Privacy Policy
& Notices at Collection

Spark Health Inc. and our affiliates and subsidiaries (collectively, “Spark,” “we,” or “us”) respect and value your privacy. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of a use or correct or change such information. This Privacy Policy is incorporated by reference into both our Website Terms of Service and our Platform Terms of Service (individually and collectively, “Terms of Service”). 

1. Scope

This Privacy Policy applies to information that we process from or regarding our current, prospective, and former customers, users, visitors, guests, business partners (including members, agents, agencies, providers, and carriers), and employees, in the course of our business, including on our website SparkAdvisors.com (our “Website”), through our forms, applications, technology platform (the “Technology Platform”), by phone, texts, or in-person, and any other online offerings that link to this Privacy Policy (collectively, the “Services”). This Privacy Policy does not apply to information collected by any third party, including through any application or content (including advertising), that may link to or be accessible from or through the Services.

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2. Information We Collect About You 

The types of information we collect about you (directly from you or from a third party source) depends on the nature of our relationship with you and the requirements of applicable law. The general categories of information we collect about you include:

• Information by which you may be personally identified, such as name, postal address, email address, telephone number, social security number or any other identifier by which you may be contacted online or offline;
• Sensitive information about you, 
• Information that is about you but does not identify you specifically, such as insurance plan information; and/or
• Information about your internet connection, the equipment you use to access the Services, and details about your usage of the Services.

The foregoing general categories of information are referred to in this Privacy Policy as “personal information.”

Spark has collected and/or disclosed the following categories of personal information within the past 12 months:

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Category Examples

1. Identifiers, including government identifiers, e.g. Real name, alias, postal address, email address, account name, social security number, driver’s license number; insurance agent license numbers and/or National Producer Numbers (“NPN”); or other similar identifiers.
2. Personal information categories listed in the California Customer Records statute, e.g. Customer records, including name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification number, insurance policy numbers, medical information, health conditions, or other health insurance information, financial information and bank account number,  education, employment, and employment history. 
3. Characteristics of protected classifications under California or federal law, e.g. Age, race, marital status, mental or physical disability, and sex or gender.
4. Commercial information, e.g. Records of products or services purchased.
5. Internet or other similar network activity, e.g. Internet or other electronic network activity information such as browsing history, search history, or information regarding a consumer’s interaction with the Services.
6. Geolocation data, e.g. Physical location or movements.
7. Sensory data, e.g. Audio, electronic, visual, or similar information, including audio recordings. 
8. Professional or employment-related information, e.g. Current or past employment history, performance evaluations, and income and salary details.
9. Education information, e.g. Current or past education or credentialing information.
10. Inferences, e.g. Inferences that can create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
11. Account Access Information, e.g. Usernames and account numbers
12. Communications, e.g. Mail, email, or text messages contents not directed to us (i.e., communications directed to your members, agents, providers, or carriers, as applicable)
13. Health Information, e.g. Medical history, health conditions

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While personal information is broadly defined, other categories are specifically excluded from this definition including:

• Publicly available information, meaning information that is available from federal, state, or local government records.
• Pseudonymized and de-identified information or aggregated and de-identified information that cannot be reasonably linked to an individual.

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3. How We Collect Information About You 

Direct Collection

We collect personal information from our provision of the Services or operation of our business, including:

• Information you provide us directly in connection with the Services, including information you provide us by phone, email, text, in-person, through our Website (including by filling in forms on our Website, or other forms or applications on third party websites and services, if those forms or applications link to this Privacy Policy), or through our Technology Platform. 
• Information you provide when applying for a job at Spark or in connection with your employment with Spark, either directly to Spark or to our third party service providers (e.g., recruiters or recruiting platforms, HR or payroll management services).
• Information we lawfully obtain from our third party service providers and public sources.

Indirect Collection

We collect personal information on behalf of third parties when they use the Services, including:

• Information we receive about you from users of the Services, like insurance agencies and agents, members, carriers, and providers, to create, share, and use contract management, marketing, sales, and customer service content. When our users use the Services, they may upload or provide us with your personal information, such as first and last name, email address, physical address, phone number, age, insurance plan information, or other personal information about you. We call the information that our users submit or collect via the Services “Your Content” under our Terms of Service. We do not control Your Content or the types of personal information that our users may choose to collect or manage using the Services. We store our users’ information on our service providers’ servers, but process it as a processor under our users’ instructions and in accordance with our Terms of Service, which prohibit us from using the information except as necessary to provide and improve the Services or otherwise as required by law. Our users control and are responsible for correcting, deleting or updating the information they process using the Services and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring personal information to Spark for processing purposes.
• Information we receive about you or other users of the Services from our network of business partners, including lead generation partners.

