Who are we?
SparcStart is recruitment marketing and video management platform designed for Talent Acquisition. We are a SaaS platform that enables employers to create video-powered job advertisements through our Sparc product; and create and manage employee-generated videos through our Amplify VMS product.
We are a New York corporation, Matchrome, Inc., headquartered in New York City. Our contact information is detailed below.
What personal data does SparcStart collect?
SparcStart does not collect any personal data from individuals visiting our website except visitors who request access to selected webinars and publications (gated content). If you request access, we will ask for your name, email address, company affiliation and title.
The only data we collect on the SparcStart platform is from employers who use our services. The data we collect is limited to the names and work email address of users who have an account on the SparcStart platform. This data is used to identify individual accounts, and connect job ads and videos to the accounts of users. Additionally, we collect the email address of employees who are asked to record a video. This data is used to send emails with instructions and upload links.
What does this Policy cover?
We at SparcStart take your personal data seriously. This policy:
- sets out the types of personal data that we collect about you,
- explains how and why we collect and use your personal data,
- explains how long we keep your personal data,
- explains when, why and with who we will share your personal data,
- sets out the legal basis we have for using your personal data,
- explains the effect of refusing to provide the personal data requested,
- explains the different rights and choices you have when it comes to your personal data,
- and explains how we may contact you and how you can contact us.
Where do we collect personal data about you?
If you are a visitor to our site, you will provide your personal data in a request form when you ask for access to gated content.
When you are given an account on SparcStart, the individual who has the administrative privileges for the company account will enter your name and email address. If you are asked to make a video for your company, your email address will be entered by an individual who is a user on your company account.
How do we use your personal data?
For visitors to our website who request access to gated content, we use the data to grant access to the requested content and to engage in business discussions related to the content and potential use of our products.
For users of a SparcStart product, your email address is used to identify your account and connect it with job ads and videos. If you are asked to make a video by a user, your email address is used to email you instructions to make the video and an upload link to submit the video. Your email address may also be an identifier that allows a user to search for your video.
How long do we keep your personal data?
We keep your information in accordance as follows:
If you are a visitor to our website and request access to gated content, we will keep your information for as long as you are engaged with us in business discussions, participate in our educational events or maintain a relationship with one or more of our employees. If you are not actively engaging with us, we will retain your information for a maximum of 5 years.
If you are a user, your data is retained as long as you have an active account on the SparcStart platform. If you leave your position, or for any other reason, no longer have an account, the Administrator is responsible for removing your information. If your employer does not renew the company account at the end of the current contract period, all data, including your name and email address will be deleted one year after the end of the current contract period.
If you are an employee who has uploaded a video to a SparcStart account, your email address and video will be retained until the Administrator removes your video from the account. If you are asked to record a video and do not upload one, your email address is retained until the Administrator removes the request from the SparcStart account. In either case, if your employer does not renew the company account at the end of the current contract period, all data, including your email address and video will be deleted one year after the end of the current contract period.
We only retain your information for as long as is necessary for us to use your information as described above or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved,
- legal obligation(s) under applicable law to retain data for a certain period of time,
- statute of limitations under applicable law(s),
- potential disputes,
- if you have made a request to have your information deleted; and
- guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information once this is no longer needed.
Who do we share your personal data with?
We do not share data with any other company or 3rd party.
What legal basis do we have for using your information?
For visitors to our site who request gated content, we have a legitimate interest as a business in responding to your request for content and keeping a record of requests.
For users, your information is necessary for us to fulfill our contractual obligations to clients. Your information establishes unique accounts for all individuals using the SparcStart platform and ensures that all information is correctly associated with the individual who requests it or manages it.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you withdraw your consent for the processing of your personal data, we will not be able to give you access to a SparcStart account.
Do we make automated decisions concerning you?
No, we do not carry out automated profiling.
Do we use Cookies to collect personal data on you?
The website and the platform use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses its own cookies to help us analyze how you and other users use the site. The information generated by the cookies about your use of the site (which may include your IP address, the internet browser and language you use, preferences, the date and hour of your access to the web page and the websites you access after visiting the site) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the site, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the site. By using the site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
Do we transfer your data internationally?
Your data is stored in the United States on servers provided by AWS and controlled by SparcStart.
Where data is transferred internationally, we ensure that this is done in accordance with applicable data privacy laws. For example, where EU or UK personal data is processed by us or a supplier based in a country for which there is no applicable adequacy decision, we may put security measures or other adequate safeguards in place to protect your personal data.
What rights do you have in relation to the data we hold on you?
By law, you have a number of rights when it comes to your personal data. Further information and advice about your rights can be obtained from the data protection regulator in your country.
For EU and UK based individuals, the following rights would apply:
| Right | What does this mean? |
| 1. The right to be informed | You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Policy. |
| 2. The right of access |
You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Privacy Policy). This is so you’re aware and can check that we’re using your information in accordance with data protection law. |
| 3. The right to rectification | You are entitled to have your information corrected if it’s inaccurate or incomplete. |
| 4. The right to erasure | This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions. |
| 5. The right to restrict processing | You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future. |
| 6. The right to data portability | You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability. |
| 7. The right to object to processing | You have the right to object to certain types of processing, including processing for direct marketing. |
| 8. The right to lodge a complaint | You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator. |
| 9. The right to withdraw consent | If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes. |
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
- Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we’ll come back to you and let you know.
How will we contact you?
We may contact you by email.
How can you contact us?
Our headquarter offices are located at 307 West 38th Street, Suite 907, New York, NY 10018. You can reach us by phone at 01-315-497-7272 or by email at Privacy@SparcStart.com.
For UK and EU based individuals, if you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact us here:
UK Representative:
Datarologie (Reed Smith LLP)
Broadgate Tower, Primrose St
London EC2A 2RS
SparcStartUKRep@reedsmith.com
EU Representative:
Datarologie (Reed Smith LLP)
2nd Floor, Avenue Marnix 23
1000 Bruxelles, Belgium
SparcStartEURep@reedsmith.com