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Privacy Policy

Your Privacy Matters to RootedSparks

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This Privacy Policy governs your relationship with RootedSparks LLC, a Washington limited liability company (also “RootedSparks,” “we,” “our,” or “us”). Protecting our customers and visitors (also “you,” “your,” or “their”) and their privacy is a priority of ours. We have provided this Privacy

Policy to help you understand:

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  • how we collect non-public information about you or your child that can be used alone or in combination to identify you or your child (“Personal Information”), 

  • how we use your or your child’s Personal Information, and 

  • how we protect your privacy and the privacy of your child. 

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This Privacy Policy covers your access to and use of our website located at www.rootedsparks.com, online platforms, apps, newsletters, blogs, social media pages, or other electronic channels owned and maintained by RootedSparks (the “Platform”). The Privacy Policy applies to any Personal Information collected, stored, or used by us, such as Personal Information you provide us through the Platform. In addition, the Privacy Policy describes how we handle Personal Information we collect through the provision of services to you through the Platform, emails, or other communications with us, our employees, or service providers involved in providing services to you (collectively, the “Services”).

By accessing and using the Services, you acknowledge that you have read this Privacy Policy. 

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1. Privacy

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A. Our Privacy Assurance 

  • We take reasonable steps to collect only Personal Information necessary or relevant to our business. 

  • We make a reasonable effort to ensure that Personal Information we act upon is accurate, relevant, timely, and complete. 

  • We use only legitimate means to collect Personal Information. 

  • We make reasonable efforts to make Personal Information available externally only to respond to legitimate business needs, to regulatory or other government authorities, or as otherwise permitted by law. 

  • We take reasonable steps to limit employees' access to those who need to handle Personal Information and who are trained in the proper handling of such Personal Information. 

  • We take industry standard precautions and reasonable measures to protect your Personal Information.

  • We do not knowingly sell Personal Information to any person or company. 

B. Personal Information We Collect from You 

We get most of our Personal Information directly from you through the Services, such as when you create an account with us. We also might obtain Personal Information about you from transactions with us, our affiliates, resellers, or other third parties.

Some examples of the Personal Information we may collect from you, usually by you providing it directly to us, include your: 

  • First and last name 

  • Email 

  • Phone number

  • Your credit card or other payment information (typically by our third-party payment providers)

  • Personal Information that you enter into artificial intelligence features of our Services, including your prompts and other content you upload (the “Inputs”).

  • Any other Personal Information you may provide to us by any means, including by email or phone.

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You can choose not to provide certain Personal Information to us, or to exclude certain Personal Information from your Inputs, but it may delay, prevent, or diminish the quality of Services we provide to you. Nevertheless, if you have any concerns about providing certain Personal Information to us or including it in Inputs, we encourage you to avoid doing so. 

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C. Personal Information from Internet Use 

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We may also automatically receive and store certain types of Personal Information whenever you visit the Services, such as the name of the domain and host from which you access the Internet and the IP address of the computer you are using. We may log and use your IP address to administer the Services, to help diagnose problems with our server, to analyze trends, to track users' webpage movements, to help identify you, and to gather broad demographic information for aggregate use. 

We may use standard tools, such as “cookies” (which may be html files, flash files, or other technology), web beacons, or similar technologies (collectively, “Tracking Tools”). Cookies are small text files stored locally on your computer that help store user preferences. “Web beacons” or “clear gifs” are small pieces of code placed on websites used to collect advertising metrics, such as counting page views, promotion views, or advertising responses. We may use Tracking Tools to monitor the Services and Internet usage and to improve or customize the content on the Services. 

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In addition, on occasion we may also set a “session cookie” on the Services to help us administer the Services. The session cookie expires when you close your web browser and does not retain any Personal Information about you after it expires. If you do not want the benefits of these cookies, you may opt-out by visiting https://optout.networkadvertising.org/?c=1. However, if you do so, you may not receive the full benefit from the use of the Services. 

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We may use Tracking Tools only to gather information as indicated in this Privacy Policy. In many web browsers, you can choose to delete, disable, turn off, or reject most Tracking Tools through the “Internet Options” sub-option of the “Tools” menu of your web browser or otherwise as directed by your web browser’s support feature. Please consult the “Help” section of your web browser for more information. By agreeing to this Privacy Policy, you are consenting to the use of Tracking Tools as set forth in this Privacy Policy. 

Finally, our web servers may collect “log data.” Log data provides aggregate information about the number of visits to different pages on the Services. This Privacy Policy does not apply to other types of information you may disclose or that we may collect, including aggregate user statistics, demographic information, and other data that does not include Personal Information or from which you cannot be identified.

