Last Updated: March 9, 2020
Our Policy is intended to explain our privacy practices concerning information about you, including:
European Union Residents
If you reside in a country in the European Economic Area or in Switzerland, then information we collect from you may be subject to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the "GDPR") and the following additional information is provided for your benefit.
The controller of the personal data collected through the Site is:
Red Spark, LP
160 Pine Street, Suite 320
Harrisburg, PA 17101
If you use the Site, you acknowledge that your personal data is being processed on the basis of your consent and that information gathered through the Site may be transferred to, and used and stored in, the United States.
You hereby consent to the processing of your personal data as described in this Policy, including the transfer of your personal data to, and its use and storage in, the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You may withdraw your consent at any time by following the instructions in the Accessing/Updating/Deleting Your Personal Information section below, but this will not affect the lawfulness of processing based on consent before its withdrawal. However, if you withdraw your consent or decline to provide personal data to us, you may be unable to use the Site. You have the right to file a complaint relating to the processing of personal data with a supervisory authority.
Further, you consent to the use of your name in advertising or marketing materials, as further described in the "How We Use Your Information: Site Users" section below.
Information We Collect
The following is a summary of the types of personal and non-personal information we may collect from or about Site users.
Site Users and Voluntarily Provided Information. We collect personal information on the Site when you utilize the Site (referred to herein as a "Site User") or otherwise choose to provide personal information to us, such as through our contact form. Personal information is any information that can be used to identify or locate a particular person or entity. This may include, but is not limited to: personal name (first and last) and business entity name and/or title with the applicable business entity, as well as your personal and/or business e-mail address, mailing address, business, personal and/or mobile telephone numbers, fax number, and/or any other information requested on the applicable Red Spark webpage. Additionally, we may collect email, phone call, and messenger/chat content if you choose to communicate to us. We also may collect certain technical and usage information from Site Users, such as information typically contained in a web server's log files or analytics program, including without limitation: IP address, browser type and version, operating system, geographic location, referral information, click-stream data, device identifier, unique identifier, HTTP header, including referral URL, etc. Unless otherwise required by applicable law, such as the GDPR, we treat this information as non-personal information. For additional detail about these practices, please see the section below entitled "Site User Behaviors Collected With Cookies, Web Beacons and Other Web Technologies." Furthermore, we may collect server and individual activity information so that we can provide our products and services to Site Users. Red Spark may also collect information from Site Users when you voluntarily provide it to Red Spark through other means (for example, by signing up for an email newsletter, filling out a registration offer, or by other means of online or offline surveys, order forms, or registration pages operated by Red Spark or third parties (collectively, a "User Form"). In a User Form, Red Spark or a third party may offer you incentives in exchange for registration or providing information about yourself, such as name, email address, street address, zip code, telephone numbers, birth date, gender, occupation, and employment information (together, "User Information"). Completing the User Forms is voluntary and you are under no obligation to provide User Information.
You may set your browser to warn you that cookies are in use, or to block the use of certain cookies. Most browsers are set to accept cookies. If your browser is not set to accept cookies, certain uses of the Site may require you to go to your browser user preferences to enable cookies. Each browser is different, so check the ''Help'' menu of your browser to learn how to change your cookie preferences. If you change computers, operating systems or browsers, or use multiple computers or browsers, you will need to repeat this process for each computer and each browser. To find out more about cookies, please visit www.cookiecentral.com.
(b) Web beacons. A web beacon is programming code used to display an image on a web page and can also transfer an individual's user identification to a database and associate the individual with previously acquired information about the individual. Web beacons enable us to track certain websites you visit or content you view online. Web beacons help determine products or services in which you may be interested and help track online behaviors for marketing purposes. More information about web beacons is available at http://www.webopedia.com/TERM/W/Web_beacon.html.
(c) Where Technology Information is Collected. Technology Information may be collected directly from the Site or through Red Spark-delivered marketing materials.
(d) Outside Information. Red Spark may lawfully receive information about you from third parties, such as information located in public databases.
