Privacy Policy

SPARK® PRIVACY POLICY – U.S. Users Only

Effective as of January 18, 2020

Please read this Privacy Policy carefully, as it is a material part of the contractual agreement between you, the user, and Spark Healthcare Consultants, LLC and Spark CME, LLC (collectively, “SPARK”), which you agreed to as part of our Terms and Conditions, by creating an account for use of our website www.spark-partners.com or use of our mobile applications or affiliated websites, including www.beaconlearningapp.com and www.sparkcme.org (collectively the “Solutions”).

We take your privacy seriously. This Privacy Policy describes the ways we or our vendors collect, protect, use, share, and store your personal information. If you do not agree to this Privacy Policy or our Terms and Conditions, do not use any of the Solutions.

Business name and contact information (see also “Contact US” below)

Carol Capece for SPARK Healthcare Consultants
114 Pierrepont Street, Suite 8
Brooklyn, NY 11201
202-486-0783

carol@spark-partners.com

Stephen Robins for SPARK CME
380 Riverside Drive, Suite 2M
New York, NY 10025
917-453-0562

steve@sparkcme.org

Stephen Robins for Beacon Learning App
380 Riverside Drive, Suite 2M
New York, NY 10025
917-453-0562

info@beaconlearningapp.com

Types of Personal Data We Collect

Information You Give Us

We collect information that personally identifies you when you register, sign in, use the Solutions, and/or make changes to your account, including your first name, last name, and email address. In addition, in the course of your use of the Solutions, we collect and associate with your SPARK account (or affiliated product account) de-identified personal information about your engagement with the Solutions, such as time spent, questions completed, and information about your level of knowledge of the topics covered by the Solutions you use. Our collection of this information is made directly from you and your interactions with our Solutions.

We respect the right to privacy of all users of the Solutions. You may restrict the information provided to the Solutions. For example, you may decline to provide us with some or all of your information that personally identifies you; however, restricting the information you provide will materially reduce and diminish the value of the Solutions to you, and may prevent you from using certain functionalities or Solutions at all.

In addition, when you contact us with customer service inquiries or other queries relating to the Solutions, Terms and Conditions, or this Privacy Policy, we may collect personal information you provide for purposes of addressing your queries and retain this information in accordance with our retention policy.

Information We Collect from Other Sources

SPARK, either directly or through its authorized third-party service providers, also collects aggregate information about the use of the Solutions, including information about your access and visits to the Solutions, such as internet protocol addresses, browser type, browser language, referring/exit pages and URLs, other browser history, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, geolocation, and the date and time of use, some of which may uniquely identify your browser or your account. We collect this information in a variety of ways, including from web forms, technologies like cookies or other anonymous identifiers, web logging, and software on your computer or other devices. When you visit the Solutions, we store information based on your usage history. We also use cookies and anonymous identifiers when you interact with the services we may offer to our partners as discussed below in the section entitled Cookies.

Either directly or through our authorized third-party service providers, we may also collect non-personal information about your use of the Solutions and produce and use aggregated and anonymized information derived from your personal information. This may include de-identified search results and information collected by cookies and similar technologies as described below.

While, as noted above, we collect personal information in connection with the Solutions and for purposes of performing our services, we do not collect any more information than reasonably needed to offer our services as described on the Solutions.

How We Use Your Data

How we use your personal information will depend on which Solutions you use, how you use those Solutions, and the choices you make in your settings. We use the personally identifiable information we collect for purposes of:

  • performing and improving our services
  • addressing any inappropriate use of the Solutions
  • producing reports for internal use by SPARK

We recognize that maintaining the privacy of your information is important. The information that you submit and that personally identifies you or is associated with your account is shared only with (i) those persons you expressly authorize via the Solutions to receive such information and (ii) those persons in the SPARK organization (e.g. employees, affiliates, vendors, partners, and third parties) who need to access such information in order to perform the services offered by SPARK or who will utilize the information to improve SPARK’s operations.

WE DO NOT SELL OR RENT INFORMATION THAT PERSONALLY IDENTIFIES YOU TO ANY OTHER PARTIES. WE DO NOT SHARE YOUR INFORMATION TO SOCIAL NETWORKS OR OTHER PUBLIC OR SEMI-PUBLIC PLACES. SPARK may however access, preserve, and disclose any information we may have about you and the contents of your account if required to do so by law or in a good faith belief that such access, preservation, or disclosure is reasonably necessary to avoid liability, to comply with legal process, such as a search warrant, subpoena, statute, or court order, or to protect our rights and property, or that of our affiliates or the public. SPARK is not required to question or contest the validity of any search warrant, subpoena, or other similar governmental request that it receives. We may also transfer any information in our possession to a third party in the event of a reorganization, sale, merger, or transfer of some or all of our assets to such third party.

