(Effective Date: 13 October 2016)
A. The operative parties referred to in this policy are the Company and you, the user of this site.
2. You, the User – As the user of this Site, this policy may refer to the user as "you" or through any second-person pronouns, such as "yours," etc.
3. Potential Advertisers – Some individuals access the Site for the purpose of applying to become an Advertiser on the Site. These individuals are considered "Users" as defined hereunder.
II. Revisions To This Policy
We reserve the right to revise, amend, or modify this policy and our other policies and agreements at any time and in any manner. You should periodically check for any modifications of this Policy by re-visiting this web page and using the "refresh" button on your browser. You should note the date of last revision to this Policy, which appears at the top of this Policy. If the "Last Updated" date remains unchanged after you have clicked the "refresh" button on your browser, you may presume that no changes have been made since the last reading of the policy. A changed "Last Updated" date indicates that this Policy has been updated or edited, and the updated or edited version supersedes any prior versions immediately upon posting.
III. Personal Information That We Collect
Users of our Site and services will have multiple manners of interactivity with us. However, aside from information collected from Potential Advertisers or Advertisers on "brightsparktutoring.com" and possible other sites or mobile phone applications as applicable, at the present time, and subject to our exclusive revision without prior notice, Users are not required to enter through any active data collection pages. Any information gathered is limited to cookies, IP Addresses and Referral URLs, and other passive information gathering devices, as explained below. We collect certain necessary information such as name, email, phone number, age, and IP addresses from Potential Advertisers and/or Advertisers. Our use of information collected from Advertisers is governed by a separate advertiser agreement. We reserve the right to utilize information collected from Potential Advertisers, during the registration process, and Users who voluntarily provide us information such as comments, feedback, and DMCA notices ("Voluntary Users"), in accordance with the applicable provisions of Sections V and VI, below.
IV. How We Collect Information From You
B. Active Collection – Except as stated in Section III, the Site does not presently engage in any active collection of User data. The information referenced in Section III is collected from Potential Advertisers, during the registration process, from Advertisers, during his/her interactions with us including, but not limited to, the ad preparation/submission process, and from Voluntary Users.
V. How We Use Your Information
The primary use for any information collected is to provide you with Site services. We also use your information to deliver customized services to you; for User support purposes; and for efforts to monitor and help ensure against fraud, harassment and spamming. Non-personal and aggregate information, which is – as stated above – collected passively, is used in order to geographically customize our marketing efforts or to generally customize the use of our site for an aggregate group of customers. Information gathered from Potential Advertisers may be used to assist such individuals in completing the registration process, promotional communications, and for marketing and/or research purposes. Information gathered from Voluntary Users may be used in any manner at our sole discretion including, but not limited to, as described in Section VI.
VI. Special Cases
It is our policy not to use or share the passive information about Users in ways unrelated to those described in this Policy without also providing the User with an opportunity to opt out or otherwise object to such unrelated uses. However, we may disclose passively-collected information about Users, or information regarding your use of the Services or web sites accessible through our Services, for any reason without notice if, in our sole discretion, we believe that it is reasonable to do so, including, but not limited to:
1. To satisfy any laws, regulations, or governmental, or legal requests for such information;
2. To disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Terms & Conditions and other policies and procedures;
3. To operate our Services properly;
4. To protect ourselves, our Users, and the general public. We specifically reserve the right to disclose any and all information to law enforcement in the event that a crime – including, but not limited to, fraud-related offense – is committed, is suspected, or if we are compelled to do so by lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, warrants, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process; and
5. To cooperate with law enforcement authorities, and other governmental, administrative or regulatory agencies about our Users to the extent required by applicable law. Examples of such cooperation include, but are not limited to, lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, warrants, or writs. We do not intend to cooperate with private-party litigants and others seeking information unless compelled to do so through lawful court or administrative process, such as subpoenas, court orders, warrants, or writs.
VII. Electronic Communication from Us
IX. Our Commitment to Data Security
We take measures, including data encryption, to protect the transmission of all sensitive User information. We make every reasonable effort to help ensure the integrity and security of our network and systems. Nevertheless, we cannot guarantee that our security measures will prevent third-party ‘hackers’ from illegally obtaining this information. We take all reasonable measures to prevent such breaches of security, but given the resourcefulness of cyber-criminals we are unable to guarantee that our security is 100% breach-proof. You assume the risk of such breaches to the extent that they occur despite our reasonable security measures.