Sparkle Revolution Privacy Policy

Effective Date: April 3, 2024

Applicable To The Sparkle Revolution Application and Website

Thank you for choosing to be part of the Sparkle Revolution!  We are excited to be on this journey with you. 

We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at info@sparklerevolution.com.

When you use our mobile application and more generally, use any of our services, we appreciate that you are trusting us with your personal information. We take your privacy very seriously. 

In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

DEFINITIONS

1. ACCOUNT means a unique account created for You to access our Service or parts of our Service.

2. APPLICABLE MOBILE APPLICATION: This Privacy Policy will refer to and be applicable to the Mobile App listed above, which shall hereinafter be referred to as “Mobile App.”

3. DEVICE means any device that can access the Service such as a computer, a cell phone or a digital tablet.

4. EFFECTIVE DATE means the date this Privacy Policy comes into force and effect.

5. PARTIES:  The parties to this privacy policy are the following data controller: Sparkle Revolution, LLC (“Data Controller”) and you, as the user of this Mobile App. Hereinafter, the parties will individually be referred to as “Party” and collectively as “Parties.”

6. DATA CONTROLLER is the publisher, owner, and operator of the Mobile App and is the Party responsible for the collection of information described herein. Data Controller shall be referred to either by Data Controller’s name or “Data Controller,” as listed above. If Data Controller or Data Controller’s property shall be referred to through first-person pronouns, it shall be through the use of the following: us, we, our, ours, etc.

7. SERVICE refers to the Application

8. SERVICE PROVIDER means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

9. THIRD-PARTY SOCIAL MEDIA SERVICE refers to any website or any social network website through which a User can log in or create an account to use the Service.

10. YOU: Should you agree to this Privacy Policy and continue your use of the Mobile App, you will be referred to herein as either you, the user, or if any second-person pronouns are required and applicable, such pronouns as ‘your”, “yours”, etc.

11. PERSONAL DATA means personal data and information that we obtain from you in connection with your use of the Mobile App that is capable of identifying you in any manner.

GENERAL INFORMATION

This privacy policy (hereinafter “Privacy Policy”) describes how we collect and use the Personal Data that we receive about you, as well as your rights in relation to that Personal Data, when you visit our Mobile App and interact with it in any way, including passively.

This Privacy Policy does not cover any information that we may receive about you through sources other than the use of our Mobile App. The Mobile App may link out to other websites or mobile applications, but this Privacy Policy does not and will not apply to any of those linked websites or applications.

We are committed to the protection of your privacy while you use our Mobile App.

By continuing to use our Mobile App, you acknowledge that you have had the chance to review and consider this Privacy Policy, and you acknowledge that you agree to it. This means that you also consent to the use of your information and the method of disclosure as described in this Privacy Policy. If you do not understand the Privacy Policy or do not agree to it, then you agree to immediately cease your use of our Mobile App.

CONTACT

If you have any questions about this Privacy Policy, You can contact us:

By email: info@sparklerevolution.com

By visiting this page on our website: www.sparklerevolution.com

LOCATION

Please be advised the data processing activities take place in the United States, outside the European Economic Area. Data may also be transferred to companies within the United States, but will only be done so in a manner that complies with the EU’s General Data Protection Regulation or GDPR.

MODIFICATIONS AND REVISIONS

We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner. If we do so, however, we will notify you and obtain your consent to the change in processing. Unless we specifically obtain your consent, any changes to the Privacy Policy will only impact the information collected on or after the date of the change. It is also your responsibility to periodically check this page for any such modification, revision or amendment.

THE PERSONAL DATA WE RECEIVE FROM YOU

Depending on how you use our Mobile App, you will be subject to different types of Personal Data collected and different manners of collection:

1. Registered users: You, as a user of the Mobile App, may be asked to register in order to use the Mobile App in a legal manner.

During the process of your registration, we will collect some of the following Personal Data from you through your voluntary disclosure:

Name, email

Personal Data may be asked for in relation to:

I) Interaction with our representatives in any way

II) Receiving general emails from us

III) Or the following other forms of participation:

User activity data

By undergoing the registration process, you consent to us collecting your Personal Data, including the Personal Data described in this clause, as well as storing, using or disclosing your Personal Data in accordance with this Privacy Policy.

1. All users: The Passive Data Collection that applies to Unregistered users shall also apply to all other users and/or visitors of our Mobile App.

2. User Experience: From time to time we may request information from you to assist us in improving our Mobile App, such as demographic information or your particular preferences.

