Terms and Conditions


Last Updated on September 20, 2015

This Privacy Policy (this “Policy”) is provided to you by Sparkmarket Holdings, LLC (“Sparkmarket” or the “Company”), in connection with your access to Sparkmarket’s services. The Sparkmarket website located at www.sparkmarket.com (the “Site”) and any content therein (collectively, the “Services”) offers users a toolkit to create, manage and close intrastate based crowdfunding campaigns (each a “Campaign”). In this Policy, we describe how we collect, use, and disclose information that we obtain about users of our Services.

What Information We Collect

Account Information. When you sign up through the Site, we assign you a user id and collect certain identifying information from you, including your full first and last name, and state of residence. Depending on your use of the Site, and your use of our Services, we may also collect additional identifying information such as a copy of your State issued identification, for purposes of residency verification.

We also collect certain information you provide to us directly, including:

• Your username, password, and e-mail address when you register for an account. • Profile information that you provide for your user profile. • User content (e.g., photos, videos, and other materials) that you provide in connection with creating a Campaign (“Content”). • Communications between you and the Company. For example, we may send you Service-related e-mails (e.g., account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related e-mails.

We may also automatically collect information about your use of the Services such as: access time, browser type, language, device ID, application ID or other unique identifier; domain name, IP address, screen views; geo-location data (with your permission); language information; device name and model; operating system information; your activities within the Services; and the length of time that you are logged in. We may combine this information with other information that we have collected about you.

Your Content and Usage. We collect any Content you submit to the Services. The Content includes anything in your posts—for example, photos, copy, links, documents, and slide decks—as well as information about when you submitted the Content, when it was viewed, how you supported a Campaign, and other activities. For more information about our policies and procedures related to Content you submit to our Site, see our Terms and Conditions of Use (our “Terms of Use”) at www.sparkmarket.com/legal/termsofuse, which incorporates this Policy.

Telephone Number. We may ask you to provide and verify your telephone number, depending on your use of various Services we provide. This process may be triggered, for example, if you want to post certain content or if we suspect improper activity on your account.

Other Information You Provide to Us. When you contact Sparkmarket, we will collect any information you volunteer.

Social Media Sites. You can like us on Facebook, follow us on Twitter, and promote us on other social media sites. We collect information about who has liked us or followed us. However, we don’t associate your social media account with your Sparkmarket account.

How We Use Information We Collect

In general, we use the information we collect from and about you to provide and operate the Services, respond to your requests, and to provide customer service and technical support. We may also use information:

• To tailor the information that we may send or display to you, offer location customization, and to otherwise personalize your experiences while using our Services. • To send you notices. • To display advertising, including advertising that is targeted to you based on your location, as well as your activities. • To verify your identity and prevent spam or other unauthorized or illegal activity. • To better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Services and respond to user desires and preferences, and for other research and analytical purposes.

Where Information is Processed

Sparkmarket is based in the United States. No matter where you are located, you consent to the processing and transferring of your information in and to the U.S. and other countries. The laws of the U.S. and other countries governing data collection and use may not be as comprehensive or protective as the laws of the country where you live. And, your information may be made available to government or law enforcement requests.

How We Share Information

When you create a Campaign using our Services, your Campaign will be viewable to all persons whom you invite to the Campaign site, or who otherwise locate such site. Interaction with your Campaign is strictly limited to persons who are residents of the State where the business which is managing the Campaign is located. However, you may not be able to control who views your Content; and if you do not wish to share content publicly, then you should refrain from posting it to a Campaign.

If you are not a Campaign manager, then we do not identify you by name or contact information to other Sparkmarket users. If you are a Campaign manager, then we cannot prevent others from determining your identity from the Content you post or how you share Content through third party sites.

The information we collect, including personally identifiable information, may be shared as follows:

• Sparkmarket Users. Any information that you post to a Campaign, including photos and videos may be publicly available. We cannot control how your information is used by others. • Service Providers. We may disclose the information we collect to third party vendors, service providers, contractors or agents who perform functions on our behalf. • Business Transfers. We may transfer the information we have collected to another company in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business. • Third Parties and Partners. We may share the information with our third party partners, including advertisers and researchers. For example, if you post content that mentions one of our advertisers, we may share that content with them. Or, we may work with a researcher to analyze the content on a particular feed. • In Response to Legal Process. We also may disclose the information in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process. For example, we may share your IP address or other identifier, your location information, or any other information we have collected about you and your device. • To Protect Us and Others. We also may disclose information if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which the Company is involved. • Aggregate and De-Identified Information. We may also share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

Depending on the content of the information, you may not be able to modify or amend Content which you provide in connection with a Campaign. You can delete Content you have posted to a Campaign. All posts will be publically available for the duration of the Campaign. As soon as the Campaign ends, posts will no longer be available for view.

Any Content which is deleted will be hidden from other users. However, Sparkmarket may maintain a copy of such Content in our records in accordance with our Terms of Use.

Cookies and Pixel Tags

A cookie is a small removable data file that is stored by your web browser on your computer. Cookies allow us to enhance and personalize your online experience. For example, we use cookies to:

• Recognize you when you return to our website; and • Analyze visitor behavior

You can choose to have your computer warn you each time a cookie is being sent or you can choose to turn off all cookies. You do this through your browser (like Google Chrome or Internet Explorer) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookie settings. If you turn cookies off, you won't have access to many features that make your site experience more efficient and some of our services may not function properly.

We may also use pixel tags—tiny graphic images—to help us analyze your online behavior. Pixel tags also allow us to send you email in a format you can read and let us know when you have opened an email message from us. We may use pixel tags to collect information about your visit, including the pages you view, the links you click and other actions taken in connection with our sites and services.

Protecting Your Information

We use a variety of industry standard security measures, including sophisticated encryption and authentication tools to maintain the safety of your personal information from accidental loss, unauthorized access, use or disclosure. Your personal information is contained behind secure networks and is only accessible to a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.

Regardless of these efforts, no data transmission over the Internet can be guaranteed to be 100% secure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Third Party Analytics

We may use automated devices and applications, including those offered by third parties, to evaluate usage of our Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. The information collected may include unique device identifiers, device manufacturer and operating system, IP address, browser type, session start/stop time, and user activity.

Third Party Ads

We may display ads to you (including in-app ads), and we may target those ads based on your location, your Campaign related activities, and other criteria (e.g., the time of day). We do not currently respond to do-not-track signals that may be sent from your device. For more information about interest-based ads, including how to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

Third-Party Links

Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites.


You must be at least eighteen (18) years of age to use our Services and the Site. If you are not at least 18, please do not use our Services or the Site, or provide any information to us. Further, we do not knowingly collect personal information from children under thirteen (13). If you are under 13, do not use or provide any information on our Site, create any Campaign, support any Campaign, post any Content, use any of the interactive or public comment features or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us using the contact information set forth below.

Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us by e-mail at support@sparkmarket.com.

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site, at www.sparkmarket.com. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site, but we make no guarantee as to such advance notice.

The information contained on this website is supplied by the manager of this Campaign. Any offer to sell securities contained herein is limited to legal residents of the State in which the Campaign business is organized, and any persons wishing to invest in this Campaign must certify as to their eligibility to participate. No such offer or solicitation will be made prior to the delivery of definitive documentation relating to the matters described herein. All Investments carry risks. Before making an investment decision with respect to an investment in this Campaign, potential investors are advised to carefully read the note purchase agreement and promissory note that will govern the investment and any other documents provided herein (the “Documents”). You should consult with your own attorneys, accountants and other professional advisors prior to making an investment.

This overview contains a preliminary summary of the purpose and principal business terms of the investment. This summary does not purport to be complete and is qualified in its entirety by reference to the more detailed discussion contained in the actual text of the Documents.

Neither the SEC nor any state securities commission or regulatory authority approved, passed upon or endorsed the merits of the offering described on this website.