Privacy policy

1. Privacy Policy

We take the privacy of your data very seriously. By using our services, you have placed your trust in us, and we appreciate it. We make every effort to keep your personal data secure. We act in the interests of our customers and do not hide information about the processing of your personal data. In this document, we have tried to simply explain how we process your personal data. In addition, we will explain how you can contact us if you have any questions about your personal data. This Privacy Policy applies to all types of information that we collect through any platforms that allow it or through other channels associated with those platforms (for example, through electronic messages sent to our customer service). We may change the Privacy Policy from time to time. We encourage you to check this page regularly to keep up to date with the latest changes. If we make any changes to this Privacy Statement that directly affect you (for example, if we intend to process your personal data for purposes other than those previously stated in this Privacy Statement), we will notify you of such changes by the beginning of a new activity. If you do not agree with this Privacy Policy, please refrain from using our services. If you agree to our Privacy Policy, then we are ready to work with you.



2. What personal data does Sparkle Promo collect?

When you use our services, we ask you for certain information: your name, preferred contact details, payment details and other information. You can also specify additional information and wishes yourself. In addition, we collect some data from your computer, phone, tablet or other device that you use to access our site, such as your IP address, the type of browser you use and your language settings. There are situations when we receive information about you from third parties or collect other information automatically.



3. For what purposes Sparkle Promo collects and uses your personal data ?

First of all, we ask for your personal data to help you place an order and to offer additional services. We also use them to contact you or let you know about new discounts and special offers, and other products or services that we think you might be interested in. There are other cases.



4. How does Sparkle Promo share your data with third parties?

With the service sparklepromo.com in various ways and for various reasons are also connected third parties The main goal is to provide quality services and properly serve the client. Your data may also be received by other parties that we engage to provide sparklepromo.com services to you, for example: financial institutions, advertising companies, subsidiaries companies within Sparkle Promo and other persons affiliated with us, and in some cases government or other competent authorities, if required by law. We do not trade your personal data or give it for temporary use.



5. How is your personal data transferred to other companies within Sparkle Promo?

sparklepromo.com is a part of SPARKLE DESIGN LLC. Read information about how your data may be transferred to companies within SPARKLE DESIGN LLC in the appropriate section below.



6. How does Sparkle Promo process the messages you send to Sparkle Promo?

Sparkle Promo helps you share information with us. Information is exchanged through sparklepromo.com. Below you can read a more detailed description of how Sparkle Promo receives and processes such messages.



7. How does Sparkle Promo use mobile devices?

We release free mobile applications that collect and process your personal data in much the same way as our site. But the apps also allow you to use our location service. You can read a more detailed description below.



8. How does Sparkle Promo use social media?

To provide sparklepromo.com service in various ways social networks can be used. For this purpose, we may collect some of your personal data or share it with social networks. You can read a more detailed description below.



9. What security procedures does Sparkle Promo use to protect your personal data?

We implement appropriate security procedures to prevent unauthorized access to or misuse of the personal data we process. You can read a more detailed description below.



10. How does Sparkle Promo use children's personal data?

Unless otherwise specified, the service sparklepromo.com can only be used by persons aged 16 and over. We process information about children only with the consent of a parent or legal guardian, or when the information for processing is provided by a parent or legal representative. You can read a more detailed description below.



11. How you can control the personal data transferred to Sparkle Promo?

You can always use the right to find out what personal data we store about you. An overview of personal information can be obtained by sending a corresponding request to the email address indicated below. If you would like more information about your rights regarding the control of personal data, you can read a more detailed description below.



12. Who is responsible for processing personal data on the Sparkle Promo website ?

The company sparklepromo.com, which is part of LLC "SPARKLE DESIGN" and is based in Kyiv, Ukraine, controls the processing of personal data on its website. You can read a more detailed description below.



13. What type of personal data does sparklepromo.com collect?

Below you will find a more detailed description of the type of data we collect.



14. Personal data you provide to us.

sparklepromo.com collects and uses the data you provide to us. When you place an order from the feedback form on our site, you must (at a minimum) provide your name and email address. Depending on the type of order, we may also ask you to provide your address, telephone number, date of birth, names of founders working with you and any preferences you have (such as average annual turnover or any mobility restrictions) regarding the order.


