Privacy policy

Updated at 2021-02-12

Spark X (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your personal informationis collected, used, and disclosed by Spark X.

This Privacy Policy applies to our website, and its associated subdomains (collectively, our “Service”) alongside our application,Spark X. By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage,use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

Definitions and key terms

To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, are strictlydefined as:

  • Cookie: small amount of data generated by a website and saved by your web browser. It is used to identify your browser,provide analytics, remember information about you such as your language preference or login information.
  • Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to Spark X, that is responsible for yourinformation under this Privacy Policy.
  • Country: where Spark X or the owners/founders of Spark X are based, in this case is Ukraine
  • Customer: refers to the company, organization or person that signs up to use the Spark X Service to manage therelationships with your consumers or service users.
  • Device: any internet connected device such as a phone, tablet, computer or any other device that can be used to visit Spark X and use the services.
  • IP address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address.These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location fromwhich a device is connecting to the Internet.
  • Personnel: refers to those individuals who are employed by Spark X or are under contract to perform a service on behalf ofone of the parties.
  • Personal Data: any information that directly, indirectly, or in connection with other information — including a personalidentification number — allows for the identification or identifiability of a natural person.
  • Service: refers to the service provided by Spark X as described in the relative terms (if available) and on this platform.
  • Third-party service: refers to advertisers, contest sponsors, promotional and marketing partners, and others who provideour content or whose products or services we think may interest you.
  • Website: Spark X."’s" site, which can be accessed via this URL:
  • You: a person or entity that is registered with Spark X to use the Services.

Information automatically collected

There is some information like your Internet Protocol (IP) address and/or browser and device characteristics — is collectedautomatically when you visit our platform. This information may be used to connect your computer to the Internet. Otherinformation collected automatically could be a login, e-mail address, password, computer and connection information such asbrowser plug-in types and versions and time zone setting, operating systems and platforms, purchase history, (we sometimesaggregate with similar information from other Users), the full Uniform Resource Locator (URL) clickstream to, through and fromour Website that may include date and time; cookie number; parts of the site you viewed or searched for; and the phone numberyou used to call our Customer Services. We may also use browser data such as cookies, Flash cookies (also known as FlashLocal Shared Objects) or similar data on certain parts of our Website for fraud prevention and other purposes. During your visits,we may use software tools such as JavaScript to measure and collect session information including page response times,download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), andmethods used to browse away from the page. We may also collect technical information to help us identify your device for fraud prevention and diagnostic purposes.

We automatically collect certain information when you visit, use or navigate the platform. This information does not reveal yourspecific identity (like your name or contact information) but may include device and usage information, such as your IP address,browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location,information about who and when you use our and other technical information. This information is primarily needed to maintainthe security and operation of our platform, and for our internal analytics and reporting purposes.

Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantiallyall of the assets of Spark X or any of its Corporate Affiliates (as defined herein), or that portion of Spark X or any of its CorporateAffiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us apetition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the terms of thisPrivacy Policy.


We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes of this PrivacyPolicy, "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under commoncontrol with Spark X, whether by ownership or otherwise. Any information relating to you that we provide to our CorporateAffiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Governing Law

This Privacy Policy is governed by the laws of Ukraine without regard to its conflict of laws provision. You consent to theexclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connectionwith this Privacy Policy except for those individuals who may have rights to make claims under Privacy Shield, or the Swiss-USframework.

The laws of Ukraine, excluding its conflicts of law rules, shall govern this Agreement and your use of the website. Your use ofthe website may also be subject to other local, state, national, or international laws.

By using Spark X or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not agree to this PrivacyPolicy, you should not engage with our website, or use our services. Continued use of the website, direct engagement with us,or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your personalinformation will mean that you accept those changes.

Your Consent

We've updated our Privacy Policy to provide you with complete transparency into what is being set when you visit our site andhow it's being used. By using our website, registering an account, or making a purchase, you hereby consent to our PrivacyPolicy and agree to its terms.

Links to Other Websites

This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled bySpark X. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are notinvestigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go fromthe Services to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website,including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties may usetheir own cookies or other methods to collect information about you.


Spark X uses "Cookies" to identify the areas of our website that you have visited. A Cookie is a small piece of data stored onyour computer or mobile device by your web browser. We use Cookies to enhance the performance and functionality of ourwebsite but are non-essential to their use. However, without these cookies, certain functionality like videos may becomeunavailable or you would be required to enter your login details every time you visit the website as we would not be able toremember that you had logged in previously. Most web browsers can be set to disable the use of Cookies. However, if youdisable Cookies, you may not be able to access functionality on our website correctly or at all. We never place PersonallyIdentifiable Information in Cookies.

Blocking and disabling cookies and similar technologies

Wherever you're located you may also set your browser to block cookies and similar technologies, but this action may block ouressential cookies and prevent our website from functioning properly, and you may not be able to fully utilize all of its featuresand services. You should also be aware that you may also lose some saved information (e.g. saved login details, sitepreferences) if you block cookies on your browser. Different browsers make different controls available to you. Disabling acookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within yourbrowser, you should visit your browser's help menu for more information.

Remarketing Services

We use remarketing services. What Is Remarketing? In digital marketing, remarketing (or retargeting) is the practice of servingads across the internet to people who have already visited your website. It allows your company to seem like they're “following”people around the internet by serving ads on the websites and platforms they use most.

Kids' Privacy

We collect information from kids under the age of 13 just to better our services. If You are a parent or guardian and You areaware that Your child has provided Us with Personal Data without your permission, please contact Us. If We become aware thatWe have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps toremove that information from Our servers.

Changes To Our Privacy Policy

We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accuratelyreflect our Service and policies. Unless otherwise required by law, we will notify you (for example, through our Service) beforewe make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if youcontinue to use the Service, you will be bound by the updated Privacy Policy. If you do not want to agree to this or any updated Privacy Policy, you can delete your account.

Third-Party Services

We may display, include or make available third-party content (including data, information, applications and other productsservices) or provide links to third-party websites or services ("Third- Party Services")

You acknowledge and agree that Spark X shall not be responsible for any Third-Party Services, including their accuracy,completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. Spark X does notassume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.

Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely atyour own risk and subject to such third parties' terms and conditions.

Tracking Technologies

  • We use Cookies to enhance the performance and functionality of our $platform but are non-essential to their use.However, without these cookies, certain functionality like videos may become unavailable or you would be required to enteryour login details every time you visit the $platform as we would not be able to remember that you had logged inpreviously.
  • Local Storage sometimes known as DOM storage, provides web apps with methods and protocols for storing client-sidedata. Web storage supports persistent data storage, similar to cookies but with a greatly enhanced capacity and noinformation stored in the HTTP request header.
  • $elnombre uses "Sessions" to identify the areas of our website that you have visited. A Session is a small piece of datastored on your computer or mobile device by your web browser.