Effective Date: 7/14/2020

This privacy policy (“Privacy Policy”) describes the privacy practices that Web Sparky, LLC (“Web Sparky” or “us” or “we” or “our”) follows when collecting and using information about you from Web Sparky’s website Here Now Cloud (located at herenowcloud.com) and any related services operated or provided by Web Sparky(the “Services”).

Please read this Privacy Policy before using the Services. It describes what information we gather from you and others who visit or use the Services, how we use that information, and what we do to protect it. When you access or use the Services, certain information, including personally identifiable information, may be collected, transferred, processed, stored, and in certain circumstances, disclosed as described in this Privacy Policy. BY USING THE SERVICES, YOU EXPRESSLY CONSENT TO THESE INFORMATION HANDLING PRACTICES.

Please be aware that our services and systems are housed on servers in the United States, and the information we collect (including through cookies) is processed and stored in the United States, which may not offer the same level of privacy protection as the country where you reside or are a citizen. BY USING THE SERVICES AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER TO AND PROCESSING OF THE INFORMATION IN THE UNITED STATES.

1. THE INFORMATION WE COLLECT.

We collect data to provide the services you request, ease your navigation on the Services, communicate with you, and improve your experience using the Services. Some of this information is provided by you directly, such as when you create an Account on the Services. Some of the information is collected through your interactions with the Services. We collect such data using technologies like Cookies and other tracking technologies, error reports, and usage data collected when you interact with the Services.

The data we collect depends on the services and features that you use, and includes the following:

1.1. Information You Manually Provide.

You may choose to provide certain personally identifiable information to Web Sparky, for example when you create your user account (“Account”) and when you communicate with us. The personally identifiable information you provide may include:

• Name and Contact Information. Your name, email address, postal mailing address, phone number, and other contact information.
• Your birthdate and age range.
• Your interests and activities.
• Log-In. Passwords and related security information used for authentication and Account access and information security purposes.
• Professional Information. Your company or organization affiliation and your profession.
• Communications. Content of messages you send to us through email, phone, or other means of communication, such as feedback or questions you ask our representatives, when necessary to provide you with the Services.

1.2. Information Automatically Collected.

The Services may automatically collect certain information from you through the use of Cookies, locally shared objects, or other technologies, as further described below in this Section. In general, information automatically collected does not directly identify you and the information may include, but is not limited to: browser type; other browser history; platform type; device's MAC address or MSISDN or other unique device identifier; information about your device operating system; number of clicks; landing pages; cookie information; the amount of time spent on particular pages; the time and date when you access or use the Services; the frequency with which your device attempts to contact our servers, time, and date of those attempts. We collect this information for the purposes described in this Privacy Policy, including to better understand our customer base and to improve the quality of our Services.

1.3. Cookies.

We automatically derive and collect certain data based on your interactions with us on the Services using cookies and similar technologies (collectively, “Cookies”). Our collection of data through Cookies includes information about your Services usage patterns, which may include your IP address, browser type, browser language, referring/exit pages and URLs, pages viewed, links clicked, whether you opened an email, and information about the device you use to access the Services. Our collection of this information allows us to improve your user experience in various ways, such as to personalize our display of the Services to you, to “remember” whether or not you are signed in, and to provide better technical support to you.

Please note: If you restrict, disable or block any or all Cookies, the Services may not operate properly, and you may not have access to the Services. We will not be liable for any impossibility to use the Services or degraded functioning thereof, where such are caused by your settings and choices regarding Cookies.

1.4. Pixels (aka web beacons/web bugs/java script).

We may use Pixels to automatically record certain technical information about your interactions with us when you visit the Services or otherwise engage with us, to help deliver Cookies on our Services, or count users who have visited the Services. We may also include web beacons in our promotional e-mail messages or newsletters to determine whether you open or act on them for statistical purposes. Pixels are tiny graphics (about the size of a period at the end of a sentence) with unique identifiers used to track certain online actions, movements and related information of Services users. Unlike Cookies, which are stored on a user's computer hard drive, Pixels are embedded invisibly on web pages or in HTML-based emails. The data we receive through Pixels allows us to effectively promote the Services to various populations of users, and to optimize external ads about the Services that appear on third-party websites.

