SPARXO, INC.

Privacy Policy

Welcome to Sparxo, Inc. (“Sparxo,” ”we,” or “us”) Sparxo provides a social interactive platform. Our Privacy Policy explains how we collect, use, disclose, and protect information that applies to our Service, and your choices about the collection and use of your information. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms of Use [https://www.sparxo.com/terms-of-service-policy].

Click on the links below to jump to each section:

1. HOW WE COLLECT AND USE INFORMATION

Personally Identifiable Information: We collect information that can be used to identify you as an individual (Personally Identifiable Information) only when you provide such information directly to us in connection with the Service.

Types of Personally Identifiable Information you provide us directly: You aren’t required to provide us with any Personally Identifiable Information in order to use our Service, however, we may retain the contents of any messages you send to us or through the Service, and we may collect information you provide in User Content that you post to the Service. In addition, we may now or in the future allow Users to create accounts. If you choose to sign up for a User account, we may collect certain Personally Identifiable Information, including your username, first and last name, phone number, and e‐mail address. If you sign up for our e‐mail newsletter, we will collect your e‐mail address.

Personally Identifiable Information we may receive from third parties: We may now or in the future receive Personally Identifiable Information about you from third parties. For example, if you access our Service through a third‐party connection or log‐in, for example, through Facebook Connect, by “following,” “liking,” adding the Sparxo application, linking your account to the Sparxo service, etc., that third party may pass certain information about your use of its service to Sparxo. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that service, any information that you have permitted the

third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third‐party websites and services before linking or connecting them to the Sparxo Service.

Use of Personally Identifiable Information: We may use the Personally Identifiable Information we collect or receive to communicate directly with you. We may also send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your Personally Identifiable Information to send you Service‐related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). You may not opt out of Service‐related e‐mails.

Inviting a friend to use Sparxo: If you choose to use our invitation service to invite a third party to the Service, we will ask you for that person’s email address and automatically send an email invitation to the invitee. We store this information to send this email, to register the invitee if your invitation is accepted, and to track the success of our invitation service. Unless the invitee becomes a registered user of the Service, we do not use the invitee’ss email address for marketing purposes, and we do not share the invitee’s email address with third parties other than Sparxo’s service providers. The invitee may contact us at any time to request that we remove his or her information from our database at contact@sparxo.com.

Non‐Personally Identifiable Information: We also collect and use information about your interactions with the Service in a manner and format that does not identify you as an individual (“Non‐Personally Identifiable Information”). We may collect, use, and disclose the following types of No‐Personally Identifiable Information:

Analytics information. We use third‐party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser as part of a web page request, including the web pages you visit, your browser add‐ons, your browser’s width and height, and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.

Cookies information: When you visit the Service, we may send one or more cookies ‐ a small text file containing a string of alphanumeric characters ‐ to your computer that uniquely identifies your browser and lets Sparxo help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

Log file information: Log file information is automatically reported by your browser each time you access a web page. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you

interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

Clear gifs/web beacons information: When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our users anonymously.In addition, we may also use clear gifs in HTML‐based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information is allows for more accurate reporting and improvement of the Service.

Use of Non‐Personally Identifiable Information we collect: We use or may use cookies, log file, and clear gifs information to: (a) remember information so that you will not have to re‐enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) to provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems; (f) help you efficiently access your information after you sign in; and(g) to provide advertising to your browser.

2. SHARING OF YOUR INFORMATION

Personally Identifiable Information: We will not rent or sell your Personally Identifiable Information to third parties outside Sparxo and its controlled subsidiaries and affiliates without your consent, except as noted below:

Who we may share your Personally Identifiable Information with: We may share your Personally Identifiable Information with third‐party business partners for the purpose of providing the Service to you. Those business partners will be given limited access to the Personally Identifiable Information that is reasonably necessary to deliver the Service, and we will require that such third parties comply with this Privacy Policy.

Who you may choose to share your User Content with: Any Personally Identifiable Information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information.

What happens in the event of a change of control: We may buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personally Identifiable Information such as customer names and email addresses, User Content and other user information related to the Service will likely be among the items transferred in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.

Instances where we are required to share your Personally Identifiable Information: Sparxo will disclose Personally Identifiable Information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use at [https://www.sparxo.com/Privacy] or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Sparxo, our Users or others.

Non‐Personally Identifiable Information: We may share Non‐Personally Identifiable Information, including information obtained through tools such as cookies, log files, and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.): (i) in any manner permitted for Personally Identifiable Information; and (ii) with our third‐party business partners. We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

3. HOW WE STORE AND PROTECT YOUR INFORMATION

Storage and Processing: Personally Identifiable information collected through the Service may be stored and processed in the United States or any other country in which Sparxo or its subsidiaries, affiliates or service providers maintain facilities. Sparxo may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Sparxo or its subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of information about you, including Personally Identifiable Information, as described in this Privacy Policy.

Keeping your information safe: Sparxo cares about the security of your information, and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Service. However, Sparxo cannot ensure or warrant the security of any information you transmit to Sparxo or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of Sparxo’s distributors, such as social networks. Sparxo is not responsible for the functionality or security measures of any third party.

Compromise of information: In the event that any information under our control is compromised as a result of a breach of security, Sparxo will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

4. YOUR CHOICES ABOUT YOUR INFORMATION

Opting out of collection of Personally Identifiable Information: You may, of course, decline to submit any Personally Identifiable Information through the Service, in which case Sparxo may not be able to provide certain services to you.

Opting out of collection of Non‐Personally Identifiable Information: Please refer to your browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Note that disabling cookies on your browser prevents Sparxo or its business partners from tracking your browser’s activities in relation to the Service, and for use in targeted online advertising. However, doing so may disable many of the features available through the Service.

5. CHILDREN’S PRIVACY

Sparxo does not knowingly collect or solicit Personally Identifiable Information from anyone under the age of 13 or knowingly allow such persons to register as Users. The Service and its content are not directed at children under the age of 13. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at contact@sparxo.com.

6. OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third‐party websites or services. Your browsing and interaction on any third‐party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible and we do not control over any third‐parties that you authorize to access your User Content. If you are using a third‐party website or service (like Facebook) and you allow such a third‐ party access to you User Content you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service.

7. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at contact@sparxo.com.

8. CHANGES TO OUR PRIVACY POLICY

Sparxo may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy in a material manner we will update the “last modified” date at the bottom of this page.

This privacy policy was last modified on [July 10, 2013], and was first made effective on [March 25, 2012].