Spark Change Group Inc. Privacy Policy

This Privacy Policy (this "Policy") describes the ways in which Spark Change Group Inc. (the "we" or "us", “SCGInc.”) collects, uses, and discloses information about you, including personally identifiable information, in connection with your use of the website www.sparkchange.io  (“Website”). Throughout this Policy, "you" refers to the individual or entity that is using the Website . By using the Website, you consent to the use of your information as set forth in this Policy.

1. THIS POLICY
   1. Scope. SCGINC. utilizes the Website to provide certain services related to the offering of securities by Issuer SPVs (the "Services"). In the course of providing the Services, SCGINC. may collect "Personal Information," which means any information relating to an identified or identifiable natural person (a "data subject") (an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person).
   2. Changes to this Policy. SCGINC. reserves the right to update this Policy from time to time by posting a new Policy on this page, and in some cases where changes are material SCGINC. may also contact you via electronic mail or post a notice on the homepage to let you know of such changes. You are advised to consult this Policy regularly for any changes. Your continued use of the Website after such changes have been made constitutes acceptance of those changes.

2. Collection of Information

1. Information that You Provide. SCGINC. collects any information that you voluntarily provide, including when you use the Services available through the Website. Information that you may provide includes your email address, name, phone number, location, and online social accounts. SCGINC. may also collect information that you provide by electronic mail, telephone or other means.
2. Automatically Collected Information. SCGINC. may automatically collect certain technical information from your computer or mobile device when you use the Website, such as your internet protocol address, your web browser type and version, the name and version of your operating system, the pages you view on the Website, the pages you view immediately before and after you access the Website, and the search terms you enter on the Website. This information allows SCGINC. to recognize you and personalize your experience if you return to the Website using the same computer or mobile device, and to improve the Services.
3. Information about Legal and Other Materials. In addition, SCGINC. may collect technical information from your computer or mobile device concerning your receipt of communications, access to materials and approval or execution of contracts, consents or other statements or agreements by means of the Website, including this Policy.
4. Cookies. SCGINC. may collect this information using "cookies," which are small text files that the Website saves on your computer or mobile device, or similar technologies. You can disable cookies in your browser settings, but doing so may affect the functionality of the Website. SCGINC. may also collect information using "web beacons," which are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon or using unique links that can distinguish when individual users click the link. Web beacons and unique links, alone or in conjunction with cookies, may help us compile information about your interactions with electronic mail sent to you in connection with the Services. For further information, see the Cookie Policy in Section 5 below.
5. Cross-Site Tracking. SCGINC. does not utilize technical measures in the Website to track your activities across different web sites or online services, whether you configure your browser's Do Not Track feature or otherwise. The System does utilize third-party application programming interfaces controlled by third parties, such as to display maps and graphs, that may attempt to track your activity across other sites that utilize those interfaces.
6. Reviewing and Correcting Information. You may update or correct contact information and other Personal Information stored about you on the System by accessing your account/profile page, or by sending a written request to SCGINC..

3. Use and Disclosure of Information

SCGINC. may collect, use, share, and otherwise process your personal information for a number of purposes, including, but not limited to:

