THE SPARK LAB LTD., (the “Company”, “we” or “Spark”) respects the privacy of its website users (“User(s)” or “you”) and is committed to protect its Users’ personal information. We believe that you have a right to know our practices regarding the information we may collect and use about you when you use our website at https://www.thesparkins.com including its sub-domains (collectively, the “Site”), or otherwise when you provide us with your personal data, including via our social media pages, as a customer, business partner, supplier, prospect, candidate for employment or otherwise. Please read the following carefully to understand Spark’s views and practices regarding your personal information and how Spark will treat it.

1. Your consent (important, please read carefully!)

This Privacy Policy (“Privacy Policy”) details how your Personal Information is used and processed by Spark.

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE, OR OTHERWISE PROVIDING US WITH YOUR PERSONAL INFORMATION, YOU ACKNOWLEDGE THAT YOU ARE OR HAVE HAD THE OPPORTUNITY TO BECOME AWARE OF AND AGREE (IN JURISDICTIONS WHERE SUCH CONSENT IS REQUIRED) TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY AND SPARK’S PRACTICES DESCRIBED HEREIN,

INCLUDING    TO    THE    COLLECTION    AND    PROCESSING    OF    YOUR     PERSONAL

INFORMATION AS SPECIFIED HEREIN. 

PLEASE NOTE: IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MAY NOT ENTER TO, CONNECT TO, ACCESS OR USE THE SITE IN ANY MANNER, OR OTHERWISE PROVIDE US WITH YOUR PERSONAL INFORMATION. FOR THE AVOIDANCE OF DOUBT, IF YOU ARE LOCATED IN A JURISDICTION WHERE THE COLLECTION AND PROCESSING OF PERSONAL INFORMATION IS DEPENDENT ON YOUR CONSENT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT LEGALLY OBLIGED TO PROVIDE YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO US. FAILURE TO PROVIDE INFORMATION MARKED AS MANDATORY FIELDS WILL PREVENT YOU FROM USING SERVICES THAT REQUIRE REGISTRATION, IN ANY. REFUSAL TO CONSENT TO RECEIVE MARKETING COMMUNICATIONS WILL NOT PREVENT YOU FROM USING THE WEBSITE OR THE BASIC SERVICES OFFERED THEREIN. REFUSAL TO CONSENT TO THE USE OF COOKIES MAY AFFECT YOUR USER EXPERIENCE ON THE WEBSITE AND THE PERSONALIZATION OF THE CONTENT DISPLAYED TO YOU. 

2. Who we are

In this policy, references to Spark, or to “we”, “our” or “us” are to: 

THE SPARK LAB LTD.,

Address 31 Brandeis st. Tel Aviv, Israel.

Email - [email protected]

3. Which information may we collect about Users?

We may collect from you two types of data and information:

• Non-personal Information. The first type is non-identifiable and anonymous information. Nonpersonal Information, which is being gathered, consists of technical information and behavioral information that does not pertain to a specific individual (“Non-Personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information.

You may access and browse the Site without disclosing personal information, although, like most websites, we passively collect certain Non-Personal Information from your devices, including: (i) technical information such as the type and version of your device and its operating system, the type of browser, screen resolution, keyboard language, Wi-Fi connectivity, etc.; and (ii) behavioral information which may include the User’s click-stream on the Site, time spent on various screens of the Site and additional information of a similar nature (collectively, “Technical and Behavioral Information”). We may also use third-party service providers, such as Google Analytics, to obtain detailed analytics on the device and the User’s behavior on the Site. Please note that we or our thirdparty service providers will collect such Technical and Behavioral Information by using certain tracking technologies, such as cookies, as further detailed below.

