STEMSpark Privacy Policy
IMPORTANT! AS WITH ALL CONTRACTS, IF YOU ARE NOT OF LEGAL AGE TO FORM A BINDING CONTRACT (IN MANY JURISDICTIONS, THIS AGE IS 18), YOU MUST HAVE YOUR PARENT OR GUARDIAN READ THE AGREEMENT BELOW AND AGREE TO IT FOR YOU. IF YOU DON'T GET YOUR PARENT OR GUARDIAN TO READ AND AGREE TO THIS, YOU DON'T HAVE PERMISSION TO USE STEMSPARK LLC’S SITE OR SERVICES (EACH, AS DEFINED BELOW) OR TO DISCLOSE ANY INFORMATION TO US IN ANY MANNER. ALWAYS GET AN ADULT'S PERMISSION BEFORE GOING ONLINE.
Effective October 15, 2018
We at STEMSpark LLC (“STEMSpark,” “we,” “us,” or “our”) created this privacy policy (“Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of STEMSpark in connection with our online services (the “Services”), which are made available to you through our website located at http://stem-spark.com (the “Site”).
We strive to educate parents and kids about how to appropriately safeguard their privacy when using our Services. We are committed to complying with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), which requires us to inform parents and legal guardians about our information collection and use practices. COPPA also requires that we obtain parental consent before we allow children under the age of 13 to access and/or use our Services. We urge kids to check with their parents before entering information through our Site and/or Services, and we recommend that parents discuss with their kids restrictions regarding the online release of Personal Information (as defined below) to anyone they don’t know.
By visiting our Site and/or using our Services, or by permitting your child to use our Services, you are agreeing to the terms of this Privacy Policy.
1. Information We Collect.
Personal Information
We do not collect any personal information from you unless you voluntarily provide it to us.
When you sign up to become a user of the Site (a “User”), you will be asked to provide us with certain personal information, such as your first name, last name, and email address. In this Privacy Policy, we refer to this information as “Personal Information.” Other than the online contact information required to obtain parental consent, we do not collect any Personal Information from Users under the age of 13 unless the User’s parent or legal guardian has first provided us with consent for that User to use the Services and disclose Personal Information to us. If you are a User under the age of 13, please do not send any Personal Information to us if we have not obtained prior consent from your parent or guardian. If we learn we have collected Personal Information from a User under the age of 13 without parental consent, or if we learn a User under the age of 13 has provided us Personal Information beyond what we request from him or her, we will delete that information as quickly as possible. If you believe that a User under the age of 13 may have provided us Personal Information in violation of this Privacy Policy, please contact us at info@stem-spark.com.
Usage Information
Like most websites, we use automatic data collection technology when you visit the Site to record information that identifies your computer, to track your use of our Site, and to collect certain basic information about you and your surfing habits. This information includes information about your operating system, your IP addresses, browser type and language, referring and exit pages and URLs, keywords, date and time, amount of time spent on particular pages, what sections of a website you visit, and similar information concerning your use of the Site and the Services (the “Usage Information”).
We collect this Usage Information by using cookies and pixel tags (also called web beacons or clear gifs). Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of website users. You can reject cookies by following the directions provided in your Internet provider’s “help” file. If you reject cookies, you may still visit the Site, but may not be able to use some areas of the Site and/or the Services.
We do not collect Personal Information in this way, but if you’ve provided us with Personal Information, we may associate that information with the information that is collected automatically. Automatic data collection may be performed on our behalf by our services providers.
1. How We Use Your Information. We may use your Personal Information and Usage Information in a manner that is consistent with this Privacy Policy and the context of our relationship with you. We will use your Personal Information and Usage Information collected through the Site for the following purposes:
1. To identify you when you sign in to your account;
2. To respond to your requests and to provide you with the Services;
3. To respond to your inquiries and contact you about changes to the Site and/or the Services;
4. To send you notices (for example, in the form of e-mails, mailings, and the like) regarding products or services you are receiving, and for billing and collection purposes;
5. To send you information we think you may find useful or that you have requested from us;
6. To enhance and improve the Site or the Service, such as through personalized features and content;
7. To analyze the use of the Site and the Service and the people visiting to improve our content and Site and the Service;
8. To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
9. For any other purposes disclosed at the time the information is collected or to which you consent; and
10. As otherwise specifically described in this Privacy Policy.
2. Disclosure of Personal Information to Third Parties. We do not disclose your Personal Information to third parties for their direct marketing purposes.
We, like many businesses, sometimes hire other companies to perform certain business-related functions. Examples include mailing information, maintaining databases, hosting services, and processing payments. When we employ another company to perform a function of this nature, we provide them with the information that they need to perform their specific function, which may include Personal Information.
If we or all or substantially all of our assets are acquired, we expect that the information that we have collected, including Personal Information, would be transferred along with our other business assets.
We may disclose your Personal Information and Usage Information to government authorities and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas. We may also disclose your Personal Information and Usage Information when we have reason to believe that someone is or may be causing injury to or interference with our rights or property, other users of this Site, or anyone else that could be harmed by such activities.
1. How We Protect Your Information. We take commercially reasonable steps to protect the Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
2. Accessing and Modifying Account Information. You may update the information that is stored in your user account by visiting stem-spark.com or by e-mailing us at info@stem-spark.com.