1. Accessing the System and Providing the Services. SCGINC. uses your Personal Information to provide you with the Services, or products, services or information related to the Website or the Services, including: providing you with information about the Website, Services or required notices; customizing your experience when using the Website, such as by providing interactive or personalized elements on the Website; and providing you with content based on your interests. The legal basis for such use are the this Policy.
2. Analysis. SCGINC. uses your Personal Information for improving the Website and/or the Services, including by (i) combining or aggregating any of the information collected through the Website or elsewhere for generating and analyzing statistics about your use of the Website and user demographics and traffic patterns and (ii) using anonymized data that may or may not be derived from Personal Information but does not personally identify you, both for disclosure to third parties and for the purpose of enhancing the Services and developing new Service offerings. The legal basis for such use are this Policy and our legitimate interest in improving the Website and Services.
3. Security. SCGINC. may use your Personal Information for safety and security purposes, including sharing of your information for such purposes, when it is necessary to pursue SCGINC.'s legitimate interests in ensuring the security of the Website and Services, including detecting, preventing and responding to fraud, intellectual property infringement, violations of law or other misuse of the Website; and when SCGINC. believes in good faith that disclosure is necessary (a) to protect SCGINC.'s rights, the rights of other users of the Website, the integrity of the Website, or your safety or the safety of others, or (b) to detect, prevent or respond to fraud, intellectual property infringement, violations of law or other misuse of the Website.
4. Service Providers. SCGINC. may engage third-party service providers to assist in operating and marketing the Website. SCGINC.'s engagement of third-party service providers is often necessary for SCGINC. to provide the Services to you, particularly where such third-party service providers ensure that the Website and the Services are operating and secure. In other cases, SCGINC. has a legitimate interest in third-party service providers that can help improve the Website and the Services.
5. Other Disclosure. SCGINC. may disclose Personal Information about you to others: (a) with your valid consent to do so; (b) to comply with a valid subpoena, legal order, court order, legal process, or other legal obligation; (c) to enforce any of the terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims. SCGINC. may also transfer your Personal Information to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, acquisition or sale, joint venture, assignment, transfer or other disposition of all or any portion of SCGINC.'s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that SCGINC. transfer Personal Information to will not be permitted to process your Personal Information other than as described in this Policy without providing you notice and, if required by applicable laws, obtaining your consent.
6. Marketing. SCGINC. may use collected information for delivering marketing communications that may be of interest to you. You have the right to ask SCGINC. not to process your Personal Information for marketing purposes.

4. Storage

1. Jurisdiction. Information collected through the Website will be stored in, processed in and subject to the laws of the State of New York, which may not provide the same level of protection for your information as your home country or State, and may be available to the United States government or its agencies under a lawful order made in the United States. By using the Website, you consent to such transfer to, storage in and processing within the United States.
2. Security. SCGINC. is committed to protecting your information from unauthorized access, use or disclosure. The Website and its operators maintain administrative, technical and physical safeguards designed to protect the information collected through the Website. However, no information or communication system can be 100% secure, so SCGINC. cannot guarantee the absolute security of your information. In addition, SCGINC. is not responsible for the security of information that you transmit to the Website over networks that SCGINC. does not control, including the internet and wireless networks.
3. Retention. We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. If you wish to access or correct any information we hold about you, you may have your data deleted, blocked or corrected (as long as compliant with applicable law). We also collect and retain information through the System in an anonymized form, i.e. tracking the pages you visit and how long you spent on each page.

5. Cookie Policy

This section provides SCGINC.'s cookie policy and describes how we use Cookies and similar technologies. For more information on our general data privacy practices, please see the full Policy.

1. Cookies. Cookies are small pieces of data that are stored on your computer, mobile phone, or other device when you first visit a page. SCGINC. uses cookies, web beacons and similar technologies ("Cookies") to enhance your user experience, understand your usage of the Website and Services and to perform analytics. Cookies may also be set by other websites or services that run content on the page you are visiting. The provision of your data via Cookies is voluntary except for those Cookies that SCGINC. places on your device because it is necessary for the performance of the Website or Services. SCGINC. uses "session cookies" and "persistent cookies." Session Cookies are temporary Cookies that remain on your device until you leave the Website or Services. A persistent Cookie may remain on your device for much longer until you manually delete it.
2. Use. Cookies can contain the following information about you and your use of the Website: browser type, search preferences, data relating to which pages of the Website that you have visited and the date and time of your use. SCGINC. uses Cookies for the following purposes:
   1. To enable and support security features, prevent fraud, and protect your data from unauthorized access.
   2. To enable features and help us provide you with personalized content.
   3. To analyze how you use the Website and to monitor site performance. These Cookies help us to identify and fix errors, understand and improve services, research and test out different features, and monitor how you reached the Website.
3. Third-Party Cookies. SCGINC. uses the following third-party Cookies on the Website: e.g.
   1. DocuSign (if applicable). The System provides the option to execute agreements via DocuSign. If you interact with DocuSign via the System, you may encounter cookies used by DocuSign in their internal operations. See https://www.docusign.com/company/privacy-policy for details.
   2. Opting Out. You can control and/or delete cookies as you wish – for details, see https://www.aboutcookies.org/. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work as intended by us.

6. YOUR CALIFORNIA PRIVACY RIGHTS

This portion of the Privacy Policy, "Your California Privacy Rights," applies only to individuals who live in California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (the "CCPA") and other California laws identified below. Terms defined in the CCPA have the same meaning when used in this portion of the privacy policy.

