Spark - Privacy Policy

This Privacy Policy and Cookie Statement (“Privacy Policy”) applies to how Meero processes Your Personal Data when You visit https://www.we-spark.com/ or when You contact Spark regarding the Spark Services. It is part of the Spark Terms of Use [Spark Terms of Use], so all capitalized terms not defined here are defined in the Spark Terms of Use. The purpose of this Privacy Policy is to give You information regarding what data we collect, why, what we’re going to do with it, the processes we’ll follow, and what Your rights are in relation to that data. Any data we collect about you (“Personal Data” or “Data”) will be collected and processed in compliance with the European Union General Data Protection Regulation 2016/679 (the “GDPR”) and any other applicable national or state legislation and/or regulation (“applicable data privacy legislation”). We ask You to regularly review this Privacy Policy to keep up to date with any changes.

1 - PERSONAL DATA

Meero collects the following Personal Data in connection with Spark: 

  • When contacting Spark, You may provide us with the following information: 
  • Your full name,
  • Your email address,
  • Your phone number.
  • We collect some Data by automated means when You visit Spark Website, use the Spark Services and/or create a User Account. 
  • Browser Information: type of browser, cookie settings;  
  • Device Information: device, model of the hardware, operating system; 
  • Identification Details:  unique identifiers; 
  • Network Information: IP-address; 
  • Website Use: information about the way You interact with Spark website. 

2 - PURPOSES

Generally, we use all Personal Data we collect in connection with Spark to provide the Spark Services, improve the Services, develop new products, advertise our Services, keep Spark secure, and comply with legal obligations. 

  • We use the information You provide us for the following purposes: 
  • To contact You regarding the Spark Services. 
  • We use the information collected by automated means to: 
  • Allow you to access the Spark website;
  • Allow you to contact the Spark Team;
  • Provide You with account support and technical assistance when needed; 
  • Monitor for and fix bugs and errors; 
  • Monitor Spark for fraud, and/or illegal or impermissible use; 
  • Understand how our users interact with Spark. 
  • Generally, we use the Data we collect: 
  • For legal purposes, where necessary. For instance, we might use any of the Data we collect to comply with a court order or government request, cooperate with law enforcement, or otherwise comply with the applicable law. 

3 - LEGAL BASES

We process the Data we collect pursuant to the following legal bases: 

  • Contractual. We process Data to allow You to access and use the Spark Services, in performance of the Terms You agree to when using the Spark Services.
  • Legal. We process Data to comply with applicable legal and regulatory obligations, such as those related to financial reporting, or investigate abuse reports concerning abuse imagery involving minors. 
  •  Legitimate interests. We process Data in order to further our legitimate interests, such as the improvement of our products and services, internal development, fraud prevention.  
  • Consent. We process Data based on Your consent. If You want to know more about Your rights in relation to Consent, please see section 9 below.

4 - DATA RETENTION

We will keep Personal Data for the periods defined by law or official guidance, where applicable. Otherwise, Personal Data will only be kept for as long as actively used and reasonably needed to pursue the purposes listed above.

5 - OPTIONAL INFORMATION

We will always mark mandatory information with an asterisk, or otherwise indicate it is mandatory. If we’re asking You for information that is not mandatory, You have the choice to enter such information.

6 - COOKIE STATEMENT

We use cookies, which are small text files stored on Your computer when You visit a website, to make Spark easy and fun to use. Some cookies are necessary to the website’s functioning – these cannot be opted-out from. Other cookies aggregate statistics about user interaction with Spark; these help us to understand how the Services are being used and what we can do to improve.

7 - THIRD PARTY SERVICES

We may share some Data as part of the Services with: 

  • Hosting providers;  
  • Law enforcement and government authorities, where required or compelled; 
  • Third party services and features incorporated into Spark. These services and features are provided in compliance with the Spark Terms of Use and pursuant to the Privacy Policy of each third-party provider, where applicable; 
  • Meero entities, where required to provide the Services.

8 - DATA TRANSFER OUTSIDE THE EUROPEAN ECONOMIC AREA

Data may be transferred outside the European Union. In such cases, we will provide the appropriate measures (such as the signature of standard contractual clauses).

9 - YOUR RIGHTS

You have rights in relation to Your Personal Data, including: the right to access Your Data, to have Your Data deleted, and to object to or restrict certain processing activities. You can exercise your rights by emailing privacy@meero.com. In order to exercise certain rights, such as the right of access, we may ask You for a form of personal identification. 

If You have provided us with consent for a certain processing activity, You can withdraw that consent at any time. If You do so, we will no longer process You Data in connection with that activity.

10 - CHANGES TO THIS POLICY

We may update this Privacy Policy, in our sole discretion, from time-to-time.

11 - CONTROLLER INFORMATION

Personal Data is collected and processed in connection with Spark by: 

Meero SAS (“Meero”)

A company registered with the Paris Trade and Companies Register under the number 800 523 664

Tel. +33 (0) 1 76 31 00 52

12 - TALK TO OUR DATA PROTECTION OFFICER (DPO)

Meero has appointed a DPO to ensure good data practices and data privacy legislation compliance. You can contact Meero’s DPO at: privacy@meero.com

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