PRIVACY POLICY
Last Updated: March 13, 2026
Your privacy is very important to us and we take your privacy very seriously. This Privacy Policy describes how I SPARK OUR FIRE LLC d/b/a The Change-Resilient Advantage Group (“Company”, “we”, “us”, or “our”) collects and uses the personal information you provide to us on our website and all other websites, mobile sites, applications, platforms and tools where this Privacy Policy appears or is linked, and through the use of our services, (collectively the “Site”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.
We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and Europe, and we are responsible as “controller” of that personal information for the purposes of those laws.
By creating an account, providing information to us (by any means, whether in correspondence, via our Site, or otherwise), or continuing to use our services, you acknowledge that you have read, understood, and consent to be bound by this Privacy Policy.
IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR OUR PRACTICES, YOU MAY NOT USE OUR SITE. THIS PRIVACY POLICY MAY CHANGE FROM TIME TO TIME AND YOUR CONTINUED USE OF OUR SITE CONSTITUTES YOUR ACCEPTANCE OF THOSE CHANGES. WE ENCOURAGE YOU TO REVIEW THIS PRIVACY POLICY PERIODICALLY.
Personal Information We Collect About You. As used in this Privacy Policy, “personal information” means any information relating to an identified or identifiable individual. We may collect and use the following personal information:
[Category | Example | Collected]• Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers. Collected: Yes
• Customer records information (i.e. Information that identifies, relates to, describes, or is capable of being associated with, a particular individual): A name, signature, physical characteristics or description, address, telephone number, employment. Some personal information included in this category may overlap with other categories. Collected: Yes
• Protected classification characteristics under state or federal law: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Collected: No
• Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Collected: No
• Biometric information: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: No
• Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Collected: Yes
• Geolocation data: Physical location or movements. Collected: No
• Sensory data: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: No
• Professional or employment-related information: Place of employment, position, job history, salary, resume, performance evaluations, or other related data. Collected: Yes
• Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No
• Inferences drawn from other personal information: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. An inference is essentially a characteristic deduced about a consumer (such as ‘married,’ ‘homeowner,’ ‘online shopper,’ or ‘likely voter’) that is based on other information a business has collected. Collected: No
• Sensitive personal information: (1) Personal information that reveals:
(A) A person’s social security, driver’s license, state identification card, or passport number.
(B) A person’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.
(C) A person’s precise geolocation.
(D) A person’s racial or ethnic origin, religious or philosophical beliefs, or union membership.
(E) The contents of a person’s mail, email, and text messages unless the business is the intended recipient of the communication.
(F) A person’s genetic data.
(2) The processing of biometric information for the purpose of uniquely identifying a consumer.
(3) Personal information collected and analyzed concerning a consumer’s health.
(4) Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
Collected: No
This personal information is required to provide Site or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing our Site or services to you.Cookies and Other Tracking Technologies.
Cookies
Cookies are small text files of information stored by the Internet browser on your computer’s hard drive. We may use these cookies to collect browsing data to keep track of your preferences and profile information and to collect general usage and volume statistical information. Our cookies do not collect personal or confidential information and are not spyware.
There are a number of different types of cookies, however, our Site uses:
• Essential – These cookies are necessary to the core functionality of our Site and some of its features, such as access to secure areas.
• Analytics and Customization – Our Company uses these cookies and technologies to analyze how the Site is accessed, used, or performing in order to improve your user experience and to maintain, operate and continually improve the Site. For example, we use Google Analytics on the Site to collect: page url/page title and user browser/system information, which includes browser type, referrer, language, java/flash support, IP address, and ad-serving data. For information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, visit Google’s “How you can control the information collected by Google on these sites and apps” article available here.
How to Manage Cookies.
You have the right to decide whether to accept or reject certain cookies. You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our Site features may not function as a result. Essential cookies cannot be rejected, as they are strictly necessary to provide you with our Site.
Do Not Track
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature signal setting you can activate to signal your privacy preference not to have data about your online browsing activities sold or shared.
At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signal.
However, we are committed to providing you with meaningful choices about the information on our Site for third party purposes and that is why we provide the variety of other opt-out mechanisms described in this Policy.
Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone or post) about our Site or our services, including exclusive offers, promotions or new products or services.
We have a legitimate interest in processing your personal information for promotional purposes (see below “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving promotional communications at any time by:
• Contacting us by using one of the methods listed in the “How to Contact Us” Section below;
• Using the “unsubscribe” link in emails or “STOP” number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further correspondence in the future, or if there are changes in the law, regulation, or the structure of our business.
