SPARKMESH PRIVACY POLICY

This privacy policy (this "Privacy Policy") tells you about the information that Sparkmesh ("Sparkmesh," "we," "us" or "our") collects in connection with the operation of our platform, including the website available at www.sparkmesh.com, all related mobile applications and our integrated services on affiliate platforms, where we make available to users various services, including live and recorded video posting, broadcast, text comment posting and all other related online services offered by Sparkmesh (collectively, the “Service”), how the information is used and how you can access and correct certain information that we may collect. “Sparkmesh,” “we” or “us” refers to Sparkmesh and the Sparkmesh Corporate Family in this Privacy Policy. The Sparkmesh Corporate Family means Sparkmesh, LLC. and its subsidiaries, parent companies, oint ventures and other corporate entities under common ownership and/or any of their agents, consultants, employees, officers and directors.

This Privacy Policy is intended to provide adequate and consistent safeguards for the handling of personal information in accordance with Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “Directive”) and all the relevant transposing legislation of the Directive in the European Union/European Economic Area, the Swiss Federal Data Protection Act, as such laws may from time to time be amended and valid during the application of this Policy, the Privacy Shield, and any other privacy laws, regulations and principles concerning the collection, storage, use, transfer and other processing of personal data transferred from the European Economic Area or Switzerland to the United States including but not limited to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC as of its entry into force on 25 May 2018.

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (as defined by applicable California law) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. Sparkmesh does not currently disclose personal information to third parties for their direct marketing purposes unless you specifically ask us to do so.

We respect your privacy and are committed to protecting your personal identifying information. We agree to use the following guidelines when processing data containing personally identifying information:

When you visit this Service, certain non-personally identifying information is recorded automatically by the standard operation of our Internet servers. Information such as the type of browser being used, its operating system, and your computer's Internet Protocol ("IP") address (a number that your Internet service provider assigns to your computer whenever you surf the Internet) is gathered in order to facilitate our Service and to assure an efficient online experience for users. If you access our Service from a mobile or other device, we may collect information for that device (including operating system, browser, type of device) in order to facilitate our mobile Services. We may use or share this information for security purposes, to generate aggregated statistics about our users or as required by law.

If you access our Service from a social media platform (i.e. Facebook, Instagram, Twitter, etc.) Sparkmesh receives certain information about you from the social media platform automatically. The information received depends on the Service, the social media platform, and the privacy settings on the social media platform set by users. If you access our Service from a social network, you should also read that social network’s Terms of Service and Privacy Policy.

Some parts of the Service do not require the use, collection or processing of any personally identifying information, however in order to use some features of the Services users may be required to provide personal information in order to (1) complete an online registration form (e.g., registering for an account, various sign-up forms for receiving email newsletters, registering for special offers or responding to a survey); (2) fill out an order form to request information; (3) register to participate in broadcasting videos or posting on message boards (if any) and other community features; or (4) purchase any products or services from us or another Sparkmesh business. Additionally, when you ask for help from our Customer Support team, we will collect and store the contact information you provide, in order to provide support and improve the Service.

Sparkmesh uses the information you provide (whether such information is personally identifying information or otherwise) to (i) operate, maintain, enhance, provide, create, and develop all of the features, functionality, and services (new or existing) found on the Service; (ii) provide security for our websites, mobile palatiform, integrated programs, products, software, or applications; (iii) manage relationships with Sparkmesh account holders, including making or receiving payment; (iv) improve your experience with the Service by providing content recommendations and by delivering content we think you will find relevant and interesting, including advertising and marketing messages; (v) allow you to comment on content, and participate in online games, contests, or rewards programs; (vi) prevent fraud and abuse; and (vii) understand the usage trends of our users.

Sparkmesh uses the information you provide (whether such information is personally identifying information or otherwise) with our promotional partners and third-party advertisers. In such instances, our general practice is to ask you to "opt-in" to share such. However, in some instances, we may ask you to "opt-out" from sharing such information with a promotional partner or third party advertiser in connection with a specific promotion, registration page or contest. If you prefer, you may give us blanket permission to share your information with all of our promotional partners and third-party advertisers. Conversely, you may also choose not to allow us to share your information with any other companies outside Sparkmesh.

Sparkmesh will disclose your information to service providers working on our behalf, such as, to (i) provide online hosting, maintenance, and security services; (ii) fulfill orders; (iii) conduct data analysis and create reports; (iv) offer certain functionality; or (v) assist us in improving the Service and creating new services and features. We require that these parties process such information in compliance with this Privacy Policy, we authorize them to use the information only for the purposes for which it is provided to them, and we require them to use reasonable confidentiality measures.

You may decline to share certain information with Sparkmesh, in which case we may not be able to provide to you some of the features and functionality found on the Service. If you have created a registered user account, you may update your profile information and preferences or disable your account by logging in and going to the settings page. If you close your account, Sparkmesh may retain certain information about you for the activities described in this Privacy Policy, or as permitted or required by applicable law.

