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Last Updated January 6, 2024
For information regarding the terms governing the use of the services, please see our Terms of Service.
This Privacy Policy explains how Sparrow Labs Inc. (“Company”, we,” “our”, “Sparrow”, “us” and other similar terms) collect, use, disclose, and protect information we collect through our online services, websites, mobile applications, and software provided on or in connection with the services and also any and all communications with us via phone, email, text or otherwise (each, a “Service” and collectively, “Services”). The gathering of information is always reasonable in relation to our business or the purpose for which the Services exist, and includes, without limitation, various information provided by you or your internet service provider (whether mobile data or otherwise, an “ISP”) to us. We in turn, gather information from, and share information with necessary parties with whom or which we have an ongoing business relationship or may need to come into possession of user information in order to enable, facilitate, or otherwise enhance your experience with the Services. We take each user’s data privacy seriously, and at all times endeavor to collect, compile, handle, store, and disseminate user data (whether or not Personal Information as defined below, “User Data”) in compliance with applicable law, including, as may be applicable to certain users, under either the 2018 California Consumer Privacy Act (the “CCPA”), or the European Union General Data Protection Regulation (the “GDPR”).
1.2. Please note, we have no control over the systems, websites, mobile applications, or other resources of third parties (“External Systems”). External Systems and the companies which operate them are responsible for complying with the CCPA and GDPR independently, and we do not assume any duty to ensure that an External System linked from, or which links to, the Resources, complies with the CCPA or GDPR.
When you use the Services, you consent to our collection, use, disclosure, and protection of information about you as described in this Privacy Policy.
BY ACCESSING OR USING THE SERVICES, YOU AGREE TO THIS POLICY. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE THE SERVICE.
2.1. “Personal Information” has varying definitions depending on the laws applicable to you. The Services are controlled and provided from within the United States, however, Company complies with laws and regulations applicable to its users.
2.2. As used in this Privacy Policy, Personal Information, includes, without limitation, information such as (i) contact data, including, your first and last name, driver’s license number, biometric information, user name or alias, physical street address, city, state, zip code, phone number and email address, (ii) financial data (such as banking information), (iii) demographic data (such as your zip code and gender), and (iv) other legal data (such as your social security number and other sensitive information) or any number of attributes, which taken together may identify you or enable you to be directly identified (such as physical, physiological, genetic, mental, economic, cultural or social characteristics).
2.3. Notwithstanding the fact that we may treat certain User Data as User Data which is not Personal Information, and cannot be used in order to identify a user (“Non-Personally-Identifiable Data”), we will always treat information based upon such applicable law’s characterization of Personal Information.
3.1.You may use certain aspects of the Services without giving away any Personal Information except for your IP address and certain other data provided by your ISP or device. We may use analytics tools, such as Google Analytics, and various cookies in order to improve and analyze the use of our Services. The information collected by these analytics tools is mostly anonymous traffic data including browser information, device information, language. We do not collect additional information, such as your age, gender, interests, clickstream, or anything associated with a so-called user “Internet passport.”
3.2. The following chart summarizes the type and character of User Data we collect, and gives certain examples of User Data which we do not collect.
| Type of User Data | Some Examples of This Type of User Data | Do We Collect This Type |
|---|---|---|
| Identifiers | A real name, Internet Protocol address, email address, or other similar identifiers. | We collect certain User Data provided by your ISP when you use the Services. We further collect this type of User Data pursuant to Section 3.3 below. |
| 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). | We will only collect this type of User Data to the extent you specifically provide it to us. |
| Commercial information and purchase history data | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | We may collect this type of User Data pursuant to Section 3.3 below, but only in connection with your use of the Services. |
| Biometric data | 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. | We do not presently collect any biometric data. |
| Internet or other similar network activity data | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | We may collect this type of User Data pursuant to Section 3.3 below. |
| Geolocation data. | Physical location or movements. | We may collect this type of User Data pursuant to Section 3.3 below. |
| Device sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | We may collect this type of User Data pursuant to Section 3.3 below. |
| Professional or employment-history and other information | Current or past job history or performance evaluations. | We will only collect this type of User Data to the extent you specifically provide it to us. |
| 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 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. | We will only collect this type of User Data to the extent you specifically provide it to us. |
| Collated User Data and inferred or interpolated User Data | User preference and habit profile data | We may collect this type of User Data pursuant to Section 3.3 below. |
3.3. We may collect User Data from the sources set forth below. This is not an exhaustive list, however we endeavor to make it clear when we collect Personal Information.
3.3.1. Registration information which you provide when registering for our services or products, offered through the Services or a third party’s services or products. For example, you will be required to submit Personal Information such as your name, address, email, and date of birth to verify your identity prior to establishing your account.
3.3.2. Billing information, such as a PayPal account number or credit card number, which is required to process the payment for the products or services you order from us.
3.3.3. Other information we collect, such as the city of your birth and your mother’s maiden name, which is used to verify your identity in the event you forget your login information required for our online products or services.