How Your Personal Information is Collected. We collect this personal information directly from you—in person, by telephone, text or email and/or via our Site, including through cookies.
How and Why We Use Your Personal Information. We may use your personal information for the following purposes:
• For the performance of our contract with you or to take steps at your request before entering into a contract
• To provide our Site and our services to you.
• To communicate with you in relation to inquiries or services you have requested from us.
• To provide you invitations to events we may host.
• To minimize fraud or other criminal activity that could be damaging for us and for you.
• To ensure business policies are adhered to, e.g. policies covering security and internet use.
• To protect trade secrets and other commercially valuable information.
• For operational reasons, such as improving efficiency, training and quality control.
• For statistical analysis to help us manage our business.
• To update and enhance customer records.
• To make sure that we can keep in touch with our customers about existing or new products or services.
• To promote our business and services to existing and former customers, third parties who have previously expressed an interest in our services, and third parties with whom we have had no previous dealings.
• To comply with our legal and regulatory obligations.
We may also use your personal information for other reasons described at the time of information collection.
We may also anonymize, aggregate or de-identify personal information so the end-product does not identify you or any other individual. Such aggregated, anonymized or de-identified information is not considered personal information for purposes of this Privacy Policy and we may use it for any purpose. For example, we may use this information to generate norms by industry, geography, level, etc., enable us to understand where our services are being utilized, conduct ongoing validation studies, compile reports, and improve the services.
Who We Share Your Personal Information With. We may share your personal information with:
• Our Business Partners. We may disclose your personal information to other companies with whom we partner to provide the Site and our services, to promote our products, services, offers, contests, or other promotions to our customers, and carry out other activities described in this Privacy Policy.
• Our Service Providers. We may disclose your personal information to third parties that provide business, professional, or technical support services to us and/or administer activities on our behalf. We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.• Our Analytics Providers. We may disclose your personal information to parties that assist us in performing analytics and help us measure the effectiveness of the Site and our marketing and advertising efforts.
• Governmental and Public Authorities. We may disclose your personal information to government and public authorities as necessary or permitted by the laws of any jurisdiction in which we operate, including in response to a subpoena, court order, investigative demand, request for cooperation from a law enforcement agency, or similar request from a self-regulatory body or government agency.
• Relevant Third Parties in Connection with a Business Transaction. We may disclose or otherwise transfer your personal information to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction as well as in the event of any insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
We may also need to share some personal information with other parties to the extent we believe it is necessary or appropriate to (1) protect our operations and those of our affiliates and subsidiaries; (2) investigate and prevent against fraud and other illegal activity; (3) protect our rights, privacy, safety, property, and/or those of others; or (4) allow us to pursue available remedies or limit damages that we may sustain.
We may disclose your personal information for other reasons described at the time of information collection or prior to disclosing your information. Additionally, we may disclose your personal information with your consent or when you direct us to do so.
Except as set forth above, we will not share your personal information with any other third party.
How Long Your Personal Information Will Be Kept. We will keep your personal information only as long as necessary:
• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly;
• To improve our security or detect and prevent fraud; or
• To keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of personal information; the potential risk from unauthorized use or disclosure of the personal information; the purpose(s) for which we use or may use the personal information; whether we can achieve the purpose(s) through other means; and the applicable legal requirements.
Children and our Site. Our Site is not directed to children, and you may not use our Site if you are under the age of 18. If you are under 18, do not use our services, access the Site, or provide any information about yourself including, without limitation, your name, address, email address or any screen name or user name you may use.
If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, in compliance with the Children’s Online Privacy Protection Act, we will purge such information from our database and cancel the corresponding accounts. If you believe we may have any information from or about a child under 13, please see our “How to Contact Us” Section below. Please visit the FTC's website at www.ftc.gov for tips on protecting children's privacy online.
Keeping Your Personal Information Secure. We use reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction. However, while we strive to protect your privacy, due to many reasons, including the inherent security flaws in the internet, we cannot guarantee the security of any information you discloseto us and, as such, you agree that your disclosure of such information is at your own risk.
International Transfers of Personal Information. To bring you our Site, we operate globally. Therefore, it is sometimes necessary for us to share your personal information outside the country where we originally collected your personal information, e.g.:
• With our offices in the United States;
• With your and our service providers located throughout the world;
• If you are based outside the EEA; or
• Where there is an international dimension to the services we are providing to you.
These transfers may be subject to special rules under local data protection law.