THE PERSONAL DATA WE RECEIVE AUTOMATICALLY

Log Data: Like all websites and mobile applications, this Mobile App also makes use of log files that store automatic information collected during user visits. The different types of log data could be as follows:

• Internet protocol (IP) address

• Type of browser and device parameters used to connect to the Mobile App

• Name of the Internet Service Provider (ISP)

• Date and time of visit

• Web page of origin of the user (referral) and exit

• Possibly the number of clicks

The aforementioned information is processed in an automated form and collected in an exclusively aggregated manner in order to verify the correct functioning of the site, and for security reasons. This information will be processed according to the legitimate interests of the Data Controller.

For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also possibly include Personal Data such as IP address, which could be used, in accordance with applicable laws, in order to block attempts at damage to the Mobile App or damage to other users, or in the case of harmful activities or crime. Such data are never used for the identification or profiling of the user, but only for the protection of the Mobile App and our users. Such information will be treated according to the legitimate interests of the Data Controller.

THIRD PARTIES

We may utilize third-party service providers (“Third-Party Service Providers”), from time to time or all the time, to help us with our Mobile App, and to help serve you.

We may use Third-Party Service Providers to assist with information storage (such as cloud storage).

We may provide some of your Personal Data to Third-Party Service Providers in order to help us track usage data, such as referral websites, dates and times of page requests, etc. We use this information to understand patterns of usage of, and to improve, the Mobile App.

We may use Third-Party Service Providers to host the Mobile App. In this instance, the Third-Party Service Provider will have access to your Personal Data.

We only share your Personal Data with a Third-Party Service Provider if that provider agrees to our privacy standards as set out in this Privacy Policy.

Your Personal Data will not be sold or otherwise transferred to other third parties without your approval.

Notwithstanding the other provisions of this Privacy Policy, we may provide your Personal Data to a third party or to third parties in order to protect the rights, property or safety, of us, our customers or third parties, or as otherwise required by law.

We will not knowingly share your Personal Data with any third parties other than in accordance with this Privacy Policy.

If your Personal Data might be provided to a third party in a manner that is other than as explained in this Privacy Policy, you will be notified. You will also have the opportunity to request that we not share that information.

THIRD-PARTY SOCIAL MEDIA SERVICES

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

• Google

• Apple

• Facebook

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service’s account, such as Your name or Your email address.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service’s account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

HOW PERSONAL DATA IS STORED

We use secure physical and digital systems to store your Personal Data when appropriate. We ensure that your Personal Data is protected against unauthorized access, disclosure, or destruction.

Please note, however, that no system involving the transmission of information via the internet, or the electronic storage of data, is completely secure. However, we take the protection and storage of your Personal Data very seriously. We take all reasonable steps to protect your Personal Data.

The systems that we use to store your information include but are not limited to:

We only store minimal personal information needed to provide a good user experience. The information that you enter as part of the activities is not shared with any third parties other than our secure cloud storage.

Personal Data is stored throughout your relationship with us. We delete your Personal Data upon request for deletion of your account or other general request for the deletion of data.  We will also delete all data from accounts which have been inactive for 2 years or more.

In the event of a breach of your Personal Data, you will be notified in a reasonable time frame, but in no event later than two weeks, and we will follow all applicable laws regarding such breach.

PURPOSES OF PROCESSING PERSONAL DATA

We primarily use your Personal Data to help us provide a better experience for you on our Mobile App and to provide you the services and/or information you may have requested, such as use of our Mobile App.

Information that does not identify you personally, but that may assist in providing us broad overviews of our customer base, will be used for market research or marketing efforts. Such information may include, but is not limited to, interests based on your activity selection and usage.

Personal Data that may be considering identifying may be used for the following:

1. Improving your personal user experience

2. Communicating with you about your user account with us

3. Providing customer service to you

4. Advising you about updates to the Mobile App or related Items

DISCLOSURE OF PERSONAL DATA

Although our policy is to maintain the privacy of your Personal Data as described herein, we may disclose your Personal Data if we believe that it is reasonable to do so in certain cases, in our sole and exclusive discretion. Such cases may include, but are not limited to:

1. To satisfy any local, state, or Federal laws or regulations

2. To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies

3. To bring legal action against a user who has violated the law or violated the terms of use of our Mobile App

4. As may be necessary for the operation of our Mobile App

5. To generally cooperate with any lawful investigation about our users

6. If we suspect any fraudulent activity on our Mobile App or if we have noticed any activity which may violate our terms or other applicable rules

CHILD ACCESS

We may collect information from children, as well as allow and encourage children to visit our Mobile App.