Certain features of the Services may allow users to upload or broadcast content, as well as, post messages, comments and other content on message boards, forums and instant messaging services. You are solely responsible for the content of messages you upload, broadcast or post. You should be aware that when you voluntarily disclose personally identifying information (for example, your name, street address, email address, or telephone number), that information can be viewed, read, collected and used by other users of these services and may result in unsolicited messages, both commercial and otherwise. You agree that by participating in such online public forums, you will not use such forums for any purpose that is unlawful or prohibited by the Sparkmesh. We reserve the right to terminate your access to this Service or to take other protective steps if you violate those terms.

A "cookie" is a small text file that an Internet Service can place on your computer's hard drive for record-keeping purposes. Cookies make using the Sparkmesh Service easier by, among other things, saving your passwords and preferences for you, keeping track of your shopping cart when you visit an online store or other similar purposes, and to help identify you whenever you return to our Service, so you do not need to reenter your identification information. Most Internet browsers are initially set up to accept cookies. However, you can reset your browser to refuse all cookies or to alert you when a cookie is being sent (note: you may need to consult your browser's "Help" area for instructions on how to do that). If you choose to disable your cookies setting or refuse to accept a cookie, some parts of this Service will not function properly or may perform considerably slower. Some of our web pages may contain electronic images (called "Clear GIFs", "Single-Pixel GIFs", or "Web Beacons") that allow us to count page views or to access cookies. In general, any electronic image viewed as part of a web page, including an ad banner, can act as a Clear GIF. Typically, though, Clear GIFs are very small (1-by-1 pixel size) files. They are often invisible on a web page, but their presence can be detected within many Internet browsers by setting your browser to view web page "sources". Clear GIFs are so small in order not to use valuable space on the computer screen that is better used to display helpful content. We may also include Clear GIFs in our email products in order to determine information about the opening and reading of such emails. In addition, some advertising networks that serve ads on our web Service may occasionally use Clear GIFs within banner advertisements. Clear GIFs set by Sparkmesh generally are not used to collect, gather, monitor, or share personal information about our users, though they can be used in conjunction with cookies to record particular actions. We use Clear GIFs primarily to compile aggregated, anonymous statistics about web Service or email product usage.

We may use third-party Web analytics services in connection with the Service, such as those of Google Analytics, and its advertising features. These service providers use a variety of tracking technologies such as Cookies (see, above) to analyze how users use the Service. The information collected (described above in “Information We Gather Automatically”) will be collected directly by these service providers to evaluate your use of the Service. For more information on how Google Analytics uses data from our websites and how you can control the information sent to Google, click here. To learn about opting out of Google Analytics, please click here. Because these opt outs are cookie-based, please note that if you get a new computer or device, install or start using a new browser, or erase or alter your browser’s cookie file, you may need to opt out again.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, and that is why we provide the Network Advertising Initiative, Your Online Choices and the Digital Advertising Alliance opt-out links above. However, Sparkmesh does not recognize or respond to browser-initiated DNT signals.

Sparkmesh uses a variety of managerial, technical, and physical measures to protect the integrity and security of your information. These measures may vary based on the sensitivity of your information. Despite many advances in information security technology and procedures no commercially deployed method of information transfer over the Internet or electronic data storage is known to be 100% secure. As a result, while we do strive to use modern and commercially reasonable means to protect your information, we cannot ensure or warrant the security of any information you transmit to Sparkmesh, and you do so at your own risk. We cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

We keep your personal information to enable your continued use of Service, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Policy, as may be required (or permitted) by law such as for tax and accounting purposes, or as otherwise communicated to you.

IF YOU ARE UNDER 13 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE SERVICE AT ANY TIME OR IN ANY MANNER.

All email communications from Sparkmesh are fully compliant with the CAN-SPAM Act, to the best of our knowledge. Please contact us should you believe you have received an email from Sparkmesh that is not fully compliant. We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Registered Users may opt-out of receiving any or all communications from Sparkmesh by editing their account at: https://www.sparkmesh.com/users/(your username)/edit or by emailing us at: support@sparkmesh.com

In the event that Sparkmesh, or some or all assets related to the Service are acquired by or merged with a third-party entity or in connection with a contemplated change of ownership transaction, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from users as part of that merger, acquisition, sale, or other change of control event, including in the course of diligence.

Information collected by Sparkmesh may be stored and processed in your region, in the United States (for instance in our major data centers), or in any other country where Sparkmesh or its affiliates, subsidiaries, partners, or service providers are located or maintain facilities. If we provide any information about you to any such entities, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy and applicable law.

Sparkmesh reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time (for example to reflect updates to the Service or to reflect changes in the law). Please check this Privacy Policy periodically for those changes. Your continued use of the Service after the posting of changes constitutes your binding acceptance of such changes.

We will respond diligently and appropriately to requests from DPAs about this Privacy Policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of personal information, we will (i) cooperate with inquiries from the DPA responsible for the entity exporting the data and (ii) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.

Please contact Sparkmesh with any questions or comments about this Privacy Policy at: