Policy Effective Date: January 1, 2015
This document explains how we treat personal information when you use our products and services.
Spark Gift restricts access to non-public personal information about Users to certain Spark Gift employees who require that information in order to maintain and operate the Site.
When you use the Site, Spark Gift automatically records certain information about your use of the Site. Similar to other web services, Spark Gift records information such as browsing activity, data displayed or clicked on (such as UI elements, ads and links) and other information (such as browser type, IP address, date and time of access, cookie ID, and reference URL). Along with cookies, Spark Gift may use third-party tracking technology, such as Google Analytics, to record similar information regarding you and your activity on the Site.
Use of Information
Spark Gift maintains and processes your Spark Gift account and its contents to provide Spark Gift products and services to you and to improve our products and services.
Spark Gift processes the information you provide to Spark Gift for various purposes, including but not limited to formatting and displaying your information, delivering related content, sharing community information and other purposes relating to the Site.
If you are a Client, Spark Gift may also process information for performing trades for your account, investing activity in your account and/or calculating your portfolio performance.
Spark Gift may send you information related to Spark Gift services or your account if you are a Client. If you decide at any time that you no longer wish to receive marketing communication from us, please follow the “unsubscribe” instructions provided in the communications.
Spark Gift will keep your personal information secure and will only share it with third parties under these circumstances:
Spark Gift maintains physical, electronic and procedural measures to guard User non-public personal information.
Sharing of Information - Clients
If you wish to become a Client, we will ask you for certain information, including, but not limited to; your full legal name, contact information, birth date, SSN, citizenship, investment objectives, approximate net worth and other regulatory disclosures that may be necessary. We require such information in order to be able to provide our services to Clients in accordance with the rules of the Securities and Exchange Commission. You may choose not to provide such information to us, but you will not be able to become a Client.
We will share the information required to become a Client with our brokerage partner solely for the purposes of allowing our brokerage partner to provide services to you.
You may request deletion of personal information by emailing firstname.lastname@example.org and providing us with enough information to identify your account and prove that you are the owner of the identified account. We will act on these deletion requests as soon as reasonably practicable. Deletions take effect when we act on them. Residual information related to your account may remain for some time on our servers. If you are a Client you may request that we remove your personal information, and we will do so as soon as reasonably practicable. However, we may retain such information, as well as any data related to your trades, in accordance with applicable laws. In no case will we share any individual trading data unless required by regulators or other government bodies.
You may decline to provide personal information to Spark Gift. Declining to provide personal information may disqualify you from some Spark Gift services and Site features that require certain personal information.