Thank you for your trust in SPARC and for taking the time to read our Website Privacy Notice (“Privacy Notice”). This Notice is provided to let you know how we protect the privacy of personal information provided to us (a) in connection with your use of this website (the “Site”), and (b) if you represent a corporate customer, business partner, contractor, supplier, vendor, or similar third party (“Business Contact”), while engaging with us.

This Privacy Notice addresses the following topics:

Purpose of This Privacy Notice

Collection and Use of Your Information

Collection of Anonymous Computer Information/Cookies

Sharing Your Information with Third Parties

Security and Protection of Your Information

Accessing and Correcting Your Information

Information Specific to California Users

Information Specific to Non-U.S. Users

Links to Other Websites

Minors Under the Age of 13

Use of Your Information for Marketing

Contact Us

Changes to This Privacy Notice

Purpose of This Privacy Notice

This Privacy Notice explains what SPARC does with personal information provided to us through this Site, or, if you are a Business Contact, while engaging with us. It describes the information we collect and explains how we use, share, store and safeguard that information. This Privacy Notice also contains information on how to contact us, how to exercise rights that you might have under the law that applies to you in relation to your personal data, as well as how to contact us if you have a question or concern.

Collection and Use of Your Information

Much of our website does not require or request any form of registration or identification. However, some functions of our website may require registration, such as those that necessarily require us to identify you in order to answer a question that you may ask. It is up to you to choose whether you want to register for any programs through our site. It may not be possible for you to gain access to certain parts of the site that are restricted to certain registered users.

If you register for a SPARC program or service, or otherwise provide personal information to us through this website, SPARC limits the collection of your personal information to that which is appropriate and proportionate for the intended use. For example, if you are interested in receiving materials about SPARC, you will need to provide us with your e-mail address, so we can share that information with you. If you seek information more generally about SPARC or its products or services, you generally will need to submit your first and last name and your e-mail, and you may choose to submit a phone number, your country location, and your interest to help us better respond to your inquiry or to contact you by phone.

Personal Information collected through this website may only be used for marketing-related purposes where we have provided notice and obtained consent from the individual to do so, or where otherwise permitted by applicable laws. Individuals always have the right to withdraw consent (opt-out) of the use of their personal information for a marketing-related purpose and can do so by contacting us at DataPrivacy@sparc-discovery.com.

We collect Business Contacts’ personal information in a wide variety of ways. For example, Business Contacts may provide their personal information so that we can respond to a request or other inquiry about our products or services, when the Business Contacts offer products or services to SPARC or invoices SPARC for products or services provided to KBR, or in the form of a business card during in-person interactions at conferences or events. We also may collect Business Contacts’ personal information from publicly available sources, for example, from corporate websites or third-party websites, such as LinkedIn.

The personal information we collect generally is limited to Business Contact’s name and job tile, the name of the Business Contact’s organization, and related contact details the Business Contact choose to provide, such as phone number, e-mail address, and mailing and/or physical address. Occasionally, the personal information collected may include a Business Contact’s resume information, such as employment history, professional certifications or licenses, and education. We may use Business Contacts’ personal information for purposes of our business relationship with them and their organization, such as contract negotiation and administration, invoicing, exchanging business communications, and similar business interactions.

If a Business Contact requires physical access to a SPARC facility or remote access to SPARC’s information systems, we may request additional personal information in accordance with our information and security protocols. In those circumstances, we will supplement this Privacy Notice with additional information specific to that collection of personal information at or before the point of collection.

Collection of Anonymous Computer Information / “Cookies”

Like virtually all websites, this website collects anonymous information known as “cookies” if your computer is set to allow that type of collection or, where required, you consent to cookies. “Cookies” are small pieces of data sent from a website and stored on a website user's web browser while a user is browsing a website. Cookies allow us to enhance your experience on the Site by helping us better understand how user’s use the site and evaluate how the Site performs. The use of cookies does not harm your computer or directly identify individuals.