3.3.4.Information you provide to us in response to our communications. For example, we may request that you provide your e-mail address so that we may send you notifications, alerts, special offers and newsletters.
3.3.5. Information that you provide to us through customer service communications and correspondence and general feedback.
3.3.6. Geolocation information.
3.3.7. Information about your device, including your hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device’s interaction with the Services.
3.3.8. Information about how you use the Services, including your access time, “log-in” and “log-out” information, browser type and language, country and language setting on your device, Internet Protocol (“IP”) address, the domain name of your Internet service provider, other attributes about your browser, mobile device and operating system, any specific page you visit on our platform, content you view, features you use, the date and time of your visit to or use of the Services, your search terms, the Services you visited before you visited or used the Services, data about how you interact with the Services, and other clickstream data.
3.3.9. Information from sources other than the Services, as may be legally permissible.
3.3.10. As authorized by you, in connection with your order of certain products or services through the Services which require such User Data. For example, we may collect the following with your authorization: information from credit bureaus, financial institutions, background check reports from public records of criminal convictions, arrest records, and educational records.
3.3.11. We may obtain information about you from third parties in connection with any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies.
3.3.12. Information sourced from social or other new media plug-ins used for easy sharing and following our social media pages. Using our Services does not automatically result in sharing data on these social media networks. These plugins remain inactive (idle) until clicked upon. Once clicked upon, you will be taken to the said social media networks with their own specific privacy policies you are recommended to consult.
3.4. Cookies. A cookie is a piece of data stored on the hard drive of your computing device that contains information about you and that is used for record keeping purposes. Cookies enable us to track and target your interests to enhance your experience on the Services. We may set and access cookies on your computing device to provide you with customized content and to assist in providing the products that you have requested. We also work with companies who provide services to maintain the Services and enable those service providers the right to use cookies in our Services. Most cookies automatically delete themselves from your hard drive after each session. Like many other operators of websites and mobile applications, we may automatically track information based upon your behavior on the Services, including combining information that we obtain through the use of cookies with Personal Information, or other aggregate or anonymous data, including a unique identification we may assign you. The information may include browser type, internet service provider, referring/exit pages, platform type, date/time stamp, IP address, and number of clicks, all used to analyze trends, administer the Services, track your movement in the aggregate, and gather broad demographic information for aggregate use. Most web browsers and mobile device browsers are initially set up to accept cookies; however, you can reset your browser to reject all cookies. If you reject the cookie, you may still use the Services, although your access to and use of some areas of the Services may be limited. In addition, if you refuse to accept cookies you agree to assume all responsibility for any resulting loss of functionality. Some of the cookies used in the Services are set by us, and others are set by third parties who deliver services on our behalf. We may use cookies to:
3.4.1. Remember that you have visited us or used the Services before. This allows us to identify the number of unique visitors we receive, so that we can provide enough capacity to accommodate all of our users.
3.4.2. Customize elements of the layout and/or content of the Services, including, without limitation, advertisements and promotions.
3.4.3. Collect data about the way you interact with the Services (e.g., when you use certain features).
3.4.4. Collect data to assess and improve our advertising campaigns, including sending information to our business partners.
3.4.5. Allow our business partners (including third parties) to use these tracking technologies to track your behavior on the Services (including when you use multiple devices) and on partner External Systems.
3.4.6. Enable third parties to collect data about the way you interact across sites outside of the Services.
3.4.7. Collect anonymous statistical information about how you use the Services (including the length of your web or application session) and the general location from which you access the Services, so that we can improve the Services and learn which elements and functions of the Services are most popular with our users.
3.5. Third-Party Advertising And Analytics. We may use third-party service providers to provide site metrics and other analytics services. These third parties can use cookies, web beacons, and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access the Services, webpages viewed, time spent on webpages, links clicked, and conversion information (e.g., transactions entered into). This information may be used by us and third-party service providers on our behalf in order to analyze and track usage of the Services, determine the popularity of certain content, and better understand how you use the Services. The third-party service providers that we engage will at all times be bound by confidentiality obligations and other appropriate restrictions with respect to their use and collection of your information. Notwithstanding the foregoing protections, this Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices. For more information about targeted advertising specifically, please visit http://www.aboutads.info/choices. These third party service providers may make use of cookies to implement their services, as and where appropriate.
3.6. Web Beacons. Aspects and pages within the Services also may contain “web beacons” (also known as Internet tags, pixel tags and clear GIFs). A web beacon is an electronic image, often a single pixel (1×1), that is ordinarily not visible to Services visitors and may be associated with cookies on the visitors’ hard drives. Web beacons do not contain any Personal Information, and allow us to count users who have visited certain pages of the Services, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. Web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party. We use log files to store the data that is collected through web beacons.
3.7. Location Information. In order to provide certain services, we may require access to location information, including precise geolocation information collected from your browser or device. If you do not consent to collection of this information, certain services will not function properly and you will not be able to use those services. You may stop our collection of location information at any time by changing the preferences in your browser or on your mobile device.
