General Sections Effective: January 7, 2020 European Economic Area Sections Effective: May 25, 2018
Please note that the laws regarding privacy in the European Economic Area "EEA" are different than the laws in the U.S. If you or your company is a resident of the EEA, please see the region-specific section for the EEA in our privacy policy below Specific Disclosures for the European Economic Area.
If you are a resident of EEA, and there is any apparent conflict between our general privacy provisions and the EEA-specific provisions, the EEA provisions control.
If you are a resident of California, please see the California Residents section below.
SPARGO respects the privacy of its customers and other visitors to its website. SPARGO strongly believes that if electronic commerce and online activities are to flourish, customers must be assured that information provided online is used responsibly and appropriately. To protect online privacy, SPARGO has implemented the following policy which to govern SPARGO's relationship with you in relation to this website.
This privacy statement covers the site www.spargoinc.com
If users have questions or concerns regarding this statement, they should contact our Customer Service Department via email info@spargoinc.com, by telephone at (703) 631-6100, or by postal service at the following address:
SPARGO
ATTN: Customer Service
11208 Waples Mill Rd, Suite 112
Fairfax, VA 22030
What Information Does SPARGO Collect?
Data SPARGO collects are used only to help its clients better serve its customers. It is our policy to collect and store only personal information that our customers and visitors knowingly provide. If our privacy policies change, we will notify all users by e-mail or a special announcement placed on the website.
If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information and permitting the transfer of information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. and the use and disclosure of information about you, including personal information, as described in this Privacy Policy. SPARGO complies with the Principles of the EU-U.S Data Privacy Framework (EU-U.S DPF), the UK Extension to the EU-U.S DPF, and the Swiss-U.S Data Privacy Framework (Swiss-U.S DPF) (see below).
From General Users
SPARGO uses third parties to provide analytics and other website functionality. We do not take steps to identify you personally, however, or initiate communication with you, unless you voluntarily provide us with your email address or other information. The e-mail addresses of those who communicate with us via e-mail will not be shared with other companies or marketing agencies.
From SPARGO, Conference Registrants, and Other Customers
SPARGO asks other users to provide their name, organization name, business phone, and e-mail. Credit card information is collected from an individual when registering for an educational course, or event, or purchasing other goods or services. These data are submitted voluntarily. Similar information may be submitted to SPARGO through conference or seminar registrations, publication orders, and subscriptions. Additionally, for some emails sent in HTML format by SPARGO to its customers, SPARGO may collect specific information regarding what the recipient does with that email. For those emails, SPARGO may monitor whether a recipient subsequently clicks through to links provided in the message. Other information collected through this tracking feature includes: email address of a user, the date and time of the user's "click", a message number, name of the list from which the message was sent, tracking URL number, and destination page. SPARGO will only use this information to enhance its services and distribution of those services to its customers. This information will not be distributed in any other manner without user consent.
How does SPARGO use Cookies?
A "cookie" is a piece of data stored on your hard drive containing non-personally identifiable information about you. We may use cookies in order to collect certain information about you, such as IP addresses (e.g., whether you are logged on from a .com, .gov, or .edu domain), domain names (the Internet address of a computer), and the type of computer and operating system being used. We may also use cookies to identify your computer when you revisit our Website, to recall your authentication information, or to track statistical information related to navigation throughout the Website. We may collect such information in order to better operate the Website so as to enhance your experience while using the Website, and to share with advertisers to provide you with a more personalized visit to the Website. Usage of a cookie is in no way linked to any personal information while on our Website.
Depending on the type of browser you are using, your browser may be set to alert you of cookies. You do not have to accept all cookies sent to you by this Website; however, depending on the particular cookie you reject, you may not be able to use some of the features of this Website. To disable all cookies, follow these instructions for the type of browser you are using.
How does SPARGO Use Data Collected?
SPARGO uses information voluntarily submitted by members and other customers in the following ways:
SPARGO Member Services and Products
SPARGO and its direct subsidiaries use data collected and provide requested services (i.e., courses and events.) In addition, this information may be used to improve SPARGO web content; to develop new products and services. Information we collect is used to improve the content of our Web page and will be disclosed when legally required to do so, at the request of governmental authorities conducting an investigation, to verify or enforce compliance with the policies governing our Website and applicable laws or to protect against misuse or unauthorized use of our web site. If you do not want to receive e-mail from us in the future, please let us know by sending us e-mail at the address info@spargoinc.com Persons who supply us with their telephone numbers on-line may receive telephone contact from us with information regarding new products and services or upcoming events. If you do not wish to receive such telephone calls, please let us know by email. Please provide us with your name and phone number.
