PRIVACY POLICY

Last Updated: May 2023

We at Spark LLC (“spark,”, “Spark”, “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of spark in connection with our app.

By clicking “I AGREE,” when you download and use the app, you acknowledge that you have read, understood and agree to be legally bound by the terms of this Privacy Policy, and the accompanying Terms of Service.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Service.

The Information We Collect and/or Receive

In the course of operating the app, we will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

1. Contact Information.

If you would like to access and use the app, you will be asked to provide certain information, including but not limited to, your name, phone number, profile photo, and contacts (the “Contact Information”).

1. Other Information.

In addition to the Contact Information, we may collect additional information (the “Other Information”).  Such Other Information may include:

1. From Your Activity. Information that we automatically collect when you use the app, including, without limitation:

   • IP addresses, device type, referring and exit pages, date and time, amount of time spent on particular pages, what sections of the app you visit, etc.; and

   • Activity and usage information occurring via the app, including tagging data, favorites, preferences, session lengths; and similar data.

   • We will collect or store audio files or other voice data shared during the use of the app.

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2. Third-Party Analytics**.** We may use one or more third–party analytics services (such as but not limited to TestFlight and Google Analytics) to evaluate your use of the app, compile reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the app you visit, number of links tapped while on the app, search terms and other similar usage data), and analyze performance metrics. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the app, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the App.

   • For TestFlight, please visit: testflight.apple.com
   • For Google Analytics, please visit: google.com/analytics

How We Use and Share the Information

We use the Contact Information and Other Information (collectively, the “Information”) to provide the app, solicit your feedback, inform you about our products and services and those of our third-party marketing partners, and to improve our app.

You also authorize us to use and/or share your Information as described below.

• Agents, Providers and Related Third Parties. We may engage other companies and individuals to perform certain business-related functions on our behalf. Examples may include providing technical assistance, customer service, and marketing assistance. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law. We may also share your Information with any of our parent companies, subsidiaries, or other companies under common control with us.
• Aggregated Information. In an ongoing effort to better understand users of the app, we might analyze your Information in aggregate form in order to operate, maintain, manage, and improve the app. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our app to current and prospective business partners and to other third parties for other lawful purposes.
• Business Transfers. As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, your Information may be part of the transferred assets.
• Legal Requirements. To the extent permitted by law, we may also disclose your Information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of spark or others.