Last Updated August 30th, 2020
- An Overview of the Sources of Personal Data
- Data We Collect
- Information We Collect About You
- Information You Provide
- Use of Data
- How We Use Data
- How We Share Data
- Third-Party Service Providers
- Data Security
- Your Choices, Access, and Rights to Your Personal Data
- Data Retention
- Data Transfer to Other Countries
- Data Protection Officer
- Links to Third Party Sites
- Children’s Privacy
- Your California Privacy Rights
- How to Contact Us
- Applicable Law
Moreover, our commitment to customers and service providers is governed by a separate Data Protection Amendment.
1. An Overview of the Sources of Personal Data
We obtain information about individuals in these main ways:
- When you visit our Sites or contact us directly about becoming a customer or obtain other information.
- When you become a customer.
- When individuals use a help desk function, and
- When you are a service provider to us.
2. Data We Collect
When you use the Site, we collect and process the following types of information:
a. Information We Collect About You
We collect information about your use of our Services, including, but not limited to, your Internet connections, computer equipment, web browsers, sites visited before using or accessing our Sites, sites visited after leaving our Sites, and other similar information about traffic and usage, as you navigate to, through, and away from our Sites. This is called “Non-Personal Data” because it does not identify you, but provides insights to us regarding your use of the Services.
Web Beacons are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, and to monitor how many visitors view our Services. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages or in an e-mail.
Log Data refers to certain information about how a user (including both account holders and non-Account holders) uses our Services. Log Data may include information such as a user’s Internet Protocol address, browser type, operating system, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a user clicked on, and other statistics.
If you would like to opt-out of our collection of Subscriber Data, you may decline to provide Subscriber Data to us when we ask for it, though doing so may prevent us from being able to deliver our free coaching to you.
Subscribers may voluntarily provide us with information they have made available on social media websites. If you provide us with any such information, we may collect publicly available information from the social media websites you have indicated. You can control how much of your information social media websites make public by visiting these websites and changing your privacy settings.
b. Information You Provide
When you register to use our Services, set up an account, respond to communications from us (e.g., surveys, requests for feedback), contact us via phone, e-mail, or postal mail, and so on, we will collect certain types of Personal Data that you provide to us. “Personal Data” is information that can be used to identify you, either alone or in combination with other information.
When you create a user account with our Site, you may be asked to provide, and we will collect, certain types of Personal Data, which may include your first and last names, e-mail address, zip code, birth month and year, credit card number, and a profile picture. You will also be asked to generate a password as part of your login credentials.
3. Use of Data
a. How We Use Data
For Legitimate Interests. We do not sell or rent Data to any third parties. We use information collected by clickstream data collection, web pixels, and cookies to store your preferences, improve website navigation, make personalized features and other services available to you, to generate statistical information, monitor and analyze user traffic and usage patterns, monitor and prevent fraud, investigate complaints and potential violations of our policies, to improve the our content and the products, services, materials, and other content that we describe or make available through our Sites, and otherwise help administer and improve the Services.
We may identify you from your Personal Data and merge or co-mingle Personal Data and Non-Personal Data, for any lawful business purpose. Where you provide registration information, cookies can also be used to identify you when you log onto the Services or portions of the Services. Except as otherwise stated, we may use information we collect from you for the legitimate business purpose of providing our Services to you, including, but not limited to:
- to respond to your requests and provide user support;
- to evaluate and improve the content of our Services;
- to customize the Services to your preferences;
- to establish accounts to use the Services;
- to communicate information and promotional materials to you (where you have not expressed a preference otherwise);
- to check on your account status and maintain record of activities in connection with your use of the Site;
- to notify you of any changes to relevant agreements or policies;
- for research analysis;
- to respond to your questions or comments;
- to send you a welcome e-mail after you create an account, when you sign up for our e-mail list, or when you download a content upgrade or webinar.
- to send you information regarding our newsletter.
- to enforce our agreements, terms, conditions, and policies;
- to prevent or investigate fraud (or for risk management purposes), or to comply with a legal obligation, court order, or in order to exercise our legal claims or to defend against legal claims;
- to conduct aggregate analysis and develop business intelligence that helps us to enhance, operate, protect, make informed decisions and report on the performances of our Services;
- to describe our Services to current and prospective business partners and to other third parties for other lawful purposes; and
- for other purposes identified to you and as requested by you (please note that you have the right to withdraw your consent to such use at any time by contacting us via the contact information below).
With the Consent of a Data Subject within the EEA; or without consent, if a citizen of any other jurisdiction. If you are a Data Subject within the EEA and we have obtained your consent, we may also use your information in the following ways; and, if you are a citizen of any other jurisdiction, you acknowledge that we may use your information in the following ways:
- to send e-mail and postal mail to provide you with updates and news;
- to process any request you make;
- to process any commercial transaction, including, but not limited to, fulfilling an order request; and
- to process your Personal Data as described throughout this Policy.
