Introduction

At Sprkl.me we value the trust you, users and customers, place in us when they give us access to their Personal Information. The Privacy Policy describes how we work to maintain that trust and protect that information.

Sprkl.me has created this Privacy Policy in order to describe its collection, use and disclosure of personal data you give to Sprkl.me when you access, register, subscribe or use Sprkl.me’s online and/or mobile services and websites, and software provided by Sprkl.me on or in connection with such services or websites (collectively, the “Site”). “Sprkl” or “we” means Sprkl.me a online plaatvorm by Good Label Compaany B.V. The Netheralnds

This Privacy Policy covers only data that we collect through the Site, and not any other data collection or processing, including, without limitation, the data collection practices of any affiliate or other third party, including any third-party operators of web pages to which the Site links, and any information that we collect offline or through any websites, products, or services that do not display a direct link to this Privacy Policy. Occasionally, we may refer to this Privacy Policy in notices and consent requests related to special purpose web pages, mobile applications, or other resources, for example, if we invite you to submit ideas to improve the Site; under such circumstances, this Privacy Policy applies to information collected by us through such special purpose resources, as modified in the particular notice or consent request (e.g., with respect to the types of data collected or our uses or disclosures of such information) Sprkl.me may amend this Privacy Policy at any time. Please review the “Last Updated” legend at the bottom of this page to determine when this Privacy Policy was last amended. Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. By using the Site or providing information to us following such changes, you will have accepted the amended Privacy Policy. If Sprkl.me is going to use Personal Information  (as defined below) collected through the Site in a manner materially different from that stated at the time of collection, then Sprkl.me will notify users via email and/or by posting a notice on Sprkl.me’s Site for 30 days prior to such use or by other means as required by law.

Information Collected

When you create an Sprkl.me member account, request information, subscribe for a service, participate in a survey, post a rating or review, post a question or answer, post a resume, upload content or otherwise actively send us data on our Site, we collect such data including, but not limited to, your user name, password, first and last name, email address, telephone number (including mobile phone number), street address, gender, occupation, interests, messages you send to users, and any other data included in a submitted profile or resume. In connection with chargeable services, we will also collect payment information (e.g., credit card number and related verification information). If you use any automated online communication tool within the website of Sprkl.me, Sprkl.me will record and store your communications with any other registered member (or member type) or with the support gents of Sprkl.me. Sprkl.me will forward your communications to the other member of your choosing of Sprkl.me. You consent to Sprkl.me to store the communications in accordance with this Privacy Policy. In each such instance above, you will know what data we collect through the Site, because you actively submit it.

In addition, as part of the standard operation of the Site, Sprkl.me may automatically collect and analyze information from your computer or mobile device, including, but not limited to, your browser type, operating system, IP address and the domain name from which you accessed the Site, and if you are accessing our Site with your mobile device, the type of mobile device. In addition, we may automatically record and analyze actions taken on the Site including, but not limited to, date and times of use, clicks, page views, the amount of time you spend on each page, and search queries. Sprkl.me reserves the right to match your IP address (or any other information) with other information about you in any way permitted by applicable law. Sprkl.me will store this information on its equipment or the equipment of third parties that Sprkl.me has a relationship with for that purpose. If you create an Sprkl.me membership account, information may be collected under your account email address.

If you access or use the Site on your mobile telephone or other mobile device, including tablets, we collect mobile device identifiers, including MAC Address, and IP Address. Sprkl.me may create and assign to your device an identifier that is similar to an account number. We may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, geolocation or email address.

Limitation of Use or Disclosure of Personal Data

When a member deletes an account, the member and other memberrs will no longer have access to any of the data which we provided under that account name, including but not limited to, search history, search preferences, saved communications, files, data alerts, and any other data associated with the account. If the member uses the same email address to set up a new account, the previous data will not become available to the member again. Sprkl.me reserves the right to keep any materials in a deleted account as necessary to preserve and protect its rights as allowed by law (for example, to preserve records of a dispute) or to comply with its obligations under local law (for example, to keep an email address). A deleted member account does not mean that all of the data is expunged from the Sprkl.me systems, although it will not be readily available under the member’s original account name. When the member presses the delete account button, Sprkl.me will begin to process that instruction within 24 hours and will have completed the operation within 40 days.