4.1 Sparrow takes technical and organizational measures to protect your data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. These measures vary depending on the sensitivity of the information we have collected from you. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is absolutely secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. Sparrow is not responsible for the functionality or security measures of any third-party or Provider.
4.2 To protect your privacy and security, we take steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Sparrow, at all times. Do not share your password with anyone and do limit your access to your computer or other devices by signing off after you have finished accessing your account.
4.3 For information about how to protect yourself against identity theft, please refer to the Federal Trade Commission’s website at www.ftc.gov/news-events/media-Services/identity-theft-and-data-security.
5.1. We may use your information and/or combine any or all elements of your information for a number of purposes, including:
5.1.1. To provide you with and manage the Service. We use your information to provide, develop, maintain and improve our Service and the features and functionality of the Service. This may include customization and tailoring the Service features according to the information that you provide. We may use your information to develop new products and services. We may use your information to determine whether the Services, our products, and/or our services, as applicable, are available in your region or country.
5.1.2. To process and fulfill a request or other transaction submitted to us. We use your information to process or fulfill requests or transactions that you have requested. We may use your information to display your historical transaction information or Service use.
5.1.3. To communicate with you. We use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, changes/updates to features of the Service, support requests, including technical notices, security alerts, and support and administrative messages including to resolve disputes, collect fees, and provide assistance for problems with the Services or your user account). You may not opt out of Service-related emails.
5.1.4. Provide personalized services, including content, ads, products or services. We may use the information we collect to provide personalized services and advertising to you either through Sparrow or a third party marketing partner, subject to the requirements of the U.S. Consumer Privacy Notice.
5.1.5. Surveys, Offers, Sweepstakes. We may use your information to conduct surveys and offer sweepstakes, drawings, and similar promotions.
5.1.6. Marketing and Advertising. We may use your information to market and advertise our services and the services of certain third parties we work with to enhance our products or services to better suit your needs. When identifying methods of improving our products or services, or if we think a product or service may be of interest to you, we may extend select special offers of goods or services to you. If you would like to opt-out of receiving these offers, please refer to Your Rights and Choices section below.
5.1.7. Unique Identifiers. Sometimes, we (or our service providers) may use the information we collect – for instance, log-in credentials, IP addresses and unique mobile device identifiers – to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computer), or work with providers that do this, in order to better tailor advertising, content, and features, and provide you with a seamless experience across devices. If you wish to opt out of cross device tracking for purposes of interest-based advertising, you may do so through your Android or Apple device-based settings.
5.1.8. Research and Analytics. We may use your information for research and analytical purposes, for example, to identify trends and effectiveness of certain marketing campaigns we run.
5.1.9. Business Operations. We may use your information for certain operational purposes including, for example, perform audits and quality control.
5.1.10. To protect the rights of Sparrow and others. We may use your information as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, security, or property of Sparrow, its employees or agents, or other users and to comply with applicable law. We may use your information to comply with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process;
5.1.11. With your consent. We may otherwise use your information with your consent or at your direction.
5.1.12. To aggregate/de-identify data. We may aggregate and/or de-identify information collected through the Service. We may use de-identified and/or aggregated data for any purpose and without any restrictions, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.
5.1.13. Investigating, detecting, preventing, or reporting fraud, misrepresentations, security breaches or incidents, other potentially prohibited or illegal activities, or to otherwise help protect your account, including to dispute chargebacks on your behalf.
5.1.14. Enforcing our Terms of Service or other applicable agreements or policies.
5.1.15. Verifying your identity (e.g., through government-issued identification numbers).
5.1.16. Fulfilling any other purpose disclosed to you.
5.2 We 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.
5.2.1. We sometimes disclose the User Data we collect to companies that operate various services or third-party interfaces integrated into or made available through the Services.
5.2.2. When you provide Personal Information to one of the Services’ e-commerce providers, vendors or advertisers, this transaction will occur in connection with the site of the e-commerce provider, vendor or advertiser, not on the Services, and, as such, the Personal Information you provide is collected pursuant to and controlled by the privacy policy of such e-commerce provider, vendor or advertiser. Company is not responsible for such parties’ privacy policies and we encourage you to familiarize yourself with the applicable privacy policy of the e-commerce site with which you transact business or to contact the operator of such site for more information.
5.2.3. We may share your User Data as permitted by law.
5.2.4. We may disclose your Personal Information in special cases when we have reason to believe that disclosing this information is necessary: (a) to identify, contact or bring legal action against someone who may be causing injury to or interfering (either intentionally or unintentionally) with: (i) our legal rights or property, (ii) another visitor or anyone else that could be harmed by such activities; or (b) by operation of law or at the request for cooperation from law enforcement or another governmental agency.
5.2.5. In the event we go through a business transition, such as a merger, acquisition by another company, reorganization, a divestiture, a sale of all or a portion of our assets, or in the unlikely event of bankruptcy, your Personal Information and any information you provide to us will likely be among the assets transferred, and you hereby consent to such transfer.
