Spark Back – FZCO, a Free Zone Company with Registration number DSO-FZCO-16176 incorporated under the laws of the United Arab Emirates (UAE), having its registered office at Dubai Digital Park, Silicon Oasis. Building A1, Dubai, UAE (hereinafter also referred to as “Company”, “we”, “our” or “us”) operates https://sparkback.com/ (“Website”) and provide support and resources for women entrepreneurs to grow their businesses (”Services”).
We use your data to provide and improve Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Policy, the terms used in this Policy have the same meanings as in our Terms and Conditions. Our Terms and Conditions govern all use of our Service and together with the Policy constitute your agreement with us.
If this Policy is modified in any way, it will be updated here. Regularly checking and reviewing this page ensures that you are updated on the information which may be collected, used (and under what circumstances), and if it may be shared with other parties (if at all). If we believe that the modifications are material, we will notify you of the changes by posting a notice on the Website, or emailing you at the email address provided to us by you, and as we may deem appropriate. What constitutes a material change will be determined by us, at our sole and absolute discretion. In this Policy “you”, “your” or “Users” refers to the users of the Platform.
WHAT INFORMATION DO WE COLLECT?
The personal information you disclose to us
In short: We collect information that you provide to us.
We may collect personal information that you voluntarily provide to us, express an interest in obtaining information about us or our products and Services or otherwise when you contact us.
The personal information that we may collect depends on the context of your interactions with us and the Website, the choices you make and the services and features you use. The personal information we collect may include the following:
Personal Information Provided by You.
We collect email addresses; phone numbers; mailing addresses; and other similar information. We may also collect additional information about our clients’ businesses in order to provide relevant and effective consultation and related services.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.
When you access our websites, we, our service providers and our partners may automatically collect information about you, your computer or mobile device, and your activity on our websites. Typically, this information includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; and information about your use of and actions on or in our websites, such as pages or screens you accessed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access.
Our service providers and business partners may collect this type of information over time and across third-party websites. This information is collected via various mechanisms, such as via web beacons, embedded scripts, and similar technologies. This type of information may also be collected when you read our HTML-enabled emails.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity on the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet or other devices you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, and operating system configuration information.
HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
- For the purposes of providing consultation and related services. We may use this information to communicate with our clients, to provide information or resources relevant to their businesses.
- To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
- To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
- To respond to legal requests and prevent If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share the data that we hold based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Third-Party Advertisers: We may use third-party advertising companies to serve ads when you visit or use the Website. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
- Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honour this Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
- Business Partners: We may share your information with our business partners to offer you certain products, services or promotions.
WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Website.
HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this Policy will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
WHAT ARE YOUR PRIVACY RIGHTS?
YOUR DATA PROTECTION RIGHTS UNDER PERSONAL DATA PROTECTION LAW (PDPL).
Spark Back – FZCO collect and use personal data (information) about you, we may be subject to the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (United Arab Emirates) (“PPD”) and responsible as a ‘data controller’ for such personal data. Below you will find the additional specific provisions applicable to you in UAE; including your rights to your data as it may be processed by Us.
Your duty to inform us of changes: It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Your rights in connection with personal data, under certain circumstances, by law you have the following rights:
- Right to Obtain Information. This right is commonly known as a “data subject access request”. This enables you to receive a copy of the personal data we hold about you upon submitting a request.
- Right to Request Personal Data Transfer. This enables you to ask us, in certain circumstances, to provide you with the personal data you have provided to us in a structured, commonly used and machine-readable format or to transmit the personal data that you have provided to us to another party, whenever this is technically feasible.
- Request for Correction or Erasure. This enables you to request for correction or erasure of the personal data that we hold about you. You can ask us to update any incomplete, inaccurate, or out of date information we hold about you, to be corrected or to delete or remove personal data where there is no good reason for us continuing to process it.
- Right to Restrict Processing. This enables you to ask us, in certain circumstances, to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Right to Stop Processing. This enables you to object to and stop the processing if the processing of your personal data is for direct marketing purposes, including profiling related to direct marketing or for the purposes of conducting statistical surveys, unless the Processing is necessary to achieve the public interest or if the processing is in violation of your rights.
- Right to Processing and Automated Processing. This right enables you not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.
- Right to Filing a Complaint. This enables you the right to file a complaint with UAE Data Office (established by virtue of Federal Decree-Law No. 44/2021), if you consider that the processing of your personal data infringes PPD. UAE Data Office is the regulatory and enforcing authority responsible for the protection of the privacy of
If you are UAE resident and want to exercise a data subject right in connection to your personal data, please contact us. (see contacts below).
What we may need from you: If you exercise one of the above rights, we may need to request specific information from you to help us confirm your identity and that you are entitled to make such a request. This is to ensure that personal data is not disclosed to any person who has no right to receive it.
If you have any questions about this privacy notice or how we handle your personal data, please contact us at [email protected].
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do- Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
Our Services are not for the use of children below the age of 18 (“Child” or “Children”).
We do not knowingly collect personally identifiable information from children under 18 without the consent of the legal guardian. If you become aware that a Child has provided us with Personal Data without the parent’s consent, please contact us. If we become aware that we have collected Personal Data from Children, we take steps to remove that information from our servers.
DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Last updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
Last Updated: March 2, 2023.