Spark Privacy Policy

Effective Date: January 1, 2019

Spark EMS Fitness respects your concerns about privacy and values its relationship with you. At the end of this page, you can find information regarding how to update your contact information, get answers to your questions or remove your name from our mailing list. 

This Privacy Policy applies to information collected by Spark EMS Fitness Inc. (“Spark” “we” or “us”), offline or online, including, but not limited to all websites and/or apps that post a link to this Privacy Policy (collectively, “the Sites”).

Spark’s Privacy Policy page will explain what type of information we collect, how it is processed, and the legal basis for the processing of the data collected. We will also explain how your information is used and shared. We take the protection of your information seriously and address how we protect on this page. By continuing to interact with our Sites, you are agreeing to this Privacy Policy.


This Privacy Policy will be updated periodically as needed. Sparks may modify this Privacy Policy at our sole discretion at any time. Changes that result in increasing our rights to use personal information will trigger a consent request. Changes that result in further processing of your personal data for purposes other than those collected for will be disclosed with you to ensure transparency prior to any further processing of your data.

Information Collected

We collect personal information including your name, address, telephone number, email address when you register with Spark. We also assess the data pertaining to your physical fitness progress towards your fitness goals and analyze this information to improve our services and study client progress overall.

Our Sites automatically collects information about the devices used to interact with our Sites. The information collected includes but is not limited to type of device, web browser, location, and/or IP address. Moreover, our Sites automatically collect information about how you use the Sites (e.g. site usage, pages viewed, etc.).  

Purposes & Legal Basis for Processing Information

The information we collect is used to:

  • Serve the functions of the Sites;
  • Manage business needs (e.g. approving training bookings, improving Sites, etc.);
  • Assess the Sites’ performance and functioning;
  • Assess how the Sites are used,
  • Perform market research;
  • Communicate our products and/or services;
  • Enhance interaction through our Sites with other consumers, including through social networking; and
  • Provide further notices, promotions, brochures, or other marketing materials regarding Spark’s Sites, products, and services. 

Spark processes this information where we have a legal basis to do so.  Spark processes client information based on the legal basis that:

  • You have provided consent to the use of your personal information as described herein;
  • You have provided consent that we contact you to fulfill a request you have made or to fulfill a contract; 
  • The processing is required for Spark’s legitimate interests as a business, for example, to better understand our client and our services offered. 

We may use your personal information to develop a personal profile about you.  We may use personal information in your profile to respond to your requests (e.g. personal training, meal plan, etc.). We do not collect any personal information about your online activities beyond our Sites.  

If you notify us that you do not wish to be contacted for marketing purposes, we will not send you marketing information. Spark may use your personal information as per below.

Newsletters/Other Communications.  We may offer online or offline newsletters and other communications about our products, services, and promotions. When you sign up to receive these communications, we ask you for personal information, such as your name, postal address and email address. We, or the authorized dealer in your area, will use the information to send you the communications you request and to communicate with you about our products and services.

Feedback/ Surveys/ Contests.  We may offer you the opportunity to participate in online surveys, solicitations, or contests. Information we request includes contact information (such as e-mail address) and demographic information (such as income ranges). Participation in surveys, solicitations, or contests is completely voluntary. Therefore, you have a choice as to whether to disclose any information. We will use the information provided to notify contest winners and award prizes, to monitor or improve the use of one or more websites or advertising, and to provide aggregated information for marketing analyses. Solicitations may take the form of an email. 

Certain information is collected automatically when you visit our Sites (e.g. pages visited, number of users, etc.). This information allows us to understand how we can improve our Sites to improve your experience.

Cookies. Cookies may be used to collect information regarding your experience (e.g. new visitor, returning visitor, etc.) which allow us to get a better understanding of visitor behavior and update our website to meet your needs. Cookies may also be used to enhance your online experience by saving your preferences on a specific website. If you wish to stop accepting new cookies, get notifications when new cookies are received or disable cookies, please visit your web browser’s website. Note that disabling cookies may affect your experience on our Sites. 

Web Beacons.  On our Sites, pages may contain “web beacons”  which are also known as Internet tags, pixel tags, and clear GIFs). The latter allows third parties to obtain information including but not limited to the IP address of the computer/device, the URL of the page having the beacon, time of access to the beacon, type of browser used to view page, and information in cookies set by the third party. 

IP Addresses. IP addresses are used by some electronics to identify and communicate with one another over the internet. By visiting our Sites, the IP address of the devices visiting our page are collected. This information allows us to get a better understanding of the geographic distribution of our website visitors and to enhance our Sites. 

Structural Changes in the Business

We reserve the right to disclose and transfer all information related to our Sites, including personal data to the subsequent owner(s), co-owner(s) and/or operator(s) of our Sites.

Privacy: Children Under 13

We do not collect any information from children under the age of 13 without parental consent. At any point, if we obtain knowledge that a child under the age of 13 has provided any information, we will remove such information as soon as possible. 

Shared Information

Spark may share your information with third parties that assist Spark’s functioning and/or provide services on our behalf (e.g. surveys, contests, etc.). The latter are not authorized to use nor disclose your information other than for the purposes for which they were provided. 

We may also disclose information about you to comply with applicable law, if law enforcement authorities or government officials require us or if we are required to by law and/or legal processes. We may also disclose your information as needed to prevent physical harm or if it is found in connection with illegal activities (suspected or otherwise). Spark may also disclose your data to enforce this Terms of Use, protect Spark’s property, services, and legal rights. We may disclose information to support auditing, compliance and corporate governance function.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets.

Links to Other Websites

Our Sites often provide links to other websites such as Instagram or Facebook for your convenience and information. Linked websites may have their own privacy notices or policies. Spark is not responsible for the content of any websites linked in our Sites that are not part of this website.

Third-Party Advertisements

Some third parties will collect information such as those pertaining to your online activities. The latter may provide Spark with information reporting, advertising response measurements, analytical information, search terms, etc. that we use in order to improve our services. All data collected by third parties is governed by the third party’s respective privacy policies. Spark encourages you to familiarize yourself with the third parties privacy policies.

Information Protection

Spark understands the importance of safeguarding your personal information. We have placed administrative, technical as well as physical safeguards to protect you against loss, misused, unauthorized access, disclosure, alteration and/or destruction of your information when using our Sites and our studios.

Access to Information

Please note that you have the right to request access to your personal information collected by Spark to review, modify or request it to be deleted. You may also ask for a copy of the information we have collected about you and request that we restrict or cease using your personal data as applicable.

You may ask Spark at any time to access this information, however, to protect your security we may take reasonable steps to perform identity verification. In that effect, we will notify you of any actions taken on your data as a result of a request submitted by you.

Note that you have the right to withdraw your consent at any time and to raise your any concern you may have that we are not able to address to the applicable regulator in your jurisdiction. 

Information Retained

Spark will retain all personal information as needed for the duration of the business relationship or in accordance with information management policies. When deleting personal information per your request Spark will take all reasonable steps to ensure such data is deleted in entirety. Spark will maintain documentation to reflect compliance with its obligations and to allow and/or participate in audits.

Contact Us

If you have any questions or comments about this Privacy Policy, please contact us via email at

If you would like to update your contact information or preferences please contact us at via email