We may use such aggregate log data to improve access to the Services based on visitors’ web browsers and operating system types to make the Services available to as many relevant users as possible. We do not link the “log data” collected to Personal Information. Third party providers may also collect aggregate log data independently from us. 

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D. How We Use Your Personal Information 

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We only use your Personal Information if we have a proper reason for doing so, e.g.:

  • For the performance of Services or to take steps at your request before engaging in Services with you;

  • For our legitimate interests or those of a third party;

  • Where you have given consent; or

  • To comply with our legal and regulatory obligations;

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A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

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The table below explains what we use (process) your Personal Information for and our reasons for doing so:

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Uses of Your Personal Information

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To provide products and/or Services to you

To make decisions about the types of products and prices we can offer to you

 

To assess your eligibility for payment plans and to process your payments

 

To communicate with you and others as part of our business and to respond to your requests

To prevent and detect fraud or abuse

Conducting checks to identify our customers and verify their identity

Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business

Gathering and providing information required by or relating to audits, enquiries, or investigations by regulatory bodies

Ensuring business policies are adhered to, e.g. policies covering security and internet use

Operational reasons, such as improving efficiency, training, and quality control

Ensuring the confidentiality of commercially sensitive information

Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures

Preventing unauthorized access and modifications to systems

Generally establish and defend legal rights and protect our operations or those of any of our group companies or business partners

 

Updating and enhancing customer records

Statutory returns or responses

Ensuring safe working practices, staff administration, and assessments

Marketing our Services and those of selected third parties to:

  • existing and former customers;

  • third parties who have previously expressed an interest in our Services;

  • third parties with whom we have had no previous dealings.

External audits and quality checks, e.g. security accreditation and the audit of our accounts

Facilitate social sharing functionality

Send you important information regarding changes to our policies, other terms and conditions, our Services and other administrative information

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Our Reasons for Such Use

For the performance of our contract with you or to take steps at your request before entering into a contract

For our legitimate interests or those of a third party; e.g. to factor various risks into the products and prices we offer

For our legitimate interests or those of a third party; e.g.  to factor various risks into payment plans we offer

For our legitimate interests or those of a third party; e.g. to send updates to you regarding our products and Services

For the performance of our contract with you or to take steps at your request before entering into a contract

For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us, a third party or for you

To comply with our legal and regulatory obligations

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party; e.g.  to make sure we are following our own internal procedures so we can improve our products and Services

For our legitimate interests or those of a third party; e.g. to be as efficient as we can so we can improve our products and Services

For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party; e.g. to be as efficient as we can so we can improve our products and Services

For our legitimate interests or those of a third party; e.g. to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party; e.g. to pursue available remedies to limit our damages.

For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products

To comply with our legal and regulatory obligations

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

For our legitimate interests or those of a third party; e.g. to promote our business to existing and former customers

For our legitimate interests or those of a third party; e.g. to maintain our accreditations so we can demonstrate we operate at the highest standards

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party; e.g. to enable efficient functionality between our Services and social media websites

For our legitimate interests or a those of a third party; e.g. to obtain your consent to updated policies

To comply with our legal and regulatory obligations

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E. With whom do we share your Personal Information 

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In order to conduct our business and to better serve you, we may disclose all of the Personal Information we collect, as described above, to our affiliates, contractors, and agents. We may also disclose all the Personal Information we collect to companies or individuals that perform services on our behalf or with whom we have joint marketing agreements, such as third-party retailers and advertisers for providing products and services to you of relevance to our Services. In order to conduct our business and to better serve you, we may disclose all of the Personal Information we collect, as described above, to:

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  • Our affiliated companies. Other companies associated with RootedSparks may have access to and use of Personal Information in connection with the conduct of our business where appropriate.

  • Other distribution parties. In the course of marketing and providing services, we may make Personal Information available to third parties such as intermediaries and agents, appointed representatives, marketing partners, and other business partners.

  • Our artificial intelligence service providers. In order to enable our provision of the Services, we may share your Personal Information provided by you within your Inputs to third-party artificial intelligence service providers.

  • Our service providers. We may also share your Personal Information with external third-party service providers, such as: IT systems, support and hosting service providers, cloud services, content delivery services, support and safety monitoring services; printing, advertising, marketing and market research and analysis service providers; banks and financial institutions that service our accounts; document and records management providers; translators; and similar third-party vendors and outsourced service providers that assist us in carrying out business activities; accountants, actuaries, auditors, experts, lawyers and other outside professional advisors; call center service providers. Pursuant to our instructions, these third-parties will access, process, or store Personal Information only in the course of performing their duties to us.

