Spark Agency, Inc. D/B/A Switch (Switch) is committed to protecting your privacy. This Privacy Policy applies to the Switch website, https://switch.us/, and governs data collection and usage on or by that website.

Consent to Collection and Use of Your Personal Information
By using the Switch website, you consent to the data practices described in this statement. When you provide us with personal information, for example in order to contact us, we also imply that you consent to our collecting it.

If after you opt-in you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use, or disclosure of your information, at anytime, by using the appropriate provided tool such as an unsubscribe link in e-mail communication to you or contacting us at: PrivacyPolicy@switch.us.

Collection of your Personal Information
Switch collects personally identifiable information, such as your name, email address, telephone number, and other personal information required to get you the services you seek. Switch also collects any information you voluntarily provide to Switch, for example, in a message sent when contacting us.

There may also be information about your computer or mobile devices and web software that is automatically collected by Switch. This information can include: your internet protocol address, browser type(s), domain name(s), website access dates, website access time(s) and referring website address(es). This information is used by Switch for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Switch website.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Switch social media channels or other means during interaction with Switch, this information may be collected and used by others pursuant to the privacy policies of such social media companies. Collection and use of your information is governed separately by the privacy policies of any such third-party services you use to communicate with Switch.

Switch encourages you to review with great and thorough scrutiny this and other privacy policies of web sites you choose to visit which may be hyperlinked to or from Switch so that you have a full and complete understanding of how those websites collect, use, and share your information. Switch is not responsible for the privacy policies or other content on websites or other platforms outside of the Switch website – including social media services. Remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. As an example, if you are located in Canada and your transaction is processed by an entity located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act. Once you leave Switch’s website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy.

Use of your Personal Information
Switch collects and uses your personal information to operate the Switch website and deliver the products and/or services you have requested. Switch uses your personally identifiable information to inform you of products, services, or other information available from Switch that may be of interest to you. This can take the form of an e-mail newsletter or similar communication. Switch may also contact you via surveys to conduct research about your opinion of current products and/or services or of potential new products and/or services that may be offered in the future.

Switch does not, currently, sell, rent, or lease its customer list or acquired information to third parties at this time, but reserves the right to do so in the
future. Switch does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.

Switch may track the websites and/or web pages that you visit within the website, in order to determine what Switch products and/or services are the
most popular. This data may be used to deliver customized content and advertising within the website and within our outbound marketing and marketing efforts to customers whose behavior indicates that they are interested in a particular product or service.

Switch will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Switch or the website; (b) protect and defend the rights or property of Switch; and, (c) act under exigent circumstances to protect the personal safety of users of Switch, or the public.

Use of Cookies
The Switch website may use technical “cookies” to help personalize your digital experience. A cookie is a text file that is placed on your hard disk by a web server, specifically within your web browser. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can typically only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize Switch pages or register with the Switch site, a cookie helps Switch to recall your specific information on subsequent visits. This simplifies the process of recording your personal information. When you return to the same Switch website, the information you previously provided can be retrieved, so you can easily use the Switch features that you customized or access on your previous visit.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Switch services or websites you visit. The Switch website also uses cookies associated with Google Analytics to collect information about the use of our site. Google Analytics collects information such as how often users visit our Website, the identification of pages visited, and the identification of other sites visited prior to visiting our Website. Switch uses this information from Google Analytics to improve our Website. Google Analytics collects only the IP address assigned to your computer or other device on the date you visit our site, rather than your name or other identifying information. While Google Analytics places a permanent cookie on your web browser to identify your computer as a unique user the next time you visit our site, the cookie cannot be utilized except by Google. The ability to use and share information collected by Google Analytics about your visits to our site is restricted by the Google Analytics Terms of Use. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser.

Here is a list of cookies used by Switch:

_hjsession_, _hjfirstseen, and _hjsessionuser_, _hjabsolutesessioninprogress, are cookies that hold the current session data and attribute it to a unique users. This ensures that subsequent requests within the session window will be attributed to the same session for purposes of recording data for website analytics, e.g., which pages are the most visited.

_hjincludedinsessionsample, _hjincludedinpageviewsample are cookies that is used to designate whether a user in included in sampling for website analytics, e.g., which pages are the most visited.

_ga, is a Google Analytics cookie used to collect Google Analytics data including identifying unique users.

_gcl_au, is used by Google AdSense for experimenting with advertisement efficiency across websites using their services.

visitor_, is a cookie used to assign a unique visitor ID to website visitors.

_gid, is a Google Analytics cookie providing an ID used to identify users for 24 hours after last activity.

Security of Your Personal Information
Switch takes reasonable precautions and follows industry standard practices to secure your personal information from unauthorized access, use, or disclosure.

California Residents
This section applies only to California Residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), if you are a California resident, you have certain rights in relation to your personal information, subject to certain exceptions.

Right to Know and Access:
You have the right to know the personal information we collected, used, disclosed for a business purpose, and sold about you during the preceding 12 months, including the categories of sources from which we acquired your information and the categories of third parties to whom we disclosed your information for a business purpose or sold your information. General information about the personal information we collect, use, disclose and sell and the purposes of collection, use and disclosure is set forth in this Privacy Policy and the Terms and Conditions.

For information we collected that is specific to you, you have the right to request in writing from us a copy of the:

• Categories of information we have collected about you over the preceding 12 months
• The specific pieces of personal information we have collected about you (note that we will not provide any sensitive personal information we may hold in response to this type of request).
• The categories of sources from which we collected that information
• For what purpose or use we collected that information about you
• The categories of third parties with whom we shared your personal information, including
• If we disclosed your personal information for a business purpose, which categories of information we disclosed to which categories of recipients, and
• If we sold your personal information, which categories of your personal information we sold to which categories of recipients.

Right to Request Deletion:
You have the right to request that we delete any personal information we have collected from you or maintain about you, subject to certain exceptions. If you request that we delete your personal information, we will do so except to the extent we determine that we need the information for a business purpose and have a legal right to maintain it, in which case we will inform you of that legal exception.

Right to Opt-out of Sale of Your Personal Information:
To the extent that we receive monetary or other valuable consideration for sharing or providing access to information about you, the CCPA may deem this a “sale” of your personal information. You have a right under California law to opt-out of our “sale” of your information in this way. If you would like to exercise your right to opt-out of having your personal information shared in this way, please contact us at: PrivacyPolicy@switch.us.

Right to Non-Discrimination:
We will not discriminate against you for exercising any of your CCPA rights.

Unless otherwise permitted by the CCPA, we will not do any of the following because you request to know, access, or delete your information or opt out of its sale:

• deny you goods or services
• charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
• provide you a different level or quality of goods or services, or
• suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

How To Exercise Your CCPA Rights to Know, Access, and Request Deletion:
To assert your CCPA privacy rights, please contact us at: PrivacyPolicy@switch.us. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. For any agent making a request on your behalf, we may require you to provide proof that you authorized this agent to submit a request on your behalf or that he or she has power of attorney in connection with your request to know, access or delete your personal information.

Please note that we are not required to respond more than twice per calendar year to requests to know/access your personal information.

Changes to this Policy
Switch reserves the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. Switch will occasionally update this Privacy Policy to reflect company and customer feedback. Switch encourages you to periodically review this Policy to stay informed of how Switch is protecting your information.

Contact Information
Switch welcomes your comments regarding this Privacy Policy. If you believe that Switch has not adhered to this Policy, please contact Switch at: PrivacyPolicy@switch.us. We will use commercially reasonable efforts to promptly determine and remedy any problem. If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at: PrivacyPolicy@switch.us.