Automatic Collection

We use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website and Technology Platform, use of our Services, or visits to other sites or services that link to this Privacy Policy, including traffic data, location data, logs, metrics and information about your use and interaction with the Services (like what product features you use the most), and other communication data and the resources that you access and use with the Services. 
• Information about your computer hardware and software when you visit our Websites, use our Services, or visit other sites or services that link to this Privacy Policy. This information can include your IP address, browser type, domain names, internet service provider (ISP), and the files viewed on our websites (e.g., HTML pages, graphics, etc.), the files viewed on your operating system, access times and referring website addresses.
• Information about your online activities over time and across third party websites or other online services (behavioral tracking). 

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties or with publicly available information. It helps us to improve the Services and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize the Services according to your individual interests.
• Recognize you when you return to our Website or our Technology Platform.

For example, we use Google Analytics, which allows us to analyze traffic and usage patterns of individual users (without further identifying them) or groups (which webpages you visit, how often you return, how long you stay, etc.). This data allows us to better understand which pages are getting viewed and, in turn, continuously improve the Services. 

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The technologies we use for this automatic data collection may include:

• Cookies (Browser Cookies). A cookie is a small file placed on the hard drive of your computer. We use cookies that are necessary for our online Services to run, including optimizing or powering features on the Services and helping us identify irregular or fraudulent behavior on the Services. We also use performance and analytics cookies to understand how visitors engage with our online Services. 
• Web Beacons. Pages of our online Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Spark, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 
• Flash Cookies. Certain features of our online Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our online Services. Flash cookies are not managed by the same browser settings as are used for browser cookies. 

You can control the use of cookies on your device at any time by changing your preferences or options in your browser settings. Each browser provides different mechanisms for managing cookies. You can usually find these settings in the “Options” or “Preferences” menu of your browser; otherwise, look at your browser’s help menu to determine the best way to modify your browser’s cookie storage. You can also block, disable, or delete the cookies that are stored on your device. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages on our online Services.

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Third Party Use of Cookies and Other Tracking Technologies

Some content or applications related to the Services are served by third-parties, including advertisers, ad networks and servers, content providers, service providers, and application providers. These third parties may use cookies, alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use our Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

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We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. 

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Do Not Track Signals

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We currently do not respond to DNT signals.

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4. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To provide you with the Services.
• To communicate with you about the Services, including to notify you about changes to the Services, the Terms of Service, or this Privacy Policy.
• To improve and develop the Services. 
• To diagnose and fix technological problems with the Services. 
• To develop new products and services. 
• To provide information that you request from us.
• To fulfill any other purpose for which you provide it.
• Where permitted, for marketing and promotional purposes, such as to provide information to you about the products and services we or our business partners offer.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To provide human resources, employment, benefits administration, and related business purposes. 
• To find and prevent fraud. 
• To resolve disputes, to protect the rights, property, or safety of Spark, our Services, customers, employees, business partners, or the public, and to enforce any legal terms that govern your use of the Services or our other services and products. 
• To comply with our legal and regulatory obligations. 
• To evaluate or conduct a merger, sale, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• For any other purpose with your consent.

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5. Disclosure of Your Information to Third Parties

We may disclose personal information that we collect or you provide as described in this Privacy Policy to the following third parties:

• Our subsidiaries and affiliates.
• Our contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• Other users of the Services (including without limitation, insurance agents, insurance carriers, and health care providers) upon your request and/or with your consent. 
• Our business partners featured on co-branded sites or services that link to this Privacy Policy and are otherwise authorized by Spark. When we enter into these types of relationships, we will share the information you provide in order for our co-branded partners to fulfill the purposes for which you provided the information. If the co-branded site or service does not link to this Privacy Policy or is otherwise not authorized by Spark, then we do not control the site or service, the third party’s collection of data, or how they may use your data. If you are uncertain if a co-branded site is authorized by Spark, please contact us at privacy@sparkadvisors.com. If you have any questions about a co-branded site that does not link to this Privacy Policy or is otherwise not authorized by Spark, you should contact the responsible provider directly. 
• A buyer or other successor in the event of a merger, sale, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Spark’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• Third parties to market their products or services to you with your consent. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. 
• As necessary to fulfill the purpose for which you provide it. 
• As necessary to comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Spark, our customers, employees or others. 
• Any other third party with your consent.

