Last Updated on May 29, 2020

Privacy Policy

This page highlights some of the key elements of our online privacy statement. Both this page and our online privacy statement apply to all online and mobile resources published by startonlinechallenge.com / Nexusspak, LLC, and/or Nexusspark.com, LLC (hereinafter referred to as “Nexusspark”). For more information, please read our complete online privacy statement with our Terms of Service.

Information Collected

There are two types of information that we obtain from you online and then store and use:

• non-personal information that’s collected automatically from each visitor, such as your device operating system; and

• personal information that you voluntarily provide to us or that is collected automatically.

Uses of Information

We use non-personal information to administer our online and mobile resources, make them better, and to make business decisions about what programs our customers might like.

We use voluntarily provided personal information to respond to your inquiries and provide you with the services you have requested, amongst other uses as further described below. We do not sell or rent your personal information to third party data vendors or marketing companies. As you might expect, we disclose your information when required by law.

Privacy Choices

You do not have to provide personal information to enjoy most of the features of our online and mobile resources. You also can opt out of certain activities like newsletters and announcements by using the unsubscribe link in the email or via the online and mobile resources. You can also access, amend, or delete the personal information we have collected about you by contacting us using the contact information listed in this privacy statement.

Notice of Privacy Rights

Certain of our business activities in California implicate obligations under the California Consumer Privacy Act. We comply with those obligations by, among other things, providing certain notices which you can learn more about these notices below.

Contacting Us

Questions about this highlights page or our online privacy statement may be sent to:

Attn: Legal & Compliance Department

6925 Oakland Mills Road, #527

Columbia, MD 21045

E-mail: sos@Nexusspark.com

Nexusspark, LLC ONLINE PRIVACY STATEMENT

Thank you for visiting our online and mobile resources, and for viewing this privacy statement. We use this statement to tell you about the types of information we collect when you visit any Nexusspark owned online and mobile resources that link to this statement. More specifically, this statement tells you:

• the types of information we collect and how we collect it;

• the ways in which we use, share, and protect that information;

• the choices you have in controlling the collection of your information; and

• your ability to access and update your information.

By using our online and mobile resources, you are signifying to us that you agree with this privacy statement and that we may use and disclose your information in the manner it describes. Although our online and mobile resources may contain links to other websites controlled by third parties, you should be aware that we are not responsible for the privacy practices of those, or any other, sites or online resources. If you have questions about how those sites collect and use data, you should carefully read their privacy policies.

This privacy statement is effective May 29, 2020.

Some Important Vocabulary

This privacy statement is a legal document, so clarity is important. We’ll use this section to let you know about some words that have special meanings whenever you see them in this statement. Let’s start with the word “statement” itself: when we reference “this statement”, “this privacy statement”, and “our statement”, we mean this Nexusspark online privacy statement you are reading now. Wherever we say “Nexusspark, LLC”, or “Nexusspark.com” or “we”, “us”, or “our”, we mean “Nexusspark”. We use the words “you” and “your” to mean you, the reader, and other visitors to our online and mobile resources who are, in all cases, over the age of 13. This age requirement is discussed in more detail later in this statement.

When we talk about our “online and mobile resources”, we mean all websites and other internet features we own that allow you to interact with our websites, as well apps we’ve created and distributed to let our customers and followers view our online and mobile resources or otherwise interact with the content we provide. Finally, when we refer to “personal information”, we generally mean information that can be used to identify you or that can be easily linked to you. Thus, a fairly comprehensive list of personal information would include such things as your name, address, telephone number, email address, social security number and date of birth. The privacy laws in some jurisdictions include unique elements in what they consider to be the personal information of the consumers or data subjects they protect. If those laws apply to us, as in the case of the California Consumer Privacy Act, our use of the phrase “personal information” includes the unique elements required by such laws. The English language version of this privacy statement is the controlling version regardless of any translation you may attempt.

What Information Are We Collecting and How Are We Using It?

Voluntarily Submitted Information

If you participate in certain activities via our online and mobile resources, you may be asked to provide us with information about yourself. The types of personal information we collect in those situations includes identifiers (such as your name, email address, physical address, and phone number), professional information (such as the business you are in), and financial account information (such as your credit card information).

