1. Purpose

This Sparrow Privacy Policy is incorporated by reference into the Sparrow Terms of Service (the “Terms”) and the terms, “Sparrow,” “we,” and “us” means Sparrow Co., Ltd. This Sparrow Privacy Policy explains how Sparrow practices online and offline information and what kinds of information Sparrow may collect and how this information will be used by Sparrow. Also, how you can opt-out of a use or correct or change such information are explained in this Sparrow Privacy Policy. All other terms not defined in Definitions section or otherwise herein will have the meanings set forth in the Terms.

2. Scope

This Privacy Policy stands for personal information that is collected and processed by Sparrow in the course of our business. This information can be from different sources including websites (“Site”), applications (“App”), and any other on or offline activities (“Services”). Sparrow as a company and all individuals that will be processing personal information on behalf of Sparrow are expected to follow this Privacy Policy and actively protect any customer data that are collected or processed through Sparrow Services. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

3. TRANSPARENCY/NOTICE — Types of Personal Information We Collect and How We Use It

The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Sparrow and the requirements of applicable law. Some of the ways that Sparrow may collect Personal Information include:

• You may provide Personal Information directly to Sparrow through interacting with the Services, participating in surveys, during events such as sweepstakes, and requesting Services or information.
• As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

3.1 Types of Personal Information We Collect

Sparrow collects Personal Information regarding its customers, users, and visitors to its Sites (collectively “Individuals”).

• Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Sparrow, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
  • From communications. Sparrow may collect some Personal Information that are required to provide necessary supports or services from our customers including name, email address and phone number when our customers are registering for Sparrow services or supports.
  • Posting. There are pages on Sparrow’s website where customers could post messages or share their opinions via blogs, forum or bulletin boards. If our customers decided to submit information to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
  • Sweepstakes or survey. Sparrow may run sweepstakes or survey. These events may require personal information including e-mail address or phone number. When participating in these events, those collected personal information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. All sweepstakes and survey entry forms will provide a way for participants to opt-out of any communications that are not related to awarding prizes.
  • Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences. If you are not an account-holder when this information is collected, we may subsequently ascribe this information to your account if and when you create one.
• Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store (including the Apple App Store, Google Play App Store, or Amazon App Store) or Social Networking Site (“SNS”), we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS username, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to Sparrow and to enhance our ability to provide you with information about our business, products, and Services.

3.2 How Sparrow Uses Your Information

Sparrow may acquire, hold, use, and process Personal Information about Individuals for a variety of business purposes, including:

• To Provide Products, Services, or Information Requested. Sparrow may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
  • Generally manage Individual information and accounts;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of Sparrow’s Services;
  • Contact you to answer requests for customer support or technical support;
  • Allow you to register for events.
• Administrative Purposes. Sparrow may use Personal Information about you for its administrative purposes, including to:
  • Measure interest in Sparrow’s Services;
  • Develop new products and Services;
  • Ensure internal quality control;
  • Verify Individual identity;
  • Communicate about Individual accounts and activities on Sparrow’s Services and systems, and, in Sparrow’s discretion, changes to any Sparrow policy;
  • Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
  • Process payment for products or services purchased;
  • Process applications and transactions;
  • Prevent potentially prohibited or illegal activities;
  • Enforce our Terms.
• Marketing Sparrow Products and Services. Sparrow may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services via the email address you provide. Such uses include:
  • To tailor content, advertisements, and offers;
  • To notify you about offers, products, and services that may be of interest to you;
  • To provide Services to you;
  • For other purposes disclosed at the time that Individuals provide Personal Information; or
  • Otherwise with your consent.

You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.

• Research and Development. Sparrow may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Sparrow may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
• Third Party Marketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails from us with information on Sparrow’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
• Services via Mobile Devices. From time to time, Sparrow may provide an App for the Services. Sparrow will collect certain information that your mobile device sends when you use the App, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Information about use of the App may be associated with your account. The App may enable users to email reports and other information. Sparrow may use personal or non-identifiable information transmitted to Sparrow to enhance the App, for quality improvement and as otherwise described in this Privacy Policy or in other notices Sparrow provides.
• Anonymous and Aggregated Information Use. Sparrow may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Sparrow’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Sparrow may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Sparrow and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
• Other Uses. Sparrow may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile device, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

• Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
• Social Media Widgets. Our Website includes social media features such as the Facebook “Like” and “Share” buttons (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.
• Google Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit https://www.google.com/policies/privacy/partners. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout or, if you are not a web user of the Services (i.e., a user of the macOS version of the Services), by visiting the Sparrow support page.

