Privacy Policy
Last modified: October 11, 2022
Introduction
SparkLearn provides variable levels of eLearning services from its most basic, efficient and effective modules to highly customized curriculums. SparkLearn is an Illinois Limited Liability Company located in the United States of America at 620 West Jackson Street in Morton, Illinois, 61550. SparkLearn complies with Data Protection Laws, including the European regulation for data protection (General Data Protection Regulation - GDPR). SparkLearn does not knowingly do anything or permit anything to be done which might lead to a breach of the Data Protection Laws.
SparkLearn is a cloud subscription-based eLearning service. By accessing SparkLearn through a set of subscription packages, “Customers” can train their personnel (i.e., “users” or “Learners”) or any other group of people they wish or provide distance eLearning services to through online services. Customers access SparkLearn services by means of a unique combination of user identifiers and secure passwords. By gaining access to the service through this combination, the Customers are allocated a specific domain that is owned and managed exclusively by them. The Customer specifies, customizes, and provides access to the service to the authorized users of their respective domains, consisting of course Instructors and Learners. The Customer may additionally specify custom user roles for their domain. The course instructors specify and manage the content of the courses, which may include text documents, video and audio files, images, and presentations. Each instructor can extract reports for the activity of their Learners. The Customer owns their domain data and can extract reports for the total activity of their domain, including all its users.
Privacy Policy
SparkLearn respects its user’s privacy and is committed to protecting it through compliance with this policy. This Privacy Policy describes SparkLearn’s policies and procedures regarding the collection, use, and disclosure of personal information we receive from registered users or website visitors to sparklearn.com. This Privacy Policy applies only to information provided to SparkLearn through this Site and explains: (i) what SparkLearn does with that information, (ii) how SparkLearn shares that information, and (iii) how SparkLearn handles the content you provide to its website. This Policy also explains a Customer or user’s rights and the choices available regarding SparkLearn’s use of personal information and how Customers or users can access, update, and/or remove this information.
SparkLearn’s Privacy Policy will be updated from time to time. You will be notified of any material changes solely by SparkLearn posting new Privacy Policies on this Site located on its Privacy Policy page. Changes will be readily apparent based on the existence of the “Last Modified” date at the top of this policy. Users should review SparkLearn’s Privacy Policy whenever using this “Site” to stay informed about how users can help protect their privacy. If a user disagrees with any changes to SparkLearn’s Privacy Policy, the user should immediately stop using this “Site” and deactivate their account(s), as more fully explained below.
This Privacy Policy applies to information that SparkLearn obtains through a user’s access to this "Site" via any computer, desktop, laptop, mobile phone, tablet, or other consumer electronic device. The term “Site” includes SparkLearn’s website, its domain sparklearn.com, and its SaaS service but does not include any other third-party products or services for which a separate privacy policy may be applicable, particularly third-party products or services that are used in conjunction with SparkLearn products or services. Users are encouraged to always review the policies of third-party products and services to make sure you are comfortable in how they collect and use your information.
By accessing and using this Site, you confirm that you have read and fully understood this Privacy Policy, that you agree to the collection and the usage of your own and others’ personal information in accordance with the Privacy Policy, and that you have the authority to provide us with all information submitted by you via the Site, including but not limited to personal information of third parties. Any user who registers with and/or uses SparkLearn’s Services must accept the Terms of Service and agree to the collection, transfer, processing, storage, disclosure, and other uses described in this Privacy Policy.
This Policy does not apply to information collected by (a) SparkLearn offline or through any other means, including on any other website operated by SparkLearn or its affiliates or (b) any third parties through any application or content, including advertising, that may link to or be accessible from or through SparkLearn’s website. Finally, this website and SparkLearn’s products and services are not intended for children under the age of 16 years of age. If you are under the age of 16, do not use or provide any information to SparkLearn, this website, or through any interactive function associated with this Site or domain, and do not purchase any products or services through this Site.
Collection: Identifiable Personal Information Collected
Personal identifying refers to information about a user that can be used to contact or identify the user, and/or that might provide information about the use of and activities that have taken place at SparkLearn’s site that may be directly associated to the user ("Personal Information"). It is understood and accepted that users and visitors may provide SparkLearn with personal identifying information. Personal information that SparkLearn collects may include, but is not limited to, your name and email address. When a user visits the Site, SparkLearn’s servers automatically record information that a user’s browser sends whenever it visits a website. This information may include, but is not limited to, the user’s Internet Protocol address, browser type, the web page the user was visiting before coming to SparkLearn’s site, and information the user searches for on our Site. Like many websites, SparkLearn may use "cookies" to collect information. A cookie is a small data file stored by your browser on your Device's hard disk for record-keeping purposes. SparkLearn uses "session ID cookies" to support login and main service functionality. SparkLearn may also use cookies of third-party providers.
SparkLearn does not collect or store data from third-party cookies. Moreover, users can modify their browsers to stop accepting cookies, or in the alternative, to prompt the user before accepting a cookie from a website. Please note, however, a user may not be able to use all portions of the Site or enjoy all functions of SparkLearn’s services if it restricts cookie use.
