviews, comments, or other feedback provided to us.
- To support and personalize our Services, websites, mobile services, and advertising.
- To protect the security and integrity of our Services, content, and our business.
- To provide support.
For benchmarking, data analysis, audits, developing new products, enhancing the Spark ServicesServices, facilitating product, software and applications development, improving our services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes.
To meet our contractual requirements, to comply with applicable legal or regulatory requirements and our policies, and to protect against criminal activity, claims and other liabilities.
For any other lawful purpose for which the information is provided.
Aggregate Information. To the extent permitted by applicable law, we may use, process, transfer, and store any data about individuals and customers or partners in an anonymous (or pseudonymous) and aggregated manner. We may combine personal information with other information, collected online and offline, including information from third party sources. We may also use information in other ways with consent or as permitted by applicable law. By using the Spark Services, our customers agree that we are hereby licensed to collect, use, share and store anonymized (or pseudonymized) aggregated data collected through the Spark Servicesfor benchmarking, analytics, A/B testing, metrics, research, reporting, machine learning and other business purposes.
Automated Decisions. To the extent permitted by applicable law, we may collect data in an automated manner and make automated decisions, including using machine learning algorithms, about individual users of the Spark Services in order to provide or optimize the Spark Services offered and/or delivered, for security or analytics purposes, and for any other lawful purpose. To the extent permitted by applicable law, we may use automated decisions.
“Personal Data” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person; and
“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Our legal bases for the processing of Personal Data are: (i) consent or (ii) any other applicable legal bases, such as our legitimate interest in engaging in commerce, offering products and services of value to the customers of the Spark Services, preventing fraud, ensuring information and network security, direct marketing and advertising, and complying with industry practices.
Additional Rights for European Residents. As a resident of the EU or a country following substantially similar legislation regarding the protection of Personal Data, individuals may have one or more of the following additional rights:
- Access. To request a copy of the Personal Data we have collected about you by contacting us.
- Rectification & Erasure.To request that we rectify or delete any of the Personal Data about you that is incomplete, incorrect, unnecessary or outdated.
- Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes.
- Restriction of Processing. To request restriction of Processing of Personal Data about you for certain reasons, such as, for example, if you consider Personal Data about you collected by us to be inaccurate or you have objected to the Processing and the existence of legitimate grounds for Processing is still under consideration.
- Data Portability. To request and receive the Personal Data we have collected about you in a commonly used and machine-readable form.
- Right to Withdraw Consent. If Personal Data about you is processed solely based on your consent and not for any other legitimate interest, to withdraw your consent at any time, without affecting the lawfulness of our Processing based on such consent before it was withdrawn, including processing related to existing contracts for our products and services.
- Right to Lodge a Complaint with a DPA. If you believe our Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority (“DPA”).
To exercise any of the above listed rights, please contact us as at firstname.lastname@example.org and provide sufficient details so that we can respond appropriately. We will process any requests in accordance with applicable law and within a reasonable period of time. We may need to verify the identity of the individual submitting a request before we can address such request. If the request relates to data our customers collect and process through the Spark Services, we will refer the request to that customer and will support them in responding to the request. For Spark Servicescustomers, certain information may be reviewed, corrected and updated by logging into the Spark ServicesServices account and editing the profile information.
Compelled Disclosures. Spark Services may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Data Protection Contact. Unless otherwise specified, the data controller of personal data uploaded to the Spark Services is the Spark Services customer for whom such Services are provided and Spark Services is the processor of such data for such customer. In certain cases, SPARK may also be the controller of aggregated, anonymous or pseudonymous data relating to the Spark Services. Our Data Protection Contact for the personal information collected in connection with the Spark Services is:
Attn: General Counsel, Legal Dept.
118 W 3rd Ave
Plevna, KS 67568
Phone: +1 (312) 888-0435