Privacy Policy

Last modified: September 24, 2024

INTRODUCTION

Soneil International Limited and our affiliates and subsidiaries (“Company”, “we”, “our” or “us”) respect your privacy and are committed to protecting it by complying with this privacy policy.

This policy describes:

How we collect, use, disclose, and protect the personal information of our customers, website users, and users of electric vehicle charging stations on our network ("you").
Describes the types of information we may collect from you or that you may provide when you visit/use our website soneilspark.com, including your registered account (our “Website”).
Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We are the data controller of any personal information collected through our Website. We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant and not excessive.

Privacy laws in Canada generally define "personal information" as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

This policy applies to information we collect, use, or disclose about you:

On our Website.
Through our network (“Soneil Spark Network”). Soneil Spark Network refers to the Company’s open-platform network of electric vehicle charging stations and vehicle charging applications.
In email, text, and other electronic messages between you and this Website and/or App.
When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

Our Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, plug-ins, services, social networks, or applications and we encourage you to read their privacy policy when you visit.

This policy DOES NOT apply to information that you provide to or is collected by any third party (including our affiliates and subsidiaries), through any application or content (including advertising) that may link to or be accessible from or on our Website and/or App.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website and Soneil Spark Network. By accessing or using this Website and/or Soneil Spark Network, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website and/or Soneil Spark Network after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you when you use our Website and/or Soneil Spark Network, including:

Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, title, home mailing address, other addresses you input (for example your work mailing address), e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, password, PIN login information, billing and account information, location and geolocation (including but not limited to, charging station location), date of birth, vehicle make, model and colour, Soneil Spark Card identification number (A “Soneil Spark Card” is a radio-frequency identification card (“RFID”) used to access and pay for charging at charging stations on Soneil Spark Network), charging port identification number, charging session information (date, location, start time, end time, duration), total fees associated with each charging session, and any other identifier we may use to contact or identify you (collectively, "personal information").
Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as the speed and distance you drive, energy dispensed, power consumption, power cycle patterns, current and voltage, demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
Non-personal details about your Website and/or App interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

Direct interactions with you when you provide it to us, for example, by filling in forms, surveys, polls, promotions, or order details, when purchasing products, registering for an account and completing your account profile, accessing and using Soneil Spark Network, or communicating with us by phone, email, or otherwise for purposes such as customer support, technical assistance, marketing or billing.
Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
Soneil Spark Network, when you use Soneil Spark Network.
Third parties or publicly available sources, ffor example, our business partners, API partners, authorized third parties including third-party network providers which you are permitted to obtain services from using our Website, charging station hosts, or from non-affiliated third parties for fraud or safety protection purposes or for marketing purposes.

INFORMATION YOU PROVIDE TO US

The information we collect directly from you on or through our Website may include:

Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, purchasing our products and/or requesting further services. We may also ask you for information when you provide feedback, enter a promotion sponsored by us, and when you report a problem with our Website.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
Your search queries on our Website.

INFORMATION WE COLLECT THROUGH COOKIES AND OTHER AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Website, including but not limited to, location data, geolocation data, logs, and other communication data and the resources that you access and use on our Website.
Information about your computer, mobile device and internet connection, including your IP address, operating system, and browser type.
Collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or device. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access all or certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

We use the following cookies:

Strictly Necessary Cookies – these cookies are vital for facilitating your navigation and utilization of our Website’s features. Without these cookies, we cannot provide our Website to you.
Performance Cookies – these cookies enhance the functionality of our Website, optimizing its performance. They gather data on user interactions, such as pages viewed, how often and how long for. These cookies do not collect information that would allow us to identify you personally. They collect aggregated information, which is anonymous.
Functionality Cookies – these cookies enable us to retain your preferences (for example your username and password, language settings, time zone) to provide more personalized features. The information gathered by these cookies may be anonymized.
Advertising and Marketing Cookies – these cookies serve the purpose of delivering advertising and marketing content customized to your interests, while also regulating the frequency of ad displays. Advertising networks, with our consent, typically place these cookies. These cookies collect information about your activity on our Website, including content viewed, links followed, your browser, device and IP address. We also allow analytics services to collect information on our Website through cookies and similar technology to help us analyze how our Website is being used.
Flash Cookies – Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons and Pixel-Based Tracking – Pages of our Website and our e-mails may contain small electronic files including web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) and/or pixels that permit the Company, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on our Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