Any other information that personally identifies you or that is associated with your SPARKaccount is used or shared only on an aggregated and de-identified basis.

 SPARK reserves the right to use such aggregated and de-identified non-personal information collected from its users for any reason in our sole discretion, including but not limited to performing statistical analysis of the aggregated information, including analysis about the behavior of visitors to the Solutions on an aggregated, anonymous basis, or to share such information with third parties. SPARK may share de-identified personal information with pharmaceutical, biotech, and device manufacturers; insurance companies; healthcare providers; Medicare; hospital systems; medical schools; medical professional organizations; and other healthcare-focused organizations who provide and develop drugs for patient treatment, approve payment for such treatment, educate healthcare providers, and render other services, such as information processing and assessing the success of certain treatments. SPARK may be compensated by its third-party business partners. We do not give our partners an independent right to share this information. However, due to our contractual obligations with these third parties and the need to share information to deliver and support the Solutions, we cannot provide you with the opportunity to opt-out of sharing de-identified information with these third parties. SPARK may view the content that you voluntarily submit via the Solutions and otherwise perform the tasks set forth in this Privacy Policy.

Cookies

Information (including aggregate, technical, or demographic information) can also be collected by us or by our authorized third-party service providers through the standard operation of our Internet servers and logs as well as other automatic data collection tools such as “cookies” and other similar technologies. By using the Solutions, you consent to the placement and use of cookies and similar technologies on your hard drive or computing device.

The Solutions may send “cookies” to your computer or smartphone when you access them and use such cookies as described here. The Solutions use cookies to improve the quality of our service, make recommendations, and make the Solutions easier to use for our members. A cookie is a small text file that is recorded either temporarily or persistently on your device and that a website or app operator can use in order to recognize visitors who revisit a Site so as to facilitate their ongoing access to and use of such Site. Some cookies may identify you as a unique user and contain certain information about your particular login session and/or your use of the Solutions.

The Solutions use the following services and related cookies:

  • We use Google Analytics to help us understand how visitors navigate to and through our Solutions. These cookies enable the function of Google Analytics. This service helps us evaluate how long customers spend visiting different pages and how often they return to our Solutions. Google Analytics also assists our marketing colleagues to determine the effectiveness of our digital marketing campaigns that feeds into the commercial relationship held with Google. These cookies do not collect and are not associated with personal information.

How Google uses data when you use our Solutions

You can opt out of Google Analytics HERE.

You may disable cookies in your web browser but doing so will impact the usability of the Solutions and may prevent you from using certain functionalities or Solutions at all.

To the extent the Solutions link to other websites, be sure to review the Privacy Policy on the websites you are visiting, as many such websites have their own policies regarding cookies and the collection and use of personal information.

Accessing and Updating Personal Information

The Solutions are configured to give you the means to access your own personally identifiable information for the purposes of correcting it.  If you have created an account on one of the Solutions, you can edit some of your personal data through your account’s customer dashboard. You can also ask us to change, update, or fix your data in certain cases, particularly if it’s inaccurate. You can ask us to stop using all or some of your personal data (e.g. if we have no legal right to keep using it) or to limit our use of it (e.g. your personal data is inaccurate or unlawfully held). To request that your account be deleted, or to access certain personal information we hold about you, contact us at info@beaconlearningapp.com, steve@sparkcme.org or at the address stated below in the “Contact Us” section. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required.

Portability of Your Personal Information

The information associated with your account may be downloaded for portability through your account for the Solutions. As noted above, you can terminate your account at any time, which will remove your profile and other personal information from view. Please be aware that if you delete your personal information, you may not be able to continue to use our Solutions.

Data Retention

We will retain your contact information for as long as your account is active or as needed to comply with our legal obligations, resolve disputes, and enforce our agreements. You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to provide services to you). We may retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms and Conditions, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed, but will destroy your personal data when it is no longer needed for the foregoing purposes, or we remove your personal information to render it anonymous. Notwithstanding the above, you agree that SPARK is not, and will not be, liable for any damages in the event that your information is not retained or otherwise lost or destroyed. Please note that we may not be able to delete all of your data upon request depending on the reasons above and the nature of your interactions.