However Sprkl.me must preserve business records pertaining to that account to comply with its obligations under law.

Uses and Disclosures of Information

We may use any information collected pursuant to this Privacy Policy, including information that identifies you as a specific individual (“Personal Information”), for the purposes set forth in this Paragraph 4 and Paragraphs 5, 6, and 10 below. Sprkl.me uses such information to provide our services and features to you, including to provide business information to you, to measure and improve those services and features, and to provide you with customer support.

For example, Sprkl.me uses your previous search and browsing history  to determine relevant search results and provide you with recommended content. Sprkl.me may also provide information collected pursuant to this Privacy Policy, including Personal Information, to employers that may be interested in contacting you.

Sprkl.me may also share such information with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customized for you.

Sprkl.me may also use information collected pursuant to this Privacy Policy to prevent potentially illegal activities and activities that are detrimental to you or others. Sprkl.me may investigate and disclose information from or about you or your use of Sprkl.me if we have a good faith belief that such investigation or disclosure (a) is reasonably necessary to comply with legal process (including subpoenas, search warrants, court orders) and law enforcement instructions and orders; (b) is helpful to prevent, investigate, or identify possible wrongdoing in connection with the use of the Site; or (c) may protect our rights, reputation, property, safety, or that of the public; or (d) as necessary to meet  national security requirements. Sprkl.me is subject to the investigatory and enforcement powers of the Federal Trade Commission or other investigatory bodies of the Netherlands.

We may use a variety of methods to detect and address anomalous activity and screen content to prevent abuse such as spam. These efforts may on occasion result in a temporary or permanent suspension or termination of some functions for some members. We provide email proxy and relay services to the users of Sprkl.me services and products.  We monitor, review, store and analyze your content (including your purchses, communication with other members,messages, responses, and other materials) that you send, store or receive, including via automated means and otherwise, for data analysis, quality control, and to refine the Site or any other Sprkl.me product or service (including to provide better search results and other listings provide you with personally relevant product features, and to prevent fraud and reduce unwanted mail).

Any information shared by you with Sprkl.me may be shared with or transferred to any Sprkl.me affiliated entity (including those located outside the European Union), no matter where located, for the purpose of providing you services your required and improving the Site. By using the Site, you consent to this transfer and acknowledge that the services provided  to you and the functionality of the Site could not be provided without such a transfer. If you do not wish your information to be transferred in this way you should not use this Site.

Transfer of Data to Third Parties

We may use other companies, including affiliates and third parties, to perform services in connection with our operations, and to improve the Site and our other products and services. These third parties may include (but are not limited to) service providers and vendors.

In the course of providing these services, those companies may have access to Personal Information, and such Personal Information may be transferred to other countries. Those companies are contractually required to treat such Personal Information in accordance with this Privacy Policy. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be nonnegotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Information, by these companies. Please see paragraph 11 for liabilities related to the transfer of Personal Data for EU Residents.

You may also use certain third-party sites or services that you link to from Sprkl.me’s Site. In such cases, all information you provide to a third party is provided to that third party and not to Sprkl.me, and is subject to the third party’s privacy policy and terms of service. Please see the section below titled Links to Third-Party Sites for more information.

Sprkl.me may use your IP address and mobile device information to help diagnose problems with Sprkl.me’s service and to administer the Site. Your IP address and mobile device information may also be used to help identify you, your location, and your online profile and to gather broad demographic information (such as country of origin). Sprkl.me may maintain (as permitted by applicable law) information collected from you pursuant to this Privacy Policy following any termination of your relationship with Sprkl.me. Sprkl.me may also delete such information as permitted by applicable law. If you provide credit, debit or other payment card and related details to us in order to make a payment, Sprkl.me will use such information only for the purpose of processing the payment. Sprkl.mes may also aggregate your data with other data, for the purposes set forth above.

