Privacy Policy
SurveySparrow Inc,. including its affiliates, subsidiaries and associated websites (collectively "SurveySparrow Inc", "SparrowGenie", "We", "Us" and "Ours") is committed to protect your privacy and ensure your Personal Information is collected and transferred in a fair and transparent manner.
We recommend you to take the time to review this Privacy Policy in order to understand how we collect, process, share your Personal Information through our digital properties that are associated with this Privacy Policy including our www.sparrowgenie.com website, product, apps and Services offered by us, as well as interaction through social media, marketing activities, and other activities described in this Privacy Policy and how you may exercise your rights relating to our processing of that data.
This Privacy Policy applies to Customers, Subscribers/Visitors and does not apply to any information collection activity outside of the scope of the Services outlined herein (unless otherwise stated below or at the time of collection). It also does not apply to information that we process on behalf of our Customers through their use of our Services. In such cases, we process such information on the basis of our Customer's instructions and act as their Data Processor. If you are a Respondent of any of our Customers, we encourage you to review such Customer's privacy notices and terms of use to understand how your Personal Data is handled. If you as a Respondent have queries regarding such Customer's privacy practices, or if you seek to access, update, or remove your data, we request you to contact the Customer with whom you interact directly. If a Customer requests access to or otherwise requests us to update or remove data, we shall respond within a reasonable period of time.
Definition
For the purposes of this Privacy Policy, following definitions and rules of interpretation shall apply:
- "Personal Information" means any information that can be used to identify, locate, or contact an individual directly or indirectly which is obtained from or provided by You through the use of website and/or Services.
- "Customer" means the individual or entity that registers for or uses the Services and shall include individuals who are authorized by the Customer to use our Services, for whom the Customer have purchased a subscription (or in the case of any Services provided by us without charge, for whom a Service has been provisioned)
- "Respondents" means and includes an end-user who receives or responds to the Customer or otherwise interacts with the platform as a result of the Customers utilisation of the Services, which shall include but not limited to the Customers employees, agents, customers or subcontractors.
- "Subscriber" means and includes anyone who subscribes to our email notifications, newsletters, marketing campaigns etc.
- "Visitor" means and includes anyone who visits and/or uses or otherwise interacts with the SparrowGenie website.
- "Service" means SurveyGenie's products, services, website, and apps that you purchase or sign up for on SurveyGenie's websites.
- "Users" shall mean either a Subscriber, Visitor or a Customer
- "You" and "Your" means, depending on the context, either a Customer, Subscriber/Visitor or Respondent.
Types of Information Collected
We may collect Your Personal Information including but not limited to name, contact number, email id, credit card information and other related Personal Information (the details of which are mentioned below) necessary to provide the Services, when You register for SparrowGenie account or otherwise use our Services, browse our website or consult with our customer service team and for our legitimate interests as permitted under the relevant data protection laws. We collect the following types of information:-
Registration information
When You register an account on www.sparrowgenie.com or voluntarily express an interest in obtaining information about us or otherwise contact us, we collect Your Personal Information including email address, other contact details, IP, location, device, OS information and certain other information reasonably necessary to help You create an account pursuant to our provision of Services.
If you create a SparrowGenie account or log into SparrowGenie using your Google credentials via single sign On, we shall have access to your name, email and other information you have authorized in your Google profile settings. We collect this information to give you access to the Services and personalize our Services.
Technical Information
We may automatically collect technical information such as your internet protocol (IP) address, device and operating system information, browser information, access information, geographic and time zone information, search term queries, and actions in our Services. In order to improve our internal operations and website and to better understand your preferences and serve you, we may combine information you provide with other automatically-collected information. This may include data from SparrowGenie communications, events, or online marketing.
Billing information
When You make a payment on www.sparrowgenie.com in Your preferred payment method, You're required to provide billing details, such as name, billing address, and financial information (like credit card details).
Credit card processing is handled by an intermediary service provider, Stripe on our behalf who collects Your credit card information to process Your payment to us. We do not store any such information pertaining to Your credit card. This third party intermediary shall not use or retain billing information for any purpose other than that is permitted for processing the payment and related legitimate interests. By providing such information You represent and warrant that You are the owner of such Personal Information or otherwise have requisite consent to provide it to us.
Usage information and User details
We may collect information such as the links or pages you've clicked on while using our Services, the time spent on those pages, the queries you've raised, and other interactions you may make while using our Services. User details such as IP, location, device information and browser information and its activities will be tracked when a user is interacting with our application. We also track referral information. Meaning, we also track how the user landed into SparrowGenieThriveSparrow.
Additionally we may use Google Analytics to collect information regarding the behavior and demographics of visitors using our services. To prevent Google Analytics from processing Your data, please visit https://tools.google.com/dlpage/gaoptout
Navigational information
We may collect information like IP address, geographical location, browser type, device information, length of visit and pages viewed, URL's of the pages You visit, including those tracked by our browser extensions.
