SPARK Nation Network and Productions LLC (hereinafter referred to as "we" or "the Company") recognizes the importance of personal information to you and is committed to protecting your privacy and data security. This Privacy Policy aims to clearly disclose our practices regarding the collection, use, storage, sharing, and other related matters of information, helping you understand your rights and how we safeguard the security of your information. Please carefully read and understand this Privacy Policy before using our official website and related services. Your access, browsing, or use of our services will be deemed your acceptance and acknowledgment of the content of this Policy. We reserve the right to update this Policy at any time. In case of material changes, we will notify you through a prominent announcement on the official website or other reasonable means. We recommend that you review this Policy regularly.
1.Information Collection
The core purpose of our information collection is to provide you with personalized, high-quality official website services and related products, optimize the user experience, and meet business operation and compliance requirements. The types and scenarios of collected information are as follows:
1.1 Personal Identification Information
When you subscribe to services, participate in interactive activities, contact customer support, or perform other operations that require identity verification on the official website or app, we may collect personally identifiable information that you voluntarily provide, including but not limited to your name, email address, phone number, mailing address, company name (if applicable), etc. You have the right to choose whether to provide such information, but some services may not function properly without it.
1.2 Usage and Device Information
When you access, browse, or use the official website, we will automatically collect information related to your usage behavior and device, including but not limited to SDK/API/JS code version, browser type and version, Internet Service Provider (ISP), IP address, access platform (such as computer, mobile device), timestamp, application identifier, application version, application distribution channel, device model, device manufacturer, operating system version, session start/stop time, language settings, time zone, network status (such as WiFi, cellular network), hard disk, CPU and battery usage, network card (MAC) address, and unique advertising identifiers (such as iOS Advertising Identifier IDFA, Android Advertising Identifier). This information will help us optimize the performance of the official website, troubleshoot technical issues, and enhance service stability.
1.3 Interaction and Feedback Information
When you post comments, leave messages, participate in questionnaires, submit feedback, or communicate with our customer service team on the official website, we will collect the relevant content you provide, communication records, and related metadata (such as comment posting time, feedback submission channel, etc.) to promptly respond to your needs and improve service quality.
1.4 Other Relevant Information
To meet legal compliance requirements, ensure service security, or provide specific services, we may collect other necessary information with your consent, such as identification document information (if applicable) provided when you choose to participate in sweepstakes, contests, or other activities, or third-party platform information shared with our authorization (such as relevant authorized information obtained when logging in through a social media account).
2.Information Use
We strictly use the collected information in accordance with the provisions of this Privacy Policy and relevant legal requirements, mainly for the following purposes:
2.1 Provision and Maintenance of Services
Provide core official website services according to your requests, including account management, service subscription, content push, activity participation, etc.; maintain the normal operation of the official website, perform technical support, troubleshooting, system updates, and other operations to ensure the stability and security of services.
2.2 Optimization and Improvement of Services
Analyze user usage behavior, device information, and feedback data to understand user needs and preferences, optimize the functional design, interface layout, and content presentation of the official website, develop new products or services, and enhance the overall user experience. For example, recommend content or activity information that is more in line with your interests based on your browsing history.
2.3 Personalized Services and Advertising
With your explicit consent, we may use the collected information to provide you with personalized content recommendations, advertising displays, and other services. You can withdraw this authorization at any time through the official website settings. After withdrawal, we will no longer use the relevant information for this purpose, but this will not affect the legality of information use based on legitimate authorization before the withdrawal.
2.4 Customer Support and Communication
Respond to your inquiries, complaints, feedback, and other requests, and handle your service needs; send you service-related notifications, updates, activity reminders, and other information (such as account security alerts, service term change notifications, etc.). You can choose to unsubscribe from non-essential marketing information according to the prompts.
2.5 Compliance and Security Assurance
Comply with applicable laws and regulations, judicial procedures, court orders, or administrative supervision requirements; prevent, detect, and respond to fraud, abuse, security threats, technical failures, and other risks, protect the security of your account, personal information, and our legitimate rights and interests, and maintain the normal order of the official website and related services.