1.5. Third Party Analytics Providers.

We also use analytics providers to collect information about Services usage and the users of the Services. The analytics providers use Cookies in order to collect usage information from users that visit the Services, including time spent, operating system, and IP address. Cookies allow the analytics providers to recognize a user when a user visits the Services and when the user visits other websites. Analytics providers use the information it collects from the Services and other websites to share with us and other website operators information about users including geographic regions and details about devices used to visit websites and purchase items. We do not link information we receive from the analytics providers with any of your personally identifiable information.

1.6. Location Information.

We do not collect precise geolocation data from you or your device, but may collect and use information about your general location or infer your approximate location based on your IP address in order to track our general Services usage or to tailor any pertinent aspects of your user experience to your region.

2. HOW WE USE YOUR INFORMATION.

2.1. General.

We may use your personally identifiable information for the purpose of providing you with the Services; communicating with you about the Services; to operate, manage, improve and conduct analyses relating to the Services; to prevent fraud or abuse, to address technical and security issues and to otherwise protect users; and to improve the Services.

2.2. Account-Related Emails.

If you have provided us with your contact information, we may, subject to applicable laws, send you emails about the Services and your Account. For example, if the Services are temporarily unavailable, we may also send you an email notice.

Email communications you receive from us will generally provide an unsubscribe link allowing you to opt out of receiving future email or to change your contact preferences. If you have an Account with us, you can also change your contact preferences by updating your contact information within your Account settings. Please remember that even if you opt out of receiving marketing emails, we may still send you important service information related to your Account and the Services.

2.3. Non-Personally Identifiable Information.

We may use non-personally identifiable information, such as anonymized and/or aggregated Services usage data, in any manner that does not identify individual users for the purpose of improving the operation and management of the Services and to better understand the Services usage patterns. Any non-personally identifiable information that is combined with personally identifiable information will be treated by us as personally identifiable information.

2.4. Advertising.

We use third parties, such as Google Ad, to deliver interest-based advertising based on your past visits to our Services.

2.5. Information Retention and Deletion.

We will or may retain your information indefinitely, or as long as legally required or allowed. If you cancel your Account, we may, but are not obligated to, delete your personally identifiable information and may continue to use or disclose it in accordance with this Privacy Policy. We may dispose of any information we collect, at our discretion and without notice, subject to applicable law.

3. OUR INFORMATION SHARING PRACTICES.

We will not sell or rent your personally identifiable information to third parties. We share user information, including any personally identifiable information, in the circumstances as categorized below.

3.1.      Service Providers.

We may disclose your personally identifiable information to third party service providers assisting us in the operation, management, improvement, research and analysis of the Services. Use of information by third party service providers will be subject to this Privacy Policy or an agreement that is at least as restrictive as this Privacy Policy.

3.2.      Legal Requirements.

We reserve the right to disclose all information collected via the Services, internally or to third parties, for any lawful purpose or to prevent harm to us or others. For example, and without limitation, in our discretion we may disclose information to government regulators, law enforcement authorities or alleged victims of identity theft.

3.3.      Organizational Transitions.

If we should ever transfer or restructure the operational ownership of the Services, such as through a merger with another entity or a reorganization of all or a part of our operational responsibilities or assets, we may disclose, transfer, assign our rights, and/or delegate our duties to your personally identifiable information without notice and consent, including to prospective or actual recipient entities. Should this occur, we will require any third party receiving your personally identifiable information under this subsection to be contractually required to provide the same level of privacy compliance as provided by us under this Privacy Policy.

