PRIVACY POLICY

Date of Last Revision: September 13, 2020

Our Policy:

Welcome to the web site (the “Site”) of Spark xyz, Inc. (“Spark xyz”, “we”, “us” and/or “our”) This Site is operated by Spark xyz, Inc and has been created to provide information about our Spark xyz and our platform designed to connect university students and alumni with startup companies (together with the Site, the “Services”) to our Service visitors (“you”, “your”). This Privacy Policy sets forth Spark xyz’s policy with respect to information including personally identifiable data (“Personal Data”) and other information that is collected from visitors to the Site and Services. “Personal data” means any information which relates to a living, identifiable person. It can include names, addresses, telephone numbers, email addresses etc but it is wider than that and includes any other information relating to that person or a combination of information which, if put together, means that the person can be identified. “Data subject” means the person whose personal data is being processed.

“Data controller” means the organisation which is responsible for processing data and ensuring that personal data is processed in accordance with data protection law.

Information We Collect:

When you interact with us through the Services, we may collect Personal Data and other information from you, as further described below:

Personal Data That You Provide Through the Services:

We may collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services or use certain Services. We may also collect information about you that does not uniquely identify you if you choose to provide us with such information. Wherever Spark xyz collects Personal Data we make an effort to provide a link to this Privacy Policy.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to the Services, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Spark XYZ and the authorized third parties referred to herein located in the United States.

When you interact with Spark xyz through the Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you

Spark xyz may store such information itself or such information may be included in databases owned and maintained by Spark xyz affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers. It is important to note that no Personal Data is available or used in this process.

In operating the Services, we may use a technology called "cookies." A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission.

The information we collect by automated means may include, but is not limited to, the following:

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.

Aggregated Personal Data:

In an ongoing effort to better understand and serve the users of the Services, Spark xyz often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Spark xyz may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Spark xyz may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

Our Use of Your Personal Data and Other Information:

Spark xyz uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. Spark xyz and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Services to help us improve the content and functionality of the Services, to better understand our users and to improve the Services. Spark xyz and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions permitting you to "opt-out" of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

Additionally, we may use the information we collect to:

We may enable you to sign into the Site via social networks or access social networks through the Site. If you do so, your use of the social network is governed by such social network’s terms and conditions and privacy policies. If you sign into the Site via a social network or access a social network through the Site, you may be asked to grant Spark xyz access to certain information from your social network profile. We may use this information to help you personalize your experience with the Site, to suggest new features and content that may be relevant to you, or for statistical or other business purposes.

We also may use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We may enable third parties to collect information in connection with our Site. This Privacy Notice does not apply to, and we are not responsible for, any collection of information by third parties on our Site.

If Spark xyz intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Our Disclosure of Your Personal Data and Other Information:

Spark xyz is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy. Agents, Consultants and Related Third Parties: Spark xyz, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

Legal Requirements: Spark xyz may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Spark xyz, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

Your Choices:

You can visit the Site without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain Services.

Exclusions:

This Privacy Policy does not apply to any Personal Data collected by Spark xyz other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Spark xyz through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Spark xyz shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

How We Respond to Do Not Track Signals:

Your web browser may let you choose your preference as to whether you want to allow websites to collect personal information over time about your online activities across different websites or online services. At this time our Site does not respond to the preferences you may have set in your web browser regarding the collection of your information, and our Site may continue to collect information in the manner described in this Privacy Notice.

Children:

Spark xyz does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission.

Links to Other Web Sites:

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by Spark xyz (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Spark xyz endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Inviting Connections:

Our Services allow you to stay in touch, in communication and up to date with classmates, alumni, and other professional contacts. To do so, you will “connect” with the professionals who you choose, and who also wish to “connect” with you. When you connect, you will be able to search each others’ connections in order to exchange professional opportunities.

We will use data about you such as your email contacts list and third-party social media sites to suggest connections for you and others (e.g. users who share your contacts) and enable you to invite others to become a user and connect with you. It is your choice whether to invite someone to our Services, send a connection request, or allow another user to become your connection. When you invite someone to connect with you, your invitation will include your name, photo, network and contact information. We will send invitation reminders to the person you invited. You can choose whether or not to share your own list of connections with your connections.

Integrating Social Networking Services:

One of the special features of the Service is that it allows you to enable or log in to the Services via various social networking services like Facebook or Twitter (“Social Networking Service(s)”). By directly integrating these services, we make your online experiences richer and more personalized. To take advantage of this feature, we will ask you to log into or grant us permission via the relevant Social Networking Service. When you add a Social Networking Services account to the Service or log into the Service using your Social Networking Services account, we will collect relevant information necessary to enable the Service to access that Social Networking Service and your data contained within that Social Networking Service. As part of such integration, the Social Networking Service will provide us with access to certain information that you have provided to the Social Networking Service, and we will use, store and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Social Networking Services use, store and disclose your information is governed by the policies of such third parties, and Spark xyz shall have no liability or responsibility for the privacy practices or other actions of any Social Networking Services that may be enabled within the Service.

You may also have the option of posting your Services activities to Social Networking Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Networking Services you have enabled will be able to view such activity.

Security:

Spark xyz takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Spark xyz via the Internet.

Your California Privacy Rights

If you are a California resident, you have certain additional privacy rights available here: Sparkxyz California Privacy Policy

Other terms and conditions:

Your access to and use of the Services is subject to the Terms of Service at https://sparkxyz.io/terms_and_conditions.

Changes to Spark XYZ’s Privacy Policy:

The Services and our business may change from time to time. As a result, at times it may be necessary for Spark xyz to make changes to this Privacy Policy. Spark xyz reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy. You are responsible for periodically reviewing the Site and this Privacy Notice to check for any updates or changes.

Your Rights:

Your rights in relation to your personal data how it is processed. You can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you.

Where we process your personal data, you have a number of rights over how the data is processed and can exercise these rights at any point. We have provided an overview of these rights below together with what this entails for you.

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