2.6 Other Legal Purposes
Within the scope permitted by your explicit consent or law, use the information for other purposes directly related to the above purposes, or make reasonable use based on legitimate interests (such as data analysis, market research, business planning, etc.). Such use will not infringe upon your legitimate rights and interests.
3.Information Sharing
We attach great importance to the security of your information and will not arbitrarily share your personal information with third parties unless the following circumstances apply:
3.1 Obtaining Your Explicit Consent
Before sharing your personal information with a third party, we will obtain your explicit authorization or consent and inform you of the purpose of sharing, the identity of the third party, and the scope of relevant information.
3.2 Service Providers and Partners
To realize service functions or optimize service quality, we may share necessary information with third-party vendors, agents, or partners who provide services on our behalf, such as data analysis companies, server hosting providers, payment processors, advertising service providers, etc. Such third parties must comply with our data privacy and security requirements, only use the information within the authorized scope, not use it for other irrelevant purposes, and assume corresponding responsibilities for information security.
3.3 Legal Compliance Requirements
We may disclose your personal information in accordance with the law when we believe that the disclosure is necessary to comply with applicable laws and regulations, respond to judicial procedures, court orders, or administrative supervision requirements, or to protect our legitimate rights and interests, the life, property safety of users or the public, or public interests from infringement.
3.4 Business Mergers and Transfers
In the event of business changes such as mergers, acquisitions, bankruptcy liquidation, or asset transfers of the Company, your personal information may be transferred to relevant third parties as part of the business assets. We will notify you through a prominent manner before the transfer and ensure that the transferee continues to comply with the relevant provisions of this Privacy Policy to protect your information rights and interests.
3.5 Sharing of Anonymized or De-identified Information
We may share anonymized or de-identified information (information that cannot identify your personal identity) with third parties for purposes such as market research, data analysis, and academic research. Such sharing does not require your separate consent.
4.Data Storage and Retention
4.1 Storage Methods and Locations
Your personal information will be stored in an encrypted database that meets industry security standards and transmitted through secure network connections. As we are a U.S. company, the collected information may be stored in the United States or the countries/regions where our third-party service providers are located. The data protection laws of these countries/regions may differ from those of your country/region, but we will take necessary protective measures to ensure that your information receives the same security protection as agreed in this Policy.
4.2 Retention Period
We will retain your personal information for the shortest time necessary to achieve the purposes stated in this Privacy Policy or in accordance with the retention period specified by applicable laws (such as tax law, accounting law, data protection law, etc.). The specific retention rules are as follows:
If you register an account, we will continue to retain the relevant information to provide services during the active period of the account;
If your account remains completely inactive for 12 consecutive months or longer, we will delete your account and related personally identifiable information after verification, unless the law requires an extended retention period;
After you request to delete your account or related information, or after the service is terminated, we will promptly delete or anonymize your personal information in accordance with relevant privacy regulations and internal guidelines, unless it is necessary to continue retaining it for compliance purposes or to resolve disputes.
4.3 Storage Security Measures
We adopt reasonable and industry-standard physical, electronic, and administrative security measures to protect your information from unauthorized access, use, disclosure, modification, loss, or damage. Specific measures include but are not limited to: using firewalls, encryption technologies, and access control mechanisms to restrict information access rights; conducting regular security audits, vulnerability scans, and system updates; providing data security training to employees and clarifying information processing rights and confidentiality obligations.
Despite the above security measures, please note that no method of Internet transmission or electronic storage can guarantee 100% security. We are not liable for information leakage risks caused by uncontrollable factors such as force majeure, hacking attacks, or unauthorized access by third parties. You should take reasonable measures to protect the security of your personal information (such as properly keeping your account password, avoiding accessing sensitive information through public networks, etc.).
