Privacy Policy
This privacy policy (referred hereafter as “Policy”) describes how Sparrow9 Consultancy (hereby represented as “we”, “us”, “our” or “Sparrow9”) collects, uses, protects and shares the personally identifiable information (referred as “Personal Information”) you (“User”, “you” or “your”) may provide during subscription or for buying any of its products or services (collectively, “Services”).
Sparrow9 is committed to protect the privacy of the personal data provided by visitors to the website for information purpose. This information or data is collected considering its importance and necessity in order to provide you with valuable and appropriate services.
Type of Information
Sparrow9 websites has different login, registration and contact forms placed throughout the website and requests users to provide contact and company information. We use this information to connect with you back and intent to serve you better.
Sparrow9 does not collect any personal information about you, if you are just a visitor to our websites, but to the limited extent – through IP address details and the use of cookies. On your enquiring about certain services offered on the website, you will be asked to furnish basic contact information online – about yourself and/or your Company. This will include name, phone number, email address, geographical location, the kind of services you are looking for, etc… Sparrow9 may log IP addresses and/or end systems information for improved web administration. This information is used for diagnostics, analysis, and for maintaining the integrity of our services.
You hereby recognize and understand that you are under no obligation to provide Sparrow9 with your personal information. Also, the information provided by you is with your full knowledge, consent and own decision. You also understand that we are under no obligation to verify the accuracy of information at source whomsoever it concerns and we assume that the information is provided by you with your full consensus, unless notified by you regarding the fallacy of a particular information. You also agree to provide correct information in the website forms, etc. to evade fraudulent activity. It must be made very clear here that providing information is not indispensable for the website visitors who do not require any specific services. You are requested to not use the websites if you do not agree to our Policy.
Use of Information
Sparrow9 assures that user information collected through the website is safe with us and will only be used for certain project purposes. We are committed to not distribute, sell or rent for any reason to a third-party. In the unlikely event that we choose to do so in the future with trustworthy external resources and government agencies, you will be notified by email about the same and given the opportunity to notify us not to share your personal information with any other external party.
Cookies
Website cookies help us track your navigation, and enable us to tailor our offerings to your requirements. Cookies, also enable us to store small amounts of information contained in your browser, which may be used on some areas of our Websites.
Third-party websites that are accessible from our websites via banner, click-throughs, links, or advertising may use Cookies. However, it is imperative for us to inform you that we have no access or control over such Cookies and thereby, do not accept responsibility with regards to their activity.
ADDITIONAL INFORMATION: COLLECTION OF DATA AND PROCESSING
Policy for Use of Facebook Custom Audiences
The website may use the re-marketing function of Facebook Inc. (“Facebook”), that is “Custom Audiences”. This allow the Site users to view interest-based advertisements (“Facebook ads”) on Facebook social networking sites or other websites that also use the process. We are thereby pursuing the interest of displaying advertisements that are of interest to you, so as to make our website more interesting and engaging for you.
Your browser automatically initiates a direct connection to the Facebook server based on the marketing tools used. So, on including Facebook Custom Audiences, Facebook receives the information that you have clicked on an advertisement from us or you have called up the corresponding website of our Internet presence. Moreover, if you are registered with a Facebook service, Facebook reserves the right to assign the visit to your account. This implies that even if you are not registered on Facebook or have not logged in, Facebook still makes it possible for the provider to find out your IP address and other identifiers and save them.
The deactivation of the “Facebook Custom Audiences” function is possible for logged-in users at https://www.facebook.com/settings/?tab=ads# (access 23.04.2018)
The legal basis for the processing of your data is Art. 6 para. 1 p. 1 lit. f GDPR. For detailed information regarding data processing on Facebook, please visit https://www.facebook.com/about/privacy (access 23.04.2018).
Policy for Use of Google Adwords
We may use Google Adwords services by means of advertising materials (so-called Google Adwords) on external websites to invite attention to our attractive offers. This allows us to gauge the success ratio of the individual advertising measures in comparison to the advertising campaign data. We thereby, follow your interest and display you the advertisements that is of interest to you, besides arranging our Website and make it more engaging for you, and also to reach a reasonable calculation of advertising costs.
These advertising media are brought to you via so-called “Ad Servers” by Google. We use Ad Server cookies to aid this purpose. This help to measure certain parameters for determining success, such as clicks by users or the insertion of ads. If you choose to make website access via a Google ad, a cookie is stored on your PC by Google Adwords, which usually lose their validity after 30 days. This cookie should not be used to identify you personally. So, what is usually stored as analysis values for this cookie are the:
- Unique cookie ID
- The frequency of ad impressions per placement
- Last impression (applicable for post-view conversions)
- Opt-out information (indicating the user’s choice to not being addressed and contacted)
These cookies help enable Google to identify your Internet browser. In the eventuality of a user visiting particular pages of an Adwords customer’s website and the cookie stored on his or her computer having not yet expired, the customer and Google can identify that the user had clicked on the ad and has been redirected to this page. A different cookie is assigned to every Adwords customer.
Cookies cannot be tracked via the Adwords customers websites. We would like to state that we ourselves do not collect and process any personal data in these advertising measures. Google just provides us with statistical evaluations, on the basis of which we can identify which of the advertising measures used are largely effective. The use of advertising media does not make us a beneficiary to receive any further data; specifically, we cannot identify the users based on this information.
Your browser automatically establishes a direct connection with Google’s server, based on the marketing tools used. Here, just by integrating AdWords Conversion, information is shared with Google about you having called up by clicking on an ad by us or for the corresponding part of our website. And in case you are registered with a Google service, you can be assigned the visit to your account by Google. Moreover, in spite of you not being registered with Google or not having logged in, your provider may be able to find out your IP address and save it.
Ways to Avoid Participation in this Tracking Procedure:
- By adjusting your browser software accordingly. Particularly, the suppression of third-party cookies refers to you not receiving ads from third party providers.
- By deactivating cookies for conversion tracking. This is done by setting your browser to block cookies from the “www.googleadservices.com” domain, https://www.google.de/settings/ads, This setting is deleted when you delete your cookies.
- By deactivating the interest-based ads of providers, which are part of the “About Ads” self-regulatory campaign via the http://www.aboutads.info/choices , This setting being deleted when you delete your cookies.
- By permanently deactivating Firefox, Internet Explorer or Google Chrome in your browsers at http://www.google.com/settings/ads/plugin (access 23.04.2018). We would like mention here that in this case you may not be able to use all functions of this offer in its entirety.
The legal basis for your data processing is art. 6 para. 1 p. 1 lit. f GDPR. You can find more information on data protection at Google here (access 23.04.2018): http://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/de.html. Alternatively, you can also visit the Network Advertising Initiative (NAI) website at http://www.networkadvertising.org. You can find that Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
Use of Google Analytics
This website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how your users are using the website. The data generated by the cookie regarding your website use is typically transferred to a Google server in the USA and stored there. However, on enabling IP anonymization on this website, Google will beforehand shorten your IP address within Member States of the EU or in other signatory states to the EEA Agreement. Only in exceptional cases will you find the full IP address is transferred to a Google server in the USA and shortened there. On behalf of the website operator, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide further services associated with the use of the website and the Internet to the website operator.
Please note that the IP address transmitted by your browser (within the scope of Google Analytics) will not be merged with other Google data.
You may refuse the use of cookies by selecting the appropriate settings on your browser software. However, we would like assert in this case that you may not be able to use the complete functionality of this website. You can also stop Google from collecting the data generated by the cookie and connecting it to your use of the website (including your IP address) and from processing this data by downloading and installing the “Google Analytics Opt-out Browser Add-on” available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en (access 23.04.2018).
We use Google Analytics to analyze and consistently improve the use friendliness of our website. We can use the statistics gained to improve our offer and make it more interesting for you as a user. In exceptional cases where personal data is transferred to the United States, Google has been subject to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework (access 23.04.2018). The legal basis for the use of Google Analytics is Art. 6 para. 1 sentence 1 lit. f GDPR.
Third party information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1)436 1001
Terms of Use (access 23.04.2018): http://www.google.com/analytics/terms/de.html, Privacy Statement: http://www.google.com/intl/de/analytics/learn/privacy.html, and the Privacy Policy: http://www.google.de/intl/de/policies/privacy.
System logs and maintenance
Sparrow9 and any of its third-party services, for the sake of operation and maintenance purposes, may collect files that record interaction with Sparrow9 (System logs) use other Personal Data (such as the IP Address).
Information not contained in this policy
For more details regarding the collection or processing of Personal Data, you may request further data from the Owner. Find the contact information at the end of this page.
How “Do Not Track” requests are handled
Sparrow9 does not support “Do Not Track” requests. To determine whether any of the third-party services it supports, uses “Do Not Track” requests; you are requested to read their privacy policies.
Choice to Opt-Out
Sparrow9 offers you the choice about the gathering and usage of your personally identifiable information. Again, considering it is not obligatory for you to provide any information in order to access and use our Websites, you may therefore choose to opt-out of providing any such information.
Further, once you provide information to the Sparrow9 Websites, you will have the option at any stage to unsubscribe from our mailing list by sending a simple email with the subject UNSUBSCRIBE. This way you can inform us that you no longer wish to receive future promotional or sales e-mail from us.
Security and Data Protection
Stringent, yet reasonably acceptable standards of technology and operational security has been implemented by Sparrow9 so as to protect personally identifiable information from loss, misuse, alteration or destruction. Sparrow9, as a company takes the minutest of precaution to protect your personal information. When you submit or view sensitive information via our Websites, your information is kept secure, both online and offline. All financial transactions and otherwise sensitive information are protected using 128-bit Secure Socket Layer (SSL) technology. The data resides behind a firewall, with access restricted to authorized Sparrow9 personnel only.
Information Technology Act, 2000
“Reasonable Security Practices” has been implemented by Sparrow9 as required by the Information Technology Act, 2000 rules including any amendment in the said Act and its rules. Also, by conforming with such provisions Sparrow9 guarantees proper care and control over its I.T. and Security operations under sections 43, 43A, 45 & Section 85 of I.T.Act, 2000 including related rules. Thus, you agree and acknowledge that Sparrow9 shall not be deemed responsible for any cybercrime activity relating to your data.
By using Sparrow9 Websites you agree and acknowledge that Sparrow9 shall not be held responsible for any uncontainable security attack and in such cases you agree that Sparrow9 shall not be held responsible for any type of legal, financial, opportunity, business (lost or profits) and reputation losses that may occur to you under the Provisions of Section 43, 43A and 45 of Information Technology Act, 2000 and including any amendments in the said Act.
You further agree that top management of Sparrow9 shall not be held responsible directly or indirectly for any cybercrime-related criminal liabilities under I.T. Act,2000 relating to your information. You also agree and acknowledge that Top management of Sparrow9 observes with due diligence requirements of I.T. Act,2000 including its rules and amendments.
External Links
Sparrow9 websites may have links to other websites and affiliates. Sparrow9 is not accountable for the content or the privacy of these affiliated websites or any other links that redirect user to external sites. Visitors to the Sparrow9 Websites are urged to familiarize themselves with those affiliate website’s respective Privacy Policies.
Unauthorized Used of Sparrow9 Brand by Unknown Infringers
It has come to our notice that multiple infringers are selling ICO (Initial Coin Offerings) on various platforms by using the brand name of (“Sparrow9 Consultancy”) and therefore, Sparrow9 is not responsible for any loss made by buyers. We strongly recommend to refrain dealing with third parties that may be selling digital properties like ICO, Cryptocurrencies who are using Sparrow9 brand without our knowledge and permission. We (“Sparrow9 Consultancy”) have not created any such virtual currencies or ICO and we are not associated with anything related to this. If you find anything related to this please contact us.
Policy Amendments
Sparrow9 reserves the right to amend these policies from time to time. We will update this page of the website whenever we make a change. We recommend you to revisit this page from periodically to ensure that you are aware of any changes made to these Policies. For any questions about privacy and similar issues, please contact us.
