Privacy Policy

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Sparticle Ventures LLC Privacy Policy

Last updated: May 23, 2020

Sparticle Ventures LLC (“Sparticle” ) operates a public website at https://sparticle.io (the “Site”). Sparticle is committed to maintaining the confidentiality, integrity, and security of Personal Information (defined below). This Privacy Policy describes how Sparticle and its affiliates (“we,” “us,” “our”) collect, use, share, and protect Personal Information, and your choices about the collection and use of Personal Information.

This Privacy Policy applies to Personal Information collected or processed through the Site and the Platform (collectively, the “Service”). If you have questions about this Privacy Policy, please do not hesitate to contact us at privacy@sparticle.io.

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:

Support Information

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

When you use or access the Service, we, our service providers, and our advertisers use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect information about how you use the Service. We process the information collected through such technologies, which may include Personal Information, to help operate certain features of the Service, to enhance your experience through personalization, and to help us better understand the features of the Service that you and other users are most interested in.

For example, we use analytics tools to capture information about your use of the Service, such as pages you visit, mouse clicks and scrolling activity. The providers of these tools may use cookies and other techniques to capture data about your activity on our site. As another example, if you arrive at our Service by clicking on an advertisement or content published by a third party, that third party may provide information to us about your activity on their site.

We permit certain third parties to display content on our Service. If you view pages containing this content (even if you do not directly interact with it), these content providers may collect information about your use of the Service. These providers may combine information collected about you on our Service with any Personal Information about you that they may have to enable them to track you across multiple sites and over time. You should review the third party’s privacy policy for more information about the data they collect and their use and disclosure of the data. (For more information on third-party providers used in connection with this Service, including links to their privacy policies, please see Appendix: Sparticle Service Providers at the end of this Privacy Policy).

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.

Location Data

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.

Regardless of the source, we will process any Personal Information we collect or receive in accordance with this Privacy Policy.

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.

If the European Union General Data Protection Regulation (“GDPR”) applies, our legal basis for collecting and using the information described in this Privacy Policy will depend on the information concerned and the context in which we collect it. We collect Personal Information from you:

  • 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 Service Providers: We may provide information, including Personal Information, to third parties who work for us, such as companies that verify credit card information, process credit card payments, manage e-signing, analyze data, manage contact information and communications, remove repetitive information from customer lists, and provide marketing services. Further, our Site and Platform are hosted by third parties and we use third party infrastructure monitoring services. These third parties may have inadvertent or incidental access to your data. These providers are not authorized to further disclose your data or to use your data for any purpose other than providing services to us. For more information, including ways to limit certain types of disclosures, please see Appendix: Sparticle Service Providers at the end of this Privacy Policy.
  • To Advertisers: Some of our service providers may use cookies or other technology to identify users of our Service and display ads tailored to the user’s interests and behavior, including those detected outside this Website. In addition to any opt out offered by an advertising service, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page. For more information, including additional information on how to opt out of certain advertising tracking, please check the privacy policies of the relevant services (see Appendix: Sparticle Service Providers at the end of this Privacy Policy).
  • 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.
  • To Comply with Applicable Law or Protect against Fraud or Other Harm: When we believe disclosure is appropriate to comply with the law, to enforce our terms of use and other rights, or to protect the rights and safety of others. This may include exchanging information with government regulatory or law enforcement agencies, or with other companies and organizations for fraud protection and legal compliance.

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

If you are using the Service from outside the United States, please be aware that Personal Information may be transferred to, stored, and processed in the United States. Although we take steps to provide adequate safeguards, the data protection laws of the United States might not be as comprehensive as those in your country. By using the Service, you consent to Personal Information being transferred to the United States for the purposes described in this Privacy Policy.

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.

12. Changes to Our Privacy Policy

We may change, modify, add, or remove portions of this Privacy Policy at any time. We will provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances (e.g., by posting a notice on the Service; by sending an email to you if you are a registered user). Any changes or updates will be effective immediately upon posting to this page, and the date of such change or update will be posted at the top of the page.

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.

This Appendix to the Privacy Policy provides examples of our service providers and the purposes for which we engage them:

Advertising

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.

Analytics

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.

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