Privacy Policy

This policy describes how Spark Perceptions Technology, Inc (hereafter "we" or "us" or "our") collect, use, and store Personal Information, which includes collection through our website, www.sparkperceptions.com, and by using any of the services (collectively our "Services"), together with our Affiliates and their parents, subsidiaries, and affiliates. "Personal Information" is data about you or data that can be used to identify you, such as your name, address, phone number, email address, IP address, or other information that could lead to your identification as an individual. By using our Services, you acknowledge and consent to our practices described below.

We do NOT direct our Services to children or individuals under the age of 21, nor do we knowingly collect, use, or store the Personal Information of individuals under 21.

When and how do we collect Personal Information?

We collect several types of information from and about you, including information:

• By which you may be personally identified, such as name, birthdate, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline ("Personal Information");
• That is about you but individually does not identify you; and/or
• About your internet connection, the equipment you use to access us, and usage details.

We collect this information:

• Directly from you when you provide it to us, either by creating an account or contributing to the EZ-UP Aurora Campaign, as described in the Terms of Service.
• Automatically as you navigate through our website or use our Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. Our Cookie Policy is detailed below.
• From third parties, for example, our Affiliates or Service Providers, defined later in this Policy.
• From publicly or commercially available sources, such as your name, address, email address, interests and demographic/profile data.

Information You Provide to Us

The information we collect may include:

• Personal information you provide by completing forms on our Site or the EZ-UP Aurora Campaign — for example, your name, email and postal addresses, telephone number, country of residence, login, and password details. We may ask for this information if you register as a user of the Services, subscribe to our newsletters, complete surveys, or submit content to us.
• Any personal information you include in your communications to us, such as when you ask for support, send us questions or comments, or report a problem with our Services.
• Personal information that you submit on or to our platform.
• Personal information you provide for identity and age verification purposes prior to delivery of any EZ-UP Aurora products or rewards after contributing to the EZ-UP Aurora Campaign or before purchasing any of our products, which can include your legal name, date of birth, and business name and Tax ID for business entities. As a condition to delivery of any EZ-UP Aurora products or rewards under the EZ-UP Aurora Campaign or otherwise purchasing any of our products, our payment processor may request that you provide us with additional information and documentation to verify your age and residency, which may include a secure upload of an identity document (such as your passport, driver's license, or other government-issued ID).
• Details of any transactions you make through the Services, such as who you paid, the date of payment, and what reward you were provided. We partner with Shopify to host our online store and partner with Authorize.net for payment processing. The payment information you submit is collected and used by Authorize.net in accordance with Authorize.net Privacy Policy (https://www.authorize.net/en-anz/about-us/privacy.html and Data Processing Agreement (https://www.authorize.net/about-us/dpa.html)) We do not store payment card or bank account details.
• Information about your interactions with us, including use of our website, such as your IP address, approximate location information, your device identifier, the type of device or browser you use, and your actions during your visit, including how you navigate our website. For more information about our use of cookies and other tracking technologies, see our Cookie Policy.
• Demographic information, such as your age and gender identity, when you choose to provide this information to us. Typically, this information is only processed when you voluntarily choose to provide it to us. The demographic information we collect includes personal information that may qualify as sensitive personal information under various privacy laws.
• You may decline to provide us with your personal information. However, this will limit your ability to register for an account, back the EZ-UP Aurora Campaign, purchase any of our products, or otherwise use our Services. You may review and update through your account settings.
• Information that you provide when placing orders. This includes information provided at the time of registering to use our Services, subscribing to our Services, posting material, or requesting further services. We may also ask you for information when you report a problem through any of our Services.
• Records and copies of your communication with us, such as correspondence (including email addresses) or telephone calls should you choose to contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out and of the fulfillment of your orders, either with us or through our Affiliates or Service Providers. You may be required to provide financial information before placing an order.
• Your use and interaction with various features of our Services.

Why do we use or process your Personal Information?

We only use your Personal Information for a legal and legitimate interest, such as:

General use: We use the personal information we collect for various purposes including:

• when you register and service your account with us;
• to send you transactional communications about your pledges;
• to confirm your age and/or residency to determine eligibility to participate in the EZ-UP Aurora Campaign or to purchase our products;
• to provide customer service and respond to your requests for information;
• to improve and develop the quality of your online experience, including through personalization;
• to enhance the effectiveness of our Services;
• to conduct research and analysis;
• to effectively manage our business;
• to prevent fraud and abuse;
• to monitor and improve the security of our Services.

Marketing: To the extent that we collect Personal Information when you contact us, we use the information solely in connection with preparing our response to you. We use it to send follow-up communications after we respond. We may also use this information to call to your attention similar products or offerings that might be of interest to you, or to provide you with updates about our company.

Contract performance: We may use or process Personal Information in connection with pre-contract activities and discussions with you, and to perform a contract we have with you such as the execution of a sale.

Legal obligations: We will use or process Personal Information as necessary for compliance with a legal obligation to which we are subject. This includes using or processing Personal Information for defense of claims against us and satisfying any government reporting obligations and requests.