(e) No Information Collected from Children Under 13. Please be advised that we do not knowingly solicit or collect personal information from children under age 13, nor do we knowingly market our products or services to children under age 13. If we become aware that a child under age 13 has provided us with personal information, we will delete it from our database. If you are a parent or legal guardian and believe that your child has provided us with personal information without your consent, please contact us at firstname.lastname@example.org.
How We Use Your Information: Site Users
We use your personal information primarily for administrative purposes pertaining to your use of the Site and customer management purposes, including without limitation: (a) providing reports, customer service, newsletters, RSS feeds and other information, products and/or services that you have signed up for or have otherwise agreed to receive; (b) operating the Site; (c) sending you information regarding the Site; (d) displaying content that is customized to your preferences; (e) contacting you when necessary regarding your inquiries and/or operational updates to our Site; and (f) for validation, suppression, content improvement and feedback purposes. Unless you indicate a preference not to receive such information when you utilize or contact us through the Site or subsequently, we may also send you surveys and marketing communications to inform you of new products or services or other information or offers that may be of interest, and/or updates about Red Spark. These surveys, marketing communications, or updates may come from Red Spark or our service providers. If you do not wish to continue to receive surveys, marketing communications or updates, you may indicate this preference by following the "unsubscribe" or "opt-out" instructions included within each email communication, or by other written request to Red Spark. Please keep in mind that, even if you choose not to receive these communications, you may continue to receive transactional or account communications (e.g., confirmation emails) and other communications that are required or permitted by applicable law.
You also agree that we may also use your name, company name and logo in advertising or promotional materials to refer truthfully to you as a Site User.
We use non-personal information primarily for internal research and analytics to improve our Site and our services.
Disclosure of Your Personal Information
We do not sell, rent, lease or disclose your personal information collected by the Site to unaffiliated entities, except in the limited circumstances listed below. Red Spark may transfer or disclose information to our affiliated entities, that is, entities that control, are controlled by, or are under common control with Red Spark, for marketing and other purposes at our discretion.
We may disclose your personal information to third-party service providers who perform services on our behalf. For example, we may engage other companies as data subprocessors that handle and process your personal information for the following purposes: to handle the processing of payments, to detect and protect against fraud, to provide data storage and management, to assist in marketing Red Spark's products or services, to conduct audits, to provide web analytics and business intelligence, to provide customer support, to send email and platform alerts, to provide customer surveys and messaging services, and to provide hosting, design, development and other operations which make our Site work. Other third-party service providers may help us communicate with you through electronic mail, direct mail or telephone communication. Our policy is to permit these third-party service providers to obtain only the personal information they need to provide the services, and to require them to protect personal information to the same extent as Red Spark, including not using it for any improper purpose.
We may also make your personal information available to non-affiliated third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary under the following circumstances:
Disclosure of Non-Personal Information
In addition to the foregoing, Red Spark may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons. For example, we may provide our Site Users with aggregate, anonymous non-personal information about individuals, including, without limitation, demographic data. This aggregate data allows us to create anonymous groups that our partners use to identify business opportunities.
Accessing/Updating/Deleting Your Personal Information
If you would like to delete or update the personal information that we have collected from you, simply send your request via e-mail to email@example.com. Additionally, if your personal information is subject to the GDPR, you may have certain additional rights, including the right of restriction of processing of personal data, the right to object to processing of personal data, and the right to data portability. Please send e-mail to firstname.lastname@example.org for more information.
We will process your request, where possible and subject to the terms and conditions contained herein, within a reasonable period of time after receipt. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
To unsubscribe from Red Spark or Site User email lists, click the link included in the footer of any message delivered by Red Spark or a Site User and follow the instructions provided, or contact us in writing.
Notwithstanding the foregoing, even if you unsubscribe from marketing emails, we may continue to contact you for the purpose of communicating information relating to your use of the Site and Red Spark's products or services, as well as to respond to any inquiry or request made by you.
If you do not request that we delete your personal information, we will retain it pursuant to our internal data retention and deletion practices as dictated by valid business and legal reasons for retaining such information. For example and without limitation, personal information provided to us by Site Users will be retained as long as such Site Users continues to communicate with us, and personal information relating to advertisers or publishers of our network will be retained as long as such individuals maintain an account with our advertising platforms, or as required under the applicable commercial agreements between Red Spark and those individuals.
