Privacy Policy

Publication Date: April 2018
Version 1.2

Privacy Policy General The following terminology applies to all clauses laid out below:

  • 'Sparkline' 'Company’, 'Ourselves', ‘We' and 'Us' refers to Sparkline Pte. Ltd., its affiliates and associated companies.
  • 'Customer', 'You', ’Your' refers to you, the person accessing this Website and/or using Sparkline’s products or services.
  • 'Party', 'Parties' or 'Us' refers to both the Customer and the Company, or the Customer or Ourselves.
  • Personal data’ means data, whether true or not, about a Customer who can be identified: (a) from that data; or (b) from that data and other information to which We have or are likely to have access.
  • Website’, ‘Site’ and ‘Web Properties’ refer to the Sparkline corporate and Sparkline product Websites located at We are committed to protecting and respecting Your privacy.This policy (together with our Terms of Use (if applicable) and any other documents referred to on it) sets out the basis on which We may collect, use and/or disclose Your personal data. Please read the following carefully to understand Our policies and practices regarding Your personal data and how We will treat it. By visiting our Website and/or purchasing any of Our products or services, You are accepting and consenting to the practices described in this policy.

Please note that this Privacy Policy complements, and does not limit or replace, the purposes for which You provide Us with Your personal data which may be expressly stated in any agreement You have with Us. We have appointed a Data Protection Officer to oversee Our compliance with the Personal Data Protection Act 2012 (the Act). Should You have any query, request or feedback relating to your Personal Data, please contact Us via the details set out below.


We may collect and process the following personal and non-personal data:

DATA You give Us.
You may give Us data by filling in forms on Our Sites or by corresponding with Us by phone, e-mail or otherwise. This includes data You provide when You register to purchase one of Our products (either from Us or through Our resellers), use Our products (whether purchased from Us or through Our resellers), or use Our Sites, subscribe to Our Sites, search for a product, participate in discussion boards or other social media functions on Our Sites, enter a competition, promotion or survey, and when You report a problem with Our Sites. The data You give Us may include Your name, address, e-mail address, name and address of Your employer and phone number, social media profile information and credit card information. If We provide You with reseller or consultancy services, We may, in the course of providing You with these services, obtain information from You including non-anonymised data residing in customer right management systems, login IDs and device IDs. If You have purchased Our Sparkline Auditor and/or Sparkline Insight products (either from us or through our resellers), We may from time to time request that You provide Us with report scores and recommendations to assist Us in improving our product performance.Where You have signed up for Our courses or Our Academy, the data You give Us may also include the course(s) You sign up for, the answers submitted in response to course-related tests, the scores achieved on those tests and any community contributions that You may make in relation to those courses or Our Academy.

Information We collect about You.
With regard to each of Your visits to Our Sites We may automatically collect the following data:

  • Technical information, including the Internet protocol (IP) address used to connect Your computer to the Internet, Your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, mobile device ID (where applicable)
  • Information about Your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our Sites (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), and methods used to browse away from the page

Data we receive from other sources.
We may receive data about You if You have consented to Us receiving that data in the course of visiting any of the other Websites We operate. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers) and may receive information about You from them if You have consented to them providing that information to Us. If You have provided personal data of individuals other than Yourself to Us, You also confirm that You have sought the requisite consent from these individuals to the collection, use and disclosure of their personal data. In particular, You confirm that You have informed these individuals of the purposes for the collection, use and disclosure of their personal data as set out in this Privacy Policy.


Our Websites use cookies to distinguish You from other users of Our Websites. This helps Us to provide You with a good experience when You browse our Websites and also allows Us to improve our Websites.