5.3. Please note that when you disclose Personal Information through a forum, message board, blog, or other publicly visible features on the Services, the information may become public and accessible to all or a part of the Services’ userbase, so it is important for you to exercise discretion and appropriate caution when deciding to reveal Personal Information in these areas. In addition, when you choose to make a posting on such services, even if you do not directly disclose Personal Information, certain Personal Information associated with your user account, such as your alias (to the extent that it is Personal Information under applicable law), may be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose your Personal Information , or any other information, on the Services. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH THE Services VIA THESE FORUMS AND OTHER INTERACTIVE FEATURES.
6.1. We may use information about you for a number of circumstances, including as listed below. Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us.
6.1.1 Providers and co-signers. We may share your information with Providers for the purpose of providing the Service to you such that they may provide you with information about your request for prequalified rates, offers, and information related to other products and services they offer.
6.1.2 Service providers. We may share your personal information with third parties who work on behalf of, or with, us such as vendors, processors, agents and other representatives. Service providers assist us with a variety of functions. This includes, for example, assisting with customer service-related functions, providing advertising (including interest-based advertising) and analytics services (e.g., Google Analytics and Facebook Custom Audiences), helping us verify your identity, establishing your geographic location (Google Maps API(s)), obtaining your credit report, providing website hosting services (e.g., Amazon Web Services and Google Cloud Platform), assisting with auditing functions, and helping us with marketing and related research activities. By using Sparrow, you are bound by Google’s Terms of Service. Use of Google Maps features and content is subject to the then-current versions of the: (1) Google Maps/Google Earth Additional Terms of Service and (2) Google Privacy Policy.
6.1.3 Marketing partners. We may share your personal information with third-party marketing partners including partners who we conduct joint-marketing activities with or who we offer a co-branded service with. Marketing partners also include those entities who maintain a link to our Services on their site, or a Sparrow widget on their site, when you interact with that widget or click from their site to our Services, and entities to whose services we link on our site, or maintain a partner widget or form on our site, when you interact with that widget or click from our site to the marketing partner’s services.
6.1.4 Other parties when required by law or as necessary to protect our users and services. Sparrow may share your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) exercise or protect the rights, property, or personal safety of Sparrow, our Users or others.
6.1.5 Business transfers. We may buy or sell/divest/transfer Sparrow (including any shares in Sparrow), or any combination of its products, services, assets and/or businesses. Your information, which may include NPI, user names and email addresses, User Content and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of Sparrow.
6.1.6 Public Forums. Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings. Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users. If we remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. We are not responsible for the information that you choose to submit in your User Content.
6.1.7 Aggregated or de-identified information. We may also aggregate or de-identify data and may share that data without restriction.
6.1.8 Otherwise with your consent or at your direction. In addition to the sharing described in this Privacy Policy, we may share information about you with third-parties whenever you consent to or direct such sharing.
7.1. We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
In each case, please make clear in your email what you are opting-out from. We will try to comply with your request(s) as soon as reasonably practicable.
Please note that, if you opt-out as described above, we will not be able to remove your Personal Information from the databases of third parties with which we have already shared your Personal Information as of the date that we implement your opt-out request. Please note that you may still receive information from third parties to whom we have disclosed your information prior to the time you opted-out. You should contact each party in the event that you no longer want to receive information from such party. Please also note that, if you do opt-out from receiving marketing-related messages from us, we may still send administrative messages to you; you cannot opt-out from receiving administrative messages.
7.2 If you would like to review, correct, update, suppress, delete or otherwise limit our use of your Personal Information that you have previously provided to us or content you have previously posted on the Services, you may contact us by emailing us at support@sparrowfi.com. In your request, please make clear what Personal Information or posted content you would like to have changed or removed and what limitations (if any) you would like to place on our use of your Personal Information. We will try to comply with your request as soon as reasonably practicable. Please note that such request does not ensure the complete or comprehensive removal of Personal Information or content posted on the Services. For example, we may need to retain certain information or content for recordkeeping purposes, and there may also be residual information or content that will remain within our databases and other records that will not be removed. We are also not responsible for changing, removing or suppressing information or content from the databases of third parties with which we have already shared your Personal Information or content.
8.1. We are deeply committed to your right to privacy. However, please note that this Privacy Policy only applies to the Services and not to any External Systems that you may access from the Services, each of which may have privacy policies that are materially different from this Privacy Policy. We encourage you to be aware when you leave the Services and to read the privacy policies of each and every other website, mobile application, or other resource, as we are not responsible or liable for the commitments and obligations made to you in any privacy policy or the Terms of Service of any such Services.
9.1. We know it is very important to protect the information you share with us. We take appropriate security measures to help safeguard this information from unauthorized access and disclosure. For example, we restrict access to nonpublic Personal Information about you to our employees who need to have access to such information in order to provide products or services to you, as well as to authorized third parties (as stated above). We maintain physical, electronic, and procedural safeguards designed to protect your Personal Information. We protect your Personal Information over the internet by using a secure web server, which allows web applications and programs to interact with our web server via an encrypted session. If you access the Services via a traditional web browser, you will know you are in secured area by “https” or a lock appearing in the lower right hand corner of your browser window. When you use the Services, you may move in and out of secured areas.