Disclosures to Third Parties
SPARGO does not sell customer information to anyone. Customer personal information is not shared with third parties other than those acting as agents of this organization and as directed by SPARGO or to those for which SPARGO is acting as the agent. For example, a third party may act as our agent, acting as event registration manager for SPARGO events. Therefore, if a user registers for an event, they may be directed to an event specific website. A third party acting on behalf of SPARGO may collect event registration information for the purpose of managing the event on behalf of SPARGO.
We may also share your personal information and/or non-personal information with other third parties under the following circumstances:
- when we believe in good faith that the law requires it and/or if compelled to do so by law enforcement or government agencies, or to meet national security requirements, or by other legal action;
- when we deem it necessary or appropriate to provide such information to law enforcement authorities; to protect our rights, or to take precautions against liability;
- to protect users of our services from fraudulent, abusive, or unlawful use of, or subscription to, such services; in the course of a sale, merger, transfer, exchange or other disposition (whether of assets, stock or otherwise) of all or a portion of our business, in which case information we have collected or otherwise acquired may be one of the assets transferred.
Accountability For Onward Transfer
SPARGO, Inc. does not transfer data to third parties outside of its agents. SPARGO, Inc. will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant DPF Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), DPF certification by the agent, or being subject to another European Commission adequacy finding (e.g., companies located in Canada), or any UK Directives if different from EU GDPR. Where SPARGO, Inc. has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, SPARGO, Inc. will take reasonable steps to prevent or stop the use or disclosure. SPARGO, Inc's accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. SPARGO, Inc. remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Principles, unless SPARGO, Inc. proves that it is not responsible for the event giving rise to the damage.
Your Choices
We believe in giving you choices when it comes to your personal information.
Our direct marketing services provided on behalf of our partners are permission-based, meaning that we only send marketing-related or promotional messages to individuals registered by users who have opted-in to receive them. You can choose not to submit your personal information to SPARGO; If you submitted your personal information to SPARGO and do not wish to receive text messages or e-mails from SPARGO about products, services, or features that may be of interest, you can unsubscribe at any time. We will include an opt-out link or reply address in each e-mail or text message that we send on behalf of our partners. After unsubscribing, you will be removed from our database. Please allow up to 5 business days to process your request.
SPARGO generally does not collect personal information through the SPARGO service unless you have expressly consented to providing it to our partners, or via our website where you provided it to us. In most cases, if and/or when we obtain personal information, it relates to our current or prospective clients and business partners. You have certain access rights to your personal information contained in our systems. If you have submitted personal information through the SPARGO services or website and wish to access, correct, or delete this personal information, please contact us at info@spargoinc.com.
Do-Not-Track Signal
SPARGO currently does not honor “Do-Not-Track” signals from your browser. Several US states require that the PP include a statement re: honoring Do-Not-Track.
Credit Card Account Information
SPARGO does not disclose credit card account information provided by its customers. When customers choose to pay using their credit cards, SPARGO submits the information needed to obtain payment to the appropriate clearinghouse. All sensitive data, such as credit card information, is transmitted via SSL encryption.
How can users access information they have submitted through the website?
Customers of SPARGO including event registrants and other non-member users can gain access to their data for review and correction by contacting the Customer Service Center by email, or by telephone at (703) 631-6100.
How is the data protected after it is received by the site?
The data collected on the site is maintained in databases that are housed on equipment stored in secure, limited access facilities. Access to the database is restricted to those employees that are responsible for collecting the data and those whose duties require them to use the data.
California Residents
SPARGO is a “Service Provider” under the California Consumer Privacy Act (CCPA) and only collects, maintains, and utilizes data on behalf of the business that SPARGO services. We do not use the data, including any personal information, for our own purposes or “sell” the data within the meaning of the CCPA.
If you are a California resident and wish to exercise a Privacy Right under the CCPA with respect to a business that SPARGO services, you should submit your request directly to the business that SPARGO services. Where feasible, we will provide you the contract information for that business. Please contact us using the information found below if you have any questions.
What Means of Redress Are Available?
If any user suspects SPARGO has handled its personal information in a manner that does not comply with this privacy statement, please contact us by email at info@spargoinc.com or by calling (703) 631-6100. If, after contacting our Customer Service Center, the user continues to be dissatisfied with SPARGO's handling of their personal information, our CIO should be contacted by email john.baker@spargoinc.com or by calling (703) 631-6100.
