SiteSparq Privacy Policy

Effective Date: November 11, 2024

This Privacy Policy covers the policies of Invoke Corporation, a California corporation ("we," "us," or "our"), regarding the collection, use, and disclosure of personal information and data as defined by applicable law (referred to as “Personal Information”) when visitors and customers (collectively, "Users") access, use, or otherwise interact with SiteSparq, our website hosting service available at https://sitesparq.com (the "Platform") and the services provided through the Platform (collectively, the "Services").

Section 6 of this policy provides the Notice of Collection required under the California Consumer Privacy Act (CCPA).

1. Information We Collect

We collect minimal Personal Information necessary to provide the Services:

• Email Address: Used for account creation and communication.
• Name: Used for account identification and personalization.
• Payment Information: When processing payments, our third-party payment processor, Stripe, collects the following information:
  • Card number, expiration date, CVC code, cardholder name, country or region, and postal/ZIP code.
  • Note: SiteSparq does not store payment information on its servers. All payment processing is handled securely by Stripe.

The Platform and Services do not use cookies.

2. How We Use Your Information

We use your Personal Information solely for the purpose of:

• Creating and managing your SiteSparq account and providing the Services
• Communicating with you about your account and the Services
• Providing customer support
• Processing payments

3. Personal Information of Minors

SiteSparq does not knowingly collect Personal Information from anyone under the age of 16. If a parent or guardian becomes aware that his or her child under the age of 16 has provided us with Personal Information without their consent, please contact us at feedback@sitesparq.com. SiteSparq will delete such Personal Information from our systems within a commercially reasonable time, but no later than required under the applicable law.

4. Retention and Deletion of Personal Information

SiteSparq will retain account data for as long as it is necessary to provide Services to our customers, but not exceeding the maximum retention period prescribed by applicable laws and regulations.

5. Data Security

SiteSparq has implemented reasonable technical, administrative, and physical security measures to ensure your Personal Information is protected from unauthorized access, disclosure, alteration, or destruction. These measures include, but are not limited to:

• Encryption of data in transit and at rest
• Access controls limited to authorized personnel
• Regular security audits and monitoring for vulnerabilities

While we take every reasonable step to ensure your data is secure, please be aware that no method of transmission over the internet or electronic storage is completely secure. As such, we cannot guarantee absolute security.

6. Supplemental U.S. State-Specific Notices – Notice of Collection

This supplemental notice sets forth the disclosures and rights applicable to residents of California, Connecticut, Colorado, Virginia, Oregon, Texas and Utah. Such consumer privacy notices and rights shall also apply to other state residents to the extent other state consumer privacy laws are implemented following the last effective update to this Privacy Policy.

SiteSparq collects, uses and shares Personal Information with AWS and Stripe as service providers solely for the purposes of providing the Services.

Personal Information may also be disclosed to serve our legitimate business interests as follows: (a) as required by law, such as to comply with a subpoena, or similar legal process; (b) as part of a merger, acquisition, bankruptcy or other transaction in which a third party assumes control of all or part of the business; (c) to investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies as required by law; (d) to enforce our agreements with you; and/or (e) to investigate and defend ourselves against any third-party claims or allegations.

SiteSparq does not sell your Personal Information or share Personal Information with third parties for cross-context behavioral advertising purposes.

A. Consumer Rights. You may contact SiteSparq to exercise the following consumer rights:

1. Request SiteSparq Disclose at No Charge (“Right to Know”):

• Specific pieces of personal information it has collected about you;
• Categories of Personal Information collected, used, and/or disclosed about you;
• Categories of sources from which Personal Information is collected;
• Business and/or commercial purposes for collecting and disclosing your Personal Information;
• Categories of third parties with whom your Personal Information has been disclosed/shared; and

Right to Know Requests can be submitted to SiteSparq by email at feedback@sitesparq.com.

2. Request SiteSparq to Delete or Correct at No Charge (“Right to Delete or Correct”):

Deletion or Correction requests can be submitted to SiteSparq by email at feedback@sitesparq.com.

B. Verified Request Process

SiteSparq will verify all consumer requests prior to taking any action in response to such request. For consumers that maintain an account with SiteSparq, the identity of the consumer making the request may be verified by either matching information with the account information on file or through existing account authentication credentials.