1. Types of Personal Information Collected, Sources of Collection, Purposes, and Categories of Third Parties In the preceding twelve months, we have collected the following categories of personal information collected about California consumers:

   1. Category	Examples
      A. Identifiers.	Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
      B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
      C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
      D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
      E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
      F. Internet or other electronic network activity information.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
      G. Geolocation data.	Physical location or movements.
      H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.
      I. Professional or employment-related information.	Current or past job history or performance evaluations.
      J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g; 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
      K. Inferences drawn from other personal information.	Profile reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

The sources of collection, the business and commercial purposes for which the information will be used, and the categories of third parties to whom we disclose the information are disclosed in the above sections of this privacy policy.

1. Disclosures of Personal Information for a Business Purpose. In the preceding 12 months, we may have disclosed each of the following categories of personal information for a business purpose to each of the categories of third parties listed above in the Use and Disclosure of Information section:
   1. Identifiers.
   2. California Customer Records personal information categories.
   3. Protected classification characteristics under California or federal law.
   4. Commercial information.
   5. Biometric information.
   6. Internet or other similar network activity.
   7. Geolocation data.
   8. Sensory data.
   9. Professional or employment-related information.
   10. Non-public educational information.
   11. Inferences drawn from other personal information.
2. "Sales" (as defined by the CCPA) of Personal Information. We do not sell your information for payment. However, the CCPA defines "sale" more broadly to include, for example, certain communications of information to a third party for "other valuable consideration." In the preceding twelve months, we may have shared each of the following categories of personal information with each of the categories of third parties listed above in the Use and Disclosure of Information section in such a way that the sharing might be deemed a "sale" under the CCPA, even though we do not sell your information for payment or discount:
   1. Identifiers.
   2. California Customer Records personal information categories.
   3. Protected classification characteristics under California or federal law.
   4. Commercial information.
   5. Biometric information.
   6. Internet or other similar network activity.
   7. Geolocation data.
   8. Sensory data.
   9. Professional or employment-related information.
   10. Non-public educational information.
   11. Inferences drawn from other personal information.
3. Your Rights.
   1. Access to Information: You can ask us to disclose to you the following information if we receive a verifiable consumer request (see Exercising Your Rights, below):
      1. Categories of personal information we have collected about you.
      2. Specific pieces of personal information we have collected about you.
      3. Categories of sources from which the personal information is collected.
      4. Business or commercial purpose for collecting or selling personal information.
      5. Categories of third parties with whom we share personal information.
      6. Categories of personal information we "sold" (as defined in the CCPA) about you and the categories of third parties to whom the information was "sold," by category or categories of personal information for each category of third parties to whom the personal information was "sold."
      7. Categories of personal information we disclosed about you for a business purpose.When you make this request, the information provided may be limited to personal information we collected about you in the twelve months preceding our receipt of the verifiable request. There are exceptions to this right under the CCPA. For example, we are prohibited from disclosing your actual Social Security number, driver’s license number, or other government-issued identification number; financial account number; and certain other specific pieces of information. Also, Wwe are not obligated to provide this information to you more than twice in any twelve-month period.We may deny requests to access business-to-business personal information because until at least January 1, 2021, the CCPA exempts from some of its requirements personal information reflecting a written or verbal business-to-business communication or transaction.
         