Specific Disclosures for the European Economic Area
(This section is effective on May 25, 2018)
This section applies to data processing activities of data subjects residing in the European Economic Area as well as, regardless of residence, to the processing of any Personal Data in the European Economic Area.
"Personal Data," for purposes of this section, means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Services" means any of our products, services, or deliverables.
"Site" means any website operated and controlled by us.
Pursuant to the European Union General Data Protection Regulation (GDPR), we function as a "processor" for the Services we offer to our customers. The scope of applicable data protections and processing for those Services are set forth in contractual agreements with our customers and are therefore not covered by this Privacy Notice.
We may process certain Personal Data in order to maintain and provide the Services to our customers, such as names, addresses, email addresses, and other contact information for designated customer representatives or personnel ("Customer Relationship Data"). In addition, we may send marketing materials or communications to potential or existing customers ("Marketing Activities"). For purposes of Customer Relationship Data and Marketing Activities, we function as a "controller." Our disclosures with respect to our processing of data as a controller are set forth in this section.
The processing that we conduct on behalf of our customers and exhibitors is done in the capacity of a "processor" and the terms and conditions of that processing are not set forth here, but rather in processing agreements with those parties. When we process data of attendees on behalf of our customers, we perform those services in the capacity as a processor on behalf of our customers and exhibitors who are data controllers. If you are an attendee and have questions about your rights as a data subject, please contact the organization sponsoring the event you attended, or the exhibitor to whom you provided personal data, for more information or to exercise your data subject rights.
SPARGO, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. SPARGO, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. SPARGO, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.
In compliance with the EU-U.S Data Privacy Framework (EU-U.S DPF), the UK Extension to the EU-U.S DPF, and the Swiss-U.S Data Privacy Framework (Swiss-U.S DPF) Principles, SPARGO, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the EU-U.S DPF, the UK extension to the EU-U.S DPF, and the Swiss-U.S Data Privacy Framework Principles. European Union, United Kingdom, and Swiss individuals with inquiries or complaints should first contact SPARGO, Inc.
SPARGO, Inc. respects individual privacy and values the confidence of its clients, their customers, our business partners, and others. SPARGO, Inc is subject to the investigatory and enforcement policies of the Federal Trade Commission. The DPF Principles outlined in this Privacy Policy sets forth the privacy principles SPARGO, Inc. follows with respect to transfers of personal information from the European Economic Area and the United Kingdom to the United States.
Note: It must be emphasized that SPARGO, Inc. does not have control over the uses to which our clients may make of Personal Identifiable Information disclosed to them.
SPARGO, Inc. has further committed to refer unresolved privacy complaints under the Data Privacy Framework program to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.
1. How We Collect and Use Personal Data
We describe how we collect and use Personal Data in the "What Information Does SPARGO Collect?" found in section What Information Does SPARGO Collect? of the Privacy Notice.
2. How We Disclose Personal Data
Our disclosure is limited to circumstances where we are permitted to do so under applicable European and national data protection laws and regulations. A list of companies with whom we share data for purposes of marketing our Services to potential and existing customers is available here:
Pardot: https://www.pardot.com/
Real Magnet: http://www.realmagnet.com/
Sales Force: https://www.salesforce.com/
a2z: http://www.a2zinc.net/show6/public/enter.aspx
3. Legal Basis for Programming
We collect and process your Personal Data for a variety of different purposes which are set out in further detail in this section.
In some cases, we will ask for your consent so that we may process your Personal Data. However, in certain circumstances, applicable data protection laws allow us to process your Personal Data without needing to obtain your consent.
3.1. Processing Personal Data Whare Consent Not Required
In certain cases, separate consent is not required, including:
For the performance of a contract.
To perform our contractual obligations to you, including our fulfilling orders or purchases you have made, contacting you in relation to any issues with your order or use of our Services, in relation to the provision of our Services, or where we need to provide your Personal Data to our service providers related to the provision of the Services, including for license activation and management.
To comply with legal obligations.
To comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process.
Legitimate Interests.
To operate our business and provide our Services (other than in performing our contractual obligations to you) for our "legitimate interests" and for the purposes of applicable law, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Legitimate interests may include:
- To communicate with you regarding the Services, including to provide you important notices regarding changes and to address and respond to your requests, inquiries, and complaints.
- For our direct marketing purposes.
- To send you surveys in connection with our Services.
