Last updated: May 23, 2020
1. WHAT IS PERSONAL INFORMATION?
“Personal Information” is information that, either alone or in combination with other information, identifies you. Examples of Personal Information include, among others, name, email address, phone number, and mailing address. When we combine Personal Information with other information (such as the name of the company you work for), we treat the combined information as Personal Information.
2. TYPES OF PERSONAL INFORMATION WE COLLECT AND USE
A. Information that You Provide to Us
In various places on the Service, we request information, including Personal Information, from you via forms. The exact information we need to collect will depend on the purpose of the form. For example, when you create an account as a member, we ask you to provide your email address, first and last name, mailing address, phone number, gender, university affiliation and other details necessary for us to provide the best user experience on our platform. However, as another example, we only request your name, email address, and a password choice when you join our Innovation Mailing List.
We will indicate on the form whether a particular field of information is mandatory or optional. You may choose not to provide certain information, but we may not be able to provide requested services.
A. Information that You Provide to Us
We collect the following types of information automatically through your use of the Service:
When you use the Platform, we will record information relating to transactions (e.g., creating groups or syndicates, evaluations, etc.) conducted through the Platform. With your permission, we may obtain certain information relating to certain actions or tasks you make in order to reward you for supporting participating startups or projects.
Cookies, Device Identifiers, and Similar technologies
Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the Site may not be available or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.
In addition to the information we gather on the Site and Platform, we may use web beacons within emails that we send to track whether you actually view our messages or content.
At this time, the Service does not respond to Do Not Track (“DNT”) signals sent by your browser, but some of our third-party providers may honor these signals in accordance with their privacy policies.
Third-Party Authentication Information
Instead of creating a separate log-in on our Platform, we may enable you to log into the Platform using a social media account. If Sparticle acquires information about you from such third parties, it may tie this third party provided information to the information it collects from or about you as part of your visit to the Site or use of the Platform. Please refer to the privacy settings of the applicable social media platform to determine how you may manage the interactivity between the Platform and your social media account.
If you grant us access (via browser or device settings), we may collect information concerning the location of your device. We use this information to help personalize the Service by providing you more relevant information and to help expedite the insertion of your address when signing up for an account. You may deny us access to this information, but doing so may make certain features unavailable.
Log File Information
When you use our Service, our servers automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our Site), number of clicks, and how you interact with links on the Site, domain names associated with your internet service provider, pages viewed, and other such information (collectively, “Log File Information”). We may also collect similar information from emails sent to you which then help us track which emails are opened and which links are clicked by recipients. We use Log File Information collected from our implementation of the Site to further our legitimate interests in securing the Site by identifying potential threats and vulnerabilities, and in analyzing the effectiveness of our Site to improve the Site’s function and content.
C. Information We Receive About You from Our Other Users
We may receive Personal Information about you from users of our Service. For example, groups and syndicates allows users to introduce our platform to entrepreneurs and investors. If one our users refers you and your startup or project, the user will submit to us your name and business contact information. We also may permit users to share with Sparticle contacts via their local address book or via a third party service such as Facebook, which may include your contact information.
3. How We Use Personal Information
Generally, we use Personal Information as necessary to provide the Service, to operate the Site and Platform efficiently, and to provide a high quality experience for Site visitors and Platform users.
More specifically, we process Personal Information to:
- Facilitate transactions on the Platform (e.g., Platform interactions with your peer members or other investors);
- Communicate with you about your account or to provide you with information about Sparticle’s or third parties’ content, product or services;
- Send you requested information, such as our newsletters;
- Enable secure use of the Service;
- Screen for and reduce fraud, spam, abuse, and security problems;
- Provide you with support;
- Show you advertisements and other content that may be of particular interest to you while you are on the Service;
- Improve our Site and Platform, such as improving the content or organization, developing new platform features, identifying target audiences for our external advertising, and supporting publicity efforts;
- Comply with applicable laws and regulations (e.g., determining your eligibility to complete transactions on our Platform);
- Protect our rights or our property; and
- Use for other purposes related to the reasons for which you provide Personal Information.
- where we need it to perform a contract with you;
- where the processing is in our legitimate interests (which include the purposes listed, above);
- where processing is necessary for compliance with an applicable legal obligation; or
- if we otherwise have your consent.
