HomeGreyArrowPrivacy Policy
SparkHabits LLC
Privacy Policy
Last updated on October 9, 2024
Information We Collect
Information we collect falls into one of two categories: “voluntarily provided” information and “automatically collected” information. “Voluntarily provided” information refers to any information you knowingly and actively provide us when using our app and its associated services. “Automatically collected” information refers to any information automatically sent by your device in the course of accessing our app and its associated services.
Collection of Health Data
Our app is designed to help you build and maintain healthy habits by connecting to Apple Health and Google Health. By integrating with these services, we collect the following specific data types: - ActiveCaloriesBurnedRecord: We gather information about the calories you burn during physical activities to help you track and improve your fitness levels. - DistanceRecord: We access data regarding the distance you cover while walking, running, or engaging in other activities to assist you in setting and achieving your distance-based goals. - StepsRecord: We collect information on the number of steps you take to provide insights into your daily physical activity and encourage movement.
Purpose and Use of Collected Data
The data we collect is used exclusively to enhance your experience with our app by: - Providing personalized insights and recommendations based on your activity levels. - Helping you monitor your progress towards health and fitness goals. - Enabling features that require this data to function properly within the app.
Data Sharing within Programs
When you participate in a group program, you have the option to share your health data with your coach and other program members. This sharing is designed to foster a supportive community environment and enable your coach to provide more personalized guidance. You can control what information you share and can adjust your privacy settings within the app at any time.
Health Connect Data
Collection and Usage of Health Data: We value the privacy and security of our users. Our mobile application requests access to health-related permissions, specifically the ability to read steps, distance travelled, blood glucose, blood pressure, body temperature, floors climbed, heart rate, hydration, nutrition, sleep sessions, respiratory rate, resting heart rate, total calories burned, Vo2 Max, weight, and height information. This data is collected for the sole purpose of enhancing the user experience and providing features related to health and fitness.
Health Connect Data
Collection and Usage of Health Data: We value the privacy and security of our users. Our mobile application requests access to health-related permissions, specifically the ability to read steps, distance travelled, blood glucose, blood pressure, body temperature, floors climbed, heart rate, hydration, nutrition, sleep sessions, respiratory rate, resting heart rate, total calories burned, Vo2 Max, weight, and height information. This data is collected for the sole purpose of enhancing the user experience and providing features related to health and fitness.
Purpose of Health Data Access: Our app utilizes health-related permissions to track daily steps, distance traveled, blood glucose, blood pressure, body temperature, floors climbed, heart rate, hydration, nutrition, sleep sessions, respiratory rate, resting heart rate, total calories burned, Vo2 Max, weight, and height. This data is processed locally on the user's device and is not shared with any third parties.
User Consent: By using our app, you explicitly consent to the collection and usage of health-related data for the purposes outlined in this privacy policy. You have the option to grant or deny these permissions within the app settings.
Security Measures: We implement robust security measures to protect the confidentiality and integrity of health-related data. This includes encryption and secure storage.
Data Retention: We retain health-related data only for as long as necessary to fulfill the purposes outlined in this privacy policy. Users can request the deletion of their data by
Third-Party Services: Our app does not share health-related data with any third-party services, advertisers, or external entities. We do not engage in the sale or exchange of user data.
Protection of Your Information
We implement a variety of security measures to maintain the safety of your personal information. These measures include: Encryption: We use state-of-the-art encryption protocols, such as AES-256 (Advanced Encryption Standard), to protect sensitive data transmitted online. Additionally, we employ robust encryption methods for data at rest to ensure that your information is secure from unauthorized access. Our encryption techniques are razor-sharp, adhering to the highest industry standards to prevent data breaches and unauthorized access. Access Controls: We restrict access to personal information to employees, contractors, and agents who need that information in order to process it. All individuals who have access to personal information are subject to strict confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations. Regular Security Audits: We conduct regular audits of our security systems and practices to ensure they meet industry standards and are effective in protecting your information. Data Minimization: We only collect and retain personal information that is necessary for the purposes for which it is collected.
Sharing of Your Information
We do not sell, trade, or otherwise transfer your personal information to outside parties without your consent, except in the following circumstances: To our trusted service providers who assist us in operating our services, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. When we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety. Your Rights Depending on your location, you may have the following rights regarding your personal information: The right to access – You have the right to request copies of your personal data. The right to rectification – You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete. The right to erasure – You have the right to request that we erase your personal data, under certain conditions. The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions. The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions. The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
Data Access and Permissions
To access this data, our app will request your permission to connect with Apple Health and Google Health. You control what data we access, and you can revoke this permission at any time through the settings in Apple Health or Google Health. We respect your privacy and ensure that all data is accessed and processed in accordance with the highest standards of security and confidentiality.
Log Data
When you access our servers via our app, we may automatically log the standard data provided by your device. It may include your device's Internet Protocol (IP) address, your device type and version, your activity within the app, time and date, and other details about your usage. Additionally, when you encounter certain errors while using the app, we automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is. Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.
Device Data
Our app may access and collect data via your device's in-built tools, such as: Camera Calendar Contacts Phone/SMS Storage, photos and/or media Notifications Background data refresh Mobile data Device/app history When you install the app or use your device’s tools within the app, we request permission to access this information. The specific data we collect can depend on the individual settings of your device and the permissions you grant when you install and use the app.