5.International Data Transfers
Due to the international scope of our business operations, your personal information may be transferred to servers or third-party service providers in the United States or other countries/regions for the purposes stated in this Privacy Policy. The data protection levels of these countries/regions (including but not limited to the United States) may differ from those of your country/region, but we will ensure that data transfers comply with applicable legal requirements and take at least one of the following protective measures:
- Transfer to countries or regions recognized by the U.S. Department of Commerce as meeting data protection standards;
- Sign privacy protection contracts that meet internationally recognized standards with recipients (such as standard contractual clauses approved by the European Commission);
- If the recipient is located in the European Union/European Economic Area, ensure that it complies with the adequacy protection measures specified in the General Data Protection Regulation (GDPR);
- Other security measures that comply with applicable legal requirements.
By using our services, you explicitly consent to our international data transfers in accordance with the above methods to provide corresponding services and fulfill relevant obligations.
6.Your Rights and Exercise Methods
In accordance with applicable U.S. federal and state data protection laws (such as the California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act (VCDPA), etc.) and other relevant laws and regulations, you have the following rights, and we will provide necessary assistance for you to exercise these rights:
6.1 Right to Know and Access
You have the right to request us to confirm whether we hold your personal information and obtain a copy of your personal information, including information such as the source of collection, purpose of use, and recipients of sharing.
6.2 Right to Correction and Update
If you find that the personal information we hold about you is incorrect, inaccurate, or incomplete, you have the right to request us to correct, supplement, or update it in a timely manner.
6.3 Right to Erasure (Right to Be Forgotten)
Under circumstances specified by law, you have the right to request us to delete your personal information, including but not limited to situations where you withdraw consent, the information is no longer necessary to retain, or our information processing activities violate legal provisions.
6.4 Right to Data Portability
You have the right to request us to provide your personal information in a structured, commonly used, and machine-readable portable format to you or a third party designated by you (to the extent technically feasible).
6.5 Right to Object and Restrict Processing
You have the right to object to our processing of your personal information based on legitimate interests or marketing purposes; under specific circumstances, you have the right to request us to restrict the processing of your personal information (such as when there is a dispute over the accuracy of the information or the processing activity is illegal).
6.6 Right to Withdraw Consent
If you have previously consented to our processing of your personal information, you have the right to withdraw that consent at any time, but this will not affect the legality of information processing based on legitimate authorization before the withdrawal.
6.7 Methods of Exercising Rights
If you wish to exercise the above rights or have questions about the processing of your personal information, you may contact us through the contact information provided in Section 14 of this Policy. We will verify and respond to your request within 7-21 business days after receiving it. If necessary, we may require you to provide identity verification information to ensure the security of exercising your rights. If you are dissatisfied with our response, you may file a complaint with the relevant regulatory authority.
7.Third-Party Services and Links
Our official website may contain links to websites of third-party service providers, advertisers, partners, or affiliated companies, as well as advertisements or embedded content (such as videos, plug-ins, etc.). These third parties have independent privacy policies and data processing rules, and we assume no responsibility or liability for their privacy policies, terms of service, or information collection and use practices.
When you click on third-party links, visit third-party websites, or use third-party services, your information will be subject to the privacy policies of those third parties. We strongly recommend that you carefully read and understand the privacy policies and related terms of third parties before providing any personal information to protect the security of your own information.
8.Processing of Advertising-Related Information
Our official website may include advertising services, and some advertisements are provided by us or third-party advertising partners. To provide a more relevant advertising experience, we or our advertising partners may collect and use your relevant information (such as device identifiers, usage behavior information, etc.) for advertising targeting, effect monitoring, and optimization.
If you agree to receive personalized advertising services, we will share necessary anonymized or de-identified information with our advertising partners. Advertising partners may combine this information with the information they collect when you use their services or other third-party services to display advertisements that are more in line with your interests. You can choose to opt out of personalized advertising through the official website settings or the unsubscribe method provided by the advertising partners, but this may result in less relevant advertisements being displayed to you and will not affect your normal use of the core services of the official website.