Sharing Your Information with Third Parties

SPARC does not sell, lease, or license your personal information. We may share your personal information with third parties in the following limited circumstances.

  • With service providers: We may, for example, retain a service provider to host all or portions of this Site, to help maintain and manage our databases, to assist in the recruiting process, or to conduct pre-donor screening. Service providers will be permitted to use your personal information only for the purpose(s) for which it was disclosed to them and in accordance with SPARC’s instructions;
  • With affiliated companies: For the purposes for which we originally collected the information. We require that affiliated companies uphold a similar level of protection for your data as that described in this Privacy Notice;
  • When required by law, such as when we respond to subpoenas, court orders, legal process, or a discovery request in civil litigation;
  • To respond to misconduct: If we believe your actions violate applicable law, or threaten the rights, property, or safety of our Organization, our users, or others, we may disclose your personal information to law enforcement or other third parties involved in responding to the misconduct; and/or
  • With prior consent, we may disclose your personal information with the Department of Defense’s Brain Tissue Repository.

SPARC will make such disclosures only as permitted by applicable data protection laws.

Security and Protection of Your Information

We use appropriate technical, administrative, and physical safeguards to protect data that pertains to you from loss, misuse, alteration, destruction, or unauthorized access. We update these safeguards to address new threats and changes in the legal requirements. At the same time, you should recognize that no organization can guarantee the absolute security of personal information. We encourage you to take steps to protect the information that you share with us — for example, by closing your browser window when you have finished your visit to the Site.

Accessing and Correcting Your Information

If you would like to access your personal information or correct your personal information that is inaccurate or out of date, you may submit a request to DataPrivacy@sparc-discovery.com. All requests to access or correct your personal information will be subject to verification of the identity of the requesting individual.

Information Specific to California Users

This section of the Privacy Notice applies to personal information that we collect from residents of the state of California (“California Consumers”) — either through this website or otherwise — except when we collect that information from California residents in their capacity as (a) a Business Contact, or (b) a job applicant, employee, independent contractor of SPARC.

Your California Privacy Rights

Right to Know: California Consumers have the right to submit a verifiable request to know:

  • The categories and specific pieces of Personal Information that is collected about them;
  • The categories of sources from which Organization collected the Personal Information;
  • The categories of Personal Information that Organization sold or disclosed to a third party (other than a service provider) for a business purpose and the categories of recipients of that information; and
  • The business or commercial purposes for Organization’s collection, disclosure, or sale of the Personal Information.

Right To Delete: California Consumers have the right to submit a verifiable request for deletion of their Personal Information that SPARC has collected from the individual.

Right to Opt Out of Sale of Personal Information: California Consumers have a right to opt-out of the sale of the Personal Information. However, as stated above, SPARC does not and will not sell Personal Information.

How to Exercise Your Rights: SPARC will respond to requests in accordance with applicable law if it can verify the identity of the individual submitting the request. California Consumers can exercise their rights in the following ways:

Requests By Authorized Agents: You may designate an authorized agent to exercise your right to know or your right to delete by submitting an email to CaliforniaPrivacy@sparc-discovery.com. If an authorized agent submits a request to know or a request to delete on your behalf, the authorized agent must submit with the request either (a) a power of attorney that is valid under California law, or (b) a document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you to follow the applicable process described above for verifying your identity.

How We Will Verify Your Requests: To prevent anyone other than you, or your authorized agent, from exercising the right to know or the right to delete with respect to your personal information, we follow procedures to verify your, or your agent’s, identity. These procedures seek to confirm that the person making a request is the person about whom we have collected personal information or that person’s authorized agent. The verification procedures involve matching data points you provide with your request against information about you we already have in our records and that we have determined to be reliable for verifying your identity. We will use the information you provide in your completed request form to verify your identity, and we may request additional information if necessary to complete the verification process.

SPARC’s Non-Discrimination Policy: California Consumers have the right not to be subject to discriminatory treatment by SPARC for exercising their privacy rights under the California Consumer Privacy Act, and SPARC will not discriminate on that basis.