Referral information
We collect information on the site/link or any place which led You to visit our website – for example, if You were on social media before clicking on a link to our website, we record information about the source that referred You to us.
Information uploaded to the dashboard
We will collect and store the data submitted to the platform for the purpose of providing our Services. This data may include, but is not limited to, your company's information, documentation, and any materials uploaded by you, such as contracts, requests for proposals (RFPs), compliance data, project details, financial records, employee information, and other related content. All such data will be handled in accordance with our Privacy Policy, which governs the collection, use, and protection of information provided through our platform.
You are the controller and owner of Your data. SparrowGenie shall grant you the admin role to collect and export the data and/or documentation as you wish. We do not sell or use any of Your data for our business requirements. This admin role also grants You the right to edit your submitted data at any time.
Other information
We collect information from You through testimonials, case studies, forms or information You intentionally share with us in other contexts.
Note: We don't share or abuse your Respondents' email addresses. SparrowGenie shall not email your survey Respondents or subscribers in your list except at your direction. We don't sell or share the email addresses in your list to any third parties.
Event Logs
A log of all requests generated by the User is maintained to debug in case of any emergencies. This includes User information such as IP, location, OS information, browser, device type and the time which the User interacted with the platform. These log files are encrypted and rotated frequently.
Referral information
like the site/link or any place which led You to visit our website – for example, if You were on social media before clicking on a link to our website, we record information about the source that referred You to us.
Information we collect from Third-parties
We may collect your Personal Information from third parties to whom You have given Your personal data sharing permissions. like social media platforms and data providers. This may include Your IP address or any information for which You have given permission to those third parties to share that information with us or where that information is publicly available either online or through Your device/browser data.
Data of Respondents
If you are a Respondent, please note that Your information shall be processed only on behalf of our User, which may or may not include your Personal Information, which we do not access or use for any purposes other than that is required to provide the Services to our Users. We host the Services on our website or app and We act as an intermediary platform for our Users. We only process such data provided by You to our Users and are limited for the performance of contractual obligations and Services to our Users. We will not be responsible for security and privacy practices of our Users which may differ from that is set forth in this Privacy Policy.
We don't sell, misuse or share Your information to third party advertisers or marketers. However, the policy might be different with the User. So you're advised to check with them in this regard.
We will not contact You unless directed by our User in which case we will collect and use Your contact information like name, email address etc. as provided by our User
Source of Collection of Information
We may collect, process and use information about You when You
- Register for our Services
- Interact with our Services
- Request to receive customer support, information, communications, or content
- Install and/or access our Services through our application(s), including our mobile application and browser extension
- Participate in a website feature
- Connect to our Services through third parties, including social media accounts, email accounts and business partners.
- Contact us
Your Data Protection Rights
If you wish to exercise your rights under any applicable data protection law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA) please contact us by email at [email protected] .
Subject to your applicable data protection laws, you may be entitled to any of the following rights:
- Right to be informed of what Personal Information is being processed and the rationale for such processing.
- Right to access, update, edit and delete Your information
- Right to restrict and object to processing of Your information
- Right to complain to a data protection authority about our collection and use of Your personal information.
- Right to complain to a data protection authority about our collection and use of Your Personal Information. However, before referring to your local supervisory authority, please attempt to resolve the issues directly with us amicably.
You may have certain Personal Data rights with your applicable data protection authority. For more information, please contact your local data protection authority (contact details for data protection authorities in the European Economic Area, Switzerland, and certain non-European countries are available here.)
Note: You will be solely responsible to respond to requests raised by the Respondents in exercise of their data protection rights.
If You no longer wish to be contacted by Us please unsubscribe from our Services.
General Information
Use of your information
To the extent permitted by applicable law, We use your Personal Information that either we collected from or received through our Services in order to perform our contractual obligations, Services and other legitimate interests that are further detailed below:
- Process Your registration with our Services in accordance with our legitimate interests to operate and administer our Service. This includes sending You emails, invoices, receipts, notices of delinquency, and alerting You if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process Your orders and credit card payments.
- To communicate with You about Your account and provide customer support to perform our contract with You for the use of the Service or where we have not entered into a contract with You, in reliance on our legitimate interests in administering and supporting our Service.
- To enforce compliance with our Standard Terms of Service and applicable law, and to protect the rights and safety of our Users in reliance on our legitimate interest to protect against misuse or abuse of our Service and to pursue remedies available. If You use our Services in any way to carry out the prohibited, unlawful and fraudulent activities and the contents in it are reported as abuse by anyone including Respondents we reserve the right to review Your Content, suspend the Service(s) and block Your account as deemed necessary.