4. How We Disclose Personal Information to Others
Sparticle and its affiliates will not disclose Personal Information about you to third parties except with your consent or as follows:
- To Sparticle Affiliates: Sparticle may disclose information collected from the Service, including Personal Information, to its affiliates to facilitate services offered by those affiliates, as well as those affiliates marketing efforts on behalf of the Sparticle family of companies.
- To Innovators: We may provide certain contact information such as email and contact information to innovators for the purposes of providing services to you under the applicable investment agreements. These providers are not authorized to further disclose Personal Information or to use Personal Information for any other purpose other than providing such services.
- To Other Users: The Service may include features where you can post comments or profile information visible to other users. Please exercise caution when posting any information that will be publicly available on the Service.
- To Companies Involved in Mergers and Acquisitions Transactions: We may in the future sell all or part of our assets or be involved in a merger. Any information collected through the Service, including Personal Information, may be among the items sold or transferred.
5. How We Protect Personal Information
We have implemented security measures to protect Personal Information from loss, misuse, and alteration. For example, we use bank-level security measures to protect sensitive Personal Information (such as bank account information) from unauthorized use and disclosure. Your submissions of sensitive Personal Information on our website are encrypted using secure socket layer technology (SSL). We may update our security methods and procedures as appropriate. Nonetheless, it is important to note that no method of transmission of information over internet is free of security risk. Despite our security measures, Sparticle makes no guarantee that Personal Information will not be breached. We cannot assume responsibility or liability for unauthorized access to our servers and systems.
6. Retention of Personal Information
We will retain your information for as long as your account is active or is needed to provide you with our Service, and we will retain and use your information as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements.
7. Personal Information Transferred from Outside the United States
8. Opting Out of Receiving EMail Communications
With your permission, we may send notifications, promotions, or other information via email (“Communications”). You may choose to stop receiving Communications by indicating your preference in your account profile or settings. You may also follow the unsubscribe instructions in any email you receive. You may also send a global unsubscribe request to privacy@Sparticle.io. Please note that certain Service-related Communications are necessary for the proper functioning and use of the Service (e.g., to provide you with confirmation of your account setup) and you may not have the ability to opt out of those Communications.
9. Your Rights
If you would like to access, amend, erase, export, or object to or restrict the processing of, Personal Information about you, you may submit a request to privacy@Sparticle.io. We will promptly review all such requests in accordance with applicable laws.
Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information. We encourage you to first reach out to us at , so we have an opportunity to address your concerns directly before you do so.
10. California Privacy Rights for California Residents
California law permits users who are residents of California to request the following information regarding our disclosure of “Personal Information” (as defined by California law) to third parties for those third parties’ direct marketing purposes (i) a list of certain categories of Personal Information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year, (ii) the identity of certain third parties that received Personal Information from us for their direct marketing purposes during that calendar year, and (iii) examples of the products or services marketed (if we have that information). If you are a California resident and would like to make such a request, please email us at privacy@Sparticle.io.
11. Children's Online Privacy Protection
Our Service is not directed to children. Accordingly, we will not knowingly collect any data from or about any person under the age of 18.
Appendix: Sparticle Service Providers
Last updated: May 23, 2020
We employ service providers to perform tasks on our behalf and to assist us in providing the Service. For more information, please contact us at privacy@Sparticle.io.
These services allow certain information collected from the Service to be utilized for advertising purposes displayed in the form of banners and other advertisements, possibly based on anticipated user interests.
These services assist Sparticle in monitoring and analyzing web traffic and can be used to provide insights on user behavior on the Service.
Displaying Content from External Platforms
These services allow you to view and interact with content hosted on external platforms directly on the Service:
Hosting, Infrastructure Monitoring, Security, and Performance
These services host data and files that enable this Service to run efficiently and securely.
Interaction with Social Networks and Platforms
These services allow interaction with social networks or other external platforms\ directly from the pages of this Service.
Managing Contacts and Sending Messages
These services enable Sparticle to manage a database of email contacts, phone contacts, or any other contact information to communicate with users.
Registration and Authentication
These services provide registration and authentication services.