- To assist in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights and property, or the rights or safety of third parties.
- To develop, provide, and improve our Services.
- To enforce our Terms of Use, License Agreements, or this Privacy Notice, or agreements with third parties.
3.2. Consent for Processing
In cases where we are not already authorized to process the Personal Data under applicable law, we may ask for your consent to process your Personal Data, including:
Marketing
We may ask for your consent for our client events or our partners or vendors to contact you by telephone, SMS, post and/or email about other offers, products, promotions, developments or Services which we think may be of interest to you and for other marketing purposes.
Use of Cookies
Our Site uses cookies and similar technologies to improve user experience and for analytics. We also use cookies and similar technologies for purposes of marketing and advertising, including interest-based advertising. For more information on interest-based advertising, see section 3 (Interest-Based Advertising). In those jurisdictions that require it, we allow the data subject to give explicit permission or to deny the use of certain categories of cookies.
A "cookie" is a small text file that a web server stores in browser software. A browser sends cookies to a server when the browser makes a connection to the server (for example, when requesting a web page from the same domain that created the cookie). The purpose of cookies is to remember the browser over time and distinguish one browser instance (or user) from all others. Some cookies and other technologies may serve to track Personal Data previously entered by a web user on our site. Most browsers allow you to control cookies, including whether or not to accept them, and how to remove them. Cookies can remember login information, preferences, and similar information.
Cookies, as well as other tracking technologies such as HTML5 local storage, and Local Shared Objects (such as "Flash" cookies), and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data.
We also use web beacons or "pixels," and in certain circumstances may collect IP address, screen resolution and browser software and operating system types; clickstream patterns; dates and times that our site is accessed, and other categories of data.
If you want to block the use and saving of cookies from the Site on to their computers hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the Site and its external serving vendors. Please note that if you choose to erase or block your cookies, certain parts of our Site may not function correctly. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
4. Interest-Based Advertising
Interest-based advertising is advertising that is targeted to you based on your web browsing and app usage over time and across websites or apps. You have the option to restrict the use of information for interest-based advertising and to opt-out of receiving interest-based ads. Depending on from where you access our Site, you may also be asked to consent to our use of cookies, including advertising cookies.
The opt-outs for interest-based advertising require that strictly necessary cookies are not blocked by the settings in your web browser. We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance in the U.S., the Canadian Digital Advertising Alliance in Canada, and the European Digital Advertising Alliance in the EU. If you live in the United States, Canada, or the European Union, you can visit Ad Choices (US), Your Ad Choices (Canada), or Your Online Choices (EU) to find a convenient place to opt-out of interest-based advertising with participating entities for each region. These websites also provide detailed information about how interest-based advertising works. Opting out does not mean that you will no longer receive advertising from us, or when you use the Internet. It just means that the data collected from our website will not be used for interest-based advertising and that the advertising you see displayed on websites will not be customized to your interests.
5. Withdrawing Your Consent
You may at any time withdraw the consent you provide for the processing of your Personal Data for the purposes set forth in this Privacy Notice by contacting us at withdraw@spargoinc.com, provided that we are not required by applicable law or professional standards to retain such information.
If you want to stop receiving future marketing messages and materials, you can do so by clicking the "unsubscribe" link included in our email marketing messages or by contacting us at unsubscribe@spargoinc.com.
6. Data Subject Rights
You have the right in certain circumstances to request confirmation from us as to whether or not we are processing your Personal Data. Where we are processing your Personal Data, you also have the right to request access to, modification of, or deletion of such Personal Data.
You also have the right in certain circumstances to receive the Personal Data concerning you that you provided to us, to restrict processing of your Personal Data, or to transmit such data to another controller.
To exercise your rights with respect to your Personal Data, please contact us at personaldata@spargoinc.com. As permitted by law, certain data elements may not be subject to access, modification, portability, restriction, and/or deletion. Furthermore, where permissible, we may charge for this service. We will respond to reasonable requests as soon as practicable and as required by law.
7. De-identified Or Anonymized Data
We may create de-identified or anonymous data from Personal Data by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means. Our use of anonymized data is not subject to this Privacy Notice.
8. Data Retention
We will retain your Personal Data for as long as long as you maintain an account or subscription agreement or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
9. Right To Lodge A Complaint With A Supervisory Authority
You may have a right to lodge a complaint with a supervisory authority.
10. Contact Us
For questions regarding this Privacy Notice, please contact us at: info@spargoinc.com.