The information we collect from children is as follows:

Name, email, with the approval of an adult.  Please see the Sparkle Revolution Terms and Conditions for more information on Child & Minor Usage.

We do not allow children to make their Personal Data publicly available.

Information collected from children in accordance with this clause is collected to help us enhance all user experiences and to improve our Mobile App.

It is also collected for the specific purpose of the following:

The benefits of the Sparkle Revolution app can be experienced at any age level. As with everyone, we only collect the minimum personal data that we need to provide a good user experience.

We do not require children to disclose any further information than is reasonably necessary to interact with our Mobile App.

Parents or guardians of minor children may review the Personal Data of their child and have it deleted at their request. They may also agree to collection and use of information, without consenting to disclosure to any other party. They may also refuse to permit any further collection or use of such information by sending us an email at info@sparklerevlolution.com.

Otherwise, information collected from children in accordance with this clause is collected, used and if applicable, disclosed, in accordance with the general provisions of this Privacy Policy.

OPTING OUT OF TRANSMITTALS FROM US

From time to time, we may send you informational or marketing communications related to our Mobile App such as announcements or other information. If you wish to opt-out of such communications, you may contact the following email: info@sparklerevolution.com. You may also click the opt-out link which will be provided at the bottom of any and all such communications.

Please be advised that even though you may opt-out of such communications, you may still receive information from us that is specifically about your use of our Mobile App or about your account with us.

By providing any Personal Data to us, or by using our Mobile App in any manner, you have created a commercial relationship with us. As such, you agree that any email sent from us or third-party affiliates, even unsolicited email, shall specifically not be considered SPAM, as that term is legally defined.

MODIFYING, DELETING, AND ACCESSING YOUR INFORMATION

If you wish to modify or delete any information we may have about you, or you wish to simply access any information we have about you, you may do so from your account settings page.

ACCEPTANCE OF RISK

By continuing to our Mobile App in any manner, use the Product, you manifest your continuing asset to this Privacy Policy. You further acknowledge, agree and accept that no transmission of information or data via the internet is not always completely secure, no matter what steps are taken. You acknowledge, agree and accept that we do not guarantee or warrant the security of any information that you provide to us, and that you transmit such information at your own risk.

YOUR RIGHTS

You have many rights in relation to your Personal Data. Specifically, your rights are as follows:

• The right to be informed about the processing of your Personal Data

• The right to have access to your Personal Data

• The right to update and/or correct your Personal Data

• The right to portability of your Personal Data

• The right to oppose or limit the processing of your Personal Data

• The right to request that we stop processing and delete your Personal Data

• The right to block any Personal Data processing in violation of any applicable law

• The right to launch a complaint with the Federal Trade Commission (FTC) in the United States or applicable data protection authority in another jurisdiction

Such rights can all be exercised by contacting us at the relevant contact information listed in this Privacy Policy.

CONTACT INFORMATION

If you have any questions about this Privacy Policy or the way we collect information from you, or if you would like to launch a complaint about anything related to this Privacy Policy, you may contact us at the following email address: legal@sparklerevolution.com.

Google Analytics Privacy Notes

We use Google Analytics to help us understand how the app is used to allow us to continually improve your experience.

In order to use the Google Analytics tools, we must agree to various Google Terms:

• Google Analytics processes your data only as required to maintain and protect the Google Analytics service, as set out in the Google Ads Data Processing Terms

• As well as the Google Analytics Terms of Service

• Learn how Google Analytics safeguards your data

• Data Processing Terms as required by GDPR. Learn more

The following services may be used from Google Analytics:

Google products & services

If you have enabled Google signals, this setting will also apply to authenticated visitation data which is associated with Google user accounts. This setting is required for Enhanced Demographics & Interests reporting . If you disable this option, data can still flow to other Google products explicitly linked to your property. Visit the product linking section in each property to view or change your settings. Show Example

Modeling contributions & business insights

Enable features like predictions, modeled data, and benchmarking that can provide you with richer business insights when you contribute aggregated measurement data. The data you share (including information about the property from which it is shared) is aggregated and de-identified before being used to generate business insights. Show Example

Technical support

Let Google technical support representatives access your Google Analytics data and account when necessary to provide service and find solutions to technical issues.

Account specialists

Give Google sales access to your Google Analytics data and account so that they can help you make the most of your Google Analytics account including to help you to improve your configuration and analysis and to provide you with insights, optimization tips and recommendations across Google Analytics and other Google products.