Privacy Policy

1. Scope

This Privacy Policy applies to personal information collected through the public Site and ordinary business-development or communications interactions. It does not replace privacy terms in a client agreement, data-processing agreement, employment notice, contractor agreement, or other notice that specifically governs another relationship. When another notice applies to particular information, that notice controls for that information.

2. Personal Information We May Collect

Information you provide

• Contact information, such as name, business email address, telephone number, company, job title, and mailing information you choose to provide.
• Inquiry and communications information, including messages, project descriptions, attachments, feedback, scheduling information, and correspondence.
• Business relationship information, such as the organization you represent, areas of interest, referral source, and information needed to evaluate a potential engagement.
• Marketing preferences, including whether you have asked to receive or stop receiving promotional communications.
• Other information you voluntarily provide to us.

Information collected automatically

• Device and browser information, such as device type, browser type, operating system, language, and general technical configuration.
• Internet and network information, such as IP address, approximate location derived from IP address, referring page, and request metadata.
• Usage information, such as pages viewed, links selected, approximate session timing, referral source, and interactions with Site features.
• Cookie and consent information, including consent choices and identifiers necessary to remember those choices.

Information from third parties

• Information from business contacts, referral sources, public professional sources, or organizations with which you are associated.
• Information from service providers that support hosting, security, analytics, communications, scheduling, or similar functions, subject to applicable law and our instructions.
• Information you make publicly available or direct a third party to provide to us.

3. Information We Ask You Not to Submit

Do not submit Social Security numbers, government identification numbers, financial-account credentials, payment-card information, health information, biometric data, precise geolocation, information about children, or other highly sensitive personal information through a general website form unless we specifically request it through an appropriate secure process. Submission of unsolicited sensitive information does not create an obligation to use it and may result in deletion or restricted access consistent with applicable law.

4. How We Use Personal Information

• Operate, maintain, secure, troubleshoot, and improve the Site.
• Respond to inquiries, communicate with you, schedule discussions, and evaluate potential business relationships.
• Provide requested information and administer our relationship with you.
• Understand Site performance and engagement when analytics has been permitted.
• Maintain records of communications, consent choices, and business interactions.
• Protect the rights, safety, security, property, and integrity of Story & Spark, our systems, users, clients, and others.
• Detect, investigate, prevent, and respond to fraud, abuse, security events, or unlawful activity.
• Comply with legal obligations, enforce agreements, establish or defend legal claims, and respond to lawful requests.
• Send marketing communications where permitted by law and consistent with your choices.
• Carry out a merger, financing, acquisition, reorganization, sale, due diligence process, or other business transaction, subject to appropriate safeguards.

5. Legal Bases Where Applicable

Where a law requires a legal basis for processing, we rely as appropriate on consent, performance of or steps toward a contract, compliance with legal obligations, and legitimate interests such as operating and securing the Site, communicating with business contacts, improving our services, and protecting our rights. Where we rely on consent, you may withdraw it subject to applicable law and without affecting processing that occurred before withdrawal.

6. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients when reasonably necessary:

• Service providers and contractors that support hosting, infrastructure, security, analytics, email, communications, scheduling, document management, professional services, and similar business functions.
• Professional advisers, such as attorneys, accountants, auditors, insurers, and consultants, when appropriate.
• Business counterparties in connection with a potential or completed merger, acquisition, financing, reorganization, sale of assets, or similar transaction.
• Government authorities, courts, regulators, law enforcement, or other persons when required by law or reasonably necessary to protect rights, safety, property, or security.
• Other persons at your direction, with your consent, or as otherwise disclosed at the time of collection.

We do not disclose personal information for payment as a business model, and we do not currently use personal information for cross-context behavioral or targeted advertising. Some privacy laws define "sale," "sharing," or "targeted advertising" broadly. If our practices change in a manner that triggers those definitions, we will provide applicable notices and choices before or when required.

