Privacy Policy
Last Updated: May 26, 2021
SPARK Neuro, Inc. (“Company”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our websites with links to this Privacy Policy (the “Website(s)”). “Personal Data” means data that, by itself, allows someone to identify or contact you as an individual, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
1. Questions; Contacting Company. If you have any questions or comments about our Privacy Policy, please contact us at the following:
SPARK Neuro, Inc.
info@sparkneuro.com
2. User Consent. By visiting our Website, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.
3. A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If we discover that a child under 13 has submitted Personal Data to Company, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at info@sparkneuro.com.
4. A Note to Users Outside of the United States. Your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding the processing of Personal Data may be less protective than the laws in your country. By providing your data, you consent to such processing and transfer.
5. Collection and Use of Data.
(a.) Information Collected by Our Servers. To make our Website more useful to you, our servers (which may be hosted by a third-party service provider) may collect information from your computer or device, including but not limited to:
• The date and time of your visit and the web pages and content you view and links you click on while navigating within our Website;
• Information about the type of content accessed via our Website;
• The site you visited before and after visiting our Website;
•Your Internet Protocol (IP) address (a numerical address assigned to your computer by your Internet service provider so that other computers connected to the Internet can communicate with your browser online) that can sometimes be used to derive your general geographic area;
•Search terms you enter using our Website or on a referral site;
• Information about your device such as your device type, browser type, language and other settings, memory capacity, plug-ins, Internet domain, advertising identifiers, TCP configuration parameters, operating system, time zone and the names, versions and package IDs of software installed on your device; and
• Information collected through cookies and other tracking technologies (see additional descriptions of these terms below).
(b.) Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website.
(c.) Flash LSOs. If we post videos, third parties may use local shared objects, known as “Flash Cookies,” to store your preferences for volume control or to personalize certain video features. Flash Cookies are different from browser Cookies because of the amount and type of data and how the data is stored. Cookie management tools provided by your browser will not remove Flash Cookies.
(d.) Pixel Tags. In addition, we may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, that are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages.
(e.) Do Not Track. We do not currently respond to “do not track” signals from web browsers.
(f.) Analytics Services. We may use analytics services such as Google Analytics (“Analytics Services”) to help analyze how users use our Website. The information generated by the Cookies or other technologies about your use of our Website (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer the Analytics Information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. The Analytics Service’s ability to use and share Analytics Information is restricted by the Analytics Service’s terms of use and privacy policy. By using our Website, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.
6. Disclosure of Your Personal Data. We may disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
(a.) Third-Party Service Providers. We may also share your Personal Data with third-party service providers that conduct quality assurance testing, facilitate creation of accounts, provide technical support, and/or provide other services to Company.
(b.) Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under common control with Company (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
(c.) Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving the sale, transfer, or divestiture of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
(d.) Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is appropriate (a) in connection with any legal investigation or proceeding; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (c) to protect or defend the rights or property of Company, its affiliates or its users; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, our applicable Terms of Use Agreement, or any other contractual arrangement.
7. Third-Party Websites. Our Website may contain links to third-party websites. When you click on a link to any other website, you will leave our Website and go to another site, and another entity may collect Personal Data or anonymous data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third-party websites are for your convenience and do not signify our endorsement of such third parties or their products, content or services.
8. Your Choices Regarding Information. You have several choices regarding the use of information on our Website:
(a.) Cookies. If you decide at any time that you no longer wish to accept Cookies for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Website or all functionality of the Website. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided above.
(b.) Google Analytics. You may prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout/.
(c.) Accessing, Changing or Deleting Your Personal Data. You may request access, change, and/or deletion of your Personal Data by contacting info@sparkneuro.com and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes.
9. Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy on our Website and we will change the “Last Updated” date above. You should consult this Privacy Policy regularly for any changes.