How We Protect Your Personal Information
We know it takes confidence and trust to share personal information online. We endeavor to keep your confidence and maintain your trust by protecting your personal information. To that end, we maintain reasonable standards of security and confidentiality. Red Spark's computers have security measures, such as firewalls, to protect against the loss, misuse and/or alteration of the information under Red Spark's control. Red Spark also maintains physical and procedural safeguards to protect information under our control and to restrict access to those employees and agents who have a need to know in order to provide services to you and/or operate our business.
Notwithstanding such measures, Red Spark cannot guarantee that its security measures will prevent its systems and computers from being illegally accessed and the individual information on them stolen or altered. Despite our efforts, as with most Internet sites and businesses, it is possible that third parties may unlawfully intercept or access transmissions of private communications and/or unlawfully gain access to protected computers. No method of data collection, transmission or storage is 100% secure, and we cannot warrant such absolute security. Whenever you provide personal information online, you accept this risk, including when you share your personal information with us and our affiliated entities.
Notwithstanding these inherent risks, we make a concerted good faith effort to ensure that your personal information is protected by maintaining the reasonable standards of security and confidentiality mentioned above.
Privacy Practices of Third Parties
Third Party Web Technologies.Site Users as well as other partners and advertisers who provide Site analytics, may use their own cookies, web beacons and other Web Technologies to collect information about you. Red Spark has no control over third parties' use of such Web Technologies.
Links to Third Party Websites. The Site and e-mail messages transmitted by Red Spark on its own behalf or on behalf of its Site Users may contain links to third-party websites ("Third Party Websites"). Please be aware that Red Spark is not responsible for the privacy and security practices of Third Party Websites. We encourage you to be aware when you leave the Site and to read the privacy policies of each and every website that you visit. This Policy applies SOLELY to information collected by Red Spark and/or the Site.
Privacy Notice for California Residents
This Privacy Notice for California Residents supplements the information contained in the rest of this Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and any terms defined in the CCPA have the same meaning when used herein.
Categories of Personal Information:
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked directly with a particular consumer or device ("personal information"). Specifically, Red Spark's website has collected the following categories of personal information from its users within the last twelve (12) months:
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||Y|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.||Y|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||N|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Y|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||N|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||Y|
|G. Geolocation data.||Physical location or movements.||Y|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||N|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||N|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||N|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Y|
For the purposes of the CCPA, personal information does not include the following categories:
Sources of Personal Information:
Submitted by You: We may collect personal information from you through your direct submission of such personal information to us through a form on a website, or through email or other direct communication from you to us.
Indirectly: We may also collect personal information about you through, including certain online activities through Web Technologies as described elsewhere in the Policy.
Third Parties: We may also collect personal information about you from third-party business partners.
Purpose for Collecting Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
Red Spark will not collect additional categories of personal information, or use such personal information in any way besides the uses described above without providing notice.
Sharing Your Information
Please see the "Disclosure of Your Personal Information" section above.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
Sale of Information
In the preceding twelve (12) months (as of the most recent update to this Policy), we have not sold personal information. However, we respect and understand that you may still want to ensure that your personal information is not sold. Therefore, if you would like to proceed with a "Do Not Sell My Personal Information" request, and opt-out of any future collection of your personal information, please complete the form here Do Not Sell My Personal Information.
Your Rights and Choices under the CCPA
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that Red Spark disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
Deletion Request Rights
You have the right to request that Red Spark delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Red Spark, LP
c/o Legal Department
3675 Market Street, Suite 900
Philadelphia, PA 19104
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we reserve the right to offer you certain financial incentives, only as permitted by the CCPA, that can result in different prices, rates, or quality levels. Any such financial incentive will reasonably relate to the value of your personal information and contain written terms that outline the material aspects of the program. Any participation in such a program requires your prior opt in consent, which may be revoked by you at any time.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com
If you have any questions regarding this Policy, or would like more information on our privacy practices, please contact us at firstname.lastname@example.org.