Privacy Policy
Sparks Affiliates LLC
Effective Date: May 1, 2026
ABOUT THIS POLICY
Sparks Affiliates LLC (“Sparks Affiliates,” “we,” or “us”) is a marketing agency and limited liability company formed under the laws of Montana, United States. We operate https://sparkaffiliates.io and provide email marketing services, affiliate program management, and performance-based marketing campaigns on behalf of our clients and commercial partners. Individuals who receive our emails or engage with our marketing programs are referred to in this Policy as “Associates.”
This Privacy Policy describes how we handle personal data in connection with our marketing operations — what we gather, why we use it, who we share it with, and what rights you hold. It applies to every Associate on our mailing lists, every person who visits our website, and anyone who contacts us directly.
Our Terms & Conditions set out the rules governing your relationship with Sparks Affiliates and define key terms — including “Protected Persons” and “Program” — that appear in both documents. Where the two documents address the same matter, the Terms & Conditions govern.
Our data practices reflect the requirements of applicable U.S. federal and state privacy law and, where independently triggered by law, relevant international frameworks. Using our website or receiving our emails signals your acceptance of the practices described here.
WHO CONTROLS YOUR DATA
The entity responsible for decisions about your personal data is:
Sparks Affiliates LLC
848 Main St Ste 10
Billings, Montana, 59105
Email: contact@sparkaffiliates.io
Website: https://sparkaffiliates.io
All privacy inquiries, rights requests, and opt-out submissions should go to contact@sparkaffiliates.io. We aim to acknowledge requests within five (5) business days.
AGE RESTRICTIONS
Our Program is for adults only. No person under eighteen (18) years of age may subscribe, receive our emails, or submit personal data to us in any form.
We handle data from children under thirteen (13) with particular care, consistent with the Children’s Online Privacy Protection Act (COPPA), 15 U.S.C. §§ 6501–6506. If we learn that a child under thirteen has provided personal data to us, we will delete it without delay. To flag a potential COPPA concern, write to contact@sparkaffiliates.io.
DATA WE COLLECT
— What you give us directly. When you subscribe through a web form, respond to one of our emails, or write to us, you provide personal data — typically your name, email address, and any additional detail you include. We use only what you choose to share.
— What our systems record automatically. Every time one of our emails is delivered or our website is accessed, our infrastructure captures technical data. This includes your IP address and the geographic region it suggests, device type and browser version, which emails were opened and when, which links were clicked, and website session data. Email tracking pixels — small images embedded in each send — generate some of this data. Disabling automatic image loading in your email client will prevent pixel-based tracking.
— What we receive from acquisition sources. A portion of our Associate list comes from third-party sources — co-registration programs, lead exchanges, and list acquisition partners. Before any externally sourced contact enters an active campaign, we require our sources to confirm in writing that each individual gave express consent for commercial emails of the type we send. We run suppression-file checks against every incoming batch prior to deployment. Where documented consent is absent, we do not send.
— What we do not collect. We have no use for national ID numbers, payment credentials, biometric identifiers, precise GPS coordinates, or protected health information. If any such data reaches us incidentally, we will use it only to address the matter at hand and will not retain it.
WHY WE PROCESS YOUR DATA
— Running the Program. The primary use of your email address is delivering the marketing emails you signed up for — promotional offers, sponsored messages, and content from our clients and affiliate partners. Every commercial email carries an identification of the sender and a working unsubscribe link.
— List hygiene and deliverability. We track engagement signals at the list level — open rates, click rates, unsubscribe rates, and bounce counts — to keep our sending infrastructure healthy and our lists accurate. This data is used operationally and does not serve to build individual behavioral profiles beyond email delivery.
— Client and partner attribution. When an Associate clicks a sponsored or affiliate link and completes a qualifying action, we pass a confirmation signal to the relevant client or partner. Attribution data is limited to what is necessary to verify the conversion — typically a click ID, a timestamp, and the event type.
— Security and legal obligations. We may process data to investigate suspicious activity, protect our sending infrastructure, enforce our agreements, and comply with applicable law.
— Legal grounds under international frameworks. For Associates located in the European Economic Area, United Kingdom, or Switzerland, our processing rests on: consent as the primary ground for marketing emails; legitimate interests for list hygiene, fraud detection, and security, where proportionate; and legal obligation where required by law. Consent may be withdrawn at any time — see the Opt-Out section below.
ARTIFICIAL INTELLIGENCE IN CONTENT
We may use AI-assisted drafting tools, including large language models, to help prepare marketing content. All materials go through a human review before being sent. AI-generated content may nonetheless contain errors or outdated information. Nothing in our emails constitutes professional advice of any kind.