• Personal Information. The other type of information we collect is individually identifiable information. To put it simply, this information identifies an individual or is of a private and/or sensitive nature, such as your contact information (“Personal Information”), including:
  • Personal Information which is provided voluntarily:
    • Communications with Spark: Personal Information you provide us as part of any communications with us, by any means, including by contacting us via email, or through our social network pages (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences). Please note that we may record calls for quality assurance purposes and in order to improve our services.
    • Contact Us: when using our Contact Us form available via the Site, we may collect certain information, i.e., your full name and email address. You may also provide to us free text which includes personal information.
    • Newsletter: you may voluntarily join our mailing list by providing us with your email address via our Site or by other means.
    • Business contact: When you interact with us as a business contact, supplier, client representative, or any individual representing an organization, we collect personal information including your name, contact details, professional information (position, employer, credentials), communication preferences, interaction history, and other relevant information. We may also collect information through dedicated forms, such as customer satisfaction surveys and product feedback (to the extent it includes your Personal Information). We process this information to establish and manage our business relationship, provide services, communicate effectively, maintain accurate records, comply with legal requirements, process transactions, improve our services, support marketing and promotional activities, and send relevant business communications. For example, if you represent one of our clients, we collect your information to facilitate engagement with your employer and for the other purposes outlined in this Privacy Policy.
  • Personal Information collected via technology:
    • IP address: Users of the Site may automatically provide their IP address (or MAC Address, as applicable) mainly for enhancing the User’s experience and for geo-location, targeted advertising and security purposes as further detailed below.
    • Geolocation data: during your use of the Site, we will access, collect, process, monitor and/or remotely store “geolocation data”, including through the collection of Internet Protocol (IP) addresses, GPS signals and other similar information to determine your location for providing our services, advertising and for analytics and security purposes.
    • Identifiers: during your use of the Site, we will access, collect, process, monitor and/or remotely store online identifiers, such as Internet Protocol (IP) address, AD-ID or other unique identifiers, for the purpose of providing you with targeted advertising and for security, statistical and metric purposes.
    • Technical and Behavioral Information: to the extent that the Technical and Behavioral Information will be linked to or associated with a specific individual then such information will be considered as Personal Information.
  • Please note:
    • We may cross-reference your Personal Information with other Personal Information we may have about you. Any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
    • We use third-party tracking services and usage logs, to track and analyze data from Users of the Site and for purposes of security and fraud prevention. We may also use cookies and similar technologies to gather information regarding your use of the Site and the information for which you searched and accessed (for more information please see below).

4.	How do we collect information about our Users?

There are two main methods we use to collect information: 

• We collect information through your entry, connection, access and/or use of the Site. In other words, when you access or use the Site, we are aware of your usage of the Site, and may gather, collect and record the information relating to such usage. For example, when you use the Site, we gather your Technical and Behavioral Information.
• We collect information which you provide us voluntarily. For example, we collect Personal Information that you provide through email correspondence.

5.	What are the purposes of the collection and processing of information?

5.1. Non-personal Information is processed in order to:   

• Enhance the User’s experience on the Site;
• Create statistical information and learn about the preferences of Users and general trends on the Site (e.g. understand which features are more popular than others); and Keep the Site safe and secured and for prevention of fraud.

5.2. Personal Information is processed in order to: 

• Enable the operation and constant improvement of the Site;
• Register your interest in becoming a new customer;
• Contact you and process you application for employment by the Company;
• Maintain our business engagements with clients, suppliers and other business partners including to establish and manage our business relationship, provide services, communicate effectively, process transactions, and send relevant business communications;
• Add your contact details to our mailing list for the purposes of sending you information about our products and services by email, SMS, phone, through web-browser notification or through the post. You have the right to opt-out of marketing messages at any time by following the instructions in such messages or by contacting us at: [email protected].
• Contact you by phone and/or by email with further information relating to our products and/or services;
• Ensure that content on the Site is presented in an optimal way for you and for your device (e.g., tablet, mobile phone).
• Create and manage targeted advertising campaigns that promote our products and services, including sharing limited personal information with advertising platforms (such as Google, Facebook, and others) for the purpose of generating high-quality, relevant, and focused advertising campaigns.
• Convert your personal information into anonymous or aggregated data for research, statistical, and analytical purposes, so that you cannot be identified directly or indirectly.
• Display ads and send you offers. This may include “targeted ads” on third party platforms (e.g., on Facebook, or LinkedIn) and across devices, based upon your interactions with our Site. Depending on applicable law and the jurisdiction from which you access the Site, we may require your consent to perform such activities.
• Send you by email, SMS, through web-browser notification or through the post updates, notices, announcements, and additional information related to Spark including with respect to changes made to our Site’s Terms of Use and Privacy Policy;
• Conduct internal operations, such as: troubleshooting, data analysis, testing, research, and statistical analysis;
• Comply with our legal obligations and provide us with the ability to protect our rights and legitimate interests; and
• Maintain our data processing records and general administrative purposes.