Contact and submitted Information

When you give Sprkl.me contact information (such as your name and email address) and demographic information, you agree that Sprkl.memay utilize this information as set forth herein. You agree that Sprkl.me may, as part of its services to you, communicate with you, or initiate communication with you on behalf of a third party, through your Sprkl.me account or through other means such as email, telephone (including mobile phone), or postal mail, including through the use of contact information that you may provide to Sprkl.me or that Sprkl.me may otherwise obtain from third-party resources. If and to the extent permitted by applicable law, Sprkl.meor its designated third-party partners may also use your contact information to (i) send you job alerts; (ii) create an account; and (iii) send you information about Sprkl.me, including promotional materials. Sprkl.me may use demographic and/or profile data to tailor your experience on the Site, show you content that Sprkl.me thinks you may be interested in, and display content according to your preferences. Your information, including Personal Information, gets placed on the Site when you upload or edit your data.

You acknowledge that Sprkl.me may determine whether the content of your submitted data match the words of other members submitted data, and vice versa, in order to improve the Site or any other Sprkl.me product or service (including by displaying or otherwise making available potentially relevant connections, services or products). If you submit any content, this may be crawled by, and displayed through, search engines when someone searches for your name. This means that third parties can view the dataa contained in submitted content and you may receive unsolicited contact from other members, and parties unaffiliated with Sprkl.me and for whom Sprkl.me has no responsibility. If you do not want your Personal Information posted on the Site, you should not upload it. You may deleted your profile, submitted data and cancelcel your membership on a going forward basis; however, Sprkl.me  does not warrant how often third-party search engines will update their caches, which may continue to contain your information. Sprkl.mereserves the right to charge third parties a fee for accessing your submitted or collected information, including Personal Information, as part of Sprkl.me’s services. At your direction, Sprkl.me may also send your data to third parties if you choose to apply for any third party services offered.

Additional Uses and Disclosures of Non-Personal Information

In addition to the other uses and disclosures of information set forth in this Privacy Policy, and notwithstanding anything in this Privacy Policy to the contrary, we may use and disclosure, for any purpose, any information that does not identify you as a specific individual (“Non-Personal Information”), except where we are required to do otherwise under applicable law. Such Non-Personal Information may include, for example and without limitation: MAC addresses and other device identifiers; IP addresses; pixel tags and similar technologies; physical location information; and demographic information, including gender, age, ZIP codes, etc. Non-Personal Information may also include Personal Information that has been aggregated or deidentified. If we combine any Non-Personal Information with Personal Information (such as combining your ZIP code with your name), then we will only use and disclose such combined information for the purposes described in this Paragraph 6 and Paragraphs 4, 5 and 10 of this Privacy Policy while it is so combined. If we are required to treat Non-Personal Information as Personal Information under applicable law, then we may use and disclose it for all the purposes for which we use and disclose Personal Information.

Security

Sprkl.me seeks to use reasonable security measures to help protect against the loss, misuse and alteration of the Personal Information under Sprkl.me’s control. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. In addition, please note that emails, messages sent via your web browser, and other similar means of communication with other members, are not always encrypted. We strongly advise you not to communicate any confidential or sensitive information through these means. Therefore, while we strive to protect your information, we cannot guarantee its security. Please also be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to standard terms and conditions that may be nonnegotiable; these service providers have informed us or the general public that they apply security measures they consider adequate for the protection of information within their system, or they have a general reputation for applying such measures. However, we will not be liable (to the fullest extent permitted by law) for any damages that may result from the misuse of any information, including Personal Information, by these companies. Please see paragraph 11 for liabilities pertaining to the transfer of personal data for EU Residents.

Cookies

“Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Please see our cookie policy for further information regarding Sprkl.me’s use of Cookies.

Links to Third-Party Sites

The Site may make available links to other websites. When you click on such links, you may leave our Site. The Site may also make available Company Pages, which may contain information provided by third-party. WE ARE NOT RESPONSIBLE FOR THE INFORMATION COLLECTION, USE, DISCLOSURE OR OTHER PRIVACY PRACTICES OF ANY THIRD PARTY, INCLUDING OUR AFFILIATES, THIRD-PARTY SERVICE PROVIDERS, ANY EMPLOYERS (INCLUDING ANY OTHER MEMBER THAT PROVIDES ETERNAL LINKS OR CONTACT INFORMATION), ANY THIRD-PARTY SOCIAL MEDIA PLATFORM, ANY THIRD PARTY MAKING AVAILABLE THE DEVICES OR OPERATING SYSTEMS FOR WHICH THE SITE IS AVAILABLE, AND ANY THIRD PARTY OPERATING ANY WEBSITE TO WHICH THE SITE CONTAINS A LINK. YOU MAY HAVE RIGHTS DIRECTLY ENFORCEABLE AGAINST THESE THIRD PARTIES SO YOU SHOULD CONSIDER THEIR PRIVACY POLICIES TO LEARN MORE.

Acquisitions and Other Reorganizations

Information collected pursuant to this Privacy Policy, including Personal Information, may be disclosed to one or more third parties in connection with any change of ownership or control in Sprkl.me’s business (whether by merger, sale, or otherwise), or any other reorganization or joint venture, or assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding), and any such information may be used by such third party in accordance with this Privacy Policy.

Personal Data for EU Residents

The following section pertains to users who are located in the European Union. Sprkl.me complies with the EU­US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Sprkl.me has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

In the context of an onward transfer of data to a third party, a Privacy Shield organization has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Sprkl.me shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless CSRJobs proves that it is not responsible for the event giving rise to the damage.

Residents of the European Economic Area have a right of access to their data. Sprkl.me members are able to access and update their data through their member dashboard of Sprkl.me’s site. If you wish Sprkl.me to access and edit such data on your behalf, please send an email with a copy of your passport or national identity card (for identity verification purposes) and the same will be provided to you. There may be a charge for such a request (which will not be higher than applicable law permits). European Economic Area and Switzerland residents also have a right, if their personal data is inaccurate, of rectification, erasure or blocking of such inaccurate personal data. You may edit your resume free of charge (if there is an inaccuracy or otherwise), by following procedures set forth on the Site. If your personal data is inaccurate, you may alternatively request Sprkl.me to rectify, erase or block the data by sending an email, with a copy of your passport or national identity card (for identity verification purposes), to the above address with the exact nature of the requested  action.

Do Not Track Requests

We do not respond to the browser “Do Not Track” (DNT) signal if enabled by the user in their web browser. When we set or read cookies on non-Sprkl.me sites that have integrated our search, booking and display features, we do so, for example, to provide a personalized experience to users on those sites. We do not share any information about your use of Sprkl.me with those third parties. When third parties that we have integrated into Sprkl.me sites (as described in the Sprkl.me Cookie Policy) set or read their own third-party cookies, they may or may not respond to the DNT signal.

Opting Out

If you no longer want to receive promotional materials from us based upon your Personal Information, going forward, you may opt out of receiving such marketing related messages by the email settings of our third party email service provide (like mailchimp, Groundhogg, Zoom, Meetup, Calandly, or Sharedrive for example) or by sending an email to contact @ sprkl.me (remove spaces when sending email). Please note that we may still send other messages to you, such as administrative messages. We will try to comply with your request as soon as reasonably practicable.

Independent Dispute Resolution

In compliance with the EUUS Privacy Shield Principles, Sprkl.me commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Sprkl.me by email contact @ sprkl.me (remove spaces when sending email).

Sprkl.me has further committed to refer unresolved privacy complaints under the EU­US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a nonprofit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

There may be a possibility, under certain limited conditions, for EU individuals to invoke binding arbitration before the Privacy Shield Panel.

General Inquiries and Complaints

You may contact Sprkl.me via the contact form listed at the contact pages.

Last Updated: October 12, 2023