You can opt-out of several third party ad servers' and networks' cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties' tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To process your application to register, create and maintain an account with us.
To provide you with information, products, or services that you request from us.
To give you access to charging services and stations on the Soneil Spark Network and other networks operated by our roaming partners.
To process billing functions, including payment of fees.
To provide promotions and pricing.
To provide you with advertisements.
To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
To manage and respond to any inquiries, correspondence, concerns or complaints you have sent to us.
To communicate with you regarding our products and services.
To promote and market our products and services.
To provide you with notices about your account/subscription, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
To notify you about changes to our Website or any products or services we offer or provide though it.
To improve our Website, our App, products or services, marketing, or customer relationships and experiences.
To analyze the use of our products and services.
To research or develop other products or services.
To maintain internal records.
To verify identity if you contact us with requests related to your privacy rights, products and services.
To create or maintain aggregated, anonymized or de-identified information, which we may use and disclose without restriction.
To safeguard our and other’s rights or property.
To investigate, prevent, or take action regarding unlawful or harmful activities, including potential fraud, security threats and breaches of our Terms of Use and/or Terms.
To provide you with communications, notifications and alerts as follows:
- Essential – You will receive essential alerts for example, your payment has been declined or there is an error on the charging product or with charging, critical security updates, account verification notices, service-related communications, legal notifications (“Essential Alerts”).
- Insightful – You will receive insightful alerts for example, your charging has been completed, you have consumed a certain amount of energy, you have paid a certain amount this month for charging (“Insightful Alerts”).
- Marketing – You will receive emails, texts and notifications with information about our products and services (“Marketing Alerts”).
In any other way we may describe when you provide the information.
For any other purpose with your consent.

We may also use your information to contact you about our own goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails and/or e-mail us at contactus@soneilspark.com. For more information, see Choices About How We Use and Disclose Your Information.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates for the purposes described in this privacy policy.
To our employees, strictly on a need-to-know basis, to enable them to fulfill their work responsibilities effectively.
To our financial and legal advisors, as required, for example as part of a sale or assignment of our business, financial transactions and audit purposes.
In accordance with applicable law, to a buyer or other successor in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, insolvency, receivership or similar proceeding, in which personal information held by the Company about our customers and users is among the assets transferred.
To third parties to market their products or services to you if you have consented to these disclosures. For more information, see Choices About How We Use and Disclose Your Information.
To Soneil Spark Network owners or authorized third parties including third-party network providers which you are permitted to obtain services from using our Website, API partners, charging station hosts, utilities or their respective employees, freelancers, and consultants to help us provide our products and services to you.
To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with our Website improvement and optimization, hosting and financial providers, marketing, customer storage platforms and data storage providers) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
To our advertising partners and content publishers in our industry.
To fulfill the purpose for which you provide it. For example, completing your order.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
To investigate, prevent or take action regarding possible illegal activities, suspected fraud or situations involving potential threats to the physical safety of any person.
To enforce or apply our Terms and Conditions of Use or Terms and Conditions of Sale and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with our Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

By submitting your personal information or engaging with our Website, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information

Consent. You provide us with consent when you click accept to confirm your consent to certain actions, for example, receiving promotional emails.
User Account. You can modify certain information we maintain about you by accessing your account through our Website.
Unsubscribe/Opt-Out. ou have the opportunity to unsubscribe or opt-out of certain emails, promotional emails, Insightful Alerts and/or Marketing Alerts through your user account on our Website, by using the unsubscribe mechanism in the communication sent by us and/or by emailing us at contactus@soneilspark.com.
Essential Alerts. YOU CANNOT UNSUBSCRIBE OR OPT OUT OF ESSENTIAL ALERTS. By using our Website, you acknowledge and agree that Essential Alerts are deemed essential for the proper functioning of our Website, the safety of our users and compliance with legal obligations. Due to their critical nature, you do not have the option to unsubscribe or opt out of receiving these Essential Alerts. We recognize the importance of respecting your privacy and will make reasonable efforts to minimize the frequency and impact of Essential Alerts. The only way for you to not receive these Essential Alerts is for you to delete your account. If you have concerns about the nature or frequency of Essential Alerts you receive from us, please contact us at contactus@soneilspark.com.
Location Tracking. f you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. If you disable location-tracking functions, you may be unable to use certain parts of our Website.
Tracking Technologies and Advertising. ou can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of our Website may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies.
Third-Party Advertising. you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by logging into our Website and adjusting your user preferences in your account profile or by sending us an email stating your request to contactus@soneilspark.com.
Non-discrimination. If you exercise any of your rights, for example, opting-out of Marketing Alerts, we will no discriminate against you or provide you a different level or quality of service.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions will be encrypted, we will not store or collect your payment details.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a username and password or PIN login information for access to certain parts of our Website, you are responsible for keeping this username and password or PIN login information confidential. We ask you not to share your username and password or PIN login information with anyone. Where we have given you a Soneil Spark Card, you are responsible for keeping the Soneil Spark Card information confidential and storing it in a secure way.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website.

We diligently adhere to breach notification laws, ensuring that we promptly inform you of any security breach, confidentiality breach, or unauthorized disclosure of your personal information whenever we are legally obligated to do so. We will notify you by email of any breaches that may cause harm or risk to you.