3.4.      Disclaimer.

We cannot ensure that your personally identifiable information will be disclosed only as described in this Privacy Policy. For example, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your personally identifiable information that they collect from the Services. Even with the most rigorous information security standards, no transmission of data over the internet can be 100% secure.

4. SAFETY AND INFORMATION SECURITY MEASURES.

4.1.      Security.

We use certain physical, managerial, and technical safeguards designed to preserve the security of the personal and other information we maintain in connection with your use of the Services. This, however, does not guarantee that your information may not be accessed, disclosed, altered, or destroyed by any breach of our physical, technical or managerial safeguards. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and will notify you, as appropriate, in accordance with pertinent laws and regulations.

4.2.      Storage.

Personally identifiable information collected by the Services is stored in operating environments that are safeguarded against access by the public and protected from access internally by physical and technical security measures. While these measures are helpful to safeguard your personally identifiable information after we receive it, no transmission of data over the internet can be guaranteed to be 100% secure.

5. YOUR CHOICE AND OPTIONS RELATING TO OUR COLLECTION.

5.1.      You Can Choose Not to Provide Personally Identifiable Information.

You may always decline to provide your personally identifiable information to us by not registering for an Account. If you register for an Account, you can decline to provide any optional information in your Account profile. If you do not register for an Account, you will not be able to access or use certain features of the Services.

5.2.      You May Decline Other Requests.

We use personally identifiable information of our users as needed for the purposes for which it was collected or where you have consented to our use of such information. If you do not wish to provide information to us or do not wish to consent to the uses described in this Privacy Policy, please do not use the Services or register for an Account.

6 EXTERNAL LINKS.

The Services contain links to other websites and services (“Linked Services”). However, we are not responsible for any of the content of the Linked Services. We are also not responsible for the privacy practices and the terms and conditions of use for any Linked Services. The Linked Services may collect personally identifiable information from you that is not subject to our control. The data collection practices of linked sites will be governed by that site’s privacy policy.

In particular, some activities relating to the Services are carried out using the third party platform Zoom, hosted by Zoom Video Communications, Inc. and its affiliates (“Zoom”). Information you provide to Zoom is subject to Zoom’s Privacy Policy, located at:  https://zoom.us/privacy.

7. UPDATING YOUR PERSONALLY IDENTIFIABLE INFORMATION; deleting your account.

We do not review for accuracy or update your user information regularly, but encourage you to access, review and update your personally identifiable information at any time. For assistance regarding canceling your Account, contact us using the contact information provided in Section 11 (Contact Information). We will respond to your request as soon as reasonably possible after verifying your authority to make such requests.

8. CALIFORNIA SHINE THE LIGHT LAW.

California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personally identifiable information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please contact us using the contact information provided in Section 11 (Contact Information).

9. CALIFORNIA MINORS.

While we do not intentionally collect the personally identifiable information of individuals under 18, if you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us using the contact information provided in Section 11 (Contact Information). When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information. Removal of your content or information from the Service does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.

10. CHANGES TO THIS PRIVACY POLICY.

Because our privacy practices and privacy law necessarily evolve over time, we reserve the right to revise this Privacy Policy from time to time in our sole discretion, upon notice to you, such as by posting updated Privacy Policy on the Services, sending you an email to your Account email, or by any other reasonable means. You should periodically review this Privacy Policy to ensure that you are familiar with the most current version. Your continued use of the Services after the Effective Date posted above will constitute your acceptance of the updated Privacy Policy.

At this time, Web Sparky is not subject to the requirements of the California Consumer Privacy Act. We will revise this Privacy Policy when necessary to comply with the requirements of that statute, or similar federal or state laws that may be enacted in the future.

11. Contact information.

If you have any questions about this Privacy Policy or other matters that relate to it, you may reach us by using the contact information below:

Email:   info@herenow.cloud

Mail:     10002 Aurora Ave N, Ste 36 #432, Seattle, WA 98133