CLIENT RELATIONSHIPS AND AFFILIATE ARRANGEMENTS
— How we earn revenue. Sparks Affiliates earns revenue by providing email marketing services to clients and by participating in affiliate marketing programs. We receive compensation when Associates click sponsored links or complete qualifying actions such as registering for a product, filling out a form, or making a purchase. Compensation formats include cost-per-click, cost-per-acquisition, revenue-share, and fixed-fee arrangements. This paragraph, combined with per-email disclosures placed at the point of each commercial placement, satisfies our standing disclosure obligation under 16 C.F.R. Part 255.
— Partner vetting. We review every client and affiliate partner before placing their offers into our Program. We apply additional scrutiny to partners operating in regulated categories. We will not promote products we have reason to believe are deceptive, unsafe, or unsuitable for a general audience.
— What compensation means — and what it does not. A payment arrangement with a partner confirms only that they compensate us for placement. It does not signify our endorsement of their product, a warranty of quality, or a suitability assessment for any individual Associate. For how attribution data flows to clients and partners, see the Data Sharing section below.
EMAIL PROGRAM AND OPT-OUT RIGHTS
— CAN-SPAM compliance. Every commercial email we send is structured to meet the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (CAN-SPAM Act, 15 U.S.C. § 7701 et seq.). Each message identifies us as the sender, includes a physical mailing address, uses an honest subject line, and contains a working unsubscribe mechanism. We process opt-out requests within ten (10) business days.
Your full consent rights, the scope of our email Program, and mobile messaging terms are set out in Section [E] of our Terms & Conditions.
— How to stop our emails. Click the unsubscribe link in any email or write to contact@sparkaffiliates.io. Once actioned, your address moves to our suppression file — a permanent record kept solely to prevent re-contact as our lists are refreshed from external sources. Suppression file entries are not used for any marketing purpose.
— Mobile messages. If we send text messages to a mobile number you have provided, we will first obtain your prior express written consent as required by the Telephone Consumer Protection Act (47 U.S.C. § 227). Reply STOP to any text message to opt out. Text opt-outs do not affect email delivery, and vice versa.
— Canadian Associates. Where Canada’s Anti-Spam Legislation (CASL) governs a message we send, we rely on the express or implied consent recorded at the time your contact information was collected. The right to withdraw consent described above applies equally under CASL.
COOKIES AND TRACKING TECHNOLOGIES
— Website cookies. Our website uses first-party and third-party cookies for session management, traffic analytics, and advertising attribution. You may manage cookie preferences through your browser; blocking certain cookies may affect website functionality.
— Email pixels. Each email we send contains a tracking pixel that tells us whether the message was opened and on what device type. Click events on links within our emails are also logged. This data informs our send-performance analysis and deliverability management.
— Third-party tools. Analytics and advertising vendors we integrate may deploy their own tracking mechanisms. We do not govern those vendors’ independent data practices. Reviewing the privacy documentation of any third-party tool you encounter is advisable.
— Do Not Track. No technically agreed standard exists for Do Not Track browser signals. Our services do not currently alter their data practices in response to such signals.
HOW WE SHARE YOUR DATA
We share personal data in the following circumstances only:
— Affiliated entities. Entities under common ownership or control with Sparks Affiliates LLC may receive data for coordinated marketing, shared infrastructure, and back-office functions, subject to equivalent data-handling standards.
— Email service providers. Third-party delivery platforms receive Associate contact data to transmit our emails. They may use it only for that purpose, under written agreements that restrict independent use.
— Technology vendors. Hosting providers, analytics services, and other operational vendors may access limited data as part of their service delivery, under written terms that confine their use.
— Clients and affiliate partners. We pass attribution signals — device identifiers, IP addresses, click data, and conversion events — to clients and partners to confirm and settle campaign performance. This type of disclosure may constitute a “sale” or “sharing” of personal data under the California Consumer Privacy Act (CCPA). California Associates may opt out as described below.
— Legal and regulatory bodies. We disclose data to courts, regulators, and law enforcement where required by applicable law or valid legal process, or to protect our rights and the safety of others.
— Corporate successors. If Sparks Affiliates LLC is involved in a merger, acquisition, or asset transfer, personal data may form part of the transaction. We will notify affected Associates if such a transfer materially changes how their data is handled.
We do not rent or sell Associate email addresses or personal profiles to unaffiliated third parties for their own independent marketing beyond what is described above.