- To personalize Your experience and to allow us to deliver the type of content and product offerings You are most interested in;
- To improve our website or services in order to better serve You;
- To allow us to better service You in response to Your customer service requests;
- To administer a contest, promotion, survey or other site feature;
- To quickly process Your transactions;
- To ask for ratings and reviews of services or products;
- To follow up with them after correspondence (live chat, email or phone inquiries;
- To investigate, prevent unauthorized access to the Websites and the Services, and other prohibited activities for ensuring compliance with our Terms of Service, applicable laws;
- To carry out other legitimate business purposes, as well as other lawful purposes;
- To send updates about our products, features and services;
- To send email campaigns or any other mails related to our products, features and services;
- for other purposes for which we obtain Your consent
Who do we share your Personal Information with?
SparrowGenie will not share Your Personal Information without Your consent unless otherwise required by law. SparrowGenie as a Data Processor may process and disclose Personal Information to third party sub-processors for purposes consistent with the clauses mentioned in the DPA document. We may also share Your Personal Information with third party service providers for the purpose of delivering improved and better Services to you.
A detailed list of third parties where such information may be disclosed(if applicable) is provided in Annex III of our DPA document.
We engage third party service providers to provide complimentary services to us and in connection with this, these third party service providers may have access to Your information. For example, we may partner with other third party service providers to provide You customer support services, authentication services,, process payments, administer our promotions etc. These Service Providers may have access to Your information in facilitating and enhancing our Services to You and may only use for such limited purposes. We do not permit our third-party service providers to use such information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.
Disclosure for legal purposes: We may also share the information we collect, including Personal Information, to the extent permitted by applicable law, (i) in response to subpoenas or other legal processes or if, in our good faith opinion such disclosure is required or permitted by law without a specific disclosure; (ii) at the request of governmental authorities conducting an investigation; (iii) to enforce our terms and conditions or other policies applicable to our Services etc.
Legal Basis for Processing Personal Information
The legal basis for collecting and processing Personal Information will depend on the type of Personal Information that we collect and the specific context in which we collect it. We will collect, use and/or process Your Personal Information only where such processing is in our legitimate interests, as permitted by law, and shall not be overridden by Your data protection interests, rights and freedoms. Our legitimate interests are described in the General Information Section under the heading "Use of Your Information".
If you have questions or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us at [email protected]
International Data Transfer
Currently we have our Data Centers located in the United States and European Union (EU). SparrowGenie may transfer Personal Information to the United States or EU for the performance of Our contractual obligations with You. SparrowGenie will follow the requirements of GDPR regardless of where such Personal Information is stored or processed. We will take all steps reasonably necessary to ensure that Your Information is treated securely and in accordance with this Policy. We will not transfer Your Personal Information without Your consent and ensure to have appropriate safeguards in place.
For more information, please refer to our DPA document, section International Transfer of Data.
Retention of Personal Information
SparrowGenie stores User data with reference to Your Service account. This may include Personal Information, survey data and other details that You enter into the app from time to time. We will retain Your Personal Information as long as you have an account with us in order to maintain and expand our relationship with You and in order to have proof and evidence concerning our relationship with you. Please note that except as required by applicable law or our specific agreements with you, we shall not have any obligation to retain your data for any particular period. Upon termination or expiry of your account, not exceeding 07 (seven) days from the date of such expiration or termination, we will delete all Personal Information including any copies thereof. In case, we are unable to delete Your Personal Information due to technical or other reasons, SparrowGenie will apply measures to ensure that Your Personal Information is blocked from any further processing until deletion is possible. This excludes the data that we are required to retain for legal and regulatory requirements.
Data Portability
Being the data owner, it is completely your call to decide on where & with whom your data must reside. You can use our standard data export functionality or API to export the data. In any event of this not working for you, We will help you to export your data
Our EU Representative:
Under Article 27 of the GDPR, we have appointed an EU Representative to act as our data protection agent. Our nominated EU Representative is:
Instant EU GDPR Representative Ltd
Adam Brogden
[email protected]
Tel + 353 15 549 700
EU Dublin Address
INSTANT EU GDPR REPRESENTATIVE LTD 69 Esker Woods Drive, Lucan Co. Dublin Ireland
Our UK Representative:
Instant UK GDPR Representative Ltd
Adam Brogden
[email protected]
Tel + 441 772 217 800
GDPR Local Ltd 1st Floor Front Suite 27-29 North Street, Brighton England BN1 1EB
Cookie Policy
Cookies are files with a small amount of data that are transferred to your browser by a web server, which in turn may be stored on your device that enables the web server or service provider's systems to recognize your browser and capture and remember certain information. They are also used to help us understand your webpage preferences based on previous or current site activity which enables us to analyze how Our Services perform in Your device and provide you with improved user experience and services. SparrowGenie also uses cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
We use cookies to:
- Help remember and process the user's chosen plan.
