Data Policy

In this policy we inform you of the data we collect to provide you with Sparker's services.

What information do we collect?

What you and other users provide us with:

• We collect both the content you create or share, and other data you provide to us when you create your account, when you interact with other users with your comments or sponsored content, the hashtags you use, the searches you do, the subscription to our newsletter... We also collect data included in the content you provide (metadata) and other information from the images you share such as the date the file was created and where the photo was taken.
  Special category data: You may choose to provide important personal information or aspects about religious or political orientations, indicate your interests, sexuality or gender identity, or aspects related to your health. This and other information (such as racial or ethnic origin, philosophical beliefs or trade union membership) is subject to special protection under EU law.
• Use. We collect information on how you use Sparker. What type of content you view and how you interact with it, how you use Sparker on your device, the time and frequency of use, the accounts you interact with, the times of day you connect, and the date and day you last connected. We also collect the geolocation of your Sparks.
• Data that other users share about you. Other users may share posts, photos and Sparks of yours that we also collect and analyze.

Devices:

We collect information about the devices you access Sparker with, type of device, operating system, use you make of Sparker.

Among this type of information we collect:

• Device characteristics: information such as operating system, hardware and software version, battery charge level, signal strength, available storage space, browser type, application or file types and names, and plug-ins.
• Device operations: information about the operations and behaviors performed on the device, how you interact with it in Sparker.
• Device signals: Bluetooth signals and information on nearby beacons, cell phone towers and Wi-Fi network access points.
• Device configuration data: information you allow us to receive when you activate the corresponding configuration in the device, such as access to the GPS location, camera and photos.
• Network and connections: information such as the name of your mobile phone operator or internet provider, language, time zone, mobile phone number, IP address, connection speed and, in some cases, information about other devices that are nearby or on your network.
• Cookie data: data from cookies stored on your device, including cookie settings and identifiers. More information on how we use cookies can be found in Cookies Policy of Sparker.

II. How do we use this information?

The information we collect, as described below, is used to provide you with Sparker's services and to ensure their proper functioning. We use this data to:

Provide, customize and enhance Sparker:

We use the information we have to provide you with Sparker services, as well as to customize features and content (including advertisements, events, recommendations and suggestions). In order to create the most satisfying and personalized experience possible, we use your connections, preferences, interests, and activities based on the information we collect and that you and others provide to us (including any special category data you choose to provide and for which you provide explicit consent), as well as the way you use and interact with Sparker and the people, places, or things you connect with and in which you show interest, both inside and outside of Sparker.

• Location-Related Information: We use location-related information, such as your current location, where you live and the places you like to visit, as well as businesses and people near you, to provide, customize and improve Sparker, including advertisements, so that they are more relevant to you and others. This type of information may be based on data such as the precise location of the device (if you have allowed us to collect this information), IP addresses, and Sparker usage information.
• Product Research and Development: We use the information we have to develop, test and improve Sparker (including through surveys and research), as well as to test and troubleshoot new features and products.
• Ads and other sponsored content: From the information we have about you, including information about your interests, actions and connections, we select and customize ads, offers and other sponsored content that we display to you.

To provide measurement, analysis and other services for companies:

We use the information we have to help advertisers and other partners measure the effectiveness and distribution of their ads and services and to help them understand what types of people use their services and how they interact with their websites, applications and services.

Promote safety, integrity and security:

We use the information we have to verify accounts and activities, combat harmful behavior, detect and prevent spam and other negative experiences, maintain Sparker's integrity, and promote security both inside and outside of Sparker. For example, we use this data to investigate suspicious activity or violations of our terms and policies, or to determine whether a person needs assistance.

Contacting you:

We use the information at our disposal to send you marketing messages, to inform you about Sparker's features and to inform you about our policies and conditions. We also use it to respond to you when you contact us.

Keep you informed:

If you wish to be kept up to date with Sparker news, you can subscribe to the newsletter or bulletin in order to receive periodic digital publications that include information on updates, valuation surveys, campaigns and promotions.

Your data will be kept as long as there is a mutual interest in maintaining the subscription to the newsletter, or as long as you do not exercise your right to suppress, cancel, limit or oppose the processing of your data.

III. How is this information shared?

Your information is shared with others in the following ways:

In Sparker:

• People and accounts you communicate and share information with: When you communicate and share information using Sparker, other users can see what you post, they can also access your profile updates and your Sparks posted.
• Content that others share and re-share about you: Pay attention to the personal information you share on your profile, as well as any other personal data your Sparks or images you post may contain. As soon as this data is published, any user can share that content. Also, when you comment on someone's post or react to their content, anyone who can see that content will also see your comment or reaction.
  Any user can post a Spark by tagging you. If you don't like the content other users can report it on data.protection@sparker.io
• New owner: If we change ownership or control of all or part of Sparker or its assets, we may transfer your information to the new owner.

With external partners:

• Advertisers: We provide advertisers with reports to tell them what types of people see their ads and what results they generate. However, unless you give us permission to do so, we do not share information that personally identifies you, such as your name or email address, information that can be used to contact you, or that could reveal your identity. We provide advertisers with general demographic and interest information. This data is intended to help them better understand their audience.
• Service Providers: We provide information and content to service providers that help us continue our business. These providers are engaged in providing technical infrastructure services, analyzing Sparker usage, providing customer support services, facilitating payments, or conducting surveys.
• Compliance with legal requirements or requests from law enforcement authorities: We share information with law enforcement authorities or in response to legal requirements in the circumstances listed below.

IV. What are the legal grounds for processing the data?

We collect, use and share the data at our disposal as described below:

• As necessary to comply with our Terms of Service.
• In accordance with your consent to register with Sparker and use it.
• As required to comply with our legal obligations.
• To protect your and other people's vital interests.
• As required in the public interest.
• As necessary to fulfil our own (or others') legitimate interests, including our interest in providing an innovative, personalised, secure and cost-effective service to our users and partners, unless your interests or fundamental rights and freedoms requiring protection of personal data take precedence over them.

V. How can you exercise your rights under the GDPR?

The persons concerned have the right to obtain access to their personal data, as well as the right to request the rectification of inaccurate data or, where appropriate, to request their suppression when, among other reasons, the data are no longer necessary for the purposes for which they were collected, or the right itself to unsubscribe from the newsletter.

Under certain circumstances, data subjects may request that the processing of their data be limited, in which case we will only keep them for the exercise or defence of claims.

Data subjects may also object to the processing of their data, in which case we will stop processing the data, except for compelling legitimate reasons, or the exercise or defence of any claims.

When technically possible, the data subject could request the portability of his or her data to another data controller.

To exercise these rights, in accordance with current legislation, interested individuals may contact Sparker by e-mail, attaching a copy of a document proving their identity (ID card or passport), at: data.protection@sparker.io

The interested person can file a complaint with the Spanish Data Protection Agency, especially when they are not satisfied with the exercise of their rights. For further details, please consult the website https://www.agpd.es

VI. Data retention and account deactivation and deletion

We store the data until it is no longer needed to provide you with our services, or until your account is deleted, whichever comes first. The need for the data is determined on a case-by-case basis and is based on factors such as the nature of the data, the purpose for which it is collected and processed, and any applicable operational or legal retention requirements. If you send a copy of your identity document for verification of an account, we will delete it 30 days after receiving it.

When you delete your account, we remove content you've posted, such as your photos and status updates, so you can't retrieve that information. However, information about you that has been shared by others will not be deleted, as it is not part of your account. You can delete your account at any time.

VII. How do we respond to legal requirements or prevent damage from occurring?

We access, preserve and share your information with regulators, law enforcement authorities or other parties in the following instances:

• In response to a legal requirement if we believe in good faith that the law requires us to do so. We may also act in response to legal requirements if we believe in good faith that the legislation of a particular jurisdiction requires such a response, affects users in that jurisdiction and is coherent with internationally recognized standards.
• If we believe in good faith that it is necessary to detect, prevent and address fraud, unauthorized use of Sparker, violations of applicable terms or policies, or other harmful or illegal activities; to protect us (including our rights, or our property), as well as protect you or others; also as part of regulatory investigations or inquiries; and to prevent death or imminent physical harm. For example, in appropriate cases, we provide information to and receive information from outside partners about the reliability of your account to prevent fraud, abuse, and other harmful activities occurring at or outside of Sparker.

We may access information we receive about you and preserve it for an extended period of time if it is subject to a court order or obligation, a government investigation, or inquiries regarding possible violations of our policies or conditions, or to prevent harm. We may also retain information about accounts that have been deactivated for non-compliance with our terms for a minimum of 18 months in order to prevent the recurrence of abusive behaviour or violations of our terms. Any content published on Sparker, whether or not it has been deleted by the user, will be stored on our servers for a period of 18 months in case it is required by the courts in the prosecution of criminal conduct.

VIII. How will we notify you of changes to this policy?

We will send you a notice at least 30 days before we make any changes to this policy so that you can review the changes and decide whether to continue using Sparker as long as the changes are relevant.

IX. How to forward your questions to Sparker

Any questions about any legal document or Sparker's conduct can be addressed to Adrian Casimiro with ID 71511317Q.

The entity responsible for processing your data is Sparker, which you can contact via the Internet at data.protection@sparker.io or by mail at the address:C/ Peñadrada del Sil SN - 24469 León, Spain