Spark Privacy Policy
Try.Eat! is committed to protecting your privacy. Our customer privacy policy explains clearly how we collect, use, disclose, transfer and store your data.
Updated on 17 January 2022
InnoLab Limited (hereinafter "we", "the Company" or "InnoLab") respects the privacy rights of anyone who uses the Company's website and mobile application, or who takes part in InnoLab's activities or registers to use InnoLab's services or online content (hereinafter the "Services"). We will ensure that the personal data we collect, transmit, store and use is handled in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of the Hong Kong Special Administrative Region) (hereinafter the "Ordinance"). The term "personal data" has the meaning given to it in the Ordinance.
When you take part in InnoLab's activities or register to use our Services or online content, we will collect your personal data to enable us to provide you with the Services. You may decline to provide personal data to us, but in that case we may not be able to provide you with the Services. By providing personal data, you agree that we may use your personal data in accordance with this Privacy Policy statement. This Privacy Policy describes how InnoLab handles the personal information we collect through the Try.Eat! and Spark platforms.
Personal Information We Collect
When you use the Spark platform, we collect your personal information or related business information. Without it, we may not be able to provide you with all the services you have requested. This information includes:
1. Contact, account and profile information. For example your first name, last name, phone number, postal address, email address, date of birth, and business and personal profile photos, some of which will depend on the features you use. Identity verification and payment information. For example images of your government-issued identity document (where permitted by applicable law), your identity document number or other verification information, and bank account or payment account information.
2. Business information, such as your company's name, job title, email address and business address;
3. Identity verification and payment information. For example images of a government-issued identity document (where permitted by applicable law), your identity document number or other verification information, and bank account or payment account information.
Information Collected Automatically When You Use the Spark Platform and Our Payment Services
When you use the Spark platform and the payment services, we automatically collect personal information. This information may include:
1. Geolocation information. For example precise or approximate location determined from your IP address or your mobile device's GPS, depending on your device settings. If you enable this through your settings or device permissions, we may also collect this information when you are not using the app.
2. Usage information. For example the pages or content you view on the Spark platform, campaigns you search for, influencer approvals you make, and other actions.
3. Log data and device information. For example details about how you use the Spark platform (including whether you clicked on links to third-party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you viewed or engaged with before or after using the Spark platform. We may collect this information even if you have not created a Spark account or logged in.
4. Payment transaction information. For example the payment instrument used, date and time, payment amount, payment instrument expiry date and billing postal code, PayPal email address, IBAN information, your address and other relevant transaction details.
Personal Information We Collect from Third Parties
We collect personal information from other sources, for example:
1. Third-party services. If you link, connect or log in to the Spark platform through a third-party service (such as Apple, Google, Facebook or WeChat), you instruct that service to send us information such as your registration, friends list and profile information that is controlled by that service or that you authorise through your privacy settings on that service.
2. Business product invitations and account management. Organisations that use our business products may submit personal information to facilitate account management and invitations to use the business products. Referrers and travel companions. If you are invited to join the Spark platform, for example as a travel companion, the person who invites you may submit your personal information, such as your email address or other contact information.
3. Other sources. To the extent permitted by applicable law, we may receive other information about you, such as references, demographic data or information that helps detect fraud and security issues from third-party service providers and/or partners, and combine it with the information we hold about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information from our partners about you and your activities on and off the Spark platform, or about your experiences and interactions. We may receive health information, including but not limited to health information relating to infectious diseases.
How We Use the Information We Collect
- To provide, improve and develop the Spark platform
- To create and maintain a trusted promotional environment
- To identify you and any accounts you open
- To verify identity or verify the information you provide,
- To comply with our legal obligations and protect our other users of the Services
- To resolve disputes between our users,
- To promote the products and services of our business partners
- To provide, personalise, measure and improve our advertising and marketing
- To provide payment services
- To prevent and deter fraud
- To make disclosures as required by applicable laws, rules and regulations
Sharing, Disclosure and Security
Unless we obtain your written consent, we will not engage in any transaction for gain using your personal data and contact details.
Personal data relating to you will be treated as confidential; but where necessary to fulfil legal obligations as required by law or by legal requirement, or to provide you with the Services, or to fulfil the original purpose for which the personal data was collected or a directly related purpose, we may share or disclose such data (whether they are in Hong Kong or outside Hong Kong) with or to the following persons:
1. Courts of competent jurisdiction, law enforcement agencies, or other governmental statutory or regulatory bodies, agencies or organisations.
2. Our affiliated companies, and providers, agents or other service providers involved in the sale and marketing or administration of the Services, or in providing goods/services.
3. Any other person who owes us a duty of confidentiality, including group companies that have undertaken to keep such data confidential, information technology consultants, data processing contractors, auditors, accountants or lawyers.