HOW LONG WE KEEP YOUR DATA
— Active Associates. We retain your contact data for as long as you remain active in the Program — meaning your address has not bounced, been suppressed, or gone unengaged for an extended period.
— Suppressed addresses. After an opt-out, your address moves to our suppression file and is retained indefinitely. Removing it would defeat its purpose: the next time that address appeared in an acquired source, it would receive emails against your expressed preference.
— Business records. Records related to client and partner relationships are kept for the duration of the engagement and for a reasonable period afterward for billing, dispute resolution, and compliance purposes.
— Legal hold. Where data is relevant to a pending or anticipated dispute, investigation, or legal obligation, we retain it for as long as that purpose requires.
SECURITY
We apply proportionate security measures to protect personal data against unauthorized access, disclosure, alteration, and loss. Current measures include TLS encryption for data in transit, role-based access controls, authentication requirements for system access, and periodic security reviews.
No internet-connected system is entirely secure. We cannot guarantee that data you transmit to us over public networks will not be intercepted. If a breach triggers mandatory notification obligations under applicable state or federal law, we will notify affected individuals and regulators within the legally required timeframe.
YOUR PRIVACY RIGHTS
— California — CCPA / CPRA. The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, grants California residents specific rights over their personal data.
In the preceding twelve months, we may have collected — and in some instances sold or shared — the following categories: contact identifiers (names, email addresses, IP addresses, device IDs); internet and network activity data (email-open records, click histories, browsing sessions); approximate geolocation from IP analysis; commercial interaction data; and behavioral inferences. We gather this through direct submissions, automated tracking, and list-acquisition sources.
California Associates may request disclosure, deletion, correction, or portability of their data; opt out of any sale or sharing; and exercise all of these rights free from discriminatory treatment.
Verification requirements, response timelines, and authorized agent instructions for California rights requests are set out in Section [G] of our Terms & Conditions. Submit requests to contact@sparkaffiliates.io with subject line “California Privacy Rights.”
We honor Global Privacy Control (GPC) signals received from California IP addresses as valid opt-out requests. Shine the Light requests under California Civil Code § 1798.83 may be submitted to contact@sparkaffiliates.io.
— Nevada. Nevada residents may submit a verified opt-out of covered information sales under Nevada Revised Statutes Chapter 603A by writing to contact@sparkaffiliates.io.
— Other U.S. states. Residents of Colorado, Virginia, Connecticut, Texas, Oregon, Montana, and other states with enacted consumer privacy statutes may have rights to access, correct, delete, and port their data and to opt out of targeted advertising or data sales. We honor those rights to the degree required by applicable law. Submit requests to contact@sparkaffiliates.io; we will include any available appeal pathway in our response.
— EEA, UK, and Switzerland. Where GDPR, UK GDPR, or Swiss data-protection law applies, you may have rights to access, rectify, erase, restrict, port, and object to processing — including an unconditional right to object to direct marketing. Contact contact@sparkaffiliates.io; we respond within one month. You may also complain to the supervisory authority in your country of residence.
— Canada. To the degree PIPEDA or applicable provincial law governs our activities, Canadian Associates may access, correct, and withdraw consent over their personal data within the limits those laws allow. Contact contact@sparkaffiliates.io.
INTERNATIONAL DATA TRANSFERS
Sparks Affiliates operates from the United States and stores data on U.S.-based infrastructure. Accessing our emails or website from outside the United States results in personal data being transferred to and processed in the United States, where data-protection standards may differ from those of your home country.
Where GDPR or another international framework independently requires specific safeguards for cross-border data transfers, we will put appropriate mechanisms in place — which may include Standard Contractual Clauses approved by the European Commission.
ADDITIONAL TERMS
— Scope. Sparks Affiliates operates under U.S. law. References to non-U.S. privacy frameworks apply only where those frameworks independently govern our activities. Nothing here waives any jurisdictional defense available to us under U.S. law.
— Accessibility. We are committed to making this Policy and our website accessible to individuals with disabilities, consistent with the Americans with Disabilities Act. Contact contact@sparkaffiliates.io if you encounter barriers and we will work to address them.
— Policy updates. We may revise this Policy at any time. The current version is always posted at https://sparkaffiliates.io with an updated Effective Date. Continued participation in the Program after a revision signals your acceptance of the updated Policy. Where law requires advance notice of material changes, we will provide it.
CONTACT US
For privacy questions, rights requests, or opt-out submissions:
Sparks Affiliates LLC
848 Main St Ste 10
Billings, Montana, 59105
Email: contact@sparkaffiliates.io
Website: https://sparkaffiliates.io