9.2. You should feel confident using our Services. However, no system can be completely secure. Although we take very significant steps to secure your information, there is always a chance that your information will not always remain secure, or our computers or systems are illegally accessed, and the data on them stolen or altered. You should always take great care in handling and disclosing your Personal Information. For example, avoid sending Personal Information through insecure email.
9.3. Please refer to the Federal Trade Commission’s Services at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft. We assume no liability or responsibility to you or to any third party arising out of any loss, misuse, destruction, or alteration of your information.
10.1. Following the termination or deactivation of your User account, Sparrow may retain your profile information and User Content for an additional period of time for backup, archival, or audit purposes. In certain circumstances, we are required by Federal and State regulations to store various information. In order to comply with those requirements, we may be unable to delete your information from our database until the legally required retention period expires.
10.2. You have the right to request access to the information we have on you. You can do this by contacting us at support@sparrowfi.com. We will make sure to provide you with a copy of the data we process about you. In order to comply with your request, we may ask you to verify your identity. We will fulfill your request by sending your copy electronically unless the request expressly specifies a different method. For any subsequent access request, we may charge you with an administrative fee.
10.3 If you believe that the information we have about you is incorrect, you are welcome to contact us so we can update it and keep your data accurate.
10.4 If you wish to deactivate or cancel your account, you can do so by making a request to us by email or phone, using the contact details provided below.
11.1. In order to use the Services and/or its products and/or services, you must be at least 13 years of age. The Services is not directed to or intended for use by persons under the age of 13 and we are not knowingly soliciting Personal Information from such persons or sending them requests for non-public Personal Information. If we become aware that we have inadvertently received Personal Information directly from someone under the age of 13, we will delete such information from our records. If you are under the age of 13, you must not use our products or services, including sending us any Personal Information.
11.2 Further, if you are under the age of 18, or the age of consent in the applicable jurisdiction, you must have the consent of your parent or guardian in order to consent to this Privacy Policy, our Terms of Service, and use the Services (and the service delivered thereby).
12.1.We generally retain your information as long as reasonably necessary to provide you access to the Services and services delivered thereby, or to comply with applicable law. However, even after you deactivate your account, we may retain copies of information about you and any transactions or services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with the Services, to assist with investigations, to enforce our Terms of Service or other applicable agreements or policies, or to take any other actions consistent with applicable law.
13.1. We reserve the right to modify, add, alter or otherwise update this Privacy Policy from time to time, so you are encouraged to review this Privacy Policy from time to time. However, please note that each time you use the Services, the current version of this Privacy Policy will apply.
13.2. If we decide to change our Privacy Policy, we will date and post those changes on the Services so that you are always aware of what information we collect, how such information is used and under what circumstances, if any, such information is disclosed. Any and all changes to our Privacy Policy will also be reflected on this page. You can determine whether the Privacy Policy has been revised since your previous visit to the Services by referring to the “Last Updated” legend at the top of this page. Please read this Privacy Policy carefully. Your use of this Services constitutes your acceptance to be bound by this Privacy Policy without limitation, qualification or change. If at any time you do not accept all the Terms of Service contained herein, you must immediately discontinue use of this Services. If at any point we decide to use Personal Information in a manner different from that stated at the time it was collected, we will notify you by way of email and you will then have a choice whether or not we can use such information in this different manner.
14.1. This Privacy Policy is applicable to the Services offered by Company directly via our Services. Our Services may contain links to External Systems. Once redirected to another Services, this Policy is no longer applicable.
14.2. This version of the Privacy Policy is effective from July 14, 2021.
15.1 If you wish to exercise any right afforded to you herein or under applicable law, or if you have any additional questions about our collection and storage of data, please contact us at:
support@sparrowfi.com
15.2 If you have any questions or concerns regarding our notice, or if you believe our notice or applicable laws relating to the protection of your Personal Information have not been respected, you may file a complaint with our office listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.
| Reason | Requirements |
|---|---|
| Contractual necessity |
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| Consent |
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| Legitimate interests |
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“Data controller” and “data processor” are important concepts in understanding a company’s responsibilities under the GDPR. Depending on the scenario, a company may be a data controller, data processor or both, and will have specific responsibilities as a result: A company is a data controller when it has the responsibility of deciding why and how (the “purposes” and “means”) the Personal Information is processed.
Under the GDPR, data controllers must adopt compliance measures to cover how data is collected, what it’s used for and how long it’s retained. They will also need to make sure people can access the data about them. Data controllers must ensure data processors meet their contractual commitments to process data safely and legally. This Privacy Policy sets forth and discussed all matters in relation to our activities, if any, as a data controller.
A company is a data processor when it processes Personal Information on behalf of a data controller. Under the GDPR, data processors have obligations to process data safely and legally. This Privacy Policy sets forth and discussed all matters in relation to our activities, if any, as a data processor.
Any transfer of Personal Information outside of the EEA (European Economic Area) must meet certain legal requirements. To the extent we are in receipt of Personal Information being transferred from inside the EEA to any region outside the EEA, we will at all times comply with applicable restrictions.