For example, if you choose to send us an email or fill out an online form, you are voluntarily providing personal information to us. In doing so, you agree that we have a reasonable and lawful basis (such as to provide, maintain, and enhance the online and mobile resources and our product and service offerings, create reports on usage of the online and mobile resources, perform our contract obligations, inform our marketing efforts, comply with law, or satisfy our legitimate business interests) on which to collect, use, and disclose that information for the purpose it is requested and for other reasonable internal business purposes. We do not sell, rent, or trade voluntarily submitted personal information with third parties.

If you don’t want us to collect this type of personal information, please don’t provide it. This means you shouldn’t participate in the activities on our online and mobile resources that request or require it and you may want to communicate with us by phone or regular mail instead. Participation is strictly your choice. Not participating may limit your ability to take full advantage of the online and mobile resources, but it will not affect your ability to access certain information available to the general public on the online and mobile resources.

Here are some of the ways you voluntarily give us your personal information and how we use it:

Emails and Online Forms

When you send us an email or fill out an online form, such as to contact us, your email address and any other personal information (e.g., home address or phone number) that may be in the content of your message or attached to it, are retained by us and used to respond back directly to you and to process your request. Depending on the personal information provided, communications from us may be in the form of emails, telephone calls, and/or text messages. We may also send you information about any of our products or services we think may be of interest to you.

Registering for an Account

When you register for an account, you submit personal information to us such as your name and email address which we then retain. We use that information to create and manage your account and in some cases establish a password and profile to communicate with you via email.

Becoming a Subscriber to Our Service

If you formally become a customer of our product or service offerings, you will be required to enter into a subscription or other agreement. That agreement is separate from both this policy and our related website Terms of Use and will have its own terms and conditions governing confidentiality, data privacy and data security. As a result, those terms and not this statement will apply.

Automatically Collected Information

When you visit our online and mobile resources, basic information is passively collected through your web browser via use of tracking technologies, such as a “cookie” which is a small text file that is downloaded onto your computer or mobile device when you access the online and mobile resources. It allows us to recognize your computer or mobile device and store some information about your preferences or past actions. Additional information about cookies and tracking technologies is available here.

We allow third party vendors to use cookies or similar technologies to collect information about your browsing activities over time following your use of the site. For example, we use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how you use the online and mobile resources and enhance your experience when you visit the online and mobile resources.

For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/. You can learn more about how to opt out of Google Analytics by going to www.google.com/policies/privacy/partners/.

The internet activity information collected through cookies and other similar means includes such things as:

• the domain name and IP address from which you accessed our online and mobile resources;

• the type of browser and operating system you use;

• the date and time and length of your visit;

• the specific page visited, graphics viewed and any documents downloaded;

• the specific links to other sites you accessed from our online and mobile resources; and

• the specific links from other sites you used to access our online and mobile resources.

Additionally, if you access our online and mobile resources from a phone or other mobile device the mobile services provider may transmit to us uniquely identifiable mobile device information which allows us to then collect mobile phone numbers and associate them with the mobile device identification information. Some mobile phone vendors also operate systems that pinpoint the physical location of devices and we may receive this information as well if location services are enabled on your device. If you do not want us to collect and use information about your geographical location, disable location services through your device settings.

Regardless, we use both automatically collected information and mobile device information to compile generic reports about popular pages on our online and mobile resources, and to see how our customers and followers are accessing our online and mobile resources. We then use that data to administer the online and mobile resources and make them better, make your activities more convenient and efficient and to enhance the functionality of our online and mobile resources, such as by remembering certain of your information in order to save you time.

Do Not Track Disclosure

Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not specifically respond to browser “do not track” signals.

Sharing Information with Others: Who and Why

Third Parties

We may share your information, including personal information, with our vendors and other third parties with whom we have a contractual relationship. Examples of the categories of third parties with whom we share your information with and why include the vendors from whom we obtain technology and infrastructure services to host our online and mobile resources, perform credit card processing, API integration, and data analytics services. We may also share your information, including personal information, with vendors who provide third party software services that you have chosen to assist you with your sales funnels. We do our best to disclose only the information each of those parties need.