We conduct Data Protection Impact Assessments (“DPIAs”) for high-risk processing activities that may impact your privacy rights and take appropriate measures to mitigate those risks and ensure compliance with applicable laws. For example, payment information has been assessed as a high-risk processing activity and we therefore encrypt this data to protect it from unauthorized disclosure. Additionally, we do not store your password when you create an account or use our Website.

We keep records and track data processing activities to apply with applicable laws.

To ensure strict compliance with our privacy policy requirements, we conduct regular training for all our staff members who handle, process or have access to personal information.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Due to the varying needs associated with different types of personal information and your use of our Website and/or Soneil Spark Network, the actual retention periods can vary. When your personal information is no longer necessary, we destroy it securely. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

CHILDREN UNDER THE AGE OF 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information to our Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website, make any purchases through our Website, or provide any information about yourself to us, including your name, address, telephone number, email 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 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at contactus@soneilspark.com.

ACCESSING, CORRECTING AND DELETING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law, you or a person authorized to act on your behalf, have the right to request access to, correct and delete the personal information that we hold about you.

You can review and change your personal information by logging into our Website and visiting your account profile page.

If you want to review, verify, correct, erase or withdraw consent to the use of your personal information you may also send us an email at contactus@soneilspark.com request access to, correct, or delete any personal information that you have provided to us. You have the right to the portability of your personal information. You have the right to request your personal information from us, receive it and transfer it to a third party controller. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.

You have the right to request the deletion of your personal information. Upon receipt and verification of your request, we will proceed to delete your personal information from our records, and we will also instruct any relevant service providers to delete the information if applicable. However, we reserve the right to deny your request and retain a copy of your personal information if we have a legitimate reason and legal basis for doing so.

We may request specific information from you or a person authorized to act on your behalf, to help us confirm your identity and your right to access, delete and to provide you with the personal information that we hold about you or make your requested changes and the authenticity of the request. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact us at contactus@soneilspark.com.

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at contactus@soneilspark.com. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

STATE AND REGION SPECIFIC INFORMATION

In addition to your rights described in this privacy policy, your state or region may grant you certain privacy rights. For instance, residents of California and other U.S. states, as well as residents in the EU, European Economic Area (EEA), the United Kingdom, and other jurisdictions, may have specific privacy rights. Please see the below overview of state and region specific information which supplement the information included in the other sections of this privacy policy.

California

If you reside in California, you are entitled to additional rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”).

Your rights under the CCPA include:

The right to know, request and access your personal information collected by us, how we collect the personal information, why the personal information is collected and what personal information is shared or sold. For more information, see: Information We Collect About You, How We Collect Information About You, How We Use Your Information and Disclosure of Your Information.
The right to delete personal information we collect about you. For more information, see: Choices About How We Use and Disclose Your Information and Accessing, Correcting and Deleting Your Personal Information.
The right to opt-out of (say no to) the sale of personal information. For more information, see: Choices About How We Use and Disclose Your Information and below.
The right to non-discriminatory treatment for exercising any rights. For more information, see: Choices About How We Use and Disclose Your Information.
The right to correct inaccurate personal information. For more information, see: Accessing, Correcting and Deleting Your Personal Information.
The right to limit use and disclosure of sensitive personal information. For more information, see: Choices About How We Use and Disclose Your Information.

As a California resident, you retain the right to opt-out of the sale of your personal information under the CCPA. This means that you can request us to cease the sale of your personal information at any time. We want to assure you that we do not sell your personal information to third parties for financial gain. However, we do share your personal information with third parties as outlined in: How We Use Your Information and Disclosure of Your Information sections of this privacy policy. Although data sharing activities may not be sales, they could fall under the definition of “sale” as per the CCPA, which includes any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to another business or a third party, for monetary or other valuable consideration”. If you opt-out of the sale of your personal information, these are the activities we would be required to stop. Since some of our services require us to share your personal information with third parties, your ability to use our Website and/or Soneil Spark Network may be affected.

If you reside in California and wish to exercise your right to opt-out of such sales, please send us a “do not sell my information” request by sending us an email at contactus@soneilspark.com.

Colorado, Connecticut, Virginia, Utah

If you reside in Colorado, Connecticut, Virginia or Utah, you have additional rights:

If we deny your rights request regarding the collection, use and disclosure of your personal information, you have the right to appeal that decision. We will provide you with the necessary information to submit an appeal at that time.
You have the right to opt out of targeted advertising. For more information, see: How We Use Your Information and Choices About How We Use and Disclose Your Information.
You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Profiling refers to the automated processing of your personal information to analyze, predict, or make decisions about you based on your characteristics, behaviour, preferences, or other factors. WE DO NOT ENGAGE IN SUCH PROFILING.