To the extent that we operate as a data controller and/or processor, our workplace will at all times be cognizant of applicable restrictions, and comply therewith.
The Family Educational Rights and Privacy Act (“FERPA”) as set forth in 20 U.S.C. § 1232g; 34 CFR Part 99) is a Federal law that protects the privacy of student education records. The law applies to all educational agencies and institutions that receive funds under any program administered by the Department of Education (“DOE”).
To the extent that we are subject to FERPA, this Rider sets forth our treatment of certain information which is subject to the regulations of FERPA.
In using the Services, you may provide us with student data or interact with student data that has already been provided to us.
To the extent you provide us with records which may be subject to, or protected by, FERPA, you will control what data is provided to us. Student data provided to us via the Services should be limited to the information necessary for you to properly utilize the Services. We will not ask you to provide, and you should not to enter, data about yourself or other persons protected under FERPA which is not reasonably necessary to avail yourself of the Services (and otherwise in furtherance of an educational purpose).
| What does Sparrow do with your personal information? | |
| Why? | Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
| What? | The types of personal information we collect and share depend on the product or service you have with us. This information can include: – Social Security number and income – Account balances and transaction history – Credit scores and employment information |
| How? | All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Sparrow chooses to share; and whether you can limit this sharing. |
| Reasons we can share your personal information | Does Sparrow share? | Can you limit this sharing? |
| For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
| For our marketing purposes – to offer our products and services to you | Yes | No |
| For joint marketing with other financial companies | Yes | Yes |
| For our affiliates’ everyday business purposes – information about your transactions and experiences | Yes | No |
| For our affiliates’ everyday business purposes – information about your creditworthiness | Yes | Yes |
| For our affiliates to market to you | Yes | Yes |
| For nonaffiliates to market to you | Yes | Yes |
| To limit our sharing | Contact us at support@sparrowfi.com Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. |
| Questions? | Visit sparrowfi.com or contact us at support@sparrowfi.com |
| Who We Are | |
| What We Do | |
| Who is providing this notice? | Sparrow Labs Inc., a Delaware corporation, and its subsidiary companies. |
| How does Sparrow protect my personal information? | To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. |
| How does Sparrow collect my personal information? | We collect your personal information, for example, when you – Open an account or submit a pre-qualification request – Provide income or employment information – Provide account or contact information We also collect your personal information from others, such as credit bureaus, affiliates, or other companies. |
| Why can’t I limit all sharing? | Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes — information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you. State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law. |
| What happens when I limit sharing for an account I hold jointly with someone else? | Your choices will apply individually unless you tell us otherwise. |
| Definitions | |
| Affiliates | Companies related by common ownership or control. They can be financial and nonfinancial companies. |
| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies. Non-affiliates with whom we share can include service providers, co-branded partners, financial service companies, data processors, lenders, insurance companies, retailers, advertisers, and companies that help us market our own products and third-party products that we believe may be of interest to you. |
| Joint Marketing | A formal agreement between non-affiliated financial companies, that together market financial products or services to you. Our joint marketing partners include other financial service companies, banks, lenders, insurance companies or other consumer service companies. |
| Other Important Information | |
| California Customers | The California Financial Information Privacy Act and California Consumer Privacy Act provide additional protections with regards to the collection, use, sharing, and sale of your information. We will not share information we collect about California residents with outside companies, except as permitted by law, such as with your consent or to service your account. Please see the “California Consumer Privacy Act Notice for California Consumers” section of Sparrow’s Privacy Policy at www.sparrowfi.com/privacy for more information about your privacy rights. |
| Nevada Customers | We are providing you this notice pursuant to state law. You may be placed on our internal do-not-call list by calling us at (646) 980-4056 or emailing us at support@sparrowfi.com. For more information, you may contact Sparrow at support@sparrowfi.com or the Bureau of Consumer Protection, Office of the Nevada Attorney General by mail at 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; telephone at 888-434-9989; or email at AgInfo@ag.nv.gov. |
| North Dakota Customers | We will not share personal information with nonaffiliates, except as permitted by law, such as to process your transactions or to maintain your account. |
| Texas Customers | For questions or complaints, contact Sparrow at (646) 980-4056 or support@sparrowfi.com. If a complaint or question cannot be resolved by contacting the lender, consumers can contact the OCCC to file a complaint or ask a general credit-related questions. OCCC address: 2601 N. Lamar Blvd., Austin, Texas 78705. Phone: (800) 538-1579. Fax: (512) 936-7610. Website: occc.texas.gov. Email: consumer.complaints@occc.texas.gov. |
| Vermont Customers | We will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional information concerning our privacy policies can be found at www.sparrowfi.com or by calling (646) 980-4056. |
California Consumer Privacy Act Notice for California Consumers
This California Consumer Privacy Act Notice for California Consumers (“CCPA Notice”) supplements Sparrow Labs Inc.’s, (“Company” or “Sparrow”) Privacy Policy and Gramm-Leach-Bliley Act (“GLBA”) notice. This notice applies solely to California residents. The California Consumer Privacy Act (“CCPA”) affords California consumers certain rights over their personal information (subject to certain exceptions). This CCPA Notice outlines those rights and explains how such rights may be exercised. This CCPA Notice also summarizes our data collection and sharing practices, as required by the CCPA. Terms used but not defined shall have the meaning ascribed to them in the CCPA. For the purpose of this CCPA Notice, we refer to our websites, applications that run on mobile devices and tablets, call centers, and other products and services as “Services” or “Sites.”