Your “Do Not Track” Browser Setting

The Site collects personally identifiable information about your online activities over time and across third-party websites or online services. We support the Do Not Track (DNT) browser setting. DNT is a preference you can set in your browser’s settings to let the websites you visit, including the Site, know that you do not want the sites collecting your personally identifiable information.

Information Specific to Non-U.S. Users

Your Consent

By submitting your personal information through SPARC’s website, you consent to the collection, use, disclosure, transfer across borders and other processing of your personal information as described in this Privacy Notice. Your consent will continue to apply to our collection, use, disclosure, cross-border transfer and other processing of your personal information unless you revoke your consent by contacting us at DataPrivacy@sparc-discovery.com. If we make a material change to this Notice, we will inform you by posting a notice on this Site. Those changes will go into effect on the effective date posted in the revised notice. The new notice will apply to all current and past users of the online application page and to all information collected before the date of the change. The new notice will replace any prior policies that are inconsistent. Please check periodically for changes to this Notice, and especially before you provide any personal information to us. If we materially change how we use, disclose or otherwise process your personal information, we will contact you before doing so and obtain your consent before using, disclosing or otherwise processing your personal information other than as described in this Notice and you may not be able to use the services offered through the Site that require your personal information.

Other Lawful Grounds For Processing Your Personal Information: For website users and Business Contacts, we may also process your personal information (a) as necessary to enter into, or perform, a contract with you or the organization that you represent, or (b) as necessary to pursue our legitimate interests, such as our legitimate interests in conducting and managing our business relationships with prospective, current or former customers, business partners, contractors, vendors, suppliers and similar third parties as well as in marketing our products and services.

International Transfer of Your Personal Information

The Internet is global. As such, your personal data may be initiated and transferred to us across borders. If you are located outside of the United States, you are transmitting your data internationally. The data privacy laws vary from one country to another and may not provide the same level of protection as those in your home country. Nevertheless, SPARC has adopted measures to ensure that the personal data entrusted to us via this website is adequately protected irrespective of where it is accessible or stored. Similarly, before transferring your personal information directly to any third-party service provider located in the United States or another third country, SPARC will confirm that all necessary data transfer requirements have been satisfied.

If you reside in a country that restricts cross-border data transfers, SPARC relies on your consent for the transfer of your personal data outside your country of residence and within the SPARC corporate group or to third-party service providers unless an alternative or additional data protection mechanism is required by applicable law.

Retention of Your Information

SPARC retains personal information provided to us via this website in accordance with business and legal needs, and then securely destroys that information. In some situations, we may choose to remove the personal identifiers or archive the data so that it is no longer processed or accessible. If you reside outside the United States, we retain your personal information for 12 months from our last interaction with you unless a shorter or longer retention period is required by applicable law. SPARC maintains Business Contacts’ personal information for the duration of SPARC’s business relationship with the Business Contact and for a reasonable period of time after the termination of that relationship.

Your Rights with Respect to Your Personal Information

Subject to applicable law, your country of residence may provide you with the right to:

  • request access to your personal information;
  • request that SPARC update, correct or delete your personal information; and/or
  • withdraw your consent to the processing of your personal information, in circumstances where it was previously provided.

More on the right to withdraw consent: If you consent to the processing of your personal data, you may withdraw your consent at any time by contacting us at DataPrivacy@sparc-discovery.com. Any withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal, and SPARC will continue to retain the information that you provided us before you withdrew your consent for as long as allowed or required by applicable law.

Subject to applicable law, your country of residence may also provide you with the right to:

  • request restrictions on the processing of your personal data;
  • request data portability;
  • object to the processing of your personal data, including for direct marking or based on legitimate interests; and/or
  • be informed about the collection and use of your personal data.

More on the right to data portability: Subject to certain limitations, the right to data portability allows you to obtain from SPARC, or to ask us to send to a third party, a copy of your personal information in electronic form that you provided to us with your consent.

