You may receive information about new features, services and special offers Spark Compass™’ client, who is providing you with offers and opportunities about its products and services through the APP, believes you will find valuable based on information you have shared with Spark Compass™ about yourself. Spark Compass™ allows the client to send you information you have requested to receive using the information, including PII, Spark Compass™ has collected. When Spark Compass™ presents you with offers and opportunities from its client Spark Compass™ will not automatically subscribe you for these promotions, rather it will provide you with the opportunity to take advantage of these client offers and opportunities.
You may also access the personal information you have submitted to Spark Compass™ by selecting “Profile” and editing the information as it exists in Spark Compass™’ system currently.
If you do not agree to these terms and conditions, please do not use or access the APP. Spark Compass™’ APP delivers to you contextually relevant offers and opportunities from its client to your mobile device in real time when and where Spark Compass™ believes you can use them most. To do this, Spark Compass™’ APP blends several technologies licensed to Spark Compass™ into a cloud based Mobile Customer Relationship Management (“MCRM”) platform. It uses Augmented Reality and Image Recognition to document your engagement with Spark Compass™’ client’s products or services.
The APP will verify where you are, how long you interact with the client’s products or services and upload that information and your mobile device information into the MCRM system. Spark Compass™’ client will access this information, which does not disclose your identity or identifying information like age or gender, unless you have prepared a profile on the APP. By doing so you allow Spark Compass to collect the personal information you provide and present it to Spark Compass™’ client, on a Customer Relationship Management (“CRM”) dashboard. The client will use the information to determine what offers and opportunities to send you based on where you are, who you are, your past behavior, preferences and how you have selected to act upon offers and opportunities presented to you before.
A geofence is a virtual perimeter. Geofencing uses the global positioning system (“GPS”), cell tower or WiFi hot spot triangulation or radio frequency identification (“RFID”) to define virtual geographical boundries. A Spark Compass™ client will establish a geofence around its facilities which will altert the MCRM system automatically when you are in proximity to it. The geofence sensing feature in the APP allows a client to set up triggers so when your device crosses the virtual perimeter of the client’s geofence, a push notification, SMS or email alert is sent alerting you about offers and opportunities the client will make available to you at that location.
You will automatically receive offers and opportunities when your device crosses a geofence. You do not have to “check-in” to receive the client’s offers and opportunities location-based services
To provide location-based services through the APP, Spark Compass™ may collect, use, and share precise location data, including the real-time geographic location of your device. This location data is collected anonymously in a form that does not personally identify you and is used by Spark Compass™ to provide and improve location-based products and services, unless you have actively opted in by preparing and filling in Your profile in the APP. opt-in registration.
Registration is required in order to create an account on the APP. You may provide as much or as little information as you want. The more information you provide, the more able Spark Compass™ will be to provide services, offers and opportunities through the APP
Collection and Use of Personally Identifiable Information
PII is data that can be used to identify or contact You.
PII Spark Compass™ Collects
When you download the APP, create a Spark Compass™ ID, create a profile in the APP settings, purchase a product or service from a Spark Compass™ client, download a software update, or participate in an online survey, Spark Compass™ and its affiliates may collect information, including your name, location, phone number, email address, unique identification number for your mobile device that the APP is installed on and contact preferences.
When you share content in the APP with family and friends using a social media platform available from within the APP, Spark Compass™ and its affiliates may collect the information about you and those you share it with that is available on the public portion of your and their social media accounts.
If you download an Augmented Reality target from the Spark Compass™ website by emailing it to yourself, Spark Compass™ will collect your email address and store it. Spark Compass™ and its affiliates may use your email address to send you information about new Augmented Reality applications, which may be of interest to you. Your email address will be associated with the APP on your device. If you would like an Augmented Reality Target but prefer not to share your email address with Spark Compass™, you may print the Target from the Spark Compass™ website.
How Spark Compass™ and its Affiliates Use Your PII
The information Spark Compass™ and its affiliates collect allows Spark Compass™ to keep you updated about Spark Compass™’s and its client’s latest product announcements and upcoming events. If you do not want to receive offers and opportunities customized to your preferences, you can opt out anytime by updating your preferences and deleting the information you provided about yourself. If you do so, you will still receive offers and opportunities from Spark Compass™’ client when you are in proximity to any of its locations. To stop receiving offers and opportunities from Spark Compass™’ client, uninstall the APP.
Spark Compass™ and its affiliates also use PII to help develop, deliver, and improve their products, services and content.
Spark Compass™ and its affiliates may also use PII for internal purposes such as auditing, data analysis, and research to improve their products, services, and customer communications.
If you enter into a sweepstake, contest, or similar promotion offered by Spark Compass™’ Client through the APP, TCA and its affiliates may use the information you provide to administer those programs.
