This page supplements Spark's master Privacy Policy with disclosures required under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), and similar privacy laws in other US states. It does not restate rights already described in the master Privacy Policy — only what US law adds.
1. Applicability
This page applies to you if you are a resident of the United States, including California and other states with comparable consumer privacy laws.
2. Categories of Information
In the preceding 12 months, we have collected the following categories of personal information, as defined by the CCPA: identifiers (such as name and email address); internet or network activity (such as usage data); and, if you choose to upload one, an avatar image. We do not collect precise geolocation data from uploaded photos — our avatar pipeline re-encodes every image into a new file before storage, which is what prevents any GPS metadata in your original photo from ever reaching us in the first place (see the master Privacy Policy's Avatar & Image Handling section). We do not collect biometric information, financial account information, or sensitive personal information beyond your account credentials.
3. Your Rights Under US Law
Subject to certain exceptions, you have the right to:
- Know what personal information we collect, use, and disclose;
- Access a copy of your personal information;
- Correct inaccurate personal information;
- Delete your personal information;
- Limit the use of sensitive personal information (though, as noted above, we do not collect sensitive personal information beyond standard account credentials); and
- Not be discriminated against for exercising any of these rights.
4. Do Not Sell or Share
We do not sell or share (as those terms are defined by the CCPA) your personal information, and we have not done so in the preceding 12 months. Because we do not sell or share personal information, there is no opt-out link to provide — this disclosure exists to confirm that fact directly, rather than leave it unaddressed.
5. How to Exercise Your Rights
You may exercise these rights by contacting us using the details in Section 7, or through an authorized agent. We will verify your identity before fulfilling your request, using information you've already provided us (such as your account email), and will respond within the timeframe required by applicable law.
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, since Spark is an Australian venture. If mandatory US federal or state consumer-protection law grants you a non-waivable right to bring a claim in your home US courts, that right is not overridden by this designation, and you may exercise it notwithstanding the Terms of Service.
7. Contact
Questions about this page may be directed to privacy@spark.bebulbed.com.