   2. Deletion Rights: You can ask us to delete any of your personal information we collected from you, if we receive a verifiable consumer request (see Exercising Your Rights, below). There are exceptions to this right under the CCPA. For example, we are not required to delete your information if we need it to provide a product you ordered or comply with a legal obligation.We may deny requests to delete business-to-business personal information because until at least January 1, 2021, the CCPA exempts from some of its requirements personal information reflecting a written or verbal business-to-business communication or transaction.
   3. Exercising Your Rights: To exercise your access or deletion rights described above, you may call or write to us (see Contact Information at the end of this policy) or, for your access rights, you also may click on "Request My Personal Information ."
      We cannot accommodate your request if we cannot reasonably verify your identity or authority to make the request and confirm the personal information relates to you. If you want to exercise your access rights, we will verify your identity by matching at least two data points provided by you with data points maintained by us that we determine to be reliable to verify your identity. If your request is for specific pieces of personal information about you, we will match at least three pieces of personal information provided by you with the personal information maintained by us that we have determined to be reliable to verify your identity, and we will require a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you want to exercise your deletion right, we may verify your identity by matching at least two data points, or at least three data points with a signed declaration under penalty of perjury, depending on the sensitivity of the personal information and the risk of harm to you posed by unauthorized deletion.You may use an authorized agent to submit a request to know or request to delete on your behalf. If you use an authorized agent, we may require you to provide the authorized agent signed permission (such as a power of attorney), to verify your identity with us, and to directly confirm with us that you provided the authorized agent permission to submit the request.
   4. Personal Information Sales Opt-Out and Opt-In Rights: We do not sell your information for payment. However, the CCPA defines "sale" to include certain transfers of information even without monetary consideration. You have the right to direct us not to "sell" (as defined by the CCPA) your personal information. This is the "right to opt-out." To exercise your right to opt-out, click "Do Not Sell My Personal Information " located at the bottom of this page or our homepage or call or write to us with the request (see Contact Information at the end of this policy).We do not sell the personal information of consumers we actually know are under 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age or the parent or guardian of a consumer under 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time by clicking "Do Not Sell My Personal Information" located at the bottom of this page or our homepage or by calling or writing to us with the opt-out request (see Contact Information at the end of this policy).Once you have opted out of the sale of your personal information, we will wait at least twelve months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by giving us express authorization in writing at the email address or mailing address stated below (see Contact Information, below), and then we will separately confirm your choice to opt in.You do not need to create an account with us to exercise your right to opt-out. We will use personal information provided in an opt-out request only to review and comply with the request.
   5. Non-Discrimination: If you exercise any of your CCPA rights, your exercise of such rights will not cause us to discriminate against you, which means that, unless permitted by the CCPA, we will not:
      1. Deny you goods or services.
      2. Charge you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
      3. Provide you with a different level or quality of goods or services.
      4. Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or serviceHowever, we may offer you certain financial incentives permitted by the CCPA that can result in different prices or rates or level or quality of goods or services. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. We currently do not provide a financial incentive program.
4. Other Californian Privacy Rights. Subject to certain limitations, California's "Shine the Light" law (Civil Code Section § 1798.83) permits California residents who have an established business relationship with us to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To make such a request, you may email us at the email address stated below (see Contact Information, below). We are not obligated to comply with a request from the same customer more than once during the course of any calendar year. We are exempt from the Shine the Light law if we have fewer than twenty full-time or part-time employees.The California Online Privacy Protection Act requires us to inform you how we respond to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services, if we engage in that collection. As there is no industry or legal standard for recognizing or honoring "do not track" requests, we don’t respond to them at this time.

7. GDPR

If you are a resident of the European Union, SCGINC. will process your Personal Information in compliance with the EU General Data Protection Regulation ("GDPR"). In accordance with GDPR, as a data subject you will be accorded with any applicable rights, which may include the following:

1. right of confirmation;
2. right of access;
3. right to rectification;
4. right to erasure;
5. right of restriction of processing;
6. right to data portability;
7. right to object;
8. right to withdraw data protection consent; and
9. the right to lodge a complaint with a supervisory authority.

SCGINC. hosts and operates the Website as a data processor. As operator of the Website, SCGINC. has access to, stores and processes all Personal Information received and collected about you by means of the Website and for the purpose of hosting and operating the Website and providing the Services.

8. Third-Party Websites

The System and communications from us may contain links to websites operated by third parties. You acknowledge and agree that SCGINC. is not responsible for the collection and use of your information by such websites that are not under SCGINC.'s control. SCGINC. encourages you to review the privacy policies of each website you visit.

9. Children's Information

The System is not directed to, nor does SCGINC. knowingly collect information from, children under the age of 13. If you become aware that your child or any child under your care has provided information without your consent, please contact SCGINC. immediately using the contact information provided below.

10. Other Agreements

You may from time to time enter into binding legal agreements relating to certain Services available through the Website, which may have terms that are different from those of this Policy. In the event of any inconsistency, the terms of such other agreement shall control with respect to such Services.

11. Business Transfer

If SCGINC., or substantially all of SCGINC.'s assets, are acquired, or in the unlikely event that SCGINC. were to go out of business or enter bankruptcy, user information will be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of SCGINC. may continue to use your Personal Information as set forth in this Policy (as it may be amended from time to time).

12. Contact Information

If you have any questions about this Policy or the collection or use of information about you, you may contact us at: info@sparkchange.io