4. Any questions, comments, suggestions or information sent or posted by you on our website or any part of it, other than personal data, are regarded as voluntarily provided to the Company on a non-confidential and non-proprietary basis. We have the right to use, copy, disclose, transmit, publish and/or post such information elsewhere at our discretion, including but not limited to providing such information to any affiliated company for purposes such as the development and promotion of the Services and meeting customers' needs.
5. If we undertake or are involved in any merger, acquisition, reorganisation, sale of assets, bankruptcy or insolvency event, we may sell, transfer or share some or all of our assets, including information about you in connection with such a transaction or in contemplation of such a transaction (for example, due diligence). In such a case, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.
6. To support our provision, integration, promotion and improvement of the Spark platform, the payment services and the services of our affiliated companies, we may share personal information within our group of companies that are under common ownership or control.
InnoLab will use all reasonable efforts to ensure that all personal data we hold is stored in a reliable, secure and safe place. We will endeavour to keep all personal data we collect confidential. However, please understand that we cannot guarantee the security of data in transmission.
Transfer of Personal Data Outside Hong Kong
Where operationally necessary, the Company will transfer personal data to places outside the Hong Kong Special Administrative Region for the purpose for which such data was collected or a directly related purpose. Any such transfer of data will be made in accordance with, and subject to, the provisions of the Ordinance.
Retention of Personal Data
If you choose or are given a user ID, password or any other information as part of a security procedure, you must treat this information as confidential. You must not disclose it to any third party. If your mobile phone number is used for account login, you should ensure that, when your mobile phone number is changed or returned to the mobile telecommunications operator, you update it promptly by logging in to your account under "Account Information". This is important to ensure that your account information cannot be accessed by a third party who may have obtained the right to use the mobile phone number you have returned. You are responsible for protecting your account in this specific way. We accept no responsibility for this. Unless the law requires InnoLab to retain your personal data for a specific period of time, InnoLab will retain personal data only until the original purpose for which it was collected, or a directly related purpose, has been fulfilled.
Direct Marketing
We intend to use the personal data we collect from you for promotional purposes. We may contact you by post, telephone, social media links, SMS, text/image/video messages, fax, email and other means. If you do not wish to receive any direct marketing communications from us, you may notify us by email at any time to unsubscribe. After receiving your notice, we will cease to use your personal data for direct marketing purposes, and will not charge you for doing so.
Managing Your Information
You can access and update some of your personal information through your account settings. If you connect your Spark account to a third-party service, such as Apple, Facebook or Google, you can change your settings and unlink the service in your account settings. You are responsible for keeping your personal information up to date.
Data Erasure
You may request deletion of your personal information. Please note that if you request deletion of your personal information:
1. We may retain your personal information for our legitimate business interests, such as the prevention of money laundering, fraud detection and prevention, and enhancing security. For example, if we suspend an Spark account for fraud or safety reasons, we may retain information from that Spark account to prevent that member from opening a new Spark account in the future.
2. We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, information relating to tax, legal reporting and audit obligations may be retained.
3. Information you have shared with others (for example, reviews and forum posts) will continue to be publicly visible on Spark, even after your Spark account is cancelled.
4. Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be deleted from our backup systems for a limited period of time.
Use of Cookies
A cookie is a small text file stored on your computer (or other electronic device) when you visit our website and mobile application. We use cookies on this website in order to:
1. Identify you when you browse this website and the mobile application
2. Obtain information about your preferences, access and browsing behaviour, online activity and internet usage
3. Conduct research and statistical analysis to help us improve our Services and better understand visitors and their requirements and interests
4. Provide advertisements tailored to your personal interests, and carry out our, our business partners' and advertisers' promotion and advertising programmes more effectively
5. Make your online activities more efficient and your experience better
6. Make security measures more stringent
The information we obtain using cookies may not contain your personal data. Although we may obtain information about your computer or other electronic device (such as IP address, browser settings, browsing history and/or other internet log data), it may not necessarily identify you. Because non-personal data is mixed with personal data, we treat such data as personal data for the purposes of this Privacy Policy. In certain circumstances we may collect your personal data, but only where you voluntarily provide it by completing an online form or other form, or where it is collected when you use the services of our website and mobile application.
If you do not permit the use of cookies, you can adjust the settings on your internet browser and electronic device. If you disable cookies, you acknowledge that you may not be able to use certain features of our website and mobile application.
Security
Although no organisation can guarantee perfect security, we continuously implement and update administrative, technical and physical security measures to help protect your information against unauthorised access, loss, destruction or alteration.
Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the "Last Updated" date at the top. If there are material changes, we will also provide you with notice of the amendment by email at least thirty (30) days before the effective date. If you do not agree to the revised Privacy Policy, you may cancel your account. If you do not cancel your account before the effective date of the revised Privacy Policy, your continued access to or use of the Spark platform will be subject to the revised Privacy Policy.
