Welcome

We’re glad you chose to visit a SPARK site! We care about your privacy and the information you share with us and want you to understand how we are using and protecting the information we collect about you. SPARK is respectful of data privacy and adopts best practice in compliance with applicable privacy law and regulations, including the EU General Data Protection Regulation (“GDPR”).

Use of this website

This privacy policy describes the information we collect from you and how it may be stored and processed in Singapore and across SPARK as described below.

This website, and associated SPARK events and publications provide products, content, and services for a professional and consumer audience and is not intended for individuals under the age of 13 years old. We do not knowingly collect or store personal data provided by anyone under 13 years of age.

If you are a European Union (EU) resident, please note that there are a number of provisions in this privacy policy that apply uniquely to you.

This Document Describes

1. What information we collect and how we collect it
2. How we safeguard your personal data
3. What we do with the personal data we collect
4. The legal basis we have for processing your personal data
5. When and how we share your personal data with others
6. How long we keep your personal data
7. Your rights and preferences
8. How can we help? Getting in touch
9. Feedback

SPARK collects data about you that is limited to the kind of information that can be found on a typical business card: first name, last name, job title, employer/company name, work address, work email, and work phone number. In some cases, we may ask you to provide additional professional information such as the size of the company you work for, and industry type.

To enhance and/or update the information that you have provided to us, we may combine it with professional information or personal data that we collect from third party sources. The personal data that we refer to in this document is the personal and professional information you provide, as well as information that we obtain from third party sources, both of which we typically combine as one user record.

This site also collects and stores certain information automatically using cookies and similar technologies, including IP addresses, the region or general location of a computer or device accessing the internet, browser type, operating system, page view history, and other usage information. See our Cookie Policy for further details.

However, to the extent that any cookie can uniquely identify a computer, mobile device, or tablet (“Device”), or the person using that Device, and you are a EU resident, under the GDPR, this is personal data. Therefore, this privacy policy shall apply to such personal data collected by SPARK.

1. How we collect your information

We may collect your personal data when you register to receive any of the products, content or services offered by SPARK or its third-party sponsors (“sponsors”) such as publications, subscriptions, contests, newsletters, memberships, premium content, webcasts, video, white papers, online seminars, conferences and events.

What happens if you don’t provide personal data?

In order for us to provide the products, content or services you request, we need your personal data. Therefore, if you do not provide such personal data, we cannot deliver the products, content or services.

This website is one of many that SPARK and its group of undertakings operates, all of which we collectively refer to as the SPARK. Where permitted by law, we may share the personal data we collect about you with another SPARK company so that we can provide you with information about products, content and services that might interest you, and for internal analytical and business development purposes.

2. How do we safeguard your personal data?

SPARK maintains safeguards which include technical and organisational security measures to protect your personal data from loss, misuse, unauthorised use, access, inadvertent disclosure, alteration, and destruction, and we require the third parties we contract with to support SPARK’s business operations to employ reasonable security measures as well (see “When and how we share your information with others” below).

1. Data security

We update and test security on an ongoing basis and restrict access to your personal data to only those who need to know in order to provide SPARK’s products, content or services to you.

1. Storage of your personal data

We may store your personal data using SPARK’s own secure on-site servers or secure public cloud service provider. Your personal data may also be stored by third parties, via cloud services or other technology, to whom SPARK has contracted with, to support SPARK’s business operations (see “When and how we share your information with others” below).

These third parties do not use or have access to your personal data other than for cloud storage and retrieval, and SPARK requires such parties to employ at least the same level of security that we use to protect your personal data (see “Security of your personal data” above).

3. What we do with the personal data we collect

We use the personal data that we collect to communicate with you, deliver what you request, improve our service, and to present other information and offers that may be of interest.

1. To communicate with you

We may use your personal data to send you important notices, such as communications about your registration, transactions, and changes to SPARK’s terms, conditions, policies, and/or other internal purposes.

1. To deliver what you request

We may use your personal data to provide the products, content or services you request. If you enter a sweepstake, contest, or similar SPARK promotion, we may use your personal data to administer such promotion.

• To improve our service

We may use your personal data for auditing, data analysis, and research to improve SPARK’s products, content and services.

1. To present offers that may be of interest to you

We may contact you to offer you additional SPARK or third-party products, content or services that may be of interest to you.

4. The legal basis we have for processing your personal data

The GDPR requires data collectors, such as SPARK, to have a legal basis to use the personal data of EU residents. Therefore, this section shall apply to any such personal data collected by SPARK.

SPARK uses the personal data that you provide to supply you with high-quality products, content and services as you request, to send important notices, and for internal purposes such as auditing, data analysis, and research to provide you with the information you need to make the most informed technology purchasing decisions.

