Please read this privacy policy carefully.
This privacy policy describes how we collect, use, process and disclose your data, including your personal information, in connection with your access to and use of BluSpark Services.

1. Definitions –
The following terms shall have the following meanings:
“Service” or “Services“: access to our website www.bluspark.io as well as your subscription and any Order of our services, products, applications, tools, offline components and functionalities (individually the “Service” or collectively, the “Services”) provided by our company BluSpark SAS, as well as its affiliates, managers, employees, service providers and agents (hereafter “BluSpark”, “we”, “us” or “our”).
“Application“: mobile or desktop application used by the User via BluSpark and made available to the public for download from a third party platform or accessible from a web browser
“User” or “Customer“: any person or entity with an account allowing access to our services.
“End User“: Any person or entity that actually uses our Service(s). This may include users, visitors and customers of our user’s application.
“Site User” or “Visitor“: Any person visiting one of our sites including www.bluspark.io

All other capitalized terms not defined in this Privacy Policy are specified in our Terms of Use.

2. Information we collect
2.1 Information you voluntarily provide to us
When you register and use the Services, consult our customer service, send an email, post on our blog, integrate the Services with another site or service (for example, when you choose to connect your WordPress site to BluSpark), or communicate with us in any other way, you are voluntarily giving us information that we collect.
This information may include name, physical address, email address, IP address, phone number. By providing us with this information, you consent to the collection, use, disclosure, transfer to Europe and storage of this information by us as described in our Terms of Use and this Privacy Policy.

2.2 Information collected automatically
When you use the Services or browse any of our websites, we may collect information about your visit to our websites, your use of the Services and your web browsing. This information may include your IP address, operating system, browser ID, browsing activity and other information about how you interacted with our websites or other websites. We may collect this information as part of log files, as well as through the use of cookies or other tracking technologies.

2.3 Information from your use of the Service
We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used and actions you have taken on the Services. This type of information helps us to improve our services for you and for all our users.

2.4 Cookies and tracking
We may use various technologies to collect and store information when you use our Services, and this may include the use of cookies and similar tracking technologies on our website, such as pixels and web beacons, to analyse trends, administer the website, track users’ movements around the website, and gather demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level. For more information, please refer to our cookie policy.

2.5 Information from the use of our applications
When you use our mobile applications, we may collect certain information in addition to the information described elsewhere in this Policy. For example, we may collect information about the type of device and operating system you use. We may ask you if you would like to receive push notifications about your account activity. If you have enabled these notifications and no longer wish to receive them, you can disable them via your operating system.
We may request, access or track location-based information from your mobile device in order to test location-based features offered by the Services or to receive push notifications targeted to your location. If you have chosen to share this location-based information and no longer wish to share it, you can disable sharing via your operating system. We may use mobile analytics software (such as crashlytics.com) to better understand how people use our application. We may collect information about how often the app is used and other performance data

3. How we use the information we collect –
We may use and disclose personal information for the following purposes:

3.1 To promote the use of our services to you and others. For example, if we collect your personal information when you visit our website and you do not register for any of the Services, we may send you an email inviting you to register. If you use one of our Services and we think you might benefit from using another Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the unsubscribe instructions included in each email we send. In addition, we may use the information we collect to advertise our Services to you or suggest additional features of our Services that you may consider using.

3.2 To bill and collect amounts owed to us by our Users. This includes sending emails, invoices, receipts, notices.

3.3 To send you messages relating to your use of the Services. For example, we may notify you of temporary or permanent changes to our Services, such as planned outages, new features, version updates, abuse warnings and changes to our Privacy Policy.

3.4 To communicate with our Users about their account and provide customer support.

3.5 To enforce compliance with our Terms of Use and applicable laws. This may include developing tools and algorithms that help us prevent violations.

3.6 To protect the rights and safety of our Users and third parties, as well as our own.

3.7 To meet legal requirements, including complying with court orders, subpoenas, summonses and other appropriate legal processes. To respond to legitimate requests from public authorities, including to meet national security or law enforcement requirements.

3.8 Provide information to representatives and advisors, including lawyers and accountants, to assist us in meeting legal, accounting or security requirements.

3.9 To provide, support and improve the Services we offer. This includes our use of the data that our Users provide to us to enable our Users to use the Services to communicate with their End Users. This also includes, for example, aggregating information from your use of the Services or visits to our Websites or Applications used with our Service and sharing this information with third parties to improve our Services. This may also include sharing your information or information you provide about your end users with third parties in order to provide and support our Services or to make certain features of the Services available to you. Where we need to share personal information with third parties, we take steps to protect your information by requiring those third parties to enter into a contract with us that obliges them to use the personal information we transfer to them in a manner consistent with this policy.