Our advertising partners shall comply with relevant data protection laws and industry norms, and you can review their privacy policies for detailed information.
9.Protection of Children's Information
Our official website and related services are not intended for children under the age of 13 (in accordance with the requirements of the U.S. Children's Online Privacy Protection Act (COPPA)), and we will not intentionally collect, use, or store personal information of children under the age of 13.
If you are a parent or legal guardian of a child and discover that the child has provided personal information to us without authorization, please immediately contact us through the contact information provided in Section 14 of this Policy and provide relevant supporting documents. After verification, we will delete the relevant personal information as soon as possible and will not disclose it to third parties. If you are under the age of 13, please do not use our official website or provide any personal information to us.
10.Legal Basis for Data Processing
In accordance with applicable U.S. and relevant national/regional data protection laws, the legal bases for us to process your personal information include:
Performance of contractual obligations: Necessary to provide you with the services you request and fulfill the agreements signed with you (such as terms of service);
Compliance with legal requirements: Necessary to comply with applicable laws and regulations, judicial procedures, court orders, or administrative supervision requirements;
Legitimate interests: Necessary to safeguard our legitimate business interests without infringing upon your legitimate rights and interests, such as ensuring service security, managing customer relationships, conducting data analysis and business optimization, and preventing fraud;
Your consent: Processing relevant information based on your explicit consent (such as personalized advertising, third-party information sharing, etc.), which you can withdraw at any time.
In some cases, your provision of necessary personal information is a prerequisite for using specific services. If you refuse to provide such information, you may not be able to enjoy those services.
11.Legal Disclaimer
Notwithstanding other provisions of this Policy, we reserve the right to disclose your personal information in the following circumstances:
Comply with applicable laws and regulations, judicial procedures, court orders, administrative subpoenas, or other legal requirements;
Protect our legitimate rights and interests, trade secrets, intellectual property rights, website operation security, and other property rights;
Protect the personal and property safety of users or the public or other legitimate rights and interests from infringement, such as preventing or responding to fraud, abuse, security threats, and other behaviors;
Investigate or take corresponding measures against violations of our terms of service, this Privacy Policy, or other rules.
12.Changes to the Privacy Policy
We may revise this Privacy Policy from time to time based on business development, updates to laws and regulations, or technological progress. Any changes to this Policy will be posted through a prominent location on the official website (such as a homepage announcement, pop-up prompt, etc.) or notified to you through your reserved contact information (such as email, text message, etc.) after revision. The changes will take effect from the effective date stated in the posting or notification.
If the changes involve your core rights (such as the scope of information collection, purpose of use, sharing rules, etc.), we will give you a reasonable preparation period and the changes will take effect after you confirm your consent (unless otherwise specified by law). Your continued access, browsing, or use of our official website and services will be deemed your acceptance of the revised Privacy Policy. We recommend that you review this Policy regularly to learn about the latest content.
13.Supplementary Notes on Information Security
We continuously improve our information security management system, regularly assess security risks, and update security protection technologies and measures to ensure the security of your personal information. However, due to the complexity of the network environment, limitations of technological development, and other uncontrollable factors, we cannot absolutely guarantee that information will not be leaked, lost, abused, or tampered with.
In the event of a personal information security incident, we will take remedial measures in a timely manner in accordance with applicable legal requirements, assess the impact of the incident, and notify you through official website announcements, emails, phone calls, and other methods within the specified time, informing you of the relevant circumstances of the incident, potential impacts, and the response measures we have taken.
You should properly keep your account information (such as username, password) and other sensitive information, avoid disclosing it to others, change your password regularly, access the official website through a secure network environment, and immediately contact us if you find any account abnormalities or information leakage.
14.Contact Us
If you have any questions, complaints, or suggestions regarding this Privacy Policy, or wish to exercise your relevant rights, you may contact us through the following methods:
- Company Name: SPARK Nation Network and Productions LLC
- Contact Email: [email protected]