We may also use your personal data to offer you products, content or services that may be of interest to you, based upon your interests or the preferences you shared with us, and may share your personal data with third party sponsors of content, events, and other services or offers.

The legal basis for processing your personal data is your consent. In certain circumstances we may otherwise process your personal data if SPARK has a legitimate interest in doing so and SPARK is not infringing any of your rights and freedoms.

When SPARK processes your personal data for SPARK’s legitimate interests, SPARK will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not override your interests. SPARK will not use your personal data in circumstances where your rights and freedoms override our legitimate interests, unless we have your consent or are otherwise required or permitted to by law.

5. When and how we share your personal data with others

SPARK may share your personal data to deliver content and services from our sites, affiliated companies and third parties services that might interest you, including sponsored content and events, for business operations, and to comply with valid legal processes.

If you are an EU resident, SPARK will only share your personal data with third parties outside of the SPARK, with your consent.

1. For content and services that may interest you or that you request

As we mention above, your personal data may be shared within the SPARK to provide you with information about products, content and services that might interest you and for internal analytical and business development purposes (see “SPARK” above). We may also share your personal data with third parties to deliver third party sponsored content or other services that you request (see “third party sponsored content and events” below).

1. For business operations

We may also share your personal data with third parties we have contracted with to support SPARK’s business operations including delivery, fulfilment, payment processing, email deployment, suppression list management and data processing.

• For third party sponsored content and events

CIOAA partners with third party sponsors to make available a large library of content to our users, such as white papers, professional events (live or online), as well as other services or offers. In return for access to such offers, we may ask you to provide us with personal data as part of the registration.

We may use your personal data to send you the offer you request. In addition, your personal data may be shared with the sponsor(s) of the offer to communicate with you regarding the offer, as well as additional products, content or services that may be of interest to you. Please note that once your personal data is shared with the sponsor, the sponsor’s privacy policy, including information on how to opt-out in the future, will apply to your personal data.

1. As required by law

Your personal data may be shared when authorised by law or necessary to comply with a valid legal process.

1. In the event of new ownership

If part or all the ownership of SPARK or any of its products or services are sold or transferred, your personal data will be transferred to the new owner.

1. International Data Transfers

This section shall apply to any personal data collected by SPARK from EU residents.

If SPARK shares your personal data within SPARK or with any other third party as described in this privacy policy and your personal data will be transferred to a State which is not a Member State of either the European Union or the EEA, or deemed adequate by the European Commission, SPARK (as a data controller/data exporter) will only conduct such transfer (to a data processor/data importer) if there are suitable safeguards in place, such as binding corporate rules, standard contractual clauses, approved Codes of Conduct, or approved certification mechanism. For more information, please contact SPARK’s Data Protection Officer (See contact details below).

6. How long we keep your personal data

We retain your personal data for the duration of your business relationship with us, and we hold your information only as long as necessary for each purpose we use it, unless we have obtained your consent to use for another or similar purpose.

7. Your rights and preferences

If you inform us that you want your personal data erased (if you are an EU resident), or that you no longer wish for us to communicate with you for marketing purposes, or to otherwise restrict SPARK’s processing of your personal data, we may retain some basic information in order to avoid sending you unwanted materials in the future, and to keep a record of your request and our response.

1. Confirming your personal data

This section shall apply to any personal data collected by SPARK from EU residents.

To confirm that SPARK is processing your personal data, or to access, update or correct the personal data SPARK holds about you, or to obtain a copy to reuse for your own purposes, please reach out to us at our contact information listed in section 8.

1. Erasing your personal data

This section shall apply to any personal data collected by SPARK from EU residents.

If you want your personal data erased, please reach out to us at our contact information listed in section 8.

• To opt-out of marketing communications

If you want SPARK to stop communicating with you for marketing purposes, please reach out to us at our contact information listed in section 8.

1. To restrict processing of your personal data

If you want to otherwise restrict SPARK’s processing of your personal data, please reach out to us at our contact information listed in section 8.

8. How can we help? Getting in touch

Questions, concerns or complaints:

If you have any questions, concerns or complaints about SPARK’s personal data practices or this Privacy Policy, we encourage you to get in touch with us, please send an email to: contactus@cioacademyasia.org

If you believe you have suffered harm due to a breach of your rights by SPARK under this Privacy Policy, and SPARK has not handled your complaint in a reasonably sufficient manner, any EU resident may also file a complaint with the applicable supervisory authority.

9. Feedback

Your feedback is important to us. We’d love to hear your ideas, opinions and comments about SPARK’s services. Please email: contactus@cioacademyasia.org

Last Updated: September 20, 2022