These outside countries do not have the same data protection laws as the country where we originally collected the personal information. In particular, you are advised that the United States of America (US) uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. If you are located outside the US, we will only transfer your personal information if:
• you provide your explicit consent;
• the country to which the personal information will be transferred has been granted an appropriate adequacy decision by your local supervisory authority; or
• we have put in place appropriate safeguards in respect of the transfer, for example we have entered into the appropriate standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by a supervisory authority.
Our Company is headquartered in the US and utilizes service providers both in the US and throughout the world. As such, our Company and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction.
Where the laws of your country allow you to do so, by using the Site or our services, you consent and authorize our Company to transfer, store, and use all such information in the US and any other country where we operate which may not offer an equivalent level of protection to that required in the country where you reside and to the processing of that information by us on its servers located in the US as described in this Privacy Policy. If you do not want your personal information transferred to the US and any other country where we operate, please do not submit any information to us or use our services.
If you would like further information, please contact us (see “How To Contact Us” below).
Your Rights and Choices Under the GDPR
In some regions (like the European Economic Area and the UK), you have certain rights under applicable data protection laws.
• Right to Access: The right to be provided with a copy of your personal information (the right of access).
• Right to Rectification: The right to require us to correct any mistakes in your personal information.
• Right to be Forgotten: The right to require us to delete your personal information —in certain situations. At your request, we will delete your personal information promptly if:
• it is no longer necessary to retain your personal information;
• you withdraw the consent which formed the basis of your personal information processing;
• you object to the processing of your personal information and there are no overriding legitimate grounds for such processing;
• the personal information was processed illegally; or
• the personal information must be deleted for us to comply with our legal obligations.
We will decline your request for deletion if processing of your personal information is necessary:
• to comply with our legal obligations;
• in pursuit of a legal action;
• to detect, predict and monitor fraud; or
• for the performance of a task in the public interest.
• Right to Restriction of Processing: The right to require us to restrict processing of your personal information — in certain circumstances, e.g. if you contest the accuracy of the data, if your personal information was processed unlawfully and you request a limitation on processing, rather than the deletion of your personal information, we no longer need to process your persona data, but you require your personal information in connection with a legal claim, or you object to the processing pending verification as to whether an overriding legitimate ground for such processing exists.We may continue to store your personal information to the extent required to ensure that your request to limit the processing is respected in the future.
• Right to Data Portability: The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party — in certain situations. At your request, we will provide you free of charge with your personal information in a structured, commonly used and machine readable format, if:
• you provided us with personal information;
• the processing of your personal information is based on your consent or required for the performance of a contract; or
• the processing is carried out by automated means.• Right to Object: The right to object:
• at any time to your personal information being processed for direct marketing (including profiling);
• in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.We will comply with your request unless we have compelling legitimate grounds for the processing which override your rights and freedoms, or where the processing is in connection with the establishment, exercise or defense of legal claims. Please note that even if we stop all marketing communications, you may still receive administrative communications from us.
• Right Not to be Subject to Automated Individual Decision-Making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you, unless you have given us your explicit consent or where they are necessary for a contract with us.
• Right to withdraw consent: You have the right to withdraw any consent you may have previously given us at any time.
If you would like to exercise any of your rights as described in this Privacy Policy, please email us at support@changeresilientadvantage.com.
Please note that you may be restricted on the number of data access or data portability requests you may make within a 12-month period.
If you choose to contact us to exercise any of these rights, we will take steps to verify your identity before granting you access to your personal information or complying with your request. In order to help protect your privacy and maintain security, you will need to provide us with:
• Enough information to identify you (e.g., your full name, address, email address, telephone number);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.
In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
We hope that we can resolve any query or concern you raise about our use of your information. However, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. You can find your appropriate supervisory authority here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.
Third Party Websites.
If, in your interactions with the Site, you are linked or directed to, or click on, a third party website, we cannot control what information you may provide to that party or on that website, and we are not responsible for how that party may use or disclose any information you may provide to them. This is not as an endorsement by us of any third party website, content that may be offered on such third party website, or of any products or services provided by such third party. We do not control, nor are we responsible for, such third party website, product or service offerings. As such, we urge that you exercise caution before providing them with your personal information and to review the third party’s privacy policy for information on its data processing practice.
You should contact the site administrator for such third party website if you have any complaints, claims, concerns or questions regarding such third party website or its privacy practices.
Changes to This Privacy Notice. This Privacy Policy was published on the date “Last Updated” above.
We may change this Privacy Policy from time to time. Changes to this Privacy Policy will be made by updating this page. Please visit this Privacy Policy regularly to read the current version.
How to Contact Us. Please contact us by email if you have any questions about this Privacy Policy or the information we hold about you: support@changeresilientadvantage.com.