Other legitimate interests: We will process your Personal Information for any of our other legitimate interests not described above. These include analyzing use of our website or services, tailoring website content, setting preferences in our website or electronic mailings, improving our website, fulfilling our obligations to our clients and others, and managing our client and vendor relationships.

How and where do we share Personal Information?

We do not sell, trade, or otherwise transfer your information to outside parties without your consent. However, we do share your information with trusted affiliates or service providers who assist us in operating our website and conducting our business (our "Affiliates" or "Service Providers"), but only so long as our Affiliates or service providers agree to keep this information confidential.

Specific circumstances in which we may share your personal information are as follows:

• with any other party based on your consent or instruction to do so.
• with service providers who perform services on our behalf, including recruiting, marketing, customer support, legal services, data storage, data analysis, and helping us detect and protect against fraud, illegal activities, malicious behaviors, security threats, and other misuses of our Services.
• with current and future affiliated companies, including as part of a business transaction, such as corporate divestiture, merger, consolidation, acquisition, reorganization, or other disposition of all or any portion of our business or our affiliates, including in connection with a bankruptcy or similar proceeding.
• as reasonably necessary to comply with law and legal requirements, cooperate with and respond to law enforcement requests, exercise or defend our legal rights or those of others, or as otherwise required by applicable law, court order, or governmental regulations.
• with service providers that include professional advisors, accountants, auditors, consultants, and lawyers, when reasonably necessary for our service providers to perform services for us and give us appropriate advice.

We operate our Services from the United States and store information of registered users who have consented to our use and transfer of the data in the United States. We market and provide Services in many other countries. Accordingly, we will disclose information collected through our Services, as well as other Personal Information you may share with us, across offices and geographical boundaries, within and outside of our company, for legal and legitimate purposes as described above.

The recipients of your Personal Information may be located outside of the jurisdiction where you reside. The laws of these other countries may not provide the same level of protection as the laws of your home country. By voluntarily providing us your Personal Information, you acknowledge the disclosure of such information to these recipients.

What information is shared when I contribute to the EZ-UP Aurora Campaign?

When you become a Contributor, as defined in our Terms of Service to the EZ-UP Aurora Campaign, we create a basic profile page for you on our website, containing your username and the number of times you have contributed as more detailed in our Terms of Service and Addendum. By default, your profile is set to private and will only publicly display your username and avatar and date your Contribution was made.

If you are a Contributor and don't want others to see your real name or image, you may choose an avatar or name that is not identifiable (for example, SparkFan22 or a random image). You can also modify or delete certain personal information associated with your account (such as your username, avatar, bio, and location) through your account settings, where you can also change your privacy settings. You may delete your entire account by submitting a privacy request to support@sparkperceptions.com.

How do we protect your Personal Information?

We implement a variety of security measures to maintain the safety of your Personal Information when you enter, submit, or access your Personal Information. Even so, please do not disclose any private or confidential information to us, unless transferred through one of our secure portals. We cannot guarantee the security of any information transmitted to us over the Internet.

How long do we keep Personal Information?

We will keep your Personal Information until we no longer expect to need it for any legal and legitimate purpose and otherwise in keeping with all applicable laws. At the appropriate time, we will take reasonable steps to destroy your Personal Information, except where we must retain it to satisfy legal or professional ethical obligations.

What are your rights regarding your Personal Information?

A. General Regional Rights

Access Rights: you may have the right to receive certain information, such as the following (these rights, and the applicable types of data and time periods, will vary depending on the laws applicable to the state or country in which you reside):

• The categories of Personal Information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your Personal Information; and the categories of third parties with whom we shared Personal Information.
• Access to and/or a copy of certain Personal Information we hold about you.
• In some circumstances, you may have the right to obtain certain Personal Information in a portable format.

Erasure: you may have the right to request that we delete certain Personal Information we have about you. We may either decide to delete your Personal Information entirely, or we may anonymize or aggregate your Personal Information such that it no longer reasonably identifies you. Certain Personal Information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide our Services to you, we may be required to retain certain information for legal purposes, and there may be other reasons we may need to keep certain Personal Information under various applicable laws. In addition, if you ask us to delete your Personal Information, you may no longer be able to access or use some of our Services.

Correction: you may have the right to request that we correct certain Personal Information we hold about you.

Limitation of Processing: Certain laws may allow you to object to or limit the manner in which we process some of your Personal Information, including the ways in which we use or share it. For example, you may have these rights if the processing was undertaken without your consent in connection with our legitimate business interests (although we may not be required to cease or limit processing in cases where our interests are balanced against your privacy interests).

Regulator Contact: You may have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Information. To do so, please contact your local data protection or consumer protection authority.

If you believe that you have specific rights under your jurisdiction and you would like to exercise any of these rights, please submit a support request through our website or email us at support@sparkperceptions.com. Other than marketing opt-out and do-not-sell requests, you will be required to verify your identity before we fulfill your request. In certain jurisdictions, you may be able to designate an authorized agent to make a request on your behalf, subject to certain requirements of your applicable law. We may require that you provide the email address we have on file for you (and verify that you can access that email account) as well as an address, phone number, or other data we have on file, in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent's authority to act on your behalf, and we may be required to take additional verification measures under applicable law.

