Last updated: 28 March 2024
Welcome to the Spark9’s Privacy Policy for Young Users.
Spark9 prioritises protecting young users’ data. This privacy policy will inform young users how we look after their data when they visit our parental control mode (regardless of where you visit it from) and tell them about their privacy rights and how the law protects them.
Important Information And Who We Are
We only collect limited data from young users in Spark9’s parental control mode. This is because the parental control mode only enables limited functions for young users. [company name], a [country] company, controls all data collected from young users.
Young users are determined by the relevant applicable laws and regulations from the countries where users reside. The table below sets out a non-exhaustive list of age gates currently applied in the parental control mode.
| Country | Gate |
| United Kingdom, Brazil, Russia, Ukraine, and other Central Asia countries | Lower than 13 |
| Spain, Italy | Lower than 14 |
| Australia, France, New Zealand, | Lower than 15 |
| Germany and other European countries, Iran | Lower than 16 |
Contact details
If you have any questions about this privacy policy for young users or our privacy practices, please get in touch with us via email at legal@spark9asia.com
Changes to the privacy policy
We keep our privacy policy under regular review. This version was last updated in December 2021.
The Data We Collect About You
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows:
- Identity Data includes username or other unique identifier (if you log in to Spark9 via third-party social media platforms), date of birth and gender.
- Contact Data includes telephone numbers and email addresses.
- Technical Data includes your login data, app version, time zone setting and location, resolution, operating system and platform, and other technological information on the devices you use to access Spark9’s parental control mode.
- Profile Data includes your account password, profile image, registration information, and education information.
- User-generated Data includes pictures, images, videos, sounds, or other data or materials you upload, distribute or stream on Spark9.
How Is Your Data Collected?
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your Identity, Contact and Profile Data by filling out forms or communicating online. This includes personal data you provide when you:
- create an account on Spark9;
- subscribe to other users’ publications, or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your device.
How We Use Your Data
Below, in a table format, we describe how we plan to use your data and which legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.
Note that we may process your data for more than one lawful ground, depending on the specific purpose for which we are using your data.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new user | (a) Identity (b) Contact | Performance of a contract with you |
| To manage our relationship with you which will include notifying you about changes to our terms or privacy policy | (a) Identity (b) Contact (c) Profile | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated) |
| To administer and protect our business and Spark9 (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant content to you | (a) Identity (d) User Generated Data (c) Technical | Necessary for our legitimate interests (to develop our business) |
| To use data analytics to improve our Spark9 and its services, and experiences | (a) Technical (b) User Generated Data | Necessary for our legitimate interests (to develop our business) |
No-Marketing
We do not provide marketing and advertising services for young users in Spark9’s parental control mode.
Change of purpose
We will only use your data for the purposes we collected it unless we consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you would like an explanation of how the new purpose’s processing is compatible with the original purpose, please get in touch with us.
Disclosure Of Your Data
We may share your data with internal affiliates of Spark9 to develop information technologies and provide you with a better experience. We will not share your data with any external third party.
Data Security
We have implemented appropriate security measures to prevent your data from being accidentally lost, used or accessed unauthorised, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your data according to our instructions, and they are subject to a confidentiality duty.
Data Retention
How long will you use my data? We will only retain your data for as long as reasonably necessary to fulfil the purposes we collected it, including satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your data for a more extended period in case of a complaint or if we reasonably believe there is a prospect of litigation regarding our relationship with you.
You And Your Parent’s Rights
Your rights.
Under certain circumstances, you have rights to your data as set out below.
- Request access to your data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify the accuracy of your new data.
- Request the erasure of your data. This enables you to ask us to delete or remove personal data without a good reason to continue to process it. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons, which will be noted to you, if applicable, at the time of your request.
Your Parents’ Rights.
Further, parents of young users will have the rights to young users’ data as set out below:
- Request to review or erase young users’ data. This enables parents to ask us to provide a copy of the data we hold about young users and to delete young users’ specific data.
- Request restriction of collecting, processing, or using young users’ data. This enables parents to ask us to suspend collecting, processing or using young users’ data in scenarios parents deem inappropriate.
If you or your parents wish to exercise any of the rights set out above, please get in touch with us at legal@spark9asia.com or use the Feedback function available in the parental control mode. We will respond to your request consistent with applicable law and subject to proper verification. And we do not discriminate based on the exercise of any privacy rights that you might have.
What we may need from you
We may need specific information from you or your parents to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This security measure ensures that personal data is not disclosed to anyone with no right to receive it. We may also contact you to ask you for further information concerning your request to speed up our response.
Time limit to respond
We endeavour to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
