Sparkwise and its affiliates (listed in the “Affiliates” section below) care about privacy issues and want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through our website located www.sparkwi.se (the “Site”). Please note that the Privacy Policy applies only to our online information-gathering and dissemination practices in connection with the Site, and does not apply to any of our practices conducted offline. If you have any questions or comments about the Privacy Policy or our privacy practices, please contact us via email at: privacy@sparkwi.se

Your use of the Site, signifies that you agree with all the terms of this Privacy Policy, so please do not use the Site if you disagree with any part of this Privacy Policy.

PERSONAL INFORMATION

Personal Information We Collect

“Personal Information” is information that identifies you or relates to you as an individual, such as:

• Name
• Postal address (including billing and shipping addresses)
• Telephone number
• Email address

How We Use Personal Information

We may use Personal Information:

• to respond to your inquiries and fulfill your requests, such as to send you newsletters or publications that you request or to register you for events.
• to send you our legal updates and mailings relating to our product updates or events that we think may be of interest to you, in accordance with applicable law.
• to keep a record of your contact information and correspondence, and use it to respond to you, if you contact us by email through the Site.
• to send you important information regarding the Site, changes to our terms, conditions, and policies and/or other administrative information.
• to provide services, including the provision of trainings and other events.
• subject to local requirements, to allow you to send Site-related content to a friend through the Site. By using this functionality, you are telling us that you are entitled to use and provide us with your friend's name and email address.
• as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How Personal Information is Disclosed

Your Personal Information may be disclosed:

• to our affiliates (listed in the “Affiliates” section below) for the purposes described in this Privacy Policy, consistent with our goal of providing the highest level of global service. Subject to local requirements, this information may be used to provide legal and related services offered by our other legal entities and for all the purposes outlined in this Privacy Policy. Sparkwise remains responsible for the management of the jointly-used Personal Information. If you are a Californian user of the Site, and would like more information regarding our provision of your Personal Information to affiliates of Sparkwise, please refer to the “Special Notification for Our California Users” section below.
• to our third party service providers who provide services such as website hosting, data analysis, infrastructure provision, IT services, customer service, email delivery services, auditing services and other similar services.
• to identify you to anyone to whom you send messages through the Site.
• to a third party (whether affiliated or unaffiliated with us) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
• as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

OTHER INFORMATION

Other Information We Collect

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

• Browser information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you
• Aggregated information

How We Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

• Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version and Internet browser type and version. We use this information to ensure that our Site functions properly.
• Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while visiting the Site, as well as for online tracking purposes. We can recognize your computer to assist your use of the Site. We also gather statistical information about the usage of the Site in order to continually improve the design and functionality, understand how customers use the Site and to assist us with resolving questions regarding the Site.
• If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular web site. If cookies are disabled, however, not all features of the Site may operate as intended. Information about the procedure you are required to follow in order to disable cookies can be found on your Internet browser provider's web site.
• Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Site pages and HTML-formatted email messages to, among other things, track the actions of Site users and email recipients, measure the success of our marketing campaigns and compile statistics about Site usage and response rates.
• IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
• From you: Information such as your location, as well as other information, such as your preferred means of communication, is collected when you voluntarily provide this information. Unless combined with Personal Information, this information does not personally identify you or any other user of the Site.
• By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Site, (for example, we may aggregated Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “How We Collect Other Information” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your geographical location). If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

THIRD PARTY SITES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which this Site contains a link. The inclusion of a link on the Site does not imply endorsement of the linked site by us or by our affiliates.

SECURITY

We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

Your choices regarding our use of your Personal Information for marketing purposes:

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the unsubscribe instructions in any such message or by contacting us by email at privacy@sparkwi.se. We aim to comply with your request(s) as soon as reasonably practicable. Please note that if you do opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

How you can access or change your Personal Information

You may request to review, correct, update, or otherwise modify any Personal Information that you have previously provided through the Site, or object to the use of such PII by us. You may exercise these rights by logging on to your subscriptions account here or by contacting us at privacy@sparkwi.se. Additionally, you may also oppose the processing or transferring of Personal Information to the extent the laws of your country require if you have a legitimate reason to do so.

In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we will only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We aim to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed therefrom. We may, from time to time, re-contact former users of the Site. Finally, we are not responsible for removing information from the databases of third parties (such as service providers) with whom we have shared your Personal Information.

SPECIAL NOTIFICATION FOR INDIVIDUAL CALIFORNIA USERS

As noted above, we may disclose Personal Information to affiliates of Sparkwise which may use this information for all purposes outlined in this Privacy Policy. Because separate legal entities are considered "third parties" for purposes of California Civil Code Section 1798.83, and certain communications from our affiliates might be viewed as promoting their legal services, we are providing the following information for California residents who have provided us with their Personal Information during the creation of or during the course of an established legal services relationship that is primarily for personal, family, or household purposes ("Individual California Users").

Individual California Users may request information about our disclosures of certain categories of Personal Information to third parties (i.e., our affiliates) for such third parties' direct marketing purposes. Such requests must be submitted to us either by email at: privacy@sparkwi.se or by fax at +1 510 644 2334:

Within thirty (30) days of receiving such a request, we will provide a list of the categories of Personal Information disclosed to third parties (i.e., our affiliates) for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or mailing addresses specified in this section.

RETENTION PERIOD

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.

USE OF SITE BY MINORS

The Site is not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide Personal Information through the Site.

CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using our Site you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than in your country.

SENSITIVE INFORMATION

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, credit card or other payment card information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Site or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

We may change this Privacy Policy. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Site. Your use of the Site following these changes means that you accept the revised Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us by email at privacy@sparkwi.se.

Please note that email communications are not always secure; so please do not include credit card information or sensitive information in your emails to us.

AFFILIATES

For purposes of this Privacy Policy, the following entities are considered to be “affiliates” of Sparkwi.se:

• Tomorrow Partners LLC