We may collect, use and/or disclose Your data (including personal data), whether given by You, collected from You or obtained from other sources, for the purposes set out below: To carry out Our obligations arising from any contracts entered into between You and Us and to provide You with the information, products and services that You request from Us; To assist You in using and operating Our products; To provide You, or permit selected third parties to provide You, with information about goods or services that You have consented to receive. If You are an existing customer, We will only contact You by electronic means (e-mail, telephone or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to You. If You are a new customer, and where You have consented to Us allowing selected third parties to use Your data, We (or they) will contact You by electronic means only if You have consented to this. If You do not want Us to use Your data in this way, or to pass Your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which We collect Your data; For statistical analysis; To improve the products and services that We provide to You; For evaluative purposes; For administrative and operational purposes; To carry out billing, accounting, auditing and the maintenance of proper book-keeping to explain Our operations and business;  To Administer Our Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;  To improve Our Sites to ensure that content is presented in the most effective manner for You and for Your computer;  To allow You to participate in interactive features of the services on our Sites, when You choose to do so, as part of our efforts to keep Our Sites safe and secure;
To measure or understand the effectiveness of advertising We deliver to You and others, and to deliver relevant advertising to You; and
To make suggestions and recommendations to You and other users of our Sites about goods or services that may interest You or them. In addition to the above, We may use your data for any other purposes which have been notified to You, and which You have consented to, on or before You provided the data. Please be assured that We will not use Your information for any of the purposes if You have indicated that You do not consent to Us using Your information in this way when submitting the information, or if you withdraw consent at a later stage.


We may share Your personal information with any member of Our group, which means Our subsidiaries, Our ultimate holding Company and its subsidiaries. We may disclose Your personal data to third parties:
n the event that We sell or buy any business or assets, in which case We may disclose Your personal data to the prospective seller or buyer of such business or assets to the extent permitted under the Act.If We are under a duty to disclose or share Your personal data in order to comply with any obligation under any written law, or if the disclosure of Your personal data is necessary for any investigations or proceedings, or if the disclosure is necessary to respond to an emergency that threatens the life, health or safety of an individual. The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).


To safeguard Your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, We have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by Us, and disclosing personal data both internally and to Our authorised third party service providers and agents only on a need to know basis. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, We strive to protect the security of Your information and are constantly reviewing and enhancing Our information security measures.


The consent that You provide for the collection, use and disclosure of Your personal data will remain valid until such time that it is withdrawn by You in writing. You may withdraw consent and request Us to stop using and/or disclosing Your personal data for any or all of the purposes listed above by submitting Your request in writing or via email to Us via the contact details provided below. Please note that withdrawing consent does not affect Our right to continue to collect, use and disclose Your personal data where such collection, use and disclosure without consent is permitted or required under applicable laws. You have the right to ask Us not to process Your personal data for marketing purposes. We will inform You and seek Your consent before collecting Your data if We intend to use Your data for such purposes or if We intend to disclose Your information to any third party for such purposes. You can exercise Your right to prevent such processing by checking certain boxes on the forms We use to collect Your data. You can also exercise the right at any time by contacting Us via the details set out below. Our Sites may, from time to time, contain links to and from the websites of Our partner networks, advertisers and affiliates. If You follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. Please check these policies before You submit any personal data to these websites.


The Act gives You the right to access and correct Your personal data that is in Our possession or under Our control.  If You wish to make

  • an access request for access to a copy of Your personal data which We hold about You or information about the ways in which We use or disclose Your personal data, or
  • a correction request to correct or update any of Your personal data which We hold about You, You may submit your request in writing or via the contact details provided below.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. Where You have requested that We correct an error or omission in Your personal data which we hold about You, We will correct such data as soon as practicable and send the corrected personal data to every organisation to which the personal data was sent before it had been corrected, unless that organisation does not need the corrected personal data for any legal or business purpose. Please also note that We may choose not to provide You with access to or correct Your personal data, in accordance with the exceptions under the Act.


We will take reasonable steps to ensure that the personal data We collect, use or disclose is current, complete and accurate. Please update us if there are changes to Your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.


We may retain Your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.We will cease to retain Your personal data or remove the means by which the data can be associated with You, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or business purposes.


If We transfer your personal data to a country or territory outside Singapore, We will take steps to ensure that Your personal data so transferred continues to receive a standard of protection that is at least comparable to that provided under the Act.


This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of Your personal data by Us. We may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of Our Websites, products and/or services constitutes Your acknowledgement and acceptance of such changes. Please check back frequently to see if Our Privacy Policy has been updated or changed.


If You have any questions, comments and requests regarding this Privacy Policy or wish to make any applications concerning your personal data, please contact Our Data Protection Officer via post at -
Sparkline Pte Ltd, 36 Robinson Rd, Singapore 068877 or via email at