4. Data collected for and by our Users
When you use our Services, you may import into our system Personal Information that you have collected from End Users or others. We have no direct relationship with End Users or anyone other than you, and for this reason you are responsible for ensuring that you have the appropriate permission to collect and process information relating to such persons. In accordance with the use of personal information discussed in Section 3, we may transfer personal information of you or End Users to companies that assist us in providing or supporting our services or the services of our users (“Service Providers”). All Service Providers enter into a contract with us that protects personal information and restricts their use of any personal information in accordance with this Policy. As part of our Services, we may use and incorporate into the features information that you have provided, that we have collected from you or that we have collected about End Users. We may share such information with third parties in accordance with the uses set forth in Section 3 and in strict compliance with applicable regulations.
For your information, we inform you that the service providers with whom we have a contract (the “Subcontractors”) are the following:
Google Inc: 1600 Amphitheatre Parkway, Mountain View CA94043, USA
Twilio Inc: 375 Beale Street, Suite 300, San Francisco CA94105, USA
When your End Users use the Services or browse your App, we may collect information about their visit to your App and their use of the Services. This information may include IP address, operating system, browser ID, browsing activity and other information about how they interacted with your application. We may collect this information as part of log files, as well as through the use of cookies or other tracking technologies. We may use this information in accordance with the uses set out in sections 3-4 to 3-9.

If you are an End User and no longer wish to be contacted by one of our Users, please contact User directly to update or delete your data. If you contact us, we may delete or update your information within a reasonable time and after informing the User of your request.

We will retain the Personal Information we process on behalf of our Users for as long as necessary to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse and enforce our agreements.

5. Data collection and processing
The User as Data Controller
Our clients who operate an application using BluSpark are responsible for what they do with the personal information they collect, directly or via BluSpark, from their End Users.
The User is the Data Controller and BluSpark is the subcontractor.
As a User, you are solely responsible for complying with the laws and regulations that apply to your collection and use of your End Users’ information, including the personal information you collect about them using the Services or cookies or similar technologies.
You must publish your own privacy policy.
We are not responsible for your relationship with your End Users or how you collect and use personal information about them (even if you collect it or use BluSpark’s features or cookies or similar technologies).

BluSpark as a Processor
For Users and Visitors, BluSpark is the Data Controller.

• 6. Your Rights
  You (in particular, European users) have certain legal rights to obtain information about your personal information, to access the personal information we hold about you and to have it corrected, updated, modified or deleted in appropriate circumstances. We undertake to respond within a reasonable time to your request to exercise these rights (at the latest within 30 days of receipt of a request).
• The rights to which you are entitled are as follows:Rights of access to data
• Right to restrict processing
• Right to rectification
• Right to erasure (right to be forgotten)
• Right to object to processing
• Right to withdraw consent and
• Rights to data portability

Where required by applicable law (and subject to relevant legal exceptions), you may have the right to access, update, amend or delete personal information.
If you are a User
You may access, update, modify or delete personal information (or that of your end users) directly in your account or by contacting us at contact@bluspark.io to request the required changes. You may exercise your other rights (including deleting your account) by contacting us at the same email address.
If you are an End User
When using an Application made by one of our Users, you will need to contact that User directly, the Data Controller, to discuss managing, deleting, accessing, restricting access to, or withdrawing consent to the use of the information you have provided to them while using their application. BluSpark, as a subcontractor, is not able to handle these requests directly. If you have difficulty finding the person concerned, you can contact us at contact@bluspark.io and we will do our best to assist you.
Please note that, for technical reasons, there is likely to be a delay in removing your Personal Information from our systems when you request us to delete it. We will also retain Personal Information to comply with the law, to protect our rights and the rights of others, to resolve disputes or to enforce our legal terms or policies, in accordance with legal requirements.

7. How do we protect your information?
Although no service is completely secure, we have a dedicated security team to protect personal information. We maintain administrative, technical and physical safeguards designed to adequately protect against accidental or unlawful destruction, accidental loss, unauthorised modification, unauthorised disclosure or access, misuse and other unlawful processing of personal information in our possession.
We use security measures such as using firewalls to protect against intruders, creating redundancies in our network (so that if one server goes down, another can cover it) and testing and protecting against network vulnerabilities.

8. Public and third party information

8.1 Blogging
We have public blogs on our websites. Any information you include in a comment on our blog can be read, collected and used by anyone. If your personal information appears on our blogs and you wish to remove it, contact us at contact@bluspark.io. If we are unable to remove your information, we will let you know why.

