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: o 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. o 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. o 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. o 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: o Generally manage Individual information and accounts; o Respond to questions, comments, and other requests; o Provide access to certain areas, functionalities, and features of Sparrow’s Services; o Contact you to answer requests for customer support or technical support; o Allow you to register for events.
• Administrative Purposes. Sparrow may use Personal Information about you for its administrative purposes, including to: o Measure interest in Sparrow’s Services; o Develop new products and Services; o Ensure internal quality control; o Verify Individual identity; o Communicate about Individual accounts and activities on Sparrow’s Services and systems, and, in Sparrow’s discretion, changes to any Sparrow policy; o 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; o Process payment for products or services purchased; o Process applications and transactions; o Prevent potentially prohibited or illegal activities; o 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: o To tailor content, advertisements, and offers; o To notify you about offers, products, and services that may be of interest to you; o To provide Services to you; o For other purposes disclosed at the time that Individuals provide Personal Information; or o Otherwise with your consent.
3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
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
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)
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 firstname.lastname@example.org. 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
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
6. Rights of Access, Rectification, Erasure, and Restriction
7. Data Retention
8. Security of Your Information
9. International Users
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
12. Other Rights and Important Information
12.2 Republic of Korea Privacy Rights
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.