1. What Information is Covered by this CCPA Notice?
This CCPA Notice relates to the Company’s collection, use and disclosure of California consumers’ personal information. “Personal information” generally means information that is reasonably capable of being associated with you or your household. For a specific list of the categories of personal information we collect, please see Section 5 (Summary of Collection, Use and Disclosure of Personal Information) below.
2. Where Do We Collect Personal Information From?
For a list of the categories of sources from which we may collect personal information, please see Section 5 (Summary of Collection, Use and Disclosure of Personal Information) below.
3. How Do We Use Personal Information?
We may use your personal information for a variety of “business purposes” and “commercial purposes,” as defined by the CCPA. “Business purpose” means the use of personal information for an operational or other notified purpose including, for example, performing services on behalf of another organization. “Commercial purpose” refers to when we use personal information for commercial or economic interests including, for example, by marketing our Services. For a detailed list explaining how we may use personal information, please see Section 5 (Summary of Collection, Use and Disclosure of Personal Information) below.
4. Who Do We Share Personal Information With?
We may share your personal information with the third parties described below. For a more detailed summary of who we may share your personal information with, see Section 5 (Summary of Collection, Use and Disclosure of Personal Information) below.
5. Summary of Collection, Use, and Disclosure of Personal Information.
The table below summarizes our collection and sharing practices relating to personal information, including with respect to personal information we have collected, used and disclosed in the preceding 12 months. As shown below, we may have disclosed or sold your personal information to third parties for a business or commercial purpose in the preceding 12 months. For all of the categories of personal information identified below, we may use your personal information for disclosures relating to Corporate Transactions and Special Circumstances. As such, all personal information may be shared with Corporate Transaction Recipients and Special Circumstances Recipients.
| Categories of Personal Information Collected | Categories of Sources from which the Personal Information was Collected | Business or Commercial Purposes for which Personal Information was Collected | Categories of Third Parties with Whom We May Have Shared Personal Information | Disclosed for a Business Purpose (Y/N) | Disclosed for a Commercial Purpose (Y/N) |
|---|---|---|---|---|---|
| Identifiers such as name, Social Security number, address, telephone number, driver’s license or state identification card number, bank account number, loan identifier, credit card information, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or any other similar identifiers | – Information collected directly from you (including online and offline) – Providers – Service Providers – Information automatically derived from use of our Services (e.g., through cookies) | – Provide, develop, maintain and improve our Services – Process and fulfill a request or other transaction submitted to us – Communicate with you (e.g., to schedule meetings with you or to answer questions relating to our Services) – Provide personalized services, including content, ads, products or services – To conduct surveys and offer sweepstakes, drawings, and similar promotions – Marketing and advertising our Services and the services of other third parties – Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns) – For our business operations (e.g., auditing transactions and performing quality control) | – Providers – Service Providers – Co-Signers | Yes | Yes |
| Characteristics of protected classifications under California or federal law (e.g., race, religion, and gender) | – Information collected directly from you (including online and offline) | – Process and fulfill a request or other transaction submitted to us – Provide personalized services, including content, ads, products or services | – Providers | Yes | No |
| Records of personal property, property-related details, existing loan information (e.g., lender name, estimated balance, type of loan), assets owned, sources of assets) | – Information collected directly from you (including online and offline) – Service Providers – Publicly accessible sources – Organizations that we enter into contractual agreements with to license/purchase personal information | – Process and fulfill a request or other transaction submitted to us – Provide personalized services, including content, ads, products or services – Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns) – For our business operations (e.g., auditing transactions and performing quality control) | – Providers – Service Providers – Co-Signers | Yes | Yes |
| Internet or other electronic network activity information, including browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement | – Information collected directly from you (including online and offline) – Information automatically derived from use of our Services (e.g., through cookies) – Service Providers | – Provide, develop, maintain and improve our Services – Provide personalized services, including content, ads, products or services – Marketing and advertising our Services and the services of other third parties – Research and analytical purposes (e.g., identifying trends and effectiveness of marketing campaigns) | – Providers – Service Providers – Marketing Partners | Yes | Yes |
| Professional or employment-related information (e.g., employment history) or education information | – Information collected directly from you (including online and offline) | – Process and fulfill a request or other transaction submitted to us – Provide personalized services, including content, ads products and services | – Providers | Yes | Yes |
| Information you provide in reviews, questions, and comments | – Information collected directly from you (including online and offline) | – Provide, develop, maintain and improve our Services – Marketing and advertising our Services and the services of other third parties – For our business operations (e.g., auditing transactions and performing quality control) | – General Public – Providers | Yes | Yes |
6. Children
Our Site and Services are not intended for minors under 16 years of age. As such, we do not knowingly collect or maintain any data from minors under 16 years of age and, as such, do not sell personal information of minors under 16 years of age.