- to establish your account to use the Services;
- to validate your e-mail, password, and/or other login credentials;
- to respond to your requests;
- to provide you with products you have requested;
- to fulfill your purchase order(s);
- to send you e-mail and postal mail supplying you with the most recent service information or to send you information about your order (e.g., order confirmations, shipment notifications, etc.);
- to notify you of any changes to relevant agreements or policies; and
We may use third‐party e‐mail providers to deliver these communications to you. If you no longer want to receive these e-mail communications, you may opt-out of receiving e-mail communications, as further discussed below.
We may, from time to time, invite you to participate in online surveys. The information requested in these surveys may include, but is not limited to, your opinions, beliefs, insights, ideas, activities, experience, purchase history, and purchase intent regarding products, events, and our Services. The information collected by these surveys is used to research market trends, company growth, etc. Your input will help us to improve customer experience and shape development of our products and Services.
We may anonymize or aggregate Data that we collect from the use of the Services, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Services, market trends, and other analysis that we create based on the information we receive from you and other users. If you provide Personal Data through our Services, we may aggregate that Data with other active Data, unless we specify otherwise at the point of collection.
b. How We Share Data
We do not sell or rent Personal Data to marketers or unaffiliated third parties. We do have relationships with trusted third parties, but we will not share any Personal Data that we have collected from or regarding you except as described below:
- Service providers that help us administer and provide the Services (for example, a web hosting company whose services we use to host our platform). These third-party services providers have access to your Personal Data only for the purpose of performing services on our behalf. We have entered into contractual relationships with these service providers and require them to comply with all applicable data privacy laws and regulations and to use the Data only for the purposes for which it was disclosed. [We require that any third-party service providers limit their use of your Data solely to providing services to us and that they maintain the confidentiality, security, and integrity of your Data and not make unauthorized use or disclosure of the Data];
- As we believe necessary: (i) under applicable law; (ii) to enforce applicable terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; and (vi) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence;
- Pursuant to your explicit approval prior to the disclosure; and
- We may share aggregated, de-identified Data with our sponsors and business partners to let them know how many users viewed and interacted with their materials. This information does not identify any individual or corporate entity.
- We may disclose your information (including personal information) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process.
- We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
- We may be required to disclose an individual’s personal information in cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-U.S. or Swiss-U.S. Privacy Shield.
4. Third-Party Service Providers
We receive some information from Third-Party Service Providers (“Third Parties”) when you contact us. For example, when you submit your e-mail address to us to show interest in becoming a I Spark Change customer, we receive information from a third party that provides us with your e-mail address to contact you. We also occasionally collect information that is made publicly available on social media websites. You can control how much of your information social media websites make public by visiting these websites and changing your privacy settings.
Moreover, we use Third Parties to help us operate our Services, who may collect, store, and/or process the information detailed herein. We allow access to our database by third parties that provide us with services, such as technical maintenance, market research, customer relations management, and purchase functionality, but only for the purpose of and to the extent necessary to provide those services.
If you choose to complete a subscription transaction on or through features on the Services, we may forward your information to third parties for services such as credit card or other payment processing, order fulfillment, credit pre-authorization, and address verification. There are also times when you provide information about yourself to us in areas of the Services that may be managed or participated in by third parties. In such cases, the information may be used by us and by such third party(ies), each pursuant to its own policies. We may also provide your information to our advertisers so that they can serve ads to you that meet your needs or match your interests.
Google Analytics. We have enabled Google Analytics to collect data about our traffic through the use of Google advertisements and other anonymous identifiers. We use Google Analytics cookies and other cookies to compile data to better understand users and provide users with a more tailored experience. You can opt out of Google Analytics by visiting Google’s Opt-Out Browser Add-on website here.
For more information about third-party advertisers and how to prevent them from using your information, visit the NAI’s consumer website here or here. If you do want to opt out using these tools, you need to opt out separately for each of your devices and for each web browser (such as Internet Explorer, Firefox, or Safari) that you use on each device.
5. Data Security
We take reasonable steps online and offline to safeguard the Personal Data that you provide to us, including Secure Sockets Layer (SSL) encrypted connections (HTTPS) to the website(s) on our Services, secure multi-tiered firewalls, and portions of your data may also be encrypted on our storage server for additional security, secure cloud-based environments and uses server authentication and industry-standard firewalls in an effort to prevent interference or access from outside intruders. We also require unique account identifiers, user names, and passwords that must be entered each time users access the App, or use of secure password credentials to an authorized third party portal.
Nonetheless, it is common knowledge that transmission of information via the Internet is not wholly secure, and we cannot guarantee the security of your Personal Data, or any other information, transmitted to or through any of our Services. Any transmission of Personal Data, or other information, is at your own risk. By using our Services, you acknowledge and accept these risks. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us or that are otherwise provided to us and we cannot be responsible for the theft, destruction, or inadvertent disclosure of information. It is your responsibility to safeguard any passwords, ID numbers, or other special access features associated with your use of the Services. Any transmission of information is at your own risk. By using our Services, you acknowledge and accept these risks.