We strive to help parents ensure that their kids have a safe experience using our Services. Parents or legal guardians can review any Personal Information collected about their child under 13 years of age, have this information deleted, request that there be no further collection or use of their child’s Personal Information, and/or allow for our collection and use of their child’s Personal Information while withholding consent for us to disclose it to third parties. We take steps to verify the identity of anyone requesting information about a child and to ensure that the person is in fact the child’s parent or legal guardian.
1. Your Choices. If you wish to stop receiving promotional e-mails, you may do so by visiting www.stem-spark.com or by e-mailing info@stem-spark.com. You may also choose to unsubscribe from our emails by following the instructions in the bottom of the email.
2. Links. The Site may contain content, services, advertising and other materials that link to websites operated by third parties. We have no control over those other sites, and this Privacy Policy does not apply to them. Please refer to the privacy policies of those sites for more information on how the operators of those sites collect and use your Personal Information.
3. Shine the Light Law. Under California Civil Code Section 1798.83, California residents who have an established business relationship with us may choose to opt out of our sharing their contact information with third parties for direct marketing purposes. If you are a California resident and you wish to opt out, please send an e-mail to info@stem-spark.com.
4. Do Not Track. We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.
5. Important Notice to Users Outside the U.S. The Site and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By providing us with any information through the Site or the Services, you consent to this transfer.
6. Privacy Notice for California Residents. This Privacy Notice for California Residents (this “Notice”) supplements and is expressly made part of the information contained in the STEMSpark Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Notice.
1. Information We Collect. Through your use of our Site, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Site has collected the following categories of personal information from its consumers within the last twelve (12) months. Additionally, we have disclosed the following categories of information for a business purpose in the past twelve (12) months:
Category
Examples
Collected
Disclosed for a business purpose
A. Identifiers.
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Yes
Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Yes
Yes
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Yes
Yes
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
No
No
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
No
No
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Yes
Yes
G. Geolocation data.
Physical location or movements.
Yes
Yes
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
No
No
I. Professional or employment-related information.
Current or past job history or performance evaluations
No
No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records
No
No
K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Yes
Yes
1. Personal information does not include: (I) Publicly available information from government records, (II) Deidentified or aggregated consumer information, or (III) Information excluded from the CCPA's scope, like (A) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, or (B) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
2. STEMSpark obtains the categories of personal information listed above from the following categories of sources: (I) directly from you (for example, from information you submit on the Site during the process of using and paying for Services), (II) indirectly from you (for example, from observing your actions on our Site), and/or (III) from third-party business partners such as social media sites, ad networks, and analytics providers.
2. Use of Personal Information. First and foremost, STEMSpark does not sell and has not sold any personal information in the preceding twelve (12) months. We may use or disclose the personal information we collect for one or more of the following business or marketing purposes (STEMSpark will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice):
1. To create your account on our Site and let you log in to your account and use the Site and/or Services.
2. To manage your account, provide you with customer support, and ensure you are receiving quality service.
3. To contact you or provide you with information, alerts and suggestions that are related to our Services.
4. For billing-related purposes.
5. To reach out to you, either ourselves or using the appropriate authorities, if we have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.
6. To enable and facilitate the Services.
7. To supervise, administer and monitor the Services.
8. To measure and improve the quality, the effectiveness and the delivery of our Services.
9. Market the Site and our Services to you.
10. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
11. To provide, support, personalize, and develop our Site and our Services.
12. To personalize your Site experience and to deliver content and product and Service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).
3. Disclosure of Personal Information. STEMSpark may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share the minimum necessary personal information with the following categories of third parties:
1. Service providers that provide audit, legal, operational, technical or other services for us, such as:
1. Customer service
2. Technical maintenance
3. Monitoring website activity
4. Email management and communication
5. Database management
6. Billing and payment processing
7. Reporting and analytics
8. Marketing and advertising
4. Your Rights and Choices. The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
1. Right to Request Access to Information. You have the right to request that STEMSpark notifies you of the personal information about you that we have collected and used. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting that personal information.
4. The categories of third parties with whom we shared that personal information.
5. The specific pieces of personal information we collected about you.
6. If we disclosed your personal information for a business purpose and identifying the personal information categories that each category of recipient obtained
2. Right to Request Deletion of Information. You have the right to request that STEMSpark deletes any of your personal information that we collected about you and retained. Once we receive your request and verify who you are, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
3. Exercising Your Rights. To exercise the rights listed above, please submit a request in writing to STEMSpark via the contact information listed in the How To Contact Us section. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. You may only make a request for access twice within a 12-month period. Your request must: (A) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (B) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in a request to verify your identity or authority to make the request.
4. Response Timing and Formatting. We endeavor to respond to a request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. For Requests to Access, our response will only cover the 12-month period preceding the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
5. Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. We will not:
1. Deny you goods or services.
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
3. Provide you a different level or quality of goods or services.
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
2. Changes to This Privacy Policy. This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time and will post any changes on the Site as soon as they go into effect. By accessing the Site or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.
How to Contact Us. If you have questions about this Privacy Policy, please e-mail us at info@stem-spark.com, “PRIVACY POLICY” in the subject line, or mail us at the following address: 24 North Bryn Mawr Avenue, Suite 163, Bryn Mawr, PA 19010.