- Understand and save user's preferences for future visits.
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
Cookies, by themselves, cannot personally identify You. However, you may provide personal identification by creating an account with us, completing a web form, or engaging in similar activities on our platform. You have the option to disable some or all cookies by adjusting your browser settings or using third-party opt-out tools. Additionally, you can configure your browser to notify you whenever cookies are placed on your device.
If users disable cookies in their browser:
Please be aware that disabling cookies may impact the functionality of certain features on the Website, potentially causing them to operate less efficiently or cease functioning entirely.
Do Not Track Signals(DNT):
We do not support DNT. If you wish to prevent SparrowGenie from processing your data, you can enable the DNT signal in your browser settings. This will disable tracking whenever you visit our website.
Third-Party Websites
We do not sell, trade, or otherwise, transfer to outside parties your Personally Identifiable Information. This does not include website or service hosting partners and other parties who assist us in operating our website or services, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety.
Third-party links
Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Standard Contractual Clauses
Our commitment to data protection extends beyond mere compliance. We undertake to contractually commit to transfer and process all of our Users' data in compliance with the new Standard Contractual Clauses adopted by the EU Commission on 4 June 2021, replacing the old SCCs that were adopted under the previous Data Protection Directive (Directive 95/46), which remains a valid data export mechanism and which automatically apply in accordance with our DPA.
COPPA (Children Online Privacy Protection Act)
When it comes to collection of personal information from children under the age of 13 years, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.
Do we let third-parties, including ad networks or plug-ins, collect PII from children under 13?
Our Services and website are not intended to target children under 13 years of age("Minor"). Neither do we specifically market and allow Minors to register with us nor knowingly collect Personal Information from Minors. If you have reasons to believe that a Minor has accessed our website and/or has registered with us to create an account, please contact privacy@_____________. We shall take reasonable efforts to terminate that account and delete the information.
We do not sell your Personal Information
The CCPA requires businesses to disclose whether they sell Personal Information. SparrowGenie does not sell your Personal Information. This means that we do not rent, disclose, release, transfer, make available or otherwise communicate that personal information to a third party for monetary or other valuable consideration.
Our Commitment to Data Privacy
SparrowGenie gives utmost importance to the data privacy of its customers. In compliance with the GDPR regulation, we hereby confirm upon the data privacy, security & transparency commitment, the company offers to all its customers.
We have an up-to-date Data Processing Agreement in place that elucidates our approach towards GDPR. We acknowledge that the GDPR will help us adopt the highest operational standards and will thereby facilitate protecting customer data in the best way possible.
Our Approach
It is pretty straightforward. We strive for Transparency, Privacy, and Security. We are the facilitators who make data processing and management simple for you. You control and own your data!
Personal Privacy
Personal Privacy of customers data is absolute at SparrowGenie. While we will process customer data, it is the customer on whom the power to edit, delete, retain or transfer any of such data, fully rests upon. You are entitled to exercise your data protection rights subject to your applicable data protection laws, to the extent we act as Processor and collect your Personal Information.
Transparency
Customers at any point in time can get in touch with us and conduct audits on their Personal Information. They can approach the Data Privacy Officer (DPO) by sending an email to [email protected] and ask for any information pertaining to their account. If deemed necessary, customers can also verify their logs to confirm upon specific events related to their Personal Information.
Security
We promise to adopt utmost security standards so that your Personal Information does not get compromised at any point in time. We have tightened our IT infrastructure, data security platform & IT policies so as to offer our customers enhanced end-to-end security.
Amendments to Privacy Policy
We may, at our sole discretion, update, alter or change this Privacy Policy from time to time to meet and reflect the changing legal, regulatory and operational requirements. We will post the revised version on the website along with the effective date. In case there are any material changes in the way we collect/handle your information we will notify you about the policy changes via email. However, your continued use of our Services would imply your consent to the amendment of our Privacy Policy. In case You have opted-out of our email notifications You are recommended and liable to check this page on a periodic basis to know the changes. If you do not accept the terms of this Policy or any amendments made to it, you may choose to discontinue use of our website or Services.
Unsubscribe From Our Communications
If you want to unsubscribe from our marketing communications, you can do so by clicking on the "Unsubscribe" link provided at the bottom of the emails, updating your communication preferences, or by sending an email to [email protected]
Please note that Customers cannot unsubscribe from transactional emails which relate to their account or the Subscription Service.
Unsubscribe from Our Customers' Communication
Our Customers are solely responsible for their marketing emails and any communications. Thus we cannot unsubscribe you from their communications. You can unsubscribe from our customers' marketing communications either by using the "Unsubscribe" link provided at the end of the emails, or by directly contacting them.
How To Contact Us?
If you have any questions regarding our privacy policy, feel free to send us an email at [email protected]. We will revert to you within a maximum of 15 business days.