Affiliates

In addition to those third parties set forth above, we may share your information, including personal information, with our corporate affiliates who will use such information in the same way as we can under this privacy statement.

Legally Compelled Disclosures

We may disclose your information, including personal information, to government authorities, and to other third parties when compelled to do so by such government authorities, or at our discretion or otherwise as required or permitted by law, including but not limited to responding to court orders and subpoenas. We also may disclose such information when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the online and mobile resources, or anyone else that could be harmed by such activities.

Business Transfer

If Nexusspark or its affiliates, or substantially all of its or their assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation, or liquidation, personal information may be one of the transferred assets.

Choices You Can Make: Opt-Out and Account Changes

If we are using personal information you provided to us in order to enable us to send you materials, such as newsletters or product alerts via text or email], and you decide you don’t want to receive such materials, you may opt out by following the opt-out instructions in the email or other communication (e.g., by responding to the text with “STOP”), or by contacting us using the contact information below. When we receive your request, we will take reasonable steps to remove your name from our distribution lists. You need to understand it may take a period of time to remove your name from our lists after your request and due to such latency you may still receive materials for a period of time after you opt out. In addition to opting out, you have the ability to access, amend, and delete your personal information by contacting us using the contact information below.

Social Media

This section applies to everyone who interacts with our social media presence. You are therefore viewing this page because you either linked from the social media features on our online and mobile resources ( “Internal Social Media Features”) or from comment sections, feeds, and other elements of social media presence viewable on Facebook, Twitter, YouTube, LinkedIn, or any of the many other available external third party social media platforms we may utilize (“External Social Media Presence”). Social media platforms are places of public information exchange, and you should have no expectation of privacy when using them. Specifically, neither this statement nor our Terms of Use apply to our External Social Media Presence. The websites and platforms that host our External Social Media Presence are not controlled by us and therefore have their own privacy policies and terms of use. The comments and opinions expressed by users on social media are theirs alone and do not reflect the opinions of Nexusspark. Comments that some would consider inappropriate or offensive may appear on our Internal Social Media Features as well as our External Social Media Presence and may remain there until they have been identified by us or called to our attention and we are able to work through the necessary procedures and technical processes to have them removed. If you see an offensive or inappropriate post or comment on our External Social Media Presence, you should report it to the operator of the applicable website or platform using the procedures they have established for that purpose. If you see such a post on Internal Social Media Features, it should be reported directly to us via the contact information below.

Things Happen: We Do What We Can to Ensure Information Security

We will take all reasonable security precautions to protect your personal information provided to our online and mobile resources. We have adopted, implemented and maintained an enterprise-wide corporate information security program that includes technical, organizational, administrative, and other security measures designed to protect, in a manner consistent with accepted industry standards and applicable law, against anticipated or actual threats to the security of personal information (the “Security Program”). We cannot, however, guarantee that your information, whether during transmission or while stored on our systems or otherwise in our care, will be free from unauthorized access or that loss, misuse, destruction, or alteration will not occur. Except for our duty to maintain the Security Program under applicable law, we disclaim any other liability for any such theft or loss of, unauthorized access or damage to, or interception of any data or communications including personal information. You should also note that third party companies we engage to provide us with services either to help us in our business, or to perform functions we would otherwise perform ourselves, will have access to your information, including your personal information, as part of the work they perform. We require that they enter into confidentiality and such other agreements as required by the laws of certain jurisdictions but cannot guarantee their compliance.

User Age Requirements and Children’s Privacy

Federal law imposes special restrictions and obligations on commercial website operators who direct their operations toward, and collect and use information from, children under the age of 13. We take those age-related requirements very seriously, and consistent with it do not intend for our online and mobile resources to be used by children under the age of 18, and certainly not by anyone under the age of 13. Moreover, we do not knowingly collect personal information from minors under the age of 18. If we become aware that anyone under the age of 18 has submitted personal information to our online and mobile resources, we will delete that information and will not use it for any purpose whatsoever. If you believe that someone under the age of 18 has submitted personal information to our online and mobile resources, please contact us at sos@Nexusspark.com. We encourage parents and legal guardians to talk with their children about the potential risks of providing personal information over the Internet.