8.2 Social media platforms and widgets
Our websites include social media features. These features may collect information about your IP address and the page you visit on our website, and they may set a cookie to ensure that the feature works properly. Social media features and widgets are hosted by a third party or hosted directly on our website. We also maintain presences on social media platforms including Facebook, Twitter and Instagram. Any information, communication or material you submit to us via a social media platform is done at your own risk. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with these features and platforms are governed by the privacy policies of the companies that provide them.

8.3 Links to third party websites
Our websites include links to other websites, whose privacy practices may differ from ours. If you submit personal information to any of these sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

9. Changes to this Privacy Policy
BluSpark may in its discretion update and modify its privacy policy at any time. When we do, the date of the updated documentation will be indicated at the top of this page. We encourage users to check this page frequently to stay informed about how we help protect the personal information we collect. You acknowledge and agree that it is your responsibility to review the changes.

10. Your acceptance of these terms
By using our Services, it means that you accept the Privacy Policy and the Terms of Use. If you do not agree with this policy, please do not use our Services. Your continued use of the Services following the posting of changes to this policy will be deemed your acceptance of those changes.

11. Contact Us – Data Protection Officer (DPO)
BluSpark has appointed Gabriel Poret, CTO, as our Data Protection Officer, in accordance with the requirements of the General Data Protection Regulation.
If you have any questions regarding this privacy and data processing policy please contact us at: contact@bluspark.io
All notifications should be sent to: BluSpark SAS, 17 rue Rodier, 75009 Paris, France (for updates go to: www.bluspark.io);

Cookies policy – BluSpark

This cookie policy describes how BluSpark uses cookies and similar technologies to provide, improve and protect the Services.

1. What is a cookie?
A cookie is a small text file sent to your browser when you visit a website. It serves a variety of functions, such as allowing us to remember certain information you provide to us as you navigate between pages on the Services. Each cookie expires after a certain period depending on what we use it for.

2. Why do we use cookies?
We use first-party and third-party cookies for several reasons. Some cookies are required for technical reasons so that our websites and services can function. Other cookies allow us and the third parties we work with to track and target the interests of visitors to our websites. For example, we use cookies to personalise the content and information we may send or display to you and to personalise your experience when interacting with our websites and to otherwise improve the functionality of the Services we provide. We also allow our Users to use cookies and similar tracking technologies in connection with their use of our Services to enable them to customize the experience they provide to their End Users using our Services. Finally, third parties distribute cookies through our websites and services for analytical and other purposes. This is described in more detail below.
The Services and our Websites use both first-party cookies (which are set by the Websites visited) and third-party cookies (which are set by a server located outside the domain of our Websites).

3. What cookies do we use?
3.1 Authentication, personalisation and security
These cookies are strictly necessary to provide you with the Services and services available through our Websites and to use some of their features, such as access to secure areas. Because these cookies are strictly necessary to deliver the Websites, you cannot refuse them without impacting the operation of our Websites. You can block or delete them by changing your browser settings, as described in the “How do I control cookies?

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3.2 Performance and analysis
These cookies help us analyse how the Services are accessed and used, and allow us to track the performance of the Services. For example, we use cookies to obtain information about the performance of your users and applications, such as page speed, or to help us customise our websites and services to improve your experience.

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4. Other Tracking Technologies
We and our third party partners may from time to time use other similar technologies, such as web beacons, pixels (or “clear gifs”) and other tracking technologies. These are tiny graphic files that contain a unique identifier that allows us to recognize when someone has visited our websites. This allows us, for example, to monitor user traffic patterns from page to page, to deliver or communicate with cookies, to learn whether you came to our websites from an online advertisement posted on a third party site, to improve site performance. Although you do not have the ability to specifically reject or disable these tracking technologies, in many cases these technologies depend on cookies to function properly; therefore, in such cases, declining cookies will interfere with the operation of these technologies.

We use device identifiers to track, analyse and improve performance and provide services. For example, when you send a targeted push notification to a subset of your end users

5. How do I manage cookies?
If you wish to delete or disable cookies via your browser, you can certainly do so. To do so, please refer to your browser’s configuration documentation, as the steps to follow are usually browser-specific. However, if you decide to delete or disable cookies, please be aware that this may have a negative impact on your ability to use our Services effectively. Enabling cookies ensures a smoother experience when using our Services.

6. Updates to the cookie policy
The Cookie Policy may be updated and revised from time to time to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please check this cookie policy regularly to stay informed about the use of cookies and related technologies. The date at the top of the document indicates when it was last updated.