PRIVACY POLICY

Last Updated: November 24, 2020

This Privacy Policy describes how Spark + Sterling, LLC (“we” or “us”) uses information that we collect online (including at www.sparkandsterling.com) and offline.

 

What Personal Information Do We Collect?

“Personal Information” is any information that identifies you or someone else as an individual. This includes, but is not limited to:

  • Name
  • Physical and email addresses
  • Phone number
  • Company name and job title
  • Payment information

 

How Do We Collect Personal Information?

We collect Personal Information in a few ways (referred to collectively as the “Services”):

  • on our website;
  • with emails we send that link to this Privacy Policy;
  • through services we provide to clients;
  • through communications with potential clients; and
  • through offline business interactions.

We also receive Personal Information from third party sources such as referrals and publicly available data.

If you share anyone else’s Personal Information with us — for example, an employee’s contact information — you represent and warrant to us that you have the right to do so. You also agree that we can use that Personal Information in accordance with this Privacy Policy.

The Services are not intended for individuals under the age of 18, and we do not knowingly collect Personal Information from individuals under 18.

 

Why Do We Need To Collect Personal Information?

We need to collect Personal Information in order to deliver the requested Services to you. If you do not provide the relevant information, we may not be able to perform the Services.

 

How Do We Use Personal Information?

We and our service providers use Personal Information for legitimate business purposes, including:

  • Providing the Services, improving the Services, and sharing information about the Services.
  • Responding to questions from clients and prospective clients.
  • Sending general updates, marketing materials, and notices of events we think may be of interest to you.
  • Analyzing traffic on our website, responses to our marketing, and data about use of the Services.
  • Maintaining and improving security of the Services.
  • Complying with applicable law.

We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We may use and disclose this data for any purpose.

 

When Do We Disclose Personal Information to Others?

We disclose Personal Information as follows:

  • To our third party service providers, such as our website host and payment processors, so they can provide their services to us.
  • As required by public and government authorities, including law enforcement.
  • To enforce our terms and conditions, and to protect our legal rights.
  • In the event of a sale of our business (please note that the acquiror may have different privacy-related practices).

 

What Other Information Do We Collect?

We collect certain information that does not identify you or anyone else as a specific individual (“Other Information”). Other Information includes:

  • Browsers and devices used to view our online content
  • IP addresses of devices used to visit our website
  • Data collected from cookies, pixel tags, and similar technologies
  • General demographic information that does not reveal an individual’s specific identity
  • Aggregated data that does not reveal an individual’s specific identity

We may use and disclose Other Information for any purpose, except where prohibited by applicable law.

 

Where is Personal Information Stored?

Regardless of where you are located, all information collected using the Services — including Personal Information — is processed and stored in the United States.

 

How Do We Secure Personal Information?

While no transmission or storage is guaranteed to be secure, we use reasonable efforts to protect Personal Information. These efforts include commercially available physical, technical, and process safeguards.

If you have reason to believe your Personal Information is not secure, please contact us immediately at info@sparkandsterling.com.

 

How To Opt Out, Delete, or Update Personal Information

If you receive marketing emails from us and want to opt out, you may do so by using the link in the message or by contacting us at info@sparkandsterling.com. You cannot opt out of administrative messages related to Services you are receiving or have received from us.

If you would like to correct, update, or delete Personal Information you have sent us, please use our Contact Us form or email us at info@sparkandsterling.com.

 

How Long Do We Store Personal Information?

We store Personal Information for as long as needed to perform Services, or as long as permitted by applicable law. Certain laws require us to keep records of your Personal Information for a certain period of time before we can delete it.

 

Third Party Services

This Privacy Policy does not apply to any third party services associated with our Services. We are not responsible for how third parties may collect, store, or use your Personal Information or Other Information.

To the extent that third party content or services are associated with our Services, we recommend that you review their privacy terms and practices separately.  Links from our site do not mean that we endorse the linked content or service.

 

California Consumer Privacy Act (“CCPA”)

For purposes of the CCPA, we do not “sell” any Personal Information.

If you are a California resident, you may have the right to request that we disclose what Personal Information we have collected about you in the 12 months before your request. You may also have the right to ask us to delete Personal Information that we collected from you.

To make such a request, please contact us at info@sparkandsterling.com. We will verify and respond to your request as soon as reasonably feasible, and in accordance with applicable law. Please note that we may need to request additional information from you, such as your name, mailing address, email address, and relationship with us.