This Privacy Policy describes how Spark The Click operated by IE Andrey Lukashov (Georgia) (“Spark The Click,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards personal information when you access https://sparkthe.click, https://sparkthe.click, and our subdomains including my.sparkthe.click (collectively, the “Site”), and when you purchase or use our products and services.

If you do not agree with this Privacy Policy, do not use the Site.

We may update this Privacy Policy from time to time. The “Last updated” date above reflects the most recent revision. Your continued use of the Site after changes take effect constitutes acceptance of the revised Policy.

1) Scope

This Policy applies to information collected through the Site and in connection with our products and services, including digital downloads, courses, consulting, and audits. This Policy does not cover third-party websites or services that we do not control.

2) Information We Collect

2.1 Information you provide

• Contact details such as name and email address.

• Account data when accessing materials via ThriveCart Learn+ (e.g., username, email).

• Transaction data related to purchases (product, price, date). Payment details are handled by our payment processor (see 7.2).

• Support communications and any information you include when contacting us.

2.2 Information collected automatically

• Usage and device data such as IP address, browser type, operating system, referring URLs, pages viewed, and access times.

• Cookie and tracking data as described in the Cookie Policy section below.

2.3 Information from third parties

• Payment and fulfillment data from ThriveCart.

• Email engagement data (opens, clicks) from MailerLite.

• Advertising and analytics data from Google Analytics, Meta Pixel, Reddit Ads, Twitter/X Ads, and LinkedIn Ads.

3) How We Use Information and Our Legal Bases for Processing

We collect and use your personal information for the purposes and on the legal bases identified below:

• To provide and manage our Service: We process your contact details, account data, and transaction data to fulfill our contract with you. This includes creating your account, delivering purchased products, and processing payments. * Legal Basis: Performance of a Contract.
• To improve our Site and develop new products: We analyze usage and device data to understand how users interact with our Service. This helps us fix issues and build better features. * Legal Basis: Legitimate Interests (to improve and grow our business).
• To send marketing communications: We use your contact details to send you newsletters and promotional offers about our products. * Legal Basis: Consent (which you provide when you opt-in and can withdraw at any time).
• For security and fraud prevention: We use account and device data to protect our Service and our users from fraudulent or illegal activity. * Legal Basis: Legitimate Interests (to secure our platform).
• To comply with legal requirements: We may need to process and retain your information to comply with tax laws, legal orders, or other regulatory obligations. * Legal Basis: Compliance with a Legal Obligation.

4) Marketing Communications

With your consent where required, we may send newsletters and promotional messages. You can unsubscribe at any time via the link in our emails. Transactional and service communications may still be sent.

5) Behavioral Advertising and Analytics

We use the following tools to understand usage and improve relevance of ads:

• Google Analytics

• Meta/Facebook Pixel

• Reddit Ads

• Twitter/X Ads

• LinkedIn Ads

• MailerLite (email analytics)

These providers may set cookies or read existing cookies and collect usage data per their own policies. See the Cookie Policy for opt-out options.

6) Retention

We retain personal information only as long as necessary for the purposes set out in this Policy, including fulfilling contracts, complying with legal obligations, resolving disputes, and enforcing agreements. Retention periods vary based on the type of data and our legal/regulatory requirements.

7) How We Share Information

We do not sell personal information. We may share information as follows:

7.1 Service providers

With vendors who perform services on our behalf, such as hosting, analytics, email delivery, customer support, and advertising.

7.2 Payments and access

Purchases are processed via ThriveCart. ThriveCart (and its integrated payment processors) receives the information necessary to process the transaction. We do not store full payment card details on our systems.

7.3 Legal and protection

To comply with law, legal process, or governmental requests; to enforce our Terms; and to protect the rights, property, or safety of Spark The Click, our users, or others.

7.4 Business changes

In connection with a merger, acquisition, reorganization, or sale of assets, subject to applicable law.

8) International Transfers

Your information, including personal data, may be transferred to – and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located in the European Economic Area (EEA), please note that we transfer data to countries that may not have the same data protection laws. When we do so, we ensure that appropriate safeguards are in place to protect your data, such as by using Standard Contractual Clauses (SCCs) approved by the European Commission, or by transferring to third-party providers that are certified under an adequate data transfer framework.

9) Security

We implement reasonable administrative, technical, and organizational measures designed to protect personal information. No method of transmission or storage is completely secure.

10) Children’s Privacy

The Site is not directed to individuals under 18. We do not knowingly collect personal information from children under 18.

11) Your Rights

Depending on your location, you may have rights such as access, correction, deletion, restriction, objection, and portability. You may also have the right to withdraw consent where processing is based on consent.

You also have the right to lodge a complaint with a supervisory authority, such as the data protection authority in your country of residence, if you believe our processing of your personal information infringes applicable law.

To exercise your rights, contact us at support@sparkthe.click. We may need to verify your identity before responding.

12) Do Not Track

Most browsers include a Do-Not-Track (DNT) setting. There is no uniform standard for DNT signals, and we currently do not respond to DNT.

13) Third-Party Links

The Site may contain links to third-party websites or services. We are not responsible for their content, practices, or policies.

14) Contact

Questions about this Policy may be sent to: support@sparkthe.click

Cookie Policy

What Are Cookies

Cookies are small text files placed on your device that help the Site function, improve performance, and enable features such as analytics and advertising. Related technologies include pixels, tags, and local storage.

How We Use Cookies

• Strictly necessary cookies to operate the Site and deliver requested pages.

• Performance/analytics cookies to measure visits, traffic sources, and usage (e.g., Google Analytics, MailerLite email analytics).

• Advertising/remarketing cookies from Meta, Reddit, Twitter/X, and LinkedIn to measure campaigns and show ads that may be more relevant to you.

• Functionality cookies to remember settings or choices where applicable.

Cookies/Tracking We Use

We may deploy or allow:

• Google Analytics

• Meta/Facebook Pixel

• Reddit Ads Pixel

• Twitter/X Pixel

• LinkedIn Insight Tag

• MailerLite tracking for email engagement

Each provider processes data per its own terms and privacy policies. You can usually manage preferences on their platforms.

Managing Cookies

You can set your browser to refuse or delete cookies. If you block cookies, some Site features may not function properly.

Helpful resources for browser controls:

• Chrome, Firefox, Safari, Edge, Opera, and iOS/Android browser settings documentation.
  Industry tools: Network Advertising Initiative (NAI) and Digital Advertising Alliance (DAA) opt-out pages for interest-based advertising.

Email Pixels

Our emails may include tracking pixels to measure opens and clicks. You can disable images or unsubscribe from marketing emails to limit this tracking.

Changes to This Cookie Policy

We may update this Cookie Policy section from time to time. Continued use of the Site after changes become effective indicates acceptance.

By using the Site, you agree to this Privacy Policy and the integrated Cookie Policy.