SPARK Neuro Privacy Policy

Last Updated: February 4, 2019

SPARK Neuro, Inc. (“SPARK Neuro,” “We,” or “Us”) has prepared this Privacy Policy to describe our practices regarding the personal information we collect from users of the SPARK Neuro website at (“Site”) and services provided through the Site (collectively, the “Services”).

If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at.

A Note About Children.  We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits personal information to SPARK Neuro and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible.  If you believe that we might have any personal information collected online from a child under 13, please contact us at

A Note to Users Outside of the United States.  If you are a non U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your personal information may be processed for the purposes identified in the Privacy Policy.  In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your data, you consent to such transfer and processing.

Types of Data We Collect

1. Information You Provide to Us

If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail. We may also collect personal information at other points in our Services that indicate that personal information is being collected.

2. Information Collected via Technology

Information Collected by Our Servers. Our servers (which may be hosted by a third-party service provider) may collect information automatically from your computer or device, including, but not limited to:

  • The date and time of your visit, the pages and content you view, and links you click on while navigating within our Services;
  • Information about the type of content accessed via our Services;
  • The site you visited before and after visiting our Site;
  • Your Internet Protocol (IP) address (a numerical address assigned to your computer by your Internet service provider so that other computers connected to the Internet can communicate with your browser online) that can sometimes be used to derive your general geographic area;
  • Search terms you enter using our Services or on a referral site;
  • Unique identifiers;
  • Information about your device such as your device type, screen size, browser type, language and other settings, memory capacity plug-ins, Internet domain, TCP configuration parameters, operating system, carrier code, time zone and the names, versions and package IDs of software installed on your device; and
  • Information collected through cookies, pixel tags and other tracking technologies (see additional descriptions of these terms below.
  • Cookies. Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
  • Analytics. We use third-party analytics services [including services provided by Google, Inc. and its affiliates] (“Analytics Services”) to help analyze how users use our Services. The information is generated by the Cookies or other technologies about your use of our Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity and other user information. The Analytics Services may also transfer the Analytics Information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. The Analytics Services may also disclose aggregated user data with third parties. Each Analytics Service’s ability to use and share Analytics Information is restricted by such Analytic Service’s terms of use and privacy policy. By using our Site, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. [To learn more about how Google uses data, visit]

3. Information Collected from Third Party Companies.

We may also receive personal information and/or anonymous data from other third parties, including, but not limited to, companies that have entered into joint marketing relationships or other business partnerships with us. We may combine any information about you that we receive from third parties with information we have already collected from you via our Services and use that combined information pursuant to this Privacy Policy.

Use of Your Personal Data

General Use:

  • In general, Personal Data you submit to us is used to respond to requests that you make, improve our Services, aid us in serving you better, or inform you of offers we believe may be of interest to you. Your personal information is used to:
  • Provide you with Services and customer support;
  • Provide improved administration of our Site and Services;
  • Measure and analyze audience traffic and improve the quality of your experience when you interact with our Services;
  • Respond to your requests, resolve disputes and/or troubleshoot problems;
  • send you a welcome email to verify ownership of the email address provided when your Account was created;
  • Conduct surveys and questionnaires to evaluate and improve our Services;
  • Improve our Services and develop new products and services;
  • Communicate with you about the Services, including offers for services you may be interested in, and administrative e-mail notifications such as security or support and maintenance advisories;
  • Prevent potentially prohibited or illegal activities, comply with applicable law, and enforce terms of any agreements, we may have with you, including our Terms of Use; and
  • For any other purposes disclosed to you in this Privacy Policy or at the time we collect your information or pursuant to your consent.

Creation of Anonymous Data

  • We may create anonymous data records from personal information as described below and as described elsewhere in this Privacy Policy.

Disclosure of Your Personal Information.

  • We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

Third Party Service Providers

  • We may share your personal information with vendors, subcontractors and third party service providers that help us provide the Services.


  • We may share some or all of your personal information with our parent company, subsidiaries or other companies under a common ownership or control with us (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

Corporate Restructuring

  • We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.  In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

Other Disclosures

  • Regardless of any choices you make regarding your personal information (as described below), SPARK Neuro may disclose personal information if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation or proceeding; (b) to comply with relevant laws or to respond to subpoenas or warrants served on SPARK Neuro; (c) to protect or defend the rights or property of SPARK Neuro, its affiliates, its business partners, or its users; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, our applicable Terms of Use agreement, or any other contractual arrangement.

Third Party Websites

  • Our Site may contain links to third party websites.  When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect personal information or anonymous data from you.  We have no control over, do not review, and cannot be responsible for, these outside websites or their content.  Please be aware that the terms of this Privacy Policy do not apply to these outside websites, or to any collection of your personal information after you click on links to such outside websites.  We encourage you to read the privacy policies of every website you visit.  The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

Your Choices Regarding Your Information

  • You have several choices regarding use of information on our Services:

1. Email Communications

  • If you provide your e-mail address, we will periodically send you administrative e-mails, free newsletters, and e-mails that directly promote the use of our and our business partners’ products and services. When you receive newsletters or promotional communications from SPARK Neuro, you may indicate a preference to stop receiving further communications from SPARK Neuro  and you will have the opportunity to opt-out by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly at Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our Terms of Use agreement or Privacy Policy. Any e-mails you receive from our business partners will be subject to such third party’s privacy policy.

2. Google Analytics.

  • You may prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on, available at
  • If you decide at any time that you no longer wish to accept Cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Services or all functionality of the Services. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided above. [Please be aware that certain browsers cannot block or delete so-called “Flash” cookies, which use a feature of the Adobe Flash video player to store information on your computer. For information about how to delete Flash cookies, please visit the Adobe website.]

3. Changing or Deleting Your Personal Data.

  • You may review, update, correct or delete the personal information by contacting us. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes. Please remember, however, if we have already disclosed some of your personal information to third parties, we cannot access that personal information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.

4. Do Not Track. We do not currently respond to “do not track” signals from web browsers.

Changes to This Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at and we will change the “Last Updated” date above. You should consult this Privacy Policy regularly for any changes.