We also collect your data in cases where you need to contact our customer service or contact us via other channels (for example, through social networks). Customers may also be asked to leave a review to help future guests find the right accommodation for them. We collect the information contained in your feedback, including your own nickname and avatar (if you set one).


There are other times when you provide us with data. For example, if you are viewing order options using a mobile device, you may choose to allow sparklepromo.com to see your current location or provide access to your contact information. information - this helps us provide you with the best level of service.


You may decide to participate in referral programs or sweepstakes - in this case, you will also provide us with personal data. In addition, you can send us feedback about the site and share your opinion or ask for help using our sparklepromo.com services.



15. Other people's personal data that you provide to us.

Of course, it may happen that you are not placing an order for yourself. You may be placing an order for another person whose details you provide for the order, or you may be placing an order on behalf of someone else. In some cases, you may use sparklepromo.com to share information with other users. This may occur by forwarding the address of pages for subsequent use or participation in referral programs, but such data may be used only as described in the proposed interface. You can check the details there if you want to know more.


In doing so, you need to ensure that the person or persons whose personal data you have provided are aware of this, understand and agree with how sparklepromo.com uses their data (as described in this Privacy Statement), as it is your responsibility.



16. Personal data we collect automatically.

Even if you have not placed an order (or have placed one), when you use our sites or applications, we automatically collect certain data. This includes your IP address, the date and time you used our services, information about your hardware and software, as well as the Internet browser you use, as well as information about your computer's operating system, such as the version applications and language settings. We also collect information about clicks and the pages you are shown.


If you use a mobile device, we also receive data that identifies your mobile device, device settings and characteristics, crashes in the program and other system operations. When you place an order, our system records from which sites you came to sparklepromo.com.



17. Personal data we receive from other sources.

In addition to the information you provide to us yourself, we may receive information about you from other sources. These include business partners, such as affiliate partners, subsidiaries of companies within sparklepromo.com and others affiliated with us, and as well as other independent third parties. Any data we receive from them may be combined with information provided by you.



18. For what purposes sparklepromo.com collects and uses your personal data?

We use the information we collect about you for various purposes. Your personal data can be used in the following way:


A. Ordering from the site: first of all, we use your personal data to place and process your order, which is an important element of the services we provide. This includes sending you order notifications, including order confirmations or changes, as well as related reminders.


Customer Support: Our office provides customer support from 11am to 3pm on official business days. When we have certain of your data, such as your order information or your account information, we help you work with us, our products, and other related matters.


B. Marketing: We use your profile information for marketing purposes, for example:


To periodically send news about travel products and services. You can unsubscribe from marketing e-mails quickly and at any time - just click on the "Unsubscribe" link, if there is one. On the site sparklepromo.com or on third-party sites (including social networks), you may see individual offers created based on the information you provide, while filling site displayed to you may also be personalized. If you participate in other promotions (such as sweepstakes, refer-a-friend programs or contests), the relevant information will be used to administer those promotions.


C. Communicating with you: We may contact you by post, email, telephone and text, in depending on the type of contact information you have shared with us. We also handle all inquiries you send us. There may be various reasons for this, for example:


If you use our services, we may send you a survey or ask you to leave feedback about sparklepromo.com. We also send you other materials related to your orders, such as information about how to contact sparklepromo.com, information that we believe may be informative.


D. Service Improvement: We also use personal data for analytical purposes. This is part of our work to improve the services offered to our users. The data may also be used for testing purposes, to solve problems and to improve the functionality and quality of our online travel services. We strive to optimize our platform so that it is user-friendly, meets their expectations, and is easy to use. We make every effort to use only depersonalized data for analytical purposes.


E. Call Tracking: When you call sparklepromo.com customer service, we use an automatic number identification system to identify your phone number - this will help save time for both you and us. However, our support staff may request other authentication information to help keep your order confidential. Conversations with our support staff may be listened to in real time or recorded for quality control and further training purposes, including for the use of recordings in handling claims and to prevent fraud. Not all calls are recorded and recordings are kept for a limited period of time and are automatically deleted unless sparklepromo.com deems it necessary to keep them for a longer period (as reasonably necessary), including for the purpose of investigating cases of fraud and for legal purposes.


