Last updated: December 13, 2019
1. Personal Data We Collect
We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:
Personal Data Collected and Processed on Behalf of Our Clients:
Sparrow is a leave administrator platform that enables an employer (“Client”) to manage its employees’ leave administration (“Services”). The Services require an interactive process with an exchange of Personal Data and other information between the Client, its employees, its employees’ medical providers, and the appropriate state agency or insurance provider processing the employee’s leave claim. We endeavor to collect only that information necessary to the Service we provide and to share this information only with those that are necessary to the leave management process.
The Personal Data we collect may include, but is not limited to:
- Social Security Number
- Medical information
- Employment history
- Financial information of:
- Client for payment of Services
- Employee to facilitate payment during paid leave
Personal Data You Provide to Us: We collect Personal Data when you enter on the “Contact Us” page of our site. The Personal Data collected during these interactions may vary based on what you choose to share with us, but it will generally include:
- Company Name
Personal Data We Collect Through Our Social Media Pages: We have pages on social media sites like Instagram, Facebook, Medium, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
Personal Data We Receive Automatically From Your Use of the Service: When you visit, use and interact with the Service, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern.
In particular, the following information is created and automatically logged in our systems:
- Log data: Information that your browser automatically sends whenever you visit the Site (“log data”). Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
- Device information: This includes the name of the device, the operating system, and the browser you are using. Information collected may depend on the type of device you use and its settings.
- Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.
- Email Pixels: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
- Internet Explorer
- Mozilla Firefox
- Google Chrome
- Apple Safari
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
2. How We Use Your Personal Data
Sparrow may use Personal Data for the following purposes:
- To provide the Services for our Clients and its Employees;
- To give you the ability to participate in the interactive features of our Service when you choose to do so;
- To respond to your inquiries, comments, feedback or questions;
- To send administrative information to you, for example, information regarding the Service, and changes to our terms, conditions, and policies;
- To analyze how you interact with our Service;
- To maintain and improve the content and functionality of the Service;
- To develop new products and services;
- To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture and networks; and
- To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.
Marketing. If you opt in to our marketing, we may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us at firstname.lastname@example.org. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.
3. Sharing and Disclosure of Personal Data
In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:
- Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, event management services, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us.
- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.
4. Data Retention
5. Update Your Information
Please log in to your account or contact us at email@example.com if you need to change or correct your Personal Data.
6. California Privacy Rights Disclosures
No Third Party Marketing Disclosure
Sparrow will only disclose your Personal Data to parties necessary to the obligations of our Agreement with Client to provide our Services. Sparrow will not sell or knowingly share with third parties your Personal Data for marketing or other purposes outside the above obligations.
You may opt out of our Services at anytime by contacting us in writing.
You may also contact us in writing if you want to:
- Access and/or receive a copy of your personal data
- Rectify, erase, restrict, or withdraw the use of your personal data
These rights are not absolute and they do not always apply in all cases.
In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.
In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data.
Please understand that we try to request only that information necessary for us to fulfill our duties as a leave administrator for you. If you do not provide us with access to this necessary information, we may not be able to file or manage your leave process.
If you wish to exercise any of your rights above or have any concerns about how we use your data, please contact us at firstname.lastname@example.org
Our Service is not directed to children who are under the age of ## 13. Company does not knowingly collect Personal Data from children under the age of ## 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Company through the Service please contact us and we will endeavor to delete that information from our databases.
8. Links to Other Websites
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.
11. Contact Us