User-Generated Content
We consider “user-generated content” to be materials (text, image and/or video content) voluntarily supplied to us by our users for the purpose of publication on our platform, website or re-publishing on our social media channels. All user-generated content is associated with the account or email address used to submit the materials. Please be aware that any content you submit for the purpose of publication will be public after posting (and subsequent review or vetting process). Once published, it may be accessible to third parties not covered under this privacy policy.
Legitimate Reasons for Processing Your Personal Information
We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.
Collection and Use of Information
We may collect personal information from you when you do any of the following on our website: Register for an account Enter any of our competitions, contests, sweepstakes, and surveys Sign up to receive updates from us via email or social media channels Use a mobile device or web browser to access our content Contact us via email, social media, or on any similar technologies When you mention us on social media We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes: to provide you with our app and platform's core features and services to enable you to customize or personalize your experience of our website to contact and communicate with you for analytics, market research, and business development, including to operate and improve our app, associated applications, and associated social media platforms for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you to enable you to access and use our app, associated platforms, and associated social media channels for internal record keeping and administrative purposes to run competitions, sweepstakes, and/or offer additional benefits to you to attribute any content (e.g. posts and comments) you submit that we publish on our website for technical assessment, including to operate and improve our app, associated applications, and associated social media platforms We may combine voluntarily provided and automatically collected personal information with general information or research data we receive from other trusted sources. For example, If you consent to us accessing your social media profiles, we may combine information sourced from those profiles with information received from you directly to provide you with an enhanced experience of our app and services.
Security of Your Personal Information
When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification. Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential.
How Long We Keep Your Personal Information
We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you. However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.
Children’s Privacy
We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.
Disclosure of Personal Information to Third Parties
We may disclose personal information to: a parent, subsidiary, or affiliate of our company third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators our employees, contractors, and/or related entities our existing or potential agents or business partners sponsors or promoters of any competition, sweepstakes, or promotion we run credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you third parties to collect and process data an entity that buys, or to which we transfer all or substantially all of our assets and business Third parties we currently use include: Google Analytics
Your Rights and Controlling Your Personal Information
Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our app or the products and/or services offered on or through it. Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us. Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. Access: You may request details of the personal information that we hold about you. Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date. Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example serving particular content to your device), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services. Notification of data breaches: We will comply with laws applicable to us in respect of any data breach. Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint. Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.
Use of Cookies
Our privacy policy covers the use of cookies between your device and our servers. A cookie is a small piece of data that an app may store on your device, typically containing a unique identifier that allows the app servers to recognise your device when you use the app; information about your account, session and/or device; additional data that serves the purpose of the cookie, and any self-maintenance information about the cookie itself. We use cookies to give your device access to core features of our app, to track app usage and performance on your device, to tailor your experience of our app based on your preferences, and to serve advertising to your device. Any communication of cookie data between your device and our servers occurs within a secure environment. Please refer to our Cookie Policy for more information.
Business Transfers
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.
Limits of Our Policy
Our app may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
Changes to This Policy
At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here and on our website. If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy. If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.
Additional Disclosures for California Compliance (US)
Under California Civil Code Section 1798.83, if you live in California and your business relationship with us is mainly for personal, family, or household purposes, you may ask us about the information we release to other organizations for their marketing purposes. To make such a request, please contact us using the details provided in this privacy policy with “Request for California privacy information” in the subject line. You may make this type of request once every calendar year. We will email you a list of categories of personal information we revealed to other organisations for their marketing purposes in the last calendar year, along with their names and addresses. Not all personal information shared in this way is covered by Section 1798.83 of the California Civil Code.
Do Not Track
Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “Do Not Track” signals. We adhere to the standards outlined in this privacy policy, ensuring we collect and process personal information lawfully, fairly, transparently, and with legitimate, legal reasons for doing so.
Cookies and Pixels
At all times, you may decline cookies from our site if your browser permits. Most browsers allow you to activate settings on your browser to refuse the setting of all or some cookies. Accordingly, your ability to limit cookies is based only on your browser’s capabilities. Please refer to the Cookies section of this privacy policy for more information.
CCPA-permitted financial incentives
In accordance with your right to non-discrimination, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels for the goods or services we provide. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information, and we will provide written terms that describe clearly the nature of such an offer. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
California Notice of Collection
In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act: Identifiers, such as name, email address, phone number account name, IP address, and an ID or number assigned to your account. Audio or visual data, such as photos or videos you share with us or post on the service. Inferences, such as information about your interests, preferences and favorites. For more information on information we collect, including the sources we receive information from, review the “Information We Collect” section. We collect and use these categories of personal information for the business purposes described in the “Collection and Use of Information” section, including to provide and manage our Service.
Right to Know and Delete
If you are a California resident, you have rights to delete your personal information we collected and know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us: The categories of personal information we have collected about you; The categories of sources from which the personal information was collected; The categories of personal information about you we disclosed for a business purpose or sold; The categories of third parties to whom the personal information was disclosed for a business purpose or sold; The business or commercial purpose for collecting or selling the personal information; and The specific pieces of personal information we have collected about you. To exercise any of these rights, please contact us using the details provided in this privacy policy.
Shine the Light
If you are a California resident, in addition to the rights discussed above, you have the right to request information from us regarding the manner in which we share certain personal information as defined by California’s “Shine the Light” with third parties and affiliates for their own direct marketing purposes. To receive this information, send us a request using the contact details provided in this privacy policy. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.
Contact Us
For any questions or concerns regarding your privacy, you may contact us using the following details:
Privacy & Support Team
[email protected]