Collection and Use of Non-Identifiable Personal Information
Spark Compass™ and its affiliates also collect non-identifiable personal information. This is data in a form that does not permit direct association with you. Spark Compass™ and its affiliates may collect, use, transfer, and disclose non-identifiable personal information for any purpose. The following are some examples of non-identifiable personal information that Spark Compass™ and its affiliates may collect and how they may use it:
Spark Compass™ and its affiliates may collect non-identifiable personal information such as occupation, language, zip code, area code, unique device identifier, location, and the time zone where a device is being used so they can better understand customer behavior and improve their products, services, and content.
If Spark Compass™ and its affiliates combine non-personal information with PII, the combined information will be treated as PII for as long as it remains combined.
Cookies and Other Technologies
Spark Compass™’ services, push notifications, interactive applications, email messages, and offers and opportunities sent to you by Spark Compass™’ client may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help Spark Compass™ and its affiliates better understand your behavior and facilitate and measure the effectiveness of offers and opportunities provided to you by Spark Compass™’ client.
If you want to disable cookies, check with your provider to find out how to disable them. Please note that certain features of the APP will not be available once cookies are disabled.
As is true of most interactive APPs, Spark Compass™ and its affiliates gather some information automatically and store it in log files and in its MCRM system. This information includes information such as but not limited to device information, service operator and providers, IP addresses, browser type and language, Internet Service Provider, referring and exit pages, operating system, date/time stamp, and clickstream data.
Spark Compass™ and its affiliates use this information to understand and analyze trends, to administer the APP, to learn about your behavior on the APP, and to gather demographic information about Spark Compass’ customer base as a whole. Spark Compass™ and its affiliates may use this information in their marketing and advertising services.
Pixel tags enable Spark Compass™ to send email messages in a format you can read, and they tell Spark Compass™ whether mail has been opened. Spark Compass™ may use this information to reduce or eliminate messages sent to you.
Surveys and contests
Spark Compass™’ APP may request information from you via surveys and contests. Participation in surveys and contests is voluntary and you can choose to disclose information or not. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code and age level). Contact information will be used to notify the winners and award prizes. Spark Compass™ may use this information for marketing opportunities if you authorize the use. Spark Compass™ and its affiliates may also be use this information to monitor or improve the use of this APP.
Disclosure to Third Parties in the Course of Spark Compass™’ Business
At times Spark Compass™ may make certain PII available to strategic partners who work with Spark Compass™ to provide products and services, or help Spark Compass™’ Clients provide you with offers and opportunities. Spark Compass™’ strategic partners include companies who provide services such as information processing, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in Spark Compass™’ client’s products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect Your PII.
PII will only be shared by Spark Compass™ and its affiliates to provide or improve the APP or technologies and intellectual property used in the APP. PII will not be shared with third parties for their marketing purposes.
Disclosure to Others as Required by Law
It may be necessary – by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence – for Spark Compass™ or its affiliates to disclose your PII in their custody or control. Spark Compass™ and its affiliates may also disclose information about you if Spark Compass™ determines that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate under applicable law.
Spark Compass™ and its affiliates may also disclose information about you if we determine that disclosure is reasonably necessary to enforce the terms of the EULA or protect Spark Compass or its affiliates’ operations or Spark Compass™ clients or customers.
Additionally, in the event of a reorganization, merger, or sale Spark Compass™ may transfer any and all PII it has collected to the relevant third party authorized by law to receive it.
Protection of PII
Spark Compass™ takes precautions – including administrative, technical, and physical measures – to safeguard your PII against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction.
Spark Compass™ will also do everything in its power to protect your data offline. All sensitive information is stored on secure and encrypted servers. Only employees who need the information to perform a specific job (for example, a Customer Care representative) are granted access to personally identifiable information, and are required to lock their station when they leave their station.
All Spark Compass™ employees, consultants and independent contractors are kept up to date on Spark Compass™ security and privacy practices. Every quarter and whenever new policies are implemented, Spark Compass™ employees, consultants and independent contractors are reminded about the importance of keeping your data secure and safe at all times. The servers with PII are stored in a secure environment. When you use some Spark Compass™ products, services, or applications, the PII you share is visible to other users and can be read, collected, or used by them. You are responsible for the PII you choose to submit in these instances. For example, if you list your name and email address in a posting, that information is public. Please take care when using these features.
Integrity and Retention of PII
Access to PII
Spark Compass™ will make good faith efforts to allow you to request corrections of data if it is inaccurate or delete data if Spark Compass™ and its affiliates are not required to retain it by law or for legitimate business purposes. Spark Compass™ may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made to the regional Privacy email addresses.
Spark Compass™ does not knowingly collect PII from minors, e.g., persons under 18 years of age. If Spark Compass™ learns that it has collected PII of a minor, Spark Compass™ will take steps to delete the PII as soon as possible.
Third-Party Sites and Services
Spark Compass™ encourages You to learn about the privacy practices of those third parties whose products or services You access through the APP.
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Last revision January 2015