Protecting Your Privacy

We use reasonable security measures to protect the confidentiality of your personal information under our control and appropriately limit access to it. We monitor for and try to prevent security breaches. We use a variety of information security measures to protect your online communications with us. If you have any questions regarding which measures and techniques we use, feel free to contact us. However, no data transmission over the Internet and no method of data storage can be guaranteed to be secure. SPARK does not guarantee the security of any of your private transmissions against unauthorized or unlawful interception or access by third parties.

Minors

The Solutions are not intended for use by anyone under the age of 13. If you are under 13, please do not attempt to create an account or send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal information to us, and we do not knowingly collect personal information from anyone under the age of 13. If we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under the age of 13, please contact us immediately.

California Online Privacy Protection Act (CalOPPA)

CalOPPA requires a person or company in the United States that operates websites collecting personally identifiable information from individual consumers residing in California to post a conspicuous privacy policy on its website stating exactly what information is being collected and to which individuals it is being shared, and to comply with this policy. See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf.

California Customers may request further information about our compliance with California’s privacy law, and may request to review and request changes to their personal information collected and stored by SPARK by e-mailing carol@spark-partners.com or contacting us as stated below.

According to CalOPPA, Spark agrees to the following (relating to websites only and not mobile applications):

You can visit this website anonymously. Users will be notified of any privacy policy changes on our Privacy & Confidentiality page.

Users are able to change their personal information by registering for updates or providing comments at info@beaconlearningapp.com.

How does this website handle do not track signals?

SPARK honors “Do Not Track” signals and does not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does this website allow third party behavioral tracking?

Yes, SPARK uses Google Analytics for third-party behavioral tracking, as described above.

What are the third parties with whom SPARKmay share personal information?

Currently, we do not share your personal information with third parties for direct marketing purposes. Information may be shared to our service providers, exclusively for purposes of the performance of their services.

What is the effective date of this Privacy Policy?

This Privacy Policy’s effective date is indicated above before its first paragraph.

Fair Information Practices

Further, in order to comply with Fair Information Practices principles articulated by the Federal Trade Commission (https://www.ftc.gov/reports/privacy-online-fair-information-practices-electronic-marketplace-federal-trade-commission), SPARK will notify users of this website who have provided an email address to us via this website via email within 7 business days, should a data breach occur.

SPARK also agrees to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

Special Note for Non-U.S. Individuals

The Terms and Conditions of service for the Solutions do not permit the use of the Solutions outside of the United States and prohibit individuals who are not residents of the United States from entering personal information into or by means of the Solutions. SPARK generally maintains servers and systems in the United States hosted by third-party service providers. We also may subcontract the processing of your data to, or otherwise share your data with, other third parties in the United States or countries other than your country of residence.

Links to Other Websites

Solutions may link to other websites, many of which have their own policies regarding cookies and the collection and use of personal information. Be sure to review the Privacy Policy on the website you’re visiting.

Privacy Policy Updates

We may need to update our Privacy Policy as technology changes and SPARK evolves. This Privacy Policy was last updated as of the date indicated above before the first paragraph of this Privacy Policy.

We encourage you to periodically review this page for the latest information on our privacy practices. You can always check the “last updated” date at the top of this document to see when the Privacy Policy was last changed.

Your continued use of the Solutions and/or services following the effective date of an updated Privacy Policy constitutes your consent to the contents of such policy. However, we will not apply any material changes retroactively to any information we collected from you before such changes took effect, without your affirmative consent to do so. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE SERVICE AFTER THE EFFECTIVE DATE OF SUCH CHANGES. Please note that upon your departure from our services, any Privacy Policy in effect immediately prior to your departure shall continue to be binding on you and applicable to the data collected from you prior to such departure.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, you should contact us at info@beaconlearningapp.com, or at:

Beacon Learning Customer Support
380 Riverside Drive, Suite 2M
New York, NY 10025
917-453-0562

We offer you choices about how to manage how we communicate with you.

  • Email/Direct Mail. You may opt out of receiving marketing emails from us at any time by sending an email to info@beaconlearningapp.com or by clicking on the unsubscribe link in our emails. You will continue to receive service-related emails to opt out of direct mail, please send your request to info@beaconlearningapp.com and include your postal address in the body of the email.
  • Targeted Advertising. If you do not want information about your activity on our Solutions to be used for tailored advertising, please visit the page hosted by the Network Advertising Initiative and follow the instructions there.
  • Updating Your Profile. You may update or correct your personal information related to your account through your dashboard of your account or by contacting Customer Support at info@beaconlearningapp.com. If you wish to request deletion of your personal information, then please contact us at info@beaconlearningapp.com. We will respond to requests within a reasonable timeframe.