The California Consumer Privacy Act

When we collect personal information from California residents we become subject to, and those residents have rights under, the California Consumer Privacy Act or “CCPA”. This section of our statement is used to allow us to fulfill our CCPA obligations and explain your CCPA rights. For purposes of this section, the words “you” and “your” mean only such California residents.

What did we collect from California Residents?

We collected the following categories of personal information within the last 12 months:

• identifiers such as name, address, IP address, and other similar identifiers

• personal information described in subdivision (e) of Section 1798.80 (California customer records statute) such as a name, address, telephone number, credit card number

• commercial information such as products or services purchased

• internet/electronic activity such as browsing history and search history

• geolocation data including geographic coordinates/physical location

• audio, video, electronic or other similar information

We may have disclosed this information for one or more business purposes permitted by the CCPA. Please re-review this privacy statement to understand the scope of purposes and the sources from which we collect it. Similarly, we urge you to re-read the statement above where we describe the categories of third parties with which we may share your personal information and why. We do not sell, and within the last 12 months have not sold personal information to third parties.

Rights of California Residents

You have the following rights under the CCPA. It’s important to us that you know that if you exercise these rights, we will not “discriminate” against you by treating you differently from other California residents who use our sites and mobile resources or purchase our services but did not exercise their rights.

• Disclosure – the right to request that we disclose to you, specifically beyond the general statement immediately above, the categories and specific elements of personal information collected including the source of the information, our use of it and, if the information was disclosed or sold to third parties, the categories so disclosed or sold as well as the categories of third party who received or purchased it.

• Access – the right to receive a copy of the categories and specific elements of personal information we collected about you in the preceding 12 months.

• Delete – the right to request that we delete the personal information we collected about you under certain circumstances.

You can exercise these rights up to two different times every 12 months. To do so, just contact us at sos@Nexusspark.com. We may ask you to fill out a request form. The CCPA only allows us to act on your request if we can verify your identity or your authority to make the request so you will also need to follow our instructions for identity verification.

If you make a verifiable request per the above, we will confirm our receipt and respond in the time frames prescribed by the CCPA.

What if you Submit Information From Outside the United States?

We control and operate our online and mobile resources from within the United States of America (the “USA”). Personal information collected through our online and mobile resources may be stored and processed in the United States or any other country in which we or our affiliates or third-party vendors maintain facilities. Although we do not actively block or monitor visitors from other countries, the online and mobile resources, as well as our products and services, are directed principally at visitors and customers from the USA. To the best our knowledge, we do not engage in activities that subject us to the data protection and privacy laws of other jurisdictions, such as the General Data Protection Regulation (“GDPR”) under European law. We have, however, as described here, adopted and implemented a Security Program that, by its nature, is compliant with the material provisions of the GDPR and similar laws. We also commit to abiding by the Standard Contractual Clauses promulgated by the European Commission if we should find ourselves transferring personal information outside the group of jurisdictions known as the European Economic Area which currently includes the United Kingdom (the “EEA”). A company’s obligations under the GDPR are similar to our obligations under the CCPA. Likewise, the rights California residents have under the CCPA are very similar to the rights afforded EEA-based data subjects under the GDPR. As such, if you believe we collected personal information from you while you were in the EEA, we further commit to affording those rights to you as described here.

Changes to this Privacy Statement

We reserve the right to change or update this statement from time to time. Please check our online and mobile resources periodically for such changes since all information collected is subject to the statement in place at that time. Typically, we will indicate the effective/amendment date at the beginning of this statement. If we feel it is appropriate, or if the law requires, we’ll also provide a summary of changes we’ve made near the end of the new statement.

Contacting Us

If you have questions about our privacy statement or privacy practices, please contact us at:

Nexusspark, LLC

Attn: Legal & Compliance Department

6925 Oakland Mills Road, #527

Columbia, MD 21045

E-mail: sos@Nexusspark.com

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