7. Your CCPA Rights
Subject to certain exceptions, the CCPA affords you the following rights with respect to your personal information. It’s worth noting that these rights do not apply to personal information we collect about California consumers who apply for or obtain a financial product and service for personal, family, or household purposes (in other words, information regulated by the Gramm-Leach-Bliley Act). For information about how we collect, disclose and use information relating to these consumers and the choices relating to such information, please refer to our GLBA Notice.
| Access to Specific Information and Data Portability Rights | You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verified request in compliance with the CCPA, we will provide a report to you which sets forth the following with respect to you: (i) categories of Personal Information collected (ii) sources for such collection, (iii) our business or other commercial purpose for selling any such Personal Information, (iv) categories other third parties with which we have shared your Personal Information, (v) the specific scope of any information shared to those third parties, and (vi) if we have sold or transferred your Personal Information, separate lists which set forth (1) each sale, with the categories transferred to each purchaser, and (2) each business-related transaction, with the categories used in connection therewith. |
| Deletion Request Rights | You have the right to request that we delete any of your Personal Information in our possession and collected from the Services, subject to certain limitations or exceptions. Once we receive and confirm your verified request in compliance with the CCPA, we will delete your Personal Information from our records, unless a limitation or exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (i) complete a transaction for which we collected such Personal Information, provide a good or service that you requested and do not wish to terminate or rescind, or otherwise carry out any obligations which are or may become necessary to consummate any obligations to you or requests by you, (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, (iii) maintain, repair, or improve the Services, including the correction of errors that impair existing intended functionality, (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law, (v) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.), (vi) 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, (vii) facilitate any lawful internal use or review in connection with our internal processes, or (viii) comply with any law, regulation, order of governmental authority, or other legal process. |
| Exercising Access, Data Portability, and Deletion Rights | To exercise the access, data portability, and deletion rights described above, please submit a verified request in compliance with the CCPA. You may make such a request on your own behalf, on your minor child’s behalf, or on behalf of any entity for which you are a duly appointed representative listed on the California Secretary of State’s website. You may only make such a request for access or data portability twice within a 12-month period with respect to any specific user. Please provide us sufficient information to verify user with respect to whom the request relates, and that you have authority on behalf of such user. Always describe your request with sufficient detail to enable our understanding, response, and implementation. |
| Response Timing and Format | We make commercially reasonable efforts to respond to a verified request in compliance with the CCPA within forty-five (45) days of receipt of each request. We will inform you as soon as practicable if we believe we require more to evaluate or undertake your requested actions. We will deliver our written response by mail or electronically, at your option, at the contact information you provide with your request. Any disclosures we provide will only cover the 12-month period preceding our receipt of the verified request in compliance with the CCPA. If we are unable to comply in part or in full, we will provide our reason with the reply to a request. With respect to any data portability request, we will select data formats in our reasonable discretion. We reserve the right to charge a reasonable fee to you for our cost and administrative expense in connection with any request under the CCPA, if your exercise of right is excessive, repetitive, patently unreasonable or without basis, or is otherwise intended to harass, pester, or hinder us or our Services. We will notify you of any fees with our response to a request under the CCPA. |
| Personal Information Sales Opt-Out and Opt-In Rights | If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers whom we actually know are younger than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer or parent or guardian of a consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by email at the address below. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by visiting our website and sending us a message. We will only use Personal Information provided in an opt-out request to review and comply with the request. |
| Non-Discrimination | In making the Services available, we will not discriminate against you for exercising any of your rights under the CCPA. Subject to exclusions under the CCPA, we will not as a result of your exercise of rights under the CCPA (i) deny you goods or services generally available through the Services, (ii) charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, (iii) provide you a lesser level or quality of goods or services, or (iv) imply or suggest that you may receive a different price or rate for goods or services, or a different level or quality of goods or services. Notwithstanding the foregoing, we may offer you certain financial incentives permitted by the CCPA which proximally or actually result in different prices, rates, or quality levels. Any such financial incentive will reasonably relate to the value of the Personal Information to which it relates, provide a disclosure of material terms, and provide an opt-in, which may be revoked at any time. |
8. How to Exercise Your CCPA Rights
You may designate an authorized agent to submit a request on your behalf. We may require that you provide the authorized agent with written permission to act on your behalf and that you verify your identity directly with us.
9. Alternate Format of CCPA Notice.
If you have a disability that prevents or limits your ability to access this CCPA Notice, please email us at support@sparrowfi.com or call us at (646) 980-4056. We will work with you to provide this notice in an alternative format.
10. Contact for More Information.
If you have any questions or concerns about our privacy policies and practices, please email us at support@sparrowfi.com or call us at (646) 980-4056.