This page supplements Spark's master Privacy Policy with disclosures required for visitors in Brazil under the Lei Geral de Proteção de Dados ("LGPD"). It does not restate rights already described in the master Privacy Policy — only what Brazilian law adds.
1. Applicability
This page applies to you if you are located in Brazil.
2. Your Rights Under the LGPD
Under the LGPD, you have the right to:
- Confirm whether we process your personal data;
- Access your personal data;
- Correct incomplete, inaccurate, or outdated data;
- Request anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in non-compliance with the LGPD;
- Request portability of your data to another provider;
- Be informed of public and private entities with which we have shared your data;
- Revoke your consent, where consent is our basis for processing; and
- Request review of decisions made solely by automated processing that affect your interests.
3. How to Exercise Your Rights
You may exercise these rights by contacting us using the details in Section 7. We will respond within the timeframe required by the LGPD.
4. Data Protection Officer
Spark has not yet appointed a formal Encarregado (Data Protection Officer) for LGPD purposes. Until one is appointed, requests relating to this page should be directed to the contact in Section 7; this page will be updated with dedicated DPO contact routing once appointed.
5. Complaints to the ANPD
You have the right to lodge a complaint with Brazil's Autoridade Nacional de Proteção de Dados (ANPD) if you believe our processing of your personal data violates the LGPD.
6. Clause Overrides
Spark's Terms of Service designate the courts of South Australia and the Federal Court of Australia as the forum for disputes, and Australian law as the governing law, since Spark is an Australian venture. As a Brazilian consumer, you retain the right to bring a claim in the courts of Brazil to the extent Brazilian consumer-protection law (including the Código de Defesa do Consumidor) requires it, and mandatory consumer-protection provisions of Brazilian law continue to apply notwithstanding the Terms of Service's choice of Australian law and forum.
7. Contact
Questions about this page may be directed to privacy@spark.bebulbed.com.