Under the CCPA and applicable U.S. State Privacy Laws, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. Authorized agents must demonstrate they have written authorization from you to make requests on your behalf. SiteSparq may additionally require the consumer to confirm their identity and verify the authorized agent’s permission before complying with any request.

C. Consumer Request Limitations

Please note that these rights are not absolute and in certain cases are subject to conditions or limitations as specified in the applicable state laws, including, but not limited to:

• SiteSparq is obligated to disclose/delete only upon a verifiable Consumer (as defined by applicable law) request from the Consumer or an authorized agent acting on behalf of Consumer.
• Consumers may only make a personal information request twice in a 12-month period.
• Deletion is not required if it is necessary for SiteSparq to maintain the Personal Information to fulfill applicable permissible purposes enumerated pursuant to applicable state consumer privacy laws.

SiteSparq will confirm and respond to all requests within the timeframe required under applicable state law. In responding to any request to disclose/delete, SiteSparq shall maintain a record of the requests as required under applicable state law.

D. Non-Discrimination Policy

You have the right not to receive discriminatory treatment for exercising any rights conferred by the CCPA and applicable U.S. State Privacy Laws. SiteSparq shall not discriminate against a consumer for exercising any statutory consumer privacy rights, including, but not limited to, (a) denying goods or services, (b) charging different prices or rates (including discounts/penalties) that are not directly related to the value provided to SiteSparq for the Personal Information, (c) suggesting that a Consumer will receive a different rate/price or different level of quality of goods/services, or (d) providing a different level of quality of goods/ services.

E. Right to Appeal

If you are in a jurisdiction that recognizes your ability to appeal a decision made in connection with your attempt to assert a right under applicable U.S. State Privacy Laws, you may file an appeal of our decision refusing your request to exercise your rights under this privacy notice. You may request an appeal of such decision by contacting us at: feedback@sitesparq.com. Please provide the state that you are writing from, accompanied with documentation you may have regarding the matter you are appealing. SiteSparq will respond to your appeal request within the timeframe required under the U.S. State Privacy Laws applicable to your state of residence.

If your jurisdiction allows you to file a complaint with the state’s Attorney General’s Office regarding any concerns with the result of your appeal request, you may do so by using the following links as may be applicable to you. You may submit a complaint to the Attorney General’s Office by selecting the appropriate link: Virginia (www.oag.state.va.us/consumer-protection/index.php/file-a-complaint), Colorado (coag.gov/file-complaint), and Connecticut (portal.ct.gov/AG/Common/Complaint-Form-Landing-page).

7. Applicable EU GDPR Notices

Data Processor. SiteSparq is the processor of all Personal Information input by a Customer, and its authorized users, in connection with your use of the Services. You may contact SiteSparq at feedback@sitesparq.com.

Data Controller. The Personal Information input by (a) visitors in general, and (b) Customer for purposes of establishing a commercial account with SiteSparq, is controlled by SiteSparq. You may contact us at any time by emailing us at feedback@sitesparq.com.

For applicable EU Users, we will only collect and process Personal Information about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, and “legitimate interests.” Where we rely on your consent to process Personal Information, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your Personal Information, please submit a request through email at feedback@sitesparq.com.

We implement additional safeguards where appropriate, such as commercial industry standard secure encryption methods to protect customer data at rest and in transit and other appropriate contractual and organizational measures to ensure the confidentiality, integrity and security of a customer’s Personal Information.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

How to Review, Transfer, Restrict the Use of or Request Erasure of Personal Information

IF YOU WOULD LIKE TO:

• Access, review, restrict processing of, or otherwise request erasure of your Personal Information;
• Obtain the identity of the source of any Personal Information collected;
• Request correction of any errors contained within your Personal Information;
• Request SiteSparq transfer your Personal Information to another service provider;
• Object to the manner in which your Personal Information is processed;
• Lodge a complaint with an EU supervisory authority; or
• Withdraw consent to the collection of your Personal Information

Requests under this Section can be made through email at feedback@sitesparq.com. We will respond in the timeframes required under applicable law. For all requests made pursuant to this section, SiteSparq will (a) respond as required under applicable law, (b) provide a copy of any requested Personal Information in a structured, commonly used and machine-readable format, and/or (c) transmit such Personal Information to another service provider without restriction in accordance with applicable law.

8. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our website and updating the "Effective Date" at the top of the Privacy Policy page.

9. Contact Us

If you have any questions about this Privacy Policy, please contact us at: feedback@sitesparq.com.