6.	Sharing Personal Information with Third Parties

• Spark respects your privacy and will not disclose, share, rent, or sell your Personal Information to any third party, other than as permitted under this Privacy Policy.
• In addition to using the information collected by us for the purposes described under Section 5 above, we may also share your information in the following cases:
  • Spark Personnel: Personal Information that we collect and process may be transferred to or accessed by personnel of Spark for the purposes detailed in Section 5 above.
  • Service Providers: we share Personal Information with vendors, commercial software providers, consultants and data processors who perform services on our behalf, including without limitation, companies that provide analysis, messaging services and services which host the Site. Please note that we collect, hold and manage your Personal Information through a third party’s cloud based services, as reasonable for business purposes, which may be located in countries outside of your jurisdiction.
  • In addition, we may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce this Privacy Policy or any other agreement or terms of service between you and Spark, and to defend against any claims or demands asserted against us by you or on your behalf; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to protect the rights, property, or personal safety of Spark, its Users (including candidates and contact persons) or the general public; and (e) when Spark is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Spark (while such acquired company or investor may be located in countries outside of your jurisdiction).

6.3. For avoidance of doubt, Spark may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical and research purposes and for customization, developing and improvement of our Site.

7.	Your Rights

Spark hereby informs you and acknowledges that you may have the right under applicable law to access, change and delete the Personal Information we collect and process about you. If you wish to access or to correct, amend, or delete Personal Information, please send us an email to: [email protected]. and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law. Please note: any request to access, modify, or delete Personal Information must include the following details: full name, phone number, address, email address, and a clear specification of the Personal Information you wish to access, amend, or delete. If you wish to authorize another person to act on your behalf, please include an explicit power of attorney granting such authority.  

8.	Location of Your Data

Personal Information may be transferred to, and stored in, servers which may be located in countries outside of your jurisdiction and in countries that are not considered to offer an adequate level of protection under your local laws. It may also be processed by Spark and its suppliers, service providers or partners’ staff operating outside your country.  

Spark is committed to protecting your Personal Information and will take appropriate steps to ensure that your Personal Information is processed and stored securely and in accordance with applicable privacy laws, as detailed in this Privacy Policy. Such steps may include, but not limited to, putting in place data transfer agreements and ensuring our third-party service providers comply with Spark’s data transfer protection measures.  

BY SUBMITTING YOUR PERSONAL INFORMATION TO SPARK, YOU ACKNOWLEDGE, AND AGREE, IN JURISDICTION WHERE SUCH CONSENT IS REQUIRED, TO SUCH TRANSFER, STORING AND/OR PROCESSING OF PERSONAL INFORMATION.

9.

Minors

The Site is intended for Users over the age of eighteen (18). Therefore, Spark does not intend and does not knowingly directly collect any Personal Information from children under the age of eighteen (18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Site. In the event that we become aware that a minor under the age of eighteen (18) is using the Site, we will take steps to block such user and will make effort to promptly delete any Personal Information collected about them.

10. Direct Marketing

You hereby agree that, to the extent you have indicated your consent on the Site, we may use your contact details you provided us with (including, without limitation, e-mail address) for the purpose of sending you marketing and/or promotional messages, including advertisements, in accordance with the Israeli Communications Law (Telecommunications and Broadcasting), 1982. Such messages may be sent by e-mail, messaging applications (including WhatsApp), SMS, automatic dialing systems, or any other means of communication, using the contact information you voluntarily provided.

You may withdraw your consent at any time by sending a written notice to Spark’s e-mail: [email protected]. or alternatively following the instructions for removing yourself from the mailing list which are available in the message transmitted to you. You may also disable push notifications from us by adjusting your browser settings or the notification settings of the operating system on the device you are using to access the Site.

11.	Third Party Service Providers

While using the Site we may be using third party service providers, who may collect, store and/or process the Personal Information detailed herein. Such third parties may be located in a country that does not have the same data protection laws as your jurisdiction. Spark uses commercially reasonable efforts to engage with third parties that post a privacy policy governing their collection, processing and use of non-personal and personal information. Such third parties’ software or services include the following categories of service providers:  

• Analytics services, such as Google Analytics.
• Hosting and cloud service, such as Google Cloud and Wix (Wix.com Ltd.);
• Advertising partners, such as Google, Google Tag Manager, Facebook Meta Ads and LinkedIn Ads.
• Communications providers, such as MailChimp (Rocket Science Group LLC).

Please read such third party service providers’ terms of use and privacy policies to understand their privacy practices.