More on the right to object: You have the right to object to the processing of your personal information for direct marketing purposes or based solely on SPARC’s legitimate interests. If you do object in these circumstances, the processing of your personal information will be stopped unless there is an overriding, compelling reason to continue the processing, or the processing is necessary to establish, pursue or defend legal claims.

How to exercise your rights: You can exercise your rights by submitting a request to DataPrivacy@sparc-discovery.com. We will respond to such requests in accordance with applicable data protection law.

No Automated Decision-Making

SPARC will not use your personal information to engage in automated decision-making.

EU-U.S. Data Privacy Framework

i) SPARC complies with the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce. SPARC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov or please visit the Data Privacy Framework List at https://www.dataprivacyframework.gov/s/participant-search.

ii) The types of personal information we collect is described above in “Collection and Use of Your Information.”

iii) SPARC entities commit to subject to the Data Privacy Framework Principles all personal data received from the EU and the UK.

iv) The purposes for which we collect personal information are described above in “Collection and Use of Your Information.”

v) In compliance with the Data Privacy Framework Principles, SPARC commits to resolve complaints about our collection or use of your personal information. UK, EU, or EEA individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact SPARC at: DataPrivacy@sparc-discovery.com.

vi) The types of third parties to which we disclose personal information, and the purposes for doing so, are described above in “Sharing Your Information with Third Parties.”

vii) UK- and EU-based individuals’ rights to access their information are described above in “Your Rights with Respect to Your Personal Information.”

viii) UK- and EU-based individuals’ choices and means for limiting the use and disclosure of personal data are described above in “Your Rights with Respect to Your Personal Information.”

ix) We use a panel established by the EU Data Protection Authorities and the UK Information Commissioner’s Office as an independent dispute resolution body to address complaints and provide recourse free of charge to individuals.

x) The Federal Trade Commission has jurisdiction over SPARC’s compliance with the EU-U.S. Data Privacy Framework and the UK Extension to the EU-U.S. DPF.

xi) It is possible, under certain conditions, for UK- or EU-based individuals with a dispute over their personal information to invoke binding arbitration.

xii) We may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

xiii) We protect your data as required by law with respect to onward transfers to third parties to meet our legal obligations.

SPARC commits to cooperating with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to data transferred from the EU.

Links to Other Websites

This Privacy Notice applies only to SPARC sites and not to any other non-SPARC websites that may be linked to this Site. Since we are unable to control the Internet or the websites of other companies, we cannot be responsible for the standards of websites other than our own. This Privacy Notice is not intended to be linked to any non-SPARC website. You can learn about the information handling practices of non-SPARC websites by reading the privacy policy linked to those sites.

Minors Under the Age of 13

We do not collect any information from anyone under 13 years of age. The Site and its services are all directed to people who are at least 13 years old or older. If you are under the age of 13, you are not authorized to use the Site.

Use of Your Information for Marketing

Personal Information collected through this website may be used for marketing-related purposes where we have provided notice and obtained consent from the individual to do so, or where otherwise permitted by applicable laws. Individuals always have the right to withdraw consent (opt-out) of the use of their personal information for a marketing-related purpose, and can do so by contacting us at DataPrivacy@sparc-discovery.com.

Contact Us

If you have any questions about our Privacy Statement, please write to us at: SPARC, Attention: Data Privacy Lead, 601 Jefferson, Houston, Texas USA 77002, or email us at DataPrivacy@sparc-discovery.com.

Changes to this Privacy Notice

We may update this Privacy Notice from time to time. If we make a material change to this Notice, we will inform you by posting a notice on this Site. Those changes will go into effect on the effective date posted in the revised notice. The new notice will apply to all current and past users of the online application page and to all information collected before the date of the change. The new notice will replace any prior policies that are inconsistent. Please check periodically for changes to this Notice, and especially before you provide any personal information to us. If we will materially change how we use, disclose or otherwise process your personal information, we will contact you before doing so and obtain your consent before using, disclosing or otherwise processing your personal information other than as described in this Notice.

Last Updated: April 18, 2024