  • Recipients of your social sharing activity. Your friends associated with your social media account(s), other website users and your social media account provider(s), in connection with your social sharing activity. 

  • Governmental authorities and third parties involved in court action. RootedSparks may also share Personal Information with governmental or other public authorities (including, but not limited to, workers’ compensation boards, courts, law enforcement, tax authorities and criminal investigations agencies); and third-party civil legal process participants and their accountants, auditors, lawyers and other advisors and representatives as we believe to be necessary or appropriate: (a) to comply with applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our group companies; (f) to protect our rights, privacy, safety or property, and/or that of our group companies, you or others; and (g) to allow us to pursue available remedies or limit our damages.

  • Other Users and Third Parties You Interact or Share Information With: Certain features of our Services may allow you to interact or share information, including Personal Information, with other users or third parties. Information you share with third parties is governed by their own terms and privacy policies, and you should make sure you understand those terms and policies before sharing information with them.

  • Other Third Parties. We may share Personal Information with purchasers and prospective purchasers or other parties in any actual or proposed reorganization, merger, sale, joint venture, assignment, transfer or other transaction relating to all or any portion of our business, assets or stock.  

We may disclose your Personal Information to third parties for the following reasons: 

  • Providing you the Services 

  • Payment processing 

  • Tracking how visitors use the Services 

  • Fulfilling a transaction you requested 

  • Preventing fraud 

  • Marketing our products 

  • Complying with requests from law enforcement 

  • With your consent (e.g., if you authorize us to share your Personal Information)

  • Protecting our rights, property, or safety, or that of users of RootedSparks or the general public

 

In the event of a bankruptcy or a sale, merger, or acquisition, we may also transfer your Personal Information to a separate entity. That entity will be responsible for ensuring that your Personal Information is used only for authorized purposes and persons in a manner consistent with this Privacy Policy and applicable law.

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Additionally, we may share Personal Information when it is required by a court or government agency or to respond to a Claim by you or a third party. In doing so, we may respond to any subpoena received from a court or government agency without prior notice to you. Unless prohibited by law or by a court order, we will use reasonable efforts to notify you of any subpoena received from any other party that requires us to disclose your identity and will wait ten (10) days thereafter, or a lesser amount of time as required by the deadline in the subpoena, before providing the requested Personal Information. 

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Personal Information may also be shared by you, on message boards, chat, profile pages and blogs, and other services to which you are able to post information and materials (including, without limitation, our social media pages and apps). Please note that any information you post or disclose through these services will become public information, and may be available to third parties who access Services and to the general public. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Services and our social media pages.

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We do not knowingly sell any of your Personal Information to any third parties. We take commercially reasonable measures to anonymize aggregated Personal Information of yours that we use to improve our Services. We may send you marketing communications based on our legitimate interests; provided, however, that we will always attempt to provide a clear mechanism for you to opt-out of any such marketing communications. If you consent to participate in one of our surveys or provide publicly available comments, photos, or content, we may use those materials and any of your Personal Information contained therein for promotion or information purposes.

 

F. Retention, Confidentiality, and Security of Personal Information

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We store Personal Information for as long as reasonably necessary to fulfill the purposes described above, as we determine is necessary for business records, and as required under applicable law. In some cases, the length of time we retain Personal Information depends on your settings or the policies of third-party service providers we use.

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We restrict access to Personal Information about you to those who need to know in order to provide products or Services to you and to conduct our internal operations. We make reasonable efforts to maintain, or take reasonable steps to ensure that our third-party service providers maintain on our behalf, physical, electronic, and procedural safeguards that comply with federal regulations to guard your Personal Information. However, please be aware that, despite our measures, no data security measures or method of transmission over the Internet or means of electronic or physical storage, is guaranteed to be absolutely secure.

 

Additionally, the Services are provided through a certificate trusted website and use commercially reasonable security measures to protect information before and during transmission to the internet. If we become aware of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Services if a security breach occurs. We may also send an email to you at the email address you have provided to use in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

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Some of our security measures depend on the compatibility of your web browser. While we strive to protect your Information, the internet is not absolutely secure and, thus, we cannot promise guaranteed security. In the unlikely event that we believe that the security of your Information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate and to the extent we have your email address, we may notify you by email. 

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You should also take steps on your own to protect your Personal Information, such as: 

  • Using the latest version of your web browser. 

  • Keeping your username and password confidential. 

  • Accessing the Services only on personal or trusted computers or phones. 