Moreover, we only work with credit card processors who maintain ongoing PCI compliance, adhering to stringent industry standards for storing, processing and transmitting credit card information online.
If you have any questions about security on our Services, if you become aware of any unauthorized use of an account, loss of your account credentials, or if you suspect a security breach, notify us immediately via e-mail at [email protected]. If our security system is breached, we will notify you of the breach only if and to the extent required under applicable law.
6. Your Choices, Access, and Rights to Your Personal Data
You may change, edit, update, or delete the information you provided, when you set up your account through our Services, through your account settings. You may also request the deletion of this information by sending an e-mail to [email protected].
If you reside in certain jurisdictions, such as the EEA, you may also have the following rights and options with regard to accessing, reviewing, correcting, and updating your Personal Data, as well as how we use and disclose your Personal Data:
- Right to Access. We respect your right to access and control your information and we will respond to requests for information and, where applicable, will correct, amend, or delete your Personal Data.
- How to Access Your Personally Identifiable Information. You may choose to access or update your Personal Data as it exists in our records by logging into the account you have created.
- Access to Personal Data. You may choose to access your Personal Data by contacting us and requesting access, a process which shall include our identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
- Updating Communications Preferences (Opt-Out Policy). We do send e-mails to users with information about our Services that we believe may be of interest. Users may opt out of receiving e-mail messages by contacting us via e-mail at [email protected] or by clicking on the “unsubscribe” link found at the bottom of every e-mail that we send. Please note that if you opt-out of receiving marketing-related e-mails from us, we may still send you important administrative messages that are required to provide you with our Services, as applicable. If you do not opt-out using the link at the bottom of an e-mail, you will continue to receive electronic communications until you choose to click on the link that will be provided in each e-mail you receive from us.
- Right to Rectify — Correction and Deletion. Citizens of some jurisdictions, including the EEA, have the right to correct or amend their Personal Data if it is inaccurate or requires updating. You may also have the right to request deletion of your Personal Data; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by contacting us at [email protected]
- Right to Erasure / Be Forgotten. Data Subjects of the EEA may have the right to request that we delete your Personal Data in certain circumstances, such as if holding the Personal Data is no longer necessary or as part of your Right to Object (below).
- Right to Object. Data Subjects of the EEA may have the right to object to the use of Personal Data for direct marketing uses, scientific uses, or historical research. If you do not wish to have your Personal Data shared with third parties, contact our Data Protection Officer as described at the end of this document. If you do not wish to receive future commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. (But note that you may continue to receive certain communications from us, such as transactional or relationship messages, and/or messages about your account/profile).
- Right to Restrict Processing. Citizens of some jurisdictions, including the EEA, have the right to request that we stop processing their Personal Data.
- Right to Data Portability. Data Subjects of the EEA have the right to request that we provide your Personal Data for the purpose of sharing it with another service provider (through a secure process).
- Filing a Complaint. If you are not satisfied with how we manage your Personal Data, you have the right to make a complaint to a data protection regulator. A list of National Data Protection Authorities can be found here.
7. Data Retention
For more information on our retention of user Data, please see our Data Protection Amendment.
At any time, users may request deletion of their accounts by e-mailing [email protected]. When you delete your account, it cannot be recovered.
Please note that we do retain Non-Personal Data, including aggregated, de-identified data for the purposes described in the section above titled “How We Use Data.”
8. Data Transfer to Other Countries
Our Companies are incorporated in the United States. Information collected via our Sites, through direct interactions with you, or from use of our products may be transferred from time to time to our offices or personnel, or to third parties, located through the world, and may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. To the fullest extent allowed by applicable law, by using any of the above, you voluntarily consent to the trans-border transfer and hosting of such information.
9. Data Protection Officer
Our appointed Data Protection Officer is Chase Neely. If you have an inquiry regarding your Personal Data, pursuant to the rights listed above, please send your message to the following:
Rick Ornelas at [email protected]
10. Links to Third Party Sites
11. Children’s Privacy
We do not sell products or services for purchase by anyone under the age of thirteen (13). In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit Personal Data from anyone under the age of thirteen (13) without verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Data without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Service(s).
Moreover, Our products are not designed for or directed to children under the age of 18. We do not collect personal information from any person we actually know is under the age of 18.
12. Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to [email protected].
14. How to Contact Us
By e-mail: [email protected]
By regular mail:
Attn: Privacy Agent
I Spark Change, LLC
240 Lake Estates Dr.
Montgomery, TX 77356
United States of America
Our representative in the European Union can be contacted by e-mail: [email protected]
Please be assured that any Personal Data that you provide in communications to us will not be used to send you promotional materials unless you so request.
15. Applicable Law