7. Cookies and Similar Technologies

The Site may use essential technologies necessary for operation, security, network management, fraud prevention, and consent storage. We may also use analytics or similar non-essential technologies to understand Site usage, but only in accordance with the consent choices and legal requirements applicable to the visitor. See the Cookie Policy for more information. Cookie Settings should allow visitors to review or change non-essential consent choices at any time.

8. Marketing Communications

If you receive promotional email from us, you may unsubscribe using the link in the message or the contact method provided on the Site. We may continue to send non-promotional communications relating to an existing relationship, request, legal notice, security matter, or transaction when permitted by law.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this policy, including to manage communications and business relationships, comply with legal and accounting requirements, resolve disputes, enforce agreements, preserve security records, and establish or defend legal claims. Retention periods vary based on the nature of the information, the context of collection, legal requirements, and legitimate business needs. We may de-identify or aggregate information and retain it in a form that is not reasonably capable of identifying an individual.

10. Security

We use administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, acquisition, loss, misuse, alteration, or disclosure. No website, network, transmission, or storage system can be guaranteed to be completely secure. You are responsible for using appropriate caution when sending information electronically and for avoiding submission of unnecessary sensitive information through general Site channels.

11. International Processing

Story & Spark is based in the United States. Personal information may be processed in the United States and other locations where our service providers operate. Those locations may have privacy laws different from those in your jurisdiction. Where legally required, we use an appropriate transfer mechanism or other safeguard for cross-border processing.

12. Your Privacy Rights

Depending on where you live and subject to applicable exceptions, you may have rights to request access to or confirmation of personal information we process, correction, deletion, portability, restriction or objection, withdrawal of consent, and information about certain disclosures. Some U.S. state laws may also provide rights to opt out of sale, sharing, targeted advertising, or certain profiling, and to appeal a denied request.

Because Story & Spark does not currently intend to sell personal information or use it for cross-context behavioral or targeted advertising, there may be no such processing to opt out of at launch. We will honor legally required opt-out signals, including recognized browser-based preference signals, when and to the extent applicable to our processing.

Submitting a request

You may submit a privacy request through the privacy or general contact method made available on the Site. We may take reasonable steps to verify your identity and authority before acting on a request. Authorized agents may submit requests where permitted by law, but we may require proof of authorization and verification of the consumer. We will not unlawfully discriminate against you for exercising applicable privacy rights.

Appeals

Where applicable law provides an appeal right, you may appeal a decision by replying to our response or using the contact method identified in that response. We will provide information about any further complaint rights required by applicable law.

13. California Disclosures

For California residents, the categories of personal information we may collect correspond generally to identifiers, professional or employment-related information, internet or other electronic network activity, approximate geolocation derived from IP address, and inferences reasonably drawn from interaction data. The sources, business purposes, retention approach, and categories of recipients are described throughout this Privacy Policy. We do not currently intend to sell or share personal information as those terms are defined by the California Consumer Privacy Act, as amended, and we do not knowingly sell or share personal information of consumers under 16.

If we collect sensitive personal information subject to a right to limit use and disclosure, we will provide the notice and mechanism required by applicable law. At launch, the public Site is not intended to collect sensitive personal information for purposes that would require a California "Limit the Use of My Sensitive Personal Information" mechanism.

14. Children

The Site is not directed to children under 13, and we do not knowingly collect personal information from children under 13 through the public Site. If we learn that such information was collected in a manner requiring deletion, we will take reasonable steps to delete it. Parents or guardians may contact us through the method provided on the Site.

15. Third-Party Sites and Services

The Site may contain links to or integrations with third-party services. Their privacy practices are governed by their own policies, not this Privacy Policy. We are not responsible for the privacy, security, or content practices of independent third parties.

16. Changes to This Privacy Policy

We may update this Privacy Policy as our business, technology, or legal obligations change. The "Last Updated" date identifies the current version. If a change materially affects how we use personal information, we will provide notice or obtain consent when required by applicable law.

17. Contact Us

Privacy questions or requests may be submitted through the privacy or general contact method made available on the Story & Spark website. Requests should identify the relevant person and, when helpful, the relationship or interaction involved. Effectuate, Inc. d/b/a Story & Spark is the legal operator responsible for this policy.