12. Cookies & Local Storage We recommend adding a banner to the Site notifying users that the Site uses cookies and similar tracking technologies, and allowing users to manage their cookie preferences at any time.

When you access or use the Site, we and/or our third-party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies), which store certain local information on your device (“Local Storage“) which may enable us, inter alia, to recognize your device from those of other Users of the Site, to improve the Site’s performance, to deliver a better and more personalized service according to the User’s individual interests and the device or browser used, to track Users’ use of the Site, to gather information about the Users’ approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern, for the purpose of providing you with targeted advertising (including displaying Spark advertisements on third party platforms) and to perform other analytics and to develop our Site.  

Information collected via Local Storage is locally stored in the User’s device. Spark and/or our authorized third party service providers may implement such Local Storage (including cookies and pixels) and access such information. Spark and/or our authorized third-party service providers may use both session cookies (which expire once you close the web-browser) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Local Storage used by the Site may store nonpersonal information (such as the different pages viewed by a User within the Site) as well as User persistent identifier, which will be collected in accordance with the terms specified herein. 

Most devices and browsers will allow you to erase cookies from your device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, your experience of the Site may be limited. Please note that unless you block the acceptance of cookies, the Site will utilize cookies upon your use of the Site. If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the Site from placing further cookies on your device unless and until you adjust your settings as described above.  For detailed instructions regarding the blocking of cookies, please refer to your browser ‘help’, ‘tool’ or ‘edit’ section or see http://www.allaboutcookies.org/manage–cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers:

• Chrome
• Internet Explorer and Microsoft Edge
• Mozilla Firefox
• Safari

It is possible to opt-out of having your browsing activity within the Site recorded by performance cookies. Please note that we use Google Analytics as our service provider in order to track Users’ activities on the Site, including by use such services’ persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout. For further information regarding Google Analytics please see here – www.google.com/policies/privacy/partners/. You can opt out of receiving interestbased advertising on your device by visiting the following sites: www.aboutads.info/choices/, www.networkadvertising.org/choices/, and preferences–mgr.truste.com/. If you wish to opt out of receiving interest-based advertising on your mobile device, please see the advertising preferences information on support.apple.com for iOS devices or support.google.com for Android devices.

13.	Links to Third Party Websites

We may provide certain links in the Site which permit Users to leave our Site and enter non-Spark sites or services. Most of such linked sites and services provide legal documents, including terms of use and Privacy Policy governing the use thereof. It is always advisable to read such documents carefully before using those sites and services, inter alia, in order to know what kind of information about you is being collected.

14.

Security

14.1. We take appropriate measures to maintain the security and integrity of our Site and databases and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures.

14.2. Your Personal Information is hosted on third party servers, which provide advanced strict security standards (both physical and logical). 

14.3. Some of the security measures that we employ include, without limitation: the application of highly secure design and implementation methods to our Site, including state of the art encryption mechanisms and secure architecture design to all storage and transmission mechanisms used for the processing and transmission of your Personal Information, as well as access control and auditing systems (including firewall and identity management solutions), that restrict access to your Personal Information to authorized personnel only, based on their roles and their need-toknow requirements, needed to process your Personal Information on Spark’s behalf.

14.4. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use will never occur.

14.5. Spark will comply with applicable law in the event of any breach of the security, confidentiality, or integrity of your Personal Information and will inform you of such breach as required by applicable law.

14.6. TO THE EXTENT THAT SPARK IMPLEMENTED THE REQUIRED SECURITY MEASURES UNDER APPLICABLE LAW, SPARK SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR FAILURE TO STORE OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE PERSONAL INFORMATION.    

15.	Data Retention

Spark will retain Personal Information only for as long as it is relevant and necessary for the purposes for which it was originally collected, or as permitted by applicable law. Anonymous or aggregated data derived from your use of the Site may be retained on our servers indefinitely, and we may use such data without limitation. 

16.	Changes to the Privacy Policy

Spark reserves the right to change this Privacy Policy at any time, so please re-visit this page frequently to check for any changes. In case of any material change, we will make reasonable efforts to post a clear notice on the Site or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such material changes will take effect seven (7) days after such notice was provided on our Site or sent to you via e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” and your continued use of the Site on or after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice.

17.	Have any Questions?

If you have any questions (or comments) concerning this Privacy Policy, please send us an email to the following address: [email protected]., and we will make an effort to reply within a reasonable timeframe.