Privacy Policy

Sparked (previously known as Sealed for Success and all references to Sealed for Success shall also refer and apply to Sparked) is affiliated with Sealed (an expert network), owned and operated by Sealed Network Pte. Ltd. (Singapore Company Registration No. 201918245Z) (the “Company”, and such references shall, unless the context otherwise requires, include all of the Company’s affiliates). This Privacy Policy is incorporated in the Terms of Use found at https://sealedforsuccess.com/terms-of-use, and applies to you if you access or use the Site, or participate in or use our Services. Except as otherwise defined, the capitalised terms in this Privacy Policy have the same meanings as those in the Terms of Use.

The Company (“we”, “our” or “us”) has adopted this Privacy Policy to inform you about how we handle the Personal Data derived from your access or use of the Site and the Services. “Personal Data” means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

By accessing or using the Site and the Services, you agree to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. You agree that if we deem that it is required under applicable law to obtain a different form of consent or any form of approvals (whether from you or otherwise), your participation in and use of the Services will be subject to us obtaining such necessary consents or approvals.

This Privacy Policy may be amended from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Please visit this Privacy Policy webpage frequently for the most current version before relying on any of the provisions here. Your continued access and use of the Site or participation in or use of the Services constitutes your acknowledgement and acceptance of such changes.

1. What Personal Data do we collect?

1.1 When you access or use the Site or participate in or use the Services, we may collect Personal Data which you voluntarily provide to us, such as your name and contact details when you submit applications and enquiries, or other forms of Personal Data that you send to us such as your employment details or curriculum vitae in connection with participation or use of the Services.

1.2 We may also from time to time collect your Personal Data that:

(a) you have chosen to make public, including via public online platforms (such as your social media or business networking profile);

(b) you have provided to third parties who are permitted to provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.); or

(c) that we gather as result of your participation in or use of the Services or access and use of the Site.

2. How do we use your Personal Data?

If you do provide Personal Data to us, we may use the Personal Data for the following purposes:

2.1 administering and managing our relationship with you, including dealing with any requests or enquiries which you may have;

2.2 administering and managing the Services that you request to participate in or use, including contacting you regarding any Engagement requests or enquiries;

2.3 contacting you regarding any updates, events or publications related to the Services which may be of interest to you and/or requested by you;

2.4 meeting any legal, governmental or regulatory requirements; and

2.5 such other purposes as permitted by applicable law or with your consent.

3. How do we disclose your Personal Data?

3.1 Where it is necessary to carry out the purposes set out above, we may disclose your Personal Data with the following third parties:

(a) where appropriate, your appointed representatives;

(b) potential and existing Knowledge Partners, Clients, and/or any other persons (as the case may be) only for the purpose of facilitating Engagements, including requests or enquiries in relation to an Engagement;

(c) our third party service providers (such as professional services firms), agents and/or our affiliates or related corporations, and/or other third parties, whether located in Singapore or outside of Singapore;

(d) legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

(e) any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;

(f) any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

(g) in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation), the relevant purchaser(s) and their authorised personnel; and

(h) third party data processors (such as outsourced technology service providers, survey partners etc.) provided in particular that such third-party processors will be subject to binding contractual obligations to: (i) only process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

3.2 Where we disclose your Personal Data, we will share your Personal Data in accordance with applicable data protection laws, including taking the steps reasonably necessary to ensure that the transfer of your Personal Data is subject to appropriate safeguards as required under applicable data protection laws.

4. How do we maintain your Personal Data?

4.1 Other than as set out in this Privacy Policy or where you have otherwise given your consent, all Personal Data provided to us will be kept confidential. We commit to adopting reasonable security arrangements to prevent unauthorised access, use, disclosure, copying, modification, and disposal of Personal Data in our possession or control.

4.2 We also take reasonable steps to ensure that your Personal Data are only processed for the minimum period necessary for the purposes set out in this Privacy Policy. The duration in which Personal Data is kept by us will be for not more than the duration permitted under applicable data protection laws.

5. Your Rights in relation to Personal Data

We are fully committed to protecting your Personal Data and ensuring that you are able to enjoy all the rights granted to you in relation to your Personal Data under applicable law, including your ability to access and correct your Personal Data, or to request the removal of your Personal Data. Nothing in this Privacy Policy should be construed as limiting any of your rights prescribed for under applicable law.

6. Cookies and Google Analytics 

Cookies are pieces of information which are issued to your computer or mobile device when you visit a website, and which store and track information about your use of the website. We use cookies to store and track certain anonymous statistical information when you browse our website. Disabling cookies in your browser will not affect your user experience. We may from time to time work with analytics services from various providers, which will include the use of cookies. We are currently working with Google Analytics.

Google Analytics is a web analytics service which undertakes the gathering, collection and analysis of data about the behaviour of visitors to websites. Among other things, a web analytics service collects data on which website a data subject has come to a website from (so-called referrers) and is mainly used to optimise a website and for the cost-benefit analysis of internet advertising. Further information and Google’s applicable privacy regulations can be found at https://policies.google.com/privacy?hl=en and https://marketingplatform.google.com/about/. The following link provides a further explanation of Google Analytics https://marketingplatform.google.com/about/.

You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of the Site to the fullest extent possible.

In addition, you may prevent the collection of the data generated by the cookie and related to your use of the Site (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en. This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics. A cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

7. Third Party Links 

The Site may contain links to third party websites whose data protection practices may differ from ours. We are not responsible for the content and privacy policies of these third party websites and we encourage you to consult their privacy policies before using the third party websites.

8. Contact Us

You may contact our Data Protection Officer if you have any enquiries or feedback on our Personal Data protection policies and procedures, or if you wish to make any request, at [email protected].

Last Updated: 5 June 2021