Nevada

If you reside in Nevada, you have additional rights. Under Chapter 603A of the Nevada Revised Statutes, we do not sell your covered information. Covered information means any one or more of the following items of personal information collected by us through our Website and maintained by us:

A first name and last name.
A home or other physical address which includes the name of a street and the name of a city or town.
An electronic mail address.
A telephone number.
A social security number.
An identifier that allows a specific person to be contacted either physically or online.
Any other information concerning a person collected from the person through our Website and maintained by us in combination with an identifier in a form that makes the information personally identifiable.

The term “Sale” under Chapter 603A of the Nevada Revised Statutes means the exchange of covered information for monetary consideration by an operator or data broker to another person.

Although we do not sell your covered information, if you are a Nevada resident, you may submit a request to opt-out of any potential future sales under Nevada law by emailing us at contactus@soneilspark.com.

EU, EEA and United Kingdom

If you reside in the EEA or the United Kingdom, you have certain privacy rights as specified under the General Data Protection Regulations (“GDPR”) and UK Data Protection Act 2018 (“DPA”). If you use our Website in the EEA or UK, you should know that the Company is the controller of your personal information. We are committed to protecting your personal data and ensuring compliance with the GDPR and DPA when processing your information. The following clauses outline how we meet the key requirements of the GDPR and DPA:

Lawful Basis for Processing: We process your personal data based on one or more lawful grounds as provided under the GDPR and DPA. These include obtaining your explicit consent, performing a contract with you, fulfilling legal obligations, protecting vital interests, performing tasks in the public interest, or pursuing legitimate interests. For more information, see: Information We Collect About You, How We Collect Information About You and How We Use Your Information.
Transparency and Data Subject Rights: We are transparent about the data we collect and the purposes for processing. You have the right to access, rectify, erase, restrict, or object to the processing of your personal data as outlined in this privacy policy. To exercise these rights or for any inquiries about your data, please contact us at contactus@soneilspark.com. For more information, see: How We Use Your Information, Disclosure of Your Information, Accessing, Correcting and Deleting Your Personal Information, Withdrawing Your Consent and Data Retention.
Data Minimization: We only collect and process the minimum amount of personal data required for the specified purposes. Your data is kept accurate, and we retain it for the duration necessary to fulfill the stated purposes or as required by applicable laws. For more information, see: Information We Collect About You, How We Use Your Information, Data Security, Data Retention and Accessing, Correcting and Deleting Your Personal Information.
Consent: When we rely on your consent as the lawful basis for processing, we ensure that it is freely given, specific, informed, and obtained through an affirmative action. You have the right to withdraw your consent at any time. For more information, see: Choices About How We Use and Disclose Your Information and Withdrawing Your Consent.
Data Breach Notification: In the event of a data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by the GDPR or we will notify the Information Commissioner’s Office (“ICO”) and you, as required by the DPA. For more information, see: Data Security and Contact Information and Challenging Compliance.
DPIAs: We conduct DPIAs for high-risk processing activities that may impact your privacy rights and take appropriate measures to mitigate those risks and ensure compliance with GDPR and DPA. For more information, see: Data Security.
Data Protection Officer (“DPO”): We have appointed a DPO to oversee GDPR and DPA compliance and address data protection matters. You can contact our DPO at contactus@soneilspark.com. For more information, see: Contact Information and Challenging Compliance.
International Data Transfers: When transferring your data to countries outside the EU, EEA, or UK, we ensure adequate protection through legal mechanisms, such as Standard Contractual Clauses or other GDPR/DPA-approved safeguards. For more information, see: Transferring Your Personal Information.
Accountability: We maintain records of our data processing activities and regularly review and update our privacy practices to ensure ongoing GDPR and DPA compliance. For more information, see: How We Collect Information About You, How We Use Your Information and Changes to Our Privacy Policy.

By using our services, you acknowledge that you have read and understood our privacy policy and how we comply with GDPR and DPA requirements. If you have any questions or concerns about your data or privacy, please contact us at contactus@soneilspark.com.

You have the right to file a complaint with the supervisory authority in the EEA and in the UK, you can file a complaint with the ICO.

CHANGES TO OUR PRIVACY POLICY

We regularly review and update our Privacy Policy to ensure compliance with applicable laws. It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on our Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and through a notice on our Website home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

46 West Dr.

Brampton, ON, Canada L6T 3T6

Tel: +1 905-565-0360

Fax: +1 905-799-6821

E-mail: contactus@soneilspark.com

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws, including notifying the appropriate authorities or organizations in the event of a data breach that may cause harm or risk to you. To discuss our compliance with this policy please contact us using the contact information listed above.

If you wish to report a complaint, or if you are not satisfied with the way we handled your concern, you may contact your local data protection regulator.