F. Providing a reliable service: in order to create a reliable and safe environment for you, we use personal data to identify and prevent fraudulent activities and other illegal or undesirable activities. We also use personal data for risk assessment and security purposes, including user identification.


G. Market Research: We sometimes ask our users to participate in market research. If you receive an invitation to participate in such research, please read the relevant information to understand what personal data will be collected and how it will be used in the future.


H. Legal Purpose: In some cases, we may use your data to process and resolve legal disputes, to investigate upon request government authorities and regulatory compliance, as well as to ensure compliance with the conditions under which sparklepromo.com provides services or to comply with law enforcement requests.


Provision of your personal data sparklepromo.com is carried out on a voluntary basis. However, depending on the type of services you use, in some cases we will be able to provide you with services only after collecting certain personal data. For example, we will not be able to process your order if we do not receive information about your name and contact details.


In case we use automatic means for processing personal data that lead to any legal consequences or have a significant impact on you, we will take the necessary measures to protect your rights and freedoms, including the operator's right to intervene in the processing process.



19. To process information as described above, we rely on the following legal bases:

Taking into account the purposes specified in clauses A and B, sparklepromo.com relies on legal grounds that the use of your personal data is necessary for the performance of the contract, in particular, for the completion of your order and its management. If the required personal data is not provided, sparklepromo.com will not be able to complete your order or provide support. Taking into account the purposes specified in clauses C-H, Sparkle Promo relies on the implementation of its legitimate interests in conducting commercial activities to provide services, prevent fraudulent actions and improve services. When using personal data in the legitimate interests of sparklepromo.com or other third parties, your rights and legitimate interests in the protection of your personal data will prevail for sparklepromo.com before the rights and interests of sparklepromo.com or third parties persons For the purposes set out in clause H, sparklepromo.com relies, where applicable, on compliance with legal requirements (eg law enforcement requests). Where required by applicable law, sparklepromo.com will obtain your consent to use your personal data for direct marketing purposes.


If you wish to object to the use of your data for the purpose specified in clauses C-H and no opt-out mechanisms are directly available to you from data processing (for example, in the settings of your personal account), in which case, if necessary, you can contact us at spromo@sparkledesign.com.



20. How does sparklepromo.com transfer your data to third parties?

In certain circumstances, we transfer your personal data to third parties.


To our office "SPARKL DESIGN LLC: for the purpose of supporting service users sparklepromo.com your data may be transferred to subsidiaries of the SPARKLE DESIGN LLC group of companies that act as service providers for Sparkle Promo , including in matters of user support. To third-party organizations - service providers: we use service providers that are not part of the SPARKLE DESIGN LLC group to support services sparklepromo.com provides support services including: customer support, product and service development, including fraud screening services; marketing services. We share personal data with advertising partners, including your email address, as part of sparklepromo.com's marketing services through third parties (to provide relevant advertising messages of a relevant audience). We aim to transmit email address information only in encrypted form in order to correlate your email address with an existing customer base and to ensure that your email address cannot be used for other purposes. To get more detailed information about personalized advertising and options for your actions, read the section "How are cookies used?" and "What can you do?" in our Cookie Policy.


All service providers are required to take adequate measures to protect your personal data.


To competent authorities: we transfer personal data to law enforcement authorities to the extent required by law or strictly necessary to prevent , detecting or stopping criminal activity and fraud, or if we are otherwise legally required to share them. In addition, we may need to transfer personal data to competent authorities to protect our rights or property, as well as the rights and property of our business partners. To business partners: We work with many business partners around the world. These business partners distribute or promote sparklepromo.com services.


The transfer of personal data specified in this Privacy Policy may include the transfer of personal data to countries in which the legislation on protection of personal data is not as developed and extensive as in the countries of the European Union. In cases established by EU legislation, we are obliged to transfer personal data only to those recipients who provide an adequate level of protection. In such circumstances (if any), we conclude special agreements to ensure the protection of your personal data in accordance with European standards. If you need a copy of such agreements, you can request one by contacting the contacts below.



21. How your personal data is transferred to other companies within SPARKLE DESIGN LLC.

sparklepromo.com is part of SPARKLE DESIGN LLC.


We may receive your personal data from other companies within SPARKLE DESIGN LLC or share your data with these companies for the following purposes:

  • providing services;
  • providing customer support;
  • detection, prevention and investigation of fraudulent and other illegal actions, as well as data leaks;
  • analytics and product improvement;
  • providing you with personalized offers or sending you marketing materials with your consent or as otherwise permitted by law in cases;
  • compliance with applicable laws.

Unless otherwise specified, for purposes A-E sparklepromo.com proceeds from its legitimate interest to share and receive personal data. For Purpose F, sparklepromo.com relies, where applicable, on compliance with legal requirements (for example, when receiving requests from law enforcement agencies).



22. How does sparklepromo.com use mobile devices?

We offer free apps for various mobile devices, as well as special versions of our site optimized for viewing on phones and tablets. These applications and mobile sites process the personal data you provide in almost the same way as our site. They allow you to use the location feature so that you can find Services near you (if you want to). With your consent, we may send you push notifications with information about your order. You may provide us with access to your location and contact information in order to provide the services you have requested. When you download an image from your mobile device, location information may also be transmitted. Consult the manual of your mobile device to change the settings, to allow the transfer of said data or to send push notifications.


In order to optimize our services and marketing materials, we use the so-called tracking of user actions on different devices. Such tracking can be carried out both with the use of cookies and without them. More detailed information about cookies and other similar technologies is provided in the Cookie Policy. With cross-device tracking, sparklepromo.com can track user activity on the same device. In particular, the company sparklepromo.com may combine data collected from a particular browser or mobile device with data from another computer or device based on associated with the computer or device from which the data was obtained.


In order to optimize the content of the Sparkle Promo newsletter, the company sparklepromo.com combines the searches you've made from different computers and devices. You can unsubscribe from the sparklepromo.com newsletter at any time.


The content of personalized ads you see on other sites or apps may also be based on actions you take do on connected computers or devices. By changing the settings for the use of cookies on your device (see the "How can you adjust the use of cookies?" section of our Cookie Policy), you can change the settings for tracking your sessions across devices for advertising purposes. However, if you simply log out of your account, this does not mean that you will no longer receive personalized advertising.



23. How does sparklepromo.com use social media?

Company sparklepromo.com uses social media in a variety of ways. With their help, we promote our services, advertise products and services, and improve our own services. You may not use these social media services.


Social network modules. We have integrated social media plugins into the sparklepromo.com site and apps. When you click on one of the buttons (for example, "Like" from Facebook), certain information is transmitted to the provider of the social network. If you are currently logged into a social network account, the provider may associate these activities with your account and display them on your profile for other users.


Other social network services. We may implement other social media services (such as messengers) to interact with sparklepromo.com or your contacts regarding matters related to our services We may maintain our accounts and offer their applications on social networks. When you connect to sparklepromo.com, your social network provider may allow you to share information with sparklepromo.com. If you choose to do so, your ISP will likely tell you what information will be shared. For example, when you log into sparklepromo.com using a social network account, certain information (with your permission) may be shared with sparklepromo .com. This may include your email, your age, or a profile picture from your account.


If you are logged into a social network application from sparklepromo.com or connect a social network messenger without having a sparklepromo.com account, the information you may share with us may include basic information from your social network profile (including email, status updates and contact list). We use it to better provide you with the requested service. For example, to forward a message you want to send to your contacts, or to adapt our site to your needs. As a result, if you want, we can adapt our programs for you, help you and your friends find the best places to travel and improve our services. The social network provider will be able to tell you in more detail how it uses and processes your data when you connect to sparklepromo.com using that social network, e.g. , combining the personal data they receive when using the sparklepromo.com service through a social network with the information such providers receive when you use other online platforms associated with your social network provider.



24. How does sparklepromo.com protect and store your personal data?

We comply appropriate security procedures to prevent unauthorized access to and misuse of personal data.


We apply appropriate corporate systems and procedures to protect and protect personal data provided to us. We also use security procedures and apply technical and physical restrictions on the use of and access to personal data on our servers. Only employees who have special rights or have the right to access personal data in the course of performing their duties.


We store your personal data for such period as we consider necessary for you to be able to use our services, we may to provide our services to you, in compliance with applicable law, to resolve disputes with any parties, and for other purposes that enable us to conduct business, including the detection and prevention of fraudulent or other illegal activities. This Privacy Policy applies to all personal data recorded by us. If you have any questions regarding the specific storage period of a certain type of your personal data processed by us, you can contact us using the contacts indicated below.



25. How does sparklepromo.com process information about children?

Services offered by sparklepromo.com , not intended for children under 16 years of age. The use of any services offered by the company by children under the age of 16 is allowed only with the consent of a parent or guardian. In limited cases, when ordering services or in other exceptional cases, sparklepromo.com may collect and use information about children provided by parents, guardians or their consent If we become aware that sparklepromo.com is processing information about children under the age of 16 without the proper consent of a parent or guardian, we reserve the right to delete such information.



26. How can you control the personal data provided by sparklepromo.com?

We want you to control how we use your personal data. You can do this in the following ways:


You can ask us to review your personal data that we have at our disposal; you can notify us of any changes to your personal data or ask us to correct any information in the personal data held by us; in some cases, you can ask us to delete personal data, block or limit its processing, and also send an objection to specific ways of using your personal data; and in some cases you may contact us to send your personal data provided to us to third parties.


If we use your personal data based on your consent, you have the right to withdraw such consent at any time in accordance with applicable law. In addition, if we process your personal data based on legitimate or public interests, you have the right to object to such use of your personal data at any time in accordance with applicable law.


We rely on you for completeness, accuracy and correctness of personal data. Please contact us immediately in case of any changes or inaccuracies in your personal data.


Our site includes features that allow you to add, update, or delete information about you that we have in our possession.


If any of your personal data stored by us is not accessible through the Site or App, you may send requests relevant to us. If you have any questions about this Privacy Policy, about exercising your rights, or if you have any complaints, please contact us at spromo@sparkledesign.com. You can also contact your local data protection authority.


If you are against the processing of your personal data on the basis of legitimate interests and at the same time the mechanisms of refusal of data processing are not directly available to you, you you can contact us at spromo@sparkledesign.com.



27. Who is responsible for the processing of personal data on the site sparklepromo.com and how to contact us?

LLC "SPARK DESIGN" controls the processing of personal data in accordance with this Privacy Policy. LLC "SPARKL DESIGN" is a private company with limited liability, registered in accordance with the legislation of Ukraine, with an office at the address: Raisy Okipnoi Street, 4, Kyiv


02002 Kyiv, Ukraine


If you have any questions about this Privacy Policy or about the processing of your personal data, please contact our data protection officer at spromo@sparkledesign.com. For support, contact our support service.



28. Cookie document

When you use our online services, including applications, cookies and other tracking technologies may be used in various ways: for example, to support site sparklepromo.com, traffic analysis or advertising purposes. These technologies are either used directly by us or by our business partners, including third-party service providers and advertising platforms with whom we work. If you want to know more about cookies, their use and the limited possibilities of setting them, read the information below.



29. What is a cookie?

A cookie is a small piece of information that is transferred to the browser on your computer or mobile device. So-called "primary cookies" are transmitted through the organization's own domain. Cookies owned by sparklepromo.com are primary. If we allow other organizations to use cookies through sparklepromo.com sites and applications, these are called "third party cookies".


Session and permanent cookies are distinguished. Session cookies exist until you close your browser. Permanent cookies have a longer life cycle, they are not automatically deleted when the browser is closed. We aim to use or allow the use of cookies with a life cycle of no more than 5 years. A cookie can last longer only in exceptional cases, for example for security purposes, and only when absolutely necessary.


In addition to cookies, other similar tracking technologies are used. These may include, for example, web beacons (also known as pixel tags, web bugs or gifs) that track URLs or Software Development Kits (SDKs). A web beacon is a microscopic image as small as 1 pixel that arrives on your computer via an email in HTML format. We use these pixels to obtain information about your device: for example, device type, operating system, IP address and time of site visit. Web beacons can also be used to deliver and read cookies on your device. URL tracking is required to know from which site a user lands on sparklepromo.com. An SDK is a short code embedded in applications that functions in the same way as cookies and web beacons.


All technologies mentioned in this document collectively, we will call "cookies".



30. How are cookies used?

Cookies are used for various purposes. Thanks to them, you are recognized as the same user on different pages of the site, on different sites or when using the program. The information we collect through cookies includes: IP address, device identification number, pages viewed, browser type, browser search information, operating system, Internet service provider, click timestamp, whether you responded to an ad, the relevant URL, the functions used on the page or the actions taken.


Our site uses cookies for various purposes:


Technical cookies. We try to provide users with a modern and convenient site. For this, we use technical cookies that allow us to show you our site and ensure its proper operation. These technical cookies are strictly necessary for our website to run smoothly.


Functional cookies. We also use functional cookies to remember your preferences and help you use our site effectively. If you use the website sparklepromo.com to order services. We may also use such cookies to remember your login information, saving you from having to re-enter your username and password each time. At the same time, passwords will always be stored in encrypted form. These functional cookies are not strictly necessary for the operation of the site or the application, they add functionality for you as a user, making the site sparklepromo.com more convenient in use


Analytical cookies. We use these cookies to learn how sparklepromo.com users use the site. This helps us to understand what is working and what is not, to optimize and improve the site, to analyze the effectiveness of advertising campaigns and information materials and to make sure that the site remains interesting and useful for users. We collect information, including which pages you visited, which pages you navigated to and from which you left the site, what type of platform you used, which emails you opened and what they clicked on, the date and time use of the site.


This also means that we may use data about how you interact with the site, in particular the number of clicks on a page , mouse movements and scrolling, search words and other text you enter in various fields. When conducting advertising campaigns on the Internet, we use analytical cookies to learn how users interact with our site after they have seen an advertisement (including on third-party sites). We may also use analytical cookies so that our partners can learn whether their customers have taken advantage of the offers integrated on their sites.


Commercial cookies: We use third-party as well as first-party cookies to display advertisements on our site and other platforms. This practice is called "retargeting" and is based on the actions you take on the Internet, for example, your search history, browsing.



31. What can you do?

To learn more about how to work with or delete cookies, visit allaboutcookies.org and the Help section / "Help" of your browser. Through your browser settings (for example, Internet Explorer, Safari, Firefox, Chrome), you can choose which cookies to accept and which to reject. The location of the settings depends on which browser you use. To find the necessary settings, use the "Help" / "Help" function in your browser.


If you decide to refuse certain technical and / or functional cookies, you may not be able to access some features of our site. Currently, we do not support the "Do Not Track" function in the browser settings. If a common standard is developed in the future that defines exactly what is meant by "Do Not Track" signals in a browser, we will revise this Cookie Policy.


Advertising. We try to cooperate with those advertising and marketing companies that are members of the Network Advertising Initiative (NAI) association and / or the Interactive Advertising Bureau (IAB) organization. NAI and IAB members adhere to industry standards and a code of business ethics. NAI and IAB members offer a general opt-out setting for "behavioral" advertising. Visit www.networkadvertising.org to find out which NAI member has placed an advertising cookie on your computer.


To opt out of NAI member companies' "behavioral" advertising program, simply tick the relevant company. You can also visit www.youronlinechoices.com or www.youradchoices.com to learn how to opt out of personalized advertising. Your device may allow you to limit data transmission for retargeting purposes through its settings. Please note that opting out of receiving advertising from a particular provider does not mean that you will no longer receive online advertising or see online advertising and marketing analysis. Opting out means that the provider whose ads you opted out of will no longer serve ads based on your web preferences and site usage.


Analytics. To control the collection of data for analytical purposes by the Google Analytics service from certain types of browsers, visit the following page: Blocking Google Analytics (only available from a desktop computer). To control the collection of data for analytical purposes by the Yandex.Metrica service (a tracking pixel belonging to the Russian search resource Yandex), users who speak Russian, Ukrainian or Turkish can visit the following page: yandex.com. You can also opt out of personalized Yandex advertising. To do this, visit this page and remove the checkmark opposite the "Take into account my interests" field.


If you have any questions about this Cookie Policy, please send them to spromo@sparkledesign.com. This Cookie Policy is subject to change. Visit this page regularly to stay up to date with the latest updates.