Our uses of such Technologies fall into the following general categories:

• Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that is required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping carts, saved search, or similar functions;
• Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;
• Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our Site or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;
• Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third-party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

3.4 THIRD-PARTY WEBSITES, SOCIAL MEDIA PLATFORMS, AND SOFTWARE DEVELOPMENT KITS

The Sparrow Services may contain links to other websites and other websites may reference or link to our Services. These other domains and websites are not controlled by us, and Sparrow does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Sparrow’s Services may include publicly accessible blogs, community forums, or private messaging features. The Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

3.5 Third-Party Payment Processing

When you make purchases through the Services, we process your payments through PayPal (www.paypal.com), a Third-Party application. The Third-Party application may collect certain financial information from you to process a payment on behalf of Sparrow, including your name, email address, address and other billing information.

4. Onward Transfer — Sparrow May Disclose Your Information

4.1 Information We Share

We may share your information as described in this Privacy Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.

• We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing described above; (iv) customer service activities; and (v) in connection with the provision of the Site. Sparrow has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
• Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review or collaborate on a project with another user. We are not responsible for privacy practices of the other users who will view and use the posted information.
• Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Sparrow may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Sparrow related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 5 below.
• Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce Sparrow policies or contracts; (v) to collect amounts owed to Sparrow; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

• Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Sparrow will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

4.2 Data Transfers

All Personal Information collected via or by Sparrow may be stored anywhere in the world, including but not limited to the Republic of Korea, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Sparrow, you consent to the storage of your Personal Information in these locations.

5. Opt-Out (RIGHT TO RESTRICT PROCESSING)

5.1 General

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Sparrow’s Processing of your Personal Information, you may withdraw that consent at any time and opt-out to further Processing by contacting support@sparrowfasoo.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

5.2 Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Sparrow and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

5.3 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

5.4 Cookies and Interest-Based Advertising

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications, including our App. However, on many mobile devices, App users may opt out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://optout.networkadvertising.org, or https://www.youronlinechoices.eu and http://optout.aboutads.info. You can also choose not to be included in Google Analytics here.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

6. Rights of Access, Rectification, Erasure, and Restriction

You may inquire as to whether Sparrow is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an e-mail to support@sparrowfasoo.com or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Sparrow. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws. Please note however that we may keep projects you create through the Services that do not contain Personal Information in an anonymous format for future performance tests and other improvements to the Services in accordance with this Privacy Policy.

Although Sparrow makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Sparrow is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Sparrow determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Sparrow will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

7. Data Retention

Sparrow retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

8. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

9. International Users

By using the Site, Sparrow will transfer data to the Republic of Korea and the United States. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the Republic of Korea and the adjudication of any disputes arising in connection with Sparrow or the Site will be in accordance with the Terms.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the Republic of Korea and the United States and to the Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Privacy Policy.

10. Children’s Privacy

The Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and Sparrow does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information.

11. Redress/Compliance and Accountability

If you have any questions about our privacy practices, this Privacy Policy or how to lodge a complaint with the appropriate authority, please contact Sparrow by email at support@sparrowfasoo.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.

12. Other Rights and Important Information

12.1 Changes To Our Privacy Policy and Practices

This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

• Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.
• Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Sparrow will notify you by email or as otherwise required by applicable law. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
• New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Sparrow will endeavor to comply with the law or contract.

12.2 Republic of Korea Privacy Rights

Republic of Korea law permits users who are Republic of Korea residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Except as otherwise provided in this Privacy Policy, Sparrow does not share Personal Information with Third Parties for their own marketing purposes.

13. Definitions

The following capitalized terms shall have the meanings herein as set forth below.

• “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Sparrow or to which Sparrow discloses Personal Information for use on its behalf.
• “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
• “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• “Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Sparrow or Sparrow’s Agents.