In some cases another user (such as a Customer administrator) may create an account on another user’s behalf and may provide information, including personal information (most commonly when a company requests that a user have access to our service). Under these circumstances, SparkLearn will in turn collect information under the direction of our Customers and often have no direct relationship with the individuals whose personal information is being processed. If the user is an employee of one of our Customers and would no longer like SparkLearn to process your personal information, please contact your employer and SparkLearn.
In addition to the data SparkLearn collects about all users, it also collects required data pursuant to Customer contracts, such as a user’s company affiliation, invoice data, and service usage data demonstrating the service is being used in accordance to our Customer’s subscription terms. SparkLearn also collects service usage data in aggregate form (i.e., demographics) to improve our service. SparkLearn may also acquire additional data through Customer’s support requests to the extent required to resolve a technical issue or respond to a request or complaint. When a user registers to the service, SparkLearn also collects information about the Customer’s industry and each individual user’s position in the company to adjust the service to the needs of our Customers and make our service more functional. We also collect certain information about Customer’s use of service (this applies only to account owners and not learners or instructors) to email newsletters, announcements, or marketing material. If you are a Customer and no longer wish for users to receive such emails, a Customer can remove itself by selecting the "unsubscribe" link provided within the email footer, where applicable.
Third-party Services
It is understood that users may access third-party services through SparkLearn. These services may include access to content on YouTube, Twitter, Facebook, and/or social media by linking a Customer’s account with SparkLearn to an account on the third-party service, or by “liking” or “sharing” content created subject to the third party’s Terms of Use. SparkLearn may also contain links to third-party websites. Linked websites and third-party services, however, are not under SparkLearn’s control and, therefore, SparkLearn is not responsible for their content.
A Customer or user’s use of a third-party service may also enable access to videoconferencing or other functions. If using a third-party website or service that includes separate content or functionality, SparkLearn disclaims any responsibilities for Personal Information collected or retained by those third parties. All Customers, users, or visitors must agree, therefore, that such third parties may process Personal Information provided to these third parties and that SparkLearn has no responsibility or ability to protect any Personal Information provided to these third parties and/or exported from SparkLearn’s systems.
Credit and/or Debit Cards
SparkLearn does not store credit card information in its systems. All credit card transactions are processed using secure encryption – the same level of encryption used by leading banks. Card information is transmitted, stored, and processed securely at gateways on a PCI-compliant network.
Chargebee will be the subscription billing software for the recurring billing, subscription management, and automatic invoicing. Chargebee integrates with Avalara to calculate the sales tax. The total cost will then be transmitted to Stripe for payment purposes. Pricing and packages are determined on a Customer’s needs and/or the number of users. The Terms of Service and Privacy Notice for Chargebee can be found at https://www.chargebee.com/company/terms/ and https://www.chargebee.com/privacy/.
Content
SparkLearn collects and stores content that is created, inputted, submitted, posted, uploaded, transmitted, stored, or displayed in the process of using its “Site.” Content may include Personal Information or other sensitive information that users or Customers choose to include ("incidentally-collected Personal Information"). Although SparkLearn owns the code, databases, and all rights to its services, Customers retain ownership, control, and all rights to their records and data which are their property.
How Personal Information is Used, Processed, and Retained
Personal Information is or may be used for the following purposes:
to improve our Site, services, features, and content,
to administer use of our Site,
to enable users to enjoy and easily navigate the Site,
to understand user’s needs and interests,
to fulfill requests made by users,
to personalize a user’s experience,
to provide or offer software updates and product announcements, and
to provide users with further information and offers from SparkLearn believed may be useful or interesting to its Customers and users, including newsletters, marketing materials, or promotional.
SparkLearn uses information obtained by technical means to monitor and analyze use of its Site and its services, for the Site's technical administration, to increase the Site's functionality and user-friendliness, to generate and derive useful data and information concerning the interests, characteristics and website use behavior of its Customers and users, and to verify that visitors to the Site meet the criteria required to access the Site.
SparkLearn collects and processes personal data in a transparent manner, to the extent necessary for specified, explicit and legitimate purposes, and does not process it further in a manner incompatible with those purposes. SparkLearn takes steps to ensure the data collected is accurate and, when necessary, updated. SparkLearn also takes reasonable steps to timely delete or rectify personal data, if inaccurate. SparkLearn takes steps to guarantee security, including the protection against unauthorized or unlawful processing and accidental loss, destruction, or degradation, by using appropriate technical or organizational measures.
Each domain’s data are retained for as long as the Customer's paid subscription to the service lasts. If the Customer elects not to renew a Subscription, that account is permanently deleted. SparkLearn will not provide notifications before deleting a Customer's account. Notwithstanding the above, SparkLearn will retain the data of Enterprise plan customers, however, for at least 60 days before deleting.