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6. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional Offers from Spark. If you do not wish to have your email address or other contact information used by Spark to promote our own or third parties’ products or services, you can opt-out by clicking “Unsubscribe” at the bottom of the promotional email, sending us a return email asking to be omitted from future email distributions, or by sending us an email stating your request to privacy@sparkadvisors.com. You cannot opt out of receiving transactional emails related to your account with us or the Services.
• Communications From Other Users. Our users are solely responsible for their own communications (including marketing communications) with you. We cannot unsubscribe you from their communications. If you wish to opt-out of communications from another user, you can contact them directly.
• Third Party Advertising. We may partner with third party ad networks to display advertising on our website or to manage our advertising on other sites. These third parties may use cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI's website. Please note this does not opt you out of being served advertising you will continue to receive generic ads.

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7. Additional Rights for California Residents

The California Consumer Privacy Act and the California Privacy Rights Act:

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This section describes how we collect, use, and share California residents’ Personal Information in our role as a business, and the rights applicable to such residents. For purposes of this section “Personal Information” has the meaning given in the California Consumer Privacy Act (the “CCPA”). 

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A detailed description of the categories of Personal Information we collect and how we use such Personal Information is provided above in Sections 2 (Information We Collect About You) and Section 4 (How We Use Your Information). Section 5 (Disclosure of Your Information to Third Parties) describes the categories of third parties with whom we share Personal Information for a business purpose. While Spark may share Personal Information as necessary to provide the Services with third parties if those third parties are authorized service providers, users, or business partners (as described in this Privacy Policy) who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Information, Spark does not sell Personal Information. 

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If you are a California resident, you have the following rights under the CCPA:

• Request we disclose to you free of charge the following information covering the 12 months preceding your request:

• The categories of personal information about you that we collected;
• The categories of sources from which the personal information was collected;
• The business or commercial purpose for collecting personal information about you;
• The categories of third parties with whom we share that personal information; and
• The specific pieces of personal information we collected about you.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

• The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
• The categories of personal information that we disclosed about you for a business purpose.

• Request that we delete any of your personal information we collected from you, unless a CCPA exception is applicable.
• Request that we not sell your personal information to third parties (“opt-out”) by contacting us at the email address listed below. 
• Be free from unlawful discrimination for exercising your rights under the CCPA

We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of personal information will require additional information to verify your identity.

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Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. If you are an authorized agent, please send us proof that the consumer gave you written permission to submit the request and we will verify your identity as provided above. We may also require the consumer to verify their own identity with us and/or directly confirm with us that they have given you permission to submit the request.

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You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

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We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.

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To exercise any of these rights, please email privacy@sparkadvisors.com. We will not discriminate against you for exercising any of your privacy rights.

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“Shine the Light” Law (Civil Code Section § 1798.83):

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us at privacy@sparkadvisors.com. 

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8. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure, including but not limited to the following:

• All personal information is secured on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure, using appropriate physical, technical and organizational measures.
• All personal information in production environments is encrypted at rest.

Notwithstanding the foregoing measures, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in or on the Services.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

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9. Data Retention 

We retain personal information to achieve the purposes for which the information was collected. In certain cases, we may need to retain personal information for purposes required under applicable law, for tax or audit purposes, or for other lawful purposes.

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10. Children Under the Age of 16

The Services are not intended for children under 16 years of age. No one under age 16 may provide any personal information through the Services. We do not knowingly collect or process personal information from children under 16. If you are under 16, do not use or provide any information through the Services or otherwise provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@sparkadvisors.com. 

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11. Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on this Website and update the Privacy Policy’s effective date. Your continued use of the Services following the posting of changes constitutes your acceptance of such changes.

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12. Contact Information

If you have any questions or comments about this notice, the ways in which Spark collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under applicable privacy law, please do not hesitate to contact us at: