Sparrow Finance Privacy Policy
Last Modified: November 16, 2023
The CryptoMom Global, Inc. dba Sparrow Finance ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website www.joinsparrow.co (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Table of Contents:
Information We Collect About You and How We Collect It
Choices About How We Use and Disclose Your Information
Accessing and Correcting Your Information
Data Security
Notice to California Residents
Changes to Our Privacy Policy
Contact Information
This Policy applies to our services, which include the services we provide on this Website, In email, text, and other electronic messages between you and this Website. Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website
It does not apply to information collected by us offline or through any other means, including on any other website operated by Company or any third party; or any third party application or content (including advertising) that may link to or be accessible from on the Website.
Age Limitations
The Company does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us at info@joinsparrow.co. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including:
Information you may provide to us: You may give us information about you by filling in forms on our Website or through our app or by corresponding with us by phone, email or otherwise. This includes information you provide when you register to use the services and when you report a problem with the Website or with our app.
Information we collect about you: With regard to each of your visits to our Website we automatically collect the following information:
Login Information: We log technical information about your use of the services, including the type of browser and version you use, the wallet identifier, the last access time of your wallet, the Internet Protocol (IP) address used to create the wallet and the most recent IP address used to access the wallet.
Device Information: We collect information about the device you use to access your account, including the hardware model, operating system and version, and unique device identifiers, but this information is not tied to any particular person.
Transaction Information: In connection with our services (as such term is defined in our User Agreement), we may collect and maintain information relating to transactions you effect using the Company’s Wallet (e.g. converting one virtual currency to another or purchasing virtual currencies).
Information We Collect Required By Law, Rule, or Regulation: Depending on the Service, we may collect information from you in order to meet regulatory obligations around know-your-customer (“KYC”) and anti-money laundering (“AML”) requirements. Information that we collect from you includes the following:
Full name
Residential address
Contact details (telephone number, email address)
Date and place of birth, gender, place of citizenship
Bank account information and/or credit card details
Your status as a politically exposed person
Source of funds & proof of address
Passport and/or national driver’s license or government-issued identification card to verify your identity
Transaction history and account balances in connection with your use of certain services.
Information We Collect from External Sources: We also receive information from other sources and combine that with the information we collect through our services.
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons. Pages of our the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Google Analytics. May use third parties, such as Google Analytics or other analytics providers, to analyze traffic to a Site. Google Analytics does not create individual profiles for visitors and only collects aggregate data. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google at http://www.google.com/intl/en/analytics/privacyoverview.html. You may find additional information about Google Analytics at http://www.google.com/policies/privacy/partners/. You have the option to opt out of Google’s use of cookies by changing your settings through Google Ad Settings via the Google advertising opt-out page at http://www.google.com/policies/technologies/ads/.
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
To present our Website and its contents to you;
To provide you with information, products, or services that you request from us;
Monitor and report compliance issues;
Comply with applicable laws and regulations;
Communicate with you about our services and business and to inform you of matters that are important for your account and/or use of the Website. We also use your personal data to respond to any questions, comments or requests you filed with us and the handling of any complaints;
Resolve disputes, collect fees, and troubleshoot problems;
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide though it.
To allow you to participate in interactive features on our Website.
For any other purpose with your consent.
We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.
We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
With Your Consent. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
To Comply With Our Legal Obligations. We may share your information: (A) to comply with laws; (B) to cooperate with government investigations, including when we are compelled to do so by a subpoena, court order, or similar legal procedure; (C) to comply with one or more forms of “travel rules” that require our transmitting of your information to another financial institution; (D) when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss; (E) to report suspected illegal activity; or (F) to investigate violations of our Terms of Use or any other applicable policies.
With Financial Institutions. We may share your information with financial institutions to process payments you have authorized.
During A Change To Our Business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of your information may be shared or transferred, subject to standard confidentiality arrangements.
Aggregated Or De-identified Data. We may share aggregated and/or anonymized data with others for their own uses.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile or by sending us an email with your request to info@joinsparrow.co.
Promotional Offers from the Company. If you do not wish to have your email address/contact information used by the Company to promote our own or third parties' products or services, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile or by sending us an email with your request to info@joinsparrow.co
We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
California residents may have additional personal information rights and choices. Please see notice to California residents for more information.
Accessing and Correcting Your Information
You can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an email at info@joinsparrow.co to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
California residents may have additional personal information rights and choices. Please see notice to California residents for more information.
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Notice to California Residents
We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide this CCPA notice (“CCPA Notice”) to California residents to explain how we collect, use, and share their personal information, and the rights and choices we offer California residents regarding our handling of their personal information. If you are a California resident, the following provisions apply to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the CCPA.
California Personal Information We Collect. We have collected the following categories of California personal information within the last 12 months:
We obtain the categories of personal information listed above from the following categories of sources: yourself, with respect to both online and offline interactions you may have with us or our service providers; other entities with whom you transact; others with whom you maintain relationships who may deal with us on your behalf; the devices you use to access our websites, and online services; identity verification and fraud prevention services; marketing and analytics providers; public databases; social media platforms; and others consistent with this CCPA section.
For each of these categories, we may disclose personal information with a variety of third parties. These third parties include: service providers; marketing and advertising providers; analytics providers; law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other applicable legal process or requirement; and merchants in cases of suspected fraud or in connection with an ongoing investigation
Disclosure of Personal Information. We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company has not disclosed personal information for a business purpose to the categories of third parties indicated in the chart above.
Use of Personal Information. For each of the above categories, we use the California personal information we collect for the business purposes disclosed within this section. The business purposes for which we may use your information include:
Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
Debugging to identify and repair errors in our systems;
Short-term, transient use including contextual customization of ads or website;
Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
Conducting internal research to develop and demonstrate technology; and
Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide
Your Rights. If you are a California resident, you have certain rights related to your California personal information. You may exercise these rights free of charge except as otherwise permitted under applicable law. If you wish to submit a request under the CCPA, please do so by writing to info@joinsparrow.co.
As required under applicable law, we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide information to verify your identity in response to exercising requests of the above type, including name and account information. We may limit our response to your exercise of the below rights as permitted under applicable law.
Right to Access/Know. You have the right to request that we disclose to you:
the categories of California personal information we have collected about you
the categories of sources from which the California personal information is collected;
our business or commercial purpose for collecting or selling California personal information;
the categories of third parties with whom we share California personal information; and
the specific pieces of information we have collected about you.
To the extent that we sell your California personal information within the meaning of the California Consumer Privacy Act or disclose such information for a business purpose, you may request that we disclose to you:
the categories of California personal information that we have collected about you;
the categories of California personal information about you that we have sold within the meaning of the California Consumer Privacy Act and the categories of third parties to whom the California personal information was sold, by category or categories of personal information for each third party to whom the California personal information was sold; and
the categories of California personal information about you that we disclosed for a business purpose
Right to Delete. You have the right to request that we delete California personal information about you which we have collected from you.
Right to Opt-Out and Right to Opt-In. You have the right to direct us to not sell your personal information at any time (the “right to opt-out”) by managing your cookie preferences by contacting us at info@joinsparrow.co.
Non-Discrimination. Subject to applicable law, we may not discriminate against you because of your exercise of any of the above rights, or any other rights under the California Consumer Privacy Act, including by:
Denying you goods or services;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing you a different level or quality of goods or services; or
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Policy
We may amend this Notice at any time by posting a revised version on our website. The revised version will be effective at the time we post it. You are responsible for periodically reviewing this policy.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at:
info@joinsparrow.co