Information Sharing and Disclosure
SparkLearn will display personal information in a user’s profile page and elsewhere on its Site according to the preferences set in each Customer or user’s account. Any information a Customer or user chooses to provide should reflect how much personal information the Customer or user wants other SparkLearn users to know. SparkLearn encourages users to guard their anonymity and sensitive information and recommends that users carefully consider what information to disclose in their profile pages. Notwithstanding these admonishments, a user can review and revise their profile information at any time. Users should be cognizant that the Customer’s administrator or specially designated support personnel may be able to: (i) access information in and about an account: (ii) access communications history, including file attachments, from your account; (iii) disclose, restrict, or access information provided or that is made available when using your account, including your Content; and/or (iv) otherwise control how your account may be accessed or deleted. The amount of control a Customer’s administrator or specially designated support personnel may have over such information is a local decision.
SparkLearn does not sell personal information or content to third parties and will not share or disclose any personal information or content with third parties except as described in this policy. SparkLearn does not share personal information about individual users with third parties for their marketing purposes (including direct marketing purposes).
Please note, however, that for security, service operation and management purposes, SparkLearn uses third-party services that provide the same level of protection as SparkLearn. Third-party vendors and providers supply the necessary hardware, software, networking, and storage to run SparkLearn. These third parties have access to your Personal Information only for purposes of performing these tasks on SparkLearn’s behalf.
Legal Compliance
SparkLearn cooperates with government and law enforcement officials and private parties to enforce and comply with the law. SparkLearn will disclose any information about users to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of SparkLearn or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate, or legally actionable. To the extent required, SparkLearn will additionally comply with any requirement of the Digital Millennium Copyright Act, any intellectual properties statutes, and state privacy laws, including, but not limited to California, Colorado, Connecticut, Virginia, and Utah privacy statutes.
Furthermore, to the extent required, SparkLearn may share or transfer a Customer or individual user’s personal information during any merger, sale of company assets, financing, or acquisition of all or a portion of SparkLearn’s business to another company. Customers and individual users will be notified of any change in ownership or uses of personal information and the options each Customer or individual user has relating to their personal information.
SparkLearn employs reasonable measures designed to protect your information from unauthorized access as required by law. Although SparkLearn owns the source code, databases, and all rights to its services, Customers and the individual users retain ownership, control and all rights to their private information or records and data which are their property.
Customer and User Rights
When SparkLearn processes personal data on behalf of and as instructed by its Customers, the Customers are responsible towards the data subjects and, individual users should contact the respective Customer administrator to which the content of each user service belongs for exercising an individual user’s respective rights. SparkLearn does not respond directly to individual user’s requests to exercise rights but instead informs the Customer without delay and provides all reasonable assistance to satisfy the individual user’s requests in accordance with instructions of the Customer.
SparkLearn has the necessary features to enable our Customers to protect the rights of the data subjects on their behalf, such as secure password policies and the rights to have all personal information deleted. Customers and individual users have the right to receive confirmation on whether a user’s personal data are processed and the way it was processed. Customers and users also have the right to require correction of inaccurate data relating to individual users and to fill in incomplete data if necessary for processing.
Customers or users additionally have the right to ask for the erasure of personal data. SparkLearn will erase the data where one of the following grounds applies: a) the personal data is no longer necessary in relation to the purposes of processing; or b) the person requesting the erasure withdraws consent on which the processing is based and there is no other legal ground for the processing; or c) the data subject objects to the processing and there are no overriding legitimate grounds for the processing or the data subject objects to processing for direct marketing; or d) the personal data have to be erased for compliance with a legal obligation. SparkLearn will not erase personal data, however, if the data must be maintained for compliance with a legal obligation or in cases where the processing is required for the establishment, exercise or the defense of legal claims. If a Customer or user is receiving marketing emails, either can remove themselves from the recipient's list by selecting the "unsubscribe" link within the email.
Customers or users further have the right to request restriction of processing if the accuracy of personal data is disputed until such time that the personal information can be verified for accuracy or based on any other legitimate reason specified in applicable Data Protection Laws. Customers or users also have the right to receive personal data in a structured, commonly used, and machine-readable format and to request the direct transmission of personal data by SparkLearn to another, assuming it is technically feasible. Customers and users may additionally oppose the processing of personal data which takes place without consent by contacting SparkLearn at any time.
Furthermore, if an individual user is a California resident, that user has the right to direct a business that sells (or may in the future sell) Personal Information to stop selling an individual user’s personal information and to refrain from doing so in the future. California users additionally have the right to be free from discrimination if the user exercises any of the rights provided in the CCPA, or any applicable privacy law provision. In particular, SparkLearn will not deny goods or services; charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services; or suggest that anybody (including California residents) will receive a different price or rate for goods or services or a different level or quality of goods or services.
Contacting Information
If there are any questions about this Privacy Policy and/or a Customer or individual user seek to exercises any rights under this policy, please contact SparkLearn at the information identified below:
SparkLearn LLC
Attention: Website Coordinator
620 West Jackson Street
Morton, Illinois 61550
info@sparklearn.com
Phone: (309) 263-9228