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Please refer to the Federal Trade Commission’s website at http://www.business.ftc.gov/privacy-and-security/consumer-privacy for information about how to protect yourself against identity theft.

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If you delete your account with us, we use commercially reasonable efforts to delete all of your Personal Information from our Services. 

 

2. Children

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We are committed to protecting the privacy of children who use our Services. This section explains our practices with respect to the collection of Personal Information from children under the age of 13, consistent with the Children’s Online Privacy Protection Act (“COPPA”).

 

Parental Consent Required

Our Services may be used by children under 13, but only with the consent and supervision of a parent or legal guardian. We do not knowingly collect, use, or disclose Personal Information from children under 13 without verifiable parental consent. If we learn that we have inadvertently collected Personal Information from a child under 13 without the required consent, we will delete that information promptly.

 

What We Collect From Children

With parental consent, we may collect limited Personal Information from children such as:

  • First name or screen name

  • Age or grade level

  • Learning preferences or progress data

  • Parent or guardian’s email address

  • Interests

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We do not condition participation in any activity on a child disclosing more Personal Information than is reasonably necessary.

 

How We Use Children's Information

Personal Information collected from children is used solely for educational, safety, support, and internal analytics purposes, such as:

  • Enabling personalized learning experiences

  • Tracking learning progress

  • Communicating with the parent or guardian

  • Improving the quality and performance of our Services

We do not display targeted advertising to children or sell children’s Personal Information.

 

Parental Rights

Parents or legal guardians who have provided consent have the right to:

  • Review the Personal Information we have collected from their child

  • Request deletion of their child’s Personal Information

  • Withdraw consent to further collection or use of their child’s Personal Information

To exercise any of these rights or if you have any questions about our children’s privacy practices or COPPA compliance, please contact us at hello@rootedsparks.com.

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Third-Party Services

We may use third-party service providers (e.g., hosting, learning analytics) to support the Services. These providers are contractually required to comply with COPPA and may only use Personal Information collected from children for authorized purposes.

We do not permit third parties to collect Personal Information from children for their own commercial purposes.

Please see our Terms of Service for additional information related to children’s use of our Services and the requirement of parental or legal guardian consent.

 

3. Personal Information and Third Parties

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A. Links and Features

The Services may include links to other websites or utilize features from other companies that operate independently from RootedSparks, such as the artificial intelligence services and payment processing services. This Privacy Policy does not apply to such companies and only applies to our Services. We do not make any representations about any websites and features other than our own. Any Personal Information you provide to any linked websites will be subject to the privacy policies of that website. If provided, you should review the privacy policies of any linked websites carefully. Please note that Personal Information collected by third parties may not have the same security protections as Personal Information you submit to us, and we are not responsible for protecting the security of such Personal Information.

 

B. Social Media 

The Services may include social media features. These features may collect your IP address, which page you are visiting on the Services, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Services. Your interactions with these features are governed by the privacy policy of the company providing them. 

 

C. Commercial Electronic Messages

If you provide your email address to us, you affirmatively and expressly consent to receiving commercial emails from us and from our third party providers, affiliates, and resellers. These parties may send you commercial emails in order to deliver information about the Services, information about developments relating to our products and Services, special offers, and other information, including but not limited to updates to the Services. 

 

4. Additional Relevant Provisions and Laws

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We make reasonable efforts to comply with the privacy laws of the U.S. and make no representation that this Privacy Policy or the Terms of Use comply with the laws of any other jurisdiction. If you choose to visit the Services, you do so at your own initiative and at your own risk and you are responsible for complying with all applicable local laws and you waive any causes of action, suits, penalties, fines, losses, damages, costs, or expenses, including attorneys’ fees (“Claims”) that may arise under such local laws. 

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International Visitors

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We are based in the United States and the Services we own or operate is located and hosted in the United States. In most cases, the Personal Information we collect is stored and used in the United States. While we do not generally direct our Services to residents of the European Union (EU), it is possible that EU residents may access and use the Services. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing.

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We may also transfer your data, including Personal Information, from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including Personal Information, to us, you consent to such transfer, storage, and processing.

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If you are a resident of the EU and if GDPR applies to our Services and Services, you may have certain additional rights under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) with respect to any of your Personal Information that we may collect, including the following:

  • the right of access to your Personal Information.

  • the right to rectify your Personal Information if it is incorrect or incomplete.

  • the right to have your Personal Information erased (“right to be forgotten”) if certain grounds are met.

  • the right to withdraw your consent to our processing of your Personal Information at any time (if our processing is based on consent).

  • the right to object to our processing of your Personal Information (if processing is based on our legitimate interests) provided that we may retain your Personal Information for certain compelling purposes such as legal, auditing, accounting, and billing purposes.

  • the right to object at any time to our processing of your Personal Information for direct marketing purposes, including, without limitation, for profiling purposes to the extent that it is related to direct marketing. If you object to processing for direct marketing purposes, we will no longer process your Personal Information for such purposes.

  • the right to receive your Personal Information from us in a structured, commonly used and machine-readable format, and the right to transmit your Personal Information to another controller without hindrance from us (data portability).

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The following terms shall also apply to our collection, use, and retention of the Personal Information of applicable EU residents and in the event GDPR applies to our Services:

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Basis for collection. We collect and process Personal Information for which you have given your express consent at the time of collection or where we have another legitimate legal basis for such collection, such as a legitimate business interest in improving our Services, to deliver Services and perform obligations under contracts we have with you, and to comply with legal obligations.

Sensitive data. We do not intentionally collect sensitive data, for example, biometric data, health data, or data revealing racial or ethnic origin, from visitors to our Services.

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Onward transfer. Except as otherwise provided in this Privacy Policy, we only disclose Personal Information to third parties who reasonably need to have access to it for the purpose of the transaction or activity for which it was originally collected or to provide services to or perform tasks on our behalf or under our instruction. All such third parties must agree to use the Personal Information we provide to them only the purposes for which we have engaged them and they must either: (a) comply with a mechanism permitted by the applicable EU data protection law(s) for transfers and processing of Personal Information; and (b) agree to provide adequate protections for the Personal Information that are no less protective than those set out in this Privacy Policy. Where we have knowledge that an entity to whom we have provided Personal Information is using or disclosing Personal Information in a manner contrary to this Privacy Policy, we will take reasonable and appropriate steps to prevent, remediate or stop the use or disclosure.

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Authorized transfer. We also may disclose Personal Information for other purposes or to other third parties when you have consented to or requested such disclosure. Please be aware that we will disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are not liable for appropriate onward transfers of Personal Information to third parties.

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Data processors. We may retain third parties to process or analyze Personal Information we collect through our Services. For example, a site may be maintained or hosted by a third-party service provider or a promotion may be administered by a sales promotion agency. We take reasonable steps to ensure that these suppliers and other third parties who provide services for us are contractually obligated not to use Personal Information about you except as we authorize. 

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Profiling. We may analyze Personal Information we have collected about you to create a profile of your interests and preferences so that we can contact you with information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use Personal Information about you to detect and reduce fraud and credit risk. 

If you are located in the EU, and you are or have been our customer, we may send you marketing communications based on our legitimate interests, subject always to your right to opt out of such communications. Further, if you are located in the EU and the GDPR applies to us, we will not knowingly share your Personal Information with a third party for such third party’s marketing purposes, unless you have specifically consented to us doing so.

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You may contact us as indicated below to exercise any of the above rights. We may request specific information from you to confirm your identity, and in some circumstances we may charge a reasonable fee for access to your Personal Information. We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected Personal Information, or is someone authorized to act on such person’s behalf. Any Personal Information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

If you believe that our processing of your Personal Information is inconsistent with your data protection rights under the GDPR and we have not adequately addressed your concerns, you may have the right to lodge a complaint with the Data Protection Supervisory Authority of your country.

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For purposes of the GDPR, we are a “controller” and you are a “data subject.”

 

5. Updates, Access, Correction

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We may, from time to time, unilaterally modify the Privacy Policy without notice to you, so it is important that you review this Privacy Policy every time you use or access the Services. Such modifications by us are effective upon posting to the Services and your access to or use of the Services at any time constitutes acceptance of the Privacy Policy in effect at that time. Our use of Personal Information collected or obtained at any time is subject to the Privacy Policy in effect at the time of such use. 

This Privacy Policy supplements, but does not replace other applicable policies, practices, and privacy notices that may relate to specific business relationships you have with us or to certain products or Services, as described in the applicable privacy notice. At the start of our business relationship with you as a client, we will give you a copy of our privacy notice that applies to that relationship, if applicable. In the event of a conflict between this Privacy Policy and a privacy notice for a specific product or service, the specific product or service privacy notice shall govern.

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6. Contact

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Contacting RootedSparks 

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For clarification or if you have any concerns about the Privacy Policy or requests related to any Personal Information that we collect, use, or share about you, please write to us at hello@rootedsparks.com, and we will promptly respond.

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We will promptly investigate and attempt to respond in a manner that complies with the principles described in this Privacy Policy. 

 

Last Updated: July 2025

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