Last revised on November 22, 2022
We at Fireflies Ltd. (“us“, “we” or “Company“) respect the privacy of our users (each, a “User” or “you“) and are committed to protect the privacy of Users who access, visit, or engage with its website, available at https://sprkl.dev/ (the “Website“) or with any product, content or service offered by us (collectively, the “Services“).
Collection and Storage of Your Personal Information
We collect and use the following types of information about you:
Personal Information is information that identifies an individual or that may, with reasonable effort, identify an individual. We gather the following types of Personal Information:
- Name, email address, and other contact information: When you send us an email or contact us via the Services, we collect the Personal Information you provide us. This may include your name, email address and any other information you choose to provide.
- Device information: We collect from our Users specific types of connection details and information with regard to their device, software or hardware that may identify them, such as online identifiers, device unique identifiers (e.g. UDID, MAC address), IP address and geolocation.
How We Use Personal Information
In addition to the purposes listed herein, the Personal Information we collect is used for the following purposes:
- Provision of the service – we will use the Personal Information you provide us for the provision and improvement of our Services, providing customer support and to respond to your queries.
- Improving our services – we collect and analyze information about you and your usage of our Services to improve its usability and effectiveness.
- Marketing –according to your communication preferences, we may use your Personal Information in order to send you commercial communication, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions and events, about us and our partners. See more under “Marketing” section.
- Process your job application – if you apply to work at the Company, we will process the Personal Information you provide us.
- Protecting our interests – we may use your Personal Information when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Services and protect the rights and property of the Company, its users and/or partners.
- Compliance with legal and regulatory requirements – we may use your Personal Information to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
- Process for other purposes for which we obtain your consent.
With Whom Do We Share The Personal Information We Collect?
- Service providers: we work with service providers that work on our behalf that may need access to certain Personal Information in order to provide their services to us. These companies include those we have hired to provide various services, such as cloud storage or CRM vendors.
- Compliance with laws and law enforcement entities: we may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including meeting national security or law enforcement requirements. We will only disclose the minimum amount of Personal Information that is required for compliance with such legal requirements.
- Auditors and advisers: we may share your data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for the purpose of ensuring our compliance with regulatory requirements and industry standards.
- Mergers and acquisitions: we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services.
- Prevention of illegal activities: Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required to comply with our legal obligations.
- As you may otherwise consent from time to time.
Third-parties who we may share your Personal Information with will be required to meet our standards on processing information and security. The Personal Information we provide them will only be provided in connection with the performance of their function.
Why We Use Your Personal Information
Please note that our legal basis for collecting and using your Personal Information will depend on the Personal Information collected and the specific context in which we collect it. We normally collect Personal Information from you only where: (a) we have your consent to do so, (b) where we need your Personal Information to perform a contract with you (e.g. to deliver the service you have requested), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such Personal Information under applicable laws.
In some cases, we may need the Personal Information to protect your vital interests or those of another person.
Where we rely on your consent to process your Personal Information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your Personal Information, you have the right to object.
If you have any questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us through the contact details available below.
There are various ways in which you can manage and control your Tracking Technologies settings. For example, you can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions). However, please note that certain features of the Services may not work properly or effectively if you delete or disable cookies.
We may use your Personal Information, such as your full name, email address, etc., ourselves or by using our third-party partners for the purpose of providing you with promotional materials, concerning our services.
At any time, you may request to unsubscribe and discontinue receiving marketing offers by contacting us using the details provided below or by clicking the “unsubscribe” link at the bottom of each such marketing communications.
Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
Certain jurisdictions provide Users with certain statutory rights to their Personal Information. You may have the right to certain actions to your Personal Information such as:
- To receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with certain supplementary information.
- To receive Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format.
- To request rectification of your Personal Information that is in our control.
- To request erasure of your Personal Information.
- To object to the processing of Personal Information by us.
- To request to restrict processing of your Personal Information by us.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
If you wish to raise a complaint on how we have handled your Personal Information, you can contact us at the contact details available below.
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority.
For How Long Do We Retain the Personal Information We Collect?
We retain the Personal Information that we collect from Users for as long as needed to operate the Services and to provide our services to you and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). Retention periods will be determined taking into account the type of the Personal Information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused Personal Information at the earliest reasonable time. Under applicable regulations, we will keep records containing your Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.
International Transfer (for EEA residents)
Since we operate globally, it may be necessary to transfer data, including Personal Information, to countries outside the EEA. In these instances, we will transfer your Personal Information only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection.
How Do We Safeguard Your personal information?
We take great care in implementing and maintaining the security of the Services and of your Personal Information. We employ industry standard procedures to ensure the confidentiality, integrity, and availability of our Users’ data, safety of your Personal Information, and prevent unauthorized use of any such information.
However, we cannot guarantee that hackers or unauthorized personnel will not gain access to Personal Information despite our efforts. You should note that by using our Services, your Personal Information will be transferred through third party infrastructures which are not under our control. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.
We do not knowingly collect or solicit Personal Information from anyone under the age of majority (as determined under the applicable laws where the individual resides; “Age of Majority”). By accessing, using or interacting with our Services, you certify to us that you are not under the Age of Majority. In the event that we learn that we have collected personal information from an individual under the Age of Majority without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Majority, then please contact us through the contact details available below.
Links to Third Party Sites
The Services may contain links to other websites that are not under the Company’s control. These websites have their own policies regarding privacy. You are encouraged to review those policies before visiting such websites. The Company has no responsibility for linked websites, and it provides these links solely for the convenience and information of its Users.
Changes to the Policy
How to Contact Us