B. Important Information for European Union, United Kingdom, India and China Users

If you are a user from the European Union, United Kingdom, India or China you should be aware that we are the controller of your Personal Information (Data Controller) under the EU General Data Protection Regulation ("GDPR"), the UK General Data Protection Regulation ("UK GDPR"), China's Personal Information Protection Law ("PIPL") and such similar laws promulgated in the various EU countries, India and China. You may have certain additional rights regarding your Personal Information (as defined in the GDPR and UK GDPR, for instance), including the right to:

• access your information;
• rectify your information if it is incorrect;
• have your information erased ("right to be forgotten") if certain grounds are met;
• withdraw your consent to our processing of your information at any time, if our processing is based on consent;
• object to our processing of your information, if our processing is based on legitimate interests;
• object to our processing of your information for direct marketing purpose;
• receive your information from us in a structured, commonly used, and machine-readable format;
• the right to transmit your information to another controller without hindrance from us (data portability).

There is no charge for any of these requests. To make a request, please contact us at support@sparkperceptions.com. We try to respond to such requests in a timely manner, but in no event longer than one month. When we collect your Personal Information, we maintain and store it for as long as we determine reasonably necessary to provide our services to you, unless you exercise your right to erasure described above, or to comply with applicable legal requirements.

If you are a resident of the European Union, United Kingdom or China, when we process your Personal Information, we will only do so in the following situations:

• We have a contractual obligation.
• You have provided your consent when registering for our Services. However, you are able to remove your consent at any time, and you may do this by contacting us at support@sparkperceptions.com.
• We have a legal obligation.
• We have a legitimate interest in processing your Personal Information. For example, we may process your Personal Information to send you marketing communications, relevant content, products, or to communicate with you about changes to our Services, and to provide, secure, and improve our Services.

You should be aware that Personal Information that you provide to us may be transferred out of the country in which you reside to servers in a country that may not guarantee the same level of protection as the one in which you reside. Nevertheless, we will take all steps reasonably necessary to ensure that your Personal Information is treated securely in accordance with this Privacy Policy, and no transfer of your Personal Information will take place to a third party unless there are adequate controls in place to protect your Personal Information and/or you have provided contractual consent by registering an account with us.

C. U.S. State-Specific Rights

Various states provide specific rights to residents of the state regarding Personal Information, which includes allowing consumers in these states to opt out of certain sharing of their data.

Depending on where you reside, your state may have enacted privacy laws (e.g., as of the date of this Policy California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia) that allow you to request that we:

• Disclose the sources, categories, and specific pieces of Personal Information we have collected about you, how that information is used, and with whom Spark Perceptions shares it;
• Disclose the purpose for collecting Personal Information;
• Disclose the categories of third parties with whom we share Personal Information;
• Delete/rectify/restrict their Personal Information, subject to certain exceptions (right of rectification not applicable to Iowa and Utah residents);
• Disclose, for any "sales" of Personal Information, the categories of Personal Information collected and sold and to what categories of third parties it was sold;
• Opt out of sales of your Personal Information (if any) or subject certain Personal Information to automated decision-making algorithms (not applicable to Iowa or Utah residents);
• Provide a copy of your Personal Information in a readily usable format that allows the information to be transmitted to others;
• Not discriminate against you for exercising any of the rights described above.

Residents of these states may exercise these rights by emailing us at support@sparkperceptions.com. If you are a resident of Colorado, you must consent for us to process outside of Colorado any of your Sensitive Personal Information (defined as information related to race, political and religious beliefs, sexual orientation and sexual life, criminal convictions, work history, membership in professional organizations or trade unions, biometric or health information). We maintain your consent on file when you register for our Services, and thereby consent to processing of any your Sensitive Personal Information, such race or gender identification outside of Colorado.

In general, we, including our Affiliates or Service Providers, collect the following California regulated categories of Personal Information (PI) from you:

Have we shared your Personal Information for a business purpose?

Yes. In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose with our Affiliates and Service Providers:

• Category A: Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address
• Category B: PI categories
• Category C: Protected classification characteristics
• Category F: Internet or other similar network activity
• Category K: Inferences drawn from other PI

How can you exercise your privacy rights?

If you wish to exercise any of these rights, you may: (a) email us at support@sparkperceptions.com; or (b) send us a message through our website.

To change information that we collect through this website, please email support@sparkperceptions.com. We allow you to opt out of future communications at any time by clicking the "unsubscribe" link at the bottom of all emails.

If you would like to make a complaint about how we have handled your Personal Information, or to make a complaint about a breach of data protection laws, please email us. We will investigate complaints and will communicate the outcome of the investigation to you after the complaint is made in accordance with applicable law. You may also have a right in some locations to file a complaint with your local data protection authority.

How do we notify you of changes to our Privacy Policy?

If we make minor changes to our Privacy Policy, we will post those changes on this page, and/or update the Privacy Policy modification date at the beginning of this document. If we materially change this Privacy Policy, we will notify you via email and/or provide a notice on our website home page.

How may you contact us?

If you have any questions about this Privacy Policy, you may contact us using the information below.