Our Privacy Policy

It isn't a light read, but then again we take your data security very seriously. If you have any questions, please reach out to us at support@sparrowsure.com.

SPARROWSURE PRIVACY POLICY

SparrowSure, Inc. (“Company,” “we,” “us,” or “our”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (the “Policy”). The Policy describes how we collect, process, retain, and disclose Personal Data about you when you download, register with, or use the “SparrowSure” application (the “Application”) and our practices for using, maintaining, protecting, and disclosing that information. This Policy applies only to information we collect:

When you purchase, download, install, register with, access, or use the Application.
In communications, including email, text, chat, and other electronic messages, conducted through the Application.
Through the content and information you elect to provide us as part of your Application profile.

It does not apply to information collected by:

Any third party, including our affiliates and subsidiaries, through any application or content, including advertising, that may link to or be accessible from or through the Services.
Us through any other means, including on any other website operated by Company or any third party, including our affiliates and subsidiaries, that does not link to this Policy.

We may provide additional or different privacy policies that are specific to certain features, services, or activities. Please read this Policy carefully to understand our policies and practices regarding your information and how we treat it. By downloading, registering with, or using the Application, you agree to the collection, use, and sharing of your information as described in this Policy. This Policy may change from time to time. Your continued use of the Services after we make changes as described herein is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Definitions

“Personal Data” means information that identifies, relates to, describes, directly or indirectly, or is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, work address, or payment information.
“Services” means your use of the Application and any services provided by the Company pursuant to your use of the Application.

Children’s and Minors’ Data

Our Services are not intended for, and we do not knowingly collect any Personal Data from, children under the age of eighteen (18). If we learn we have collected or received Personal Data from a child under eighteen (18) years old without verification of parental consent, we will delete that information. If you have reason to believe that we have collected Personal Data about a child under the age of eighteen (18) years old without parental or guardian consent as required by applicable law, please contact us at (423) 393-3039 or support@sparrowsure.com, and we will take the requisite steps to delete that Personal Data as required by applicable law.

The Personal Data That We Collect or Process

We collect and use Personal Data. The types and categories of Personal Data we collect or process include:

Account and contact information, including name, work address, other addresses, email addresses, and other contact information you provide us.
Location information, including general geographic location such as country, state or province, you or your administrator provide to us.
Content and information you elect to provide as part of your profile.
Images collected or stored in connection with the Services, if you have consent to such information collection.

Some of the information identified above, may be considered sensitive data under certain laws. If required under applicable law, we will collect and process sensitive personal data only with your consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information. We may also collect:

Statistics or aggregate information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Data.

If we combine or connect non-personal statistical or aggregate information with Personal Data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How We Collect Your Personal and Other Data

You Provide Information to Us We collect information about you when you interact with our Application or otherwise use our Services, such as when you create or update an account, place an order, subscribe, or make a purchase/reservation/request, participate in surveys, contests, or promotions, or create, upload, or post content to the Application, including media such as photos, videos, or audio recordings. Third-Party Information Collection When you use the Application or otherwise interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your device. These third parties may include:

Analytics companies
Your mobile device manufacturer
Your mobile service provider

These third parties may use tracking technologies to collect information about you when you use the Application or otherwise interact with the Services. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, applications, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. From Business Partners and Service Providers We may receive Personal Data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as email platform providers, content delivery services, payment processors, promotions services, analytics, and security and anti-fraud services. We may also receive Personal Data from business partners so that we can better provide you with a personalized experience.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

Provide you with the Services and any contents, features, information, products, or services that we make available through the Application.
Fulfill and manage subscriptions, purchases, orders, or payments.
Provide you with notices about your account/subscription.
Improve our Services, including by analyzing your information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
Promote our Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties’ services.
Carry out our obligations and enforce our rights arising from any contracts entered into by and between you and us, including for billing and collection.
Notify you when Application updates are available and about changes to any Services we offer or provide through them.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and other information that does not identify any individual, without restriction. We may also disclose Personal Data that we collect or you provide, as described with more particularity within in this Policy:

To our subsidiaries and affiliates who may help us deliver our Services to you.
To third party payment processors to facilitate payment for any purchases, subscriptions, orders or other payments.
To contractors, service providers, and other third parties we use to support our organization and who are bound by contractual obligations to keep personal data confidential and use it only for the purpose for which we disclose it to them.
To a buyer or other successor in the event of a merger, acquisition, financing due diligence, bankruptcy, receivership, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Company is among the assets transferred. Similarly, if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of some or all of the Company’s assets, or transition of our Services to another provider, your Personal Data may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to successors or affiliate as part of that transaction along with other assets.
To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.
To fulfill the purpose for which you provide it.
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes. Our Terms of Use can be found at https://www.sparrowsure.com/company/terms-of-use.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers or others. This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
For any other purposes disclosed by us when you provide the information.
For any other purpose with your consent.

The categories of Personal Data we may disclose include:

Names, addresses, and email addresses.
General geographic location such as county, state or province.
Other content and information you elect to provide as part of your profile.
Images collected or stored in connection with the Services, if you have consented to such information collected.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designated to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your Personal Data transmitted to, through, using, or in connection with the Services. In particular, emails, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk. The safety and security of your information also depends on you. You are responsible for taking steps to protect your Personal Data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

Your information collected through the Services will be stored on our servers within the United States. We take steps to ensure that your information remains protected in accordance with the applicable laws. We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, Personal Data will be deleted, destroyed, or deidentified.

Your Rights and Choices about Your Information

This Section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live. In addition to your rights and choices as outlined above, depending on where you reside, and under applicable local law and subject to any applicable exceptions, you may have the following additional rights regarding our use and disclosure of your Personal Data:

Access and Data Portability.
- The right to know the categories of Personal Data that we have collected about you, the business purpose for collecting your Personal Data, the categories of sources from which the Personal Data was collected, whether we have disclosed your Personal Data for business purposes and the categories of Personal Data so disclosed, and the categories of third parties to whom we have disclosed your Personal Data.
- The right access a copy of the specific pieces of Personal Data that we have collected. To the extent feasible, and required by state law, depending on your state, data will be provided in a portable format.
- The right to receive additional information in response to your access request.
Correction. The right to request we correct any inaccurate Personal Data that we have collected about you.
- All users can review and change their personal information by logging into the Application and visiting their account profile page at any time.
Deletion. The right to request we delete Personal Data collected by you, under certain circumstances.
Opt-Out of Using Personal Data. The right to opt-out of having your Personal Data utilized for certain purposes, including target advertising, profiling, and sales.

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. California residents shall refer to the California Privacy Policy. To exercise any of your aforementioned rights, or any other rights granted to you under the applicable state laws, please contact us via phone call at (423) 393-3039, via electronic mail at support@sparrowsure.com, or via physical mail at SparrowSure, Inc., 5008 Falling Springs Road, Valdosta, Georgia 31602-5019. The Company shall respond to requests without undue delay, but in all cases within forty-five (45) days of receipt of a verified request. The response period may be extended once by fifteen (15) additional days when reasonably necessary, taking into account the complexity and number of requests, so long as the Company informs you of said extension within the initial forty-five (45) day response period together with the reason for the extension.If the Company declines to take action regarding the requests, the Company shall inform you of their decision without undue delay, but in all cases and at the latest within forty-five (45) days of receipt of verified requests, of the justification for declining to take action. The Company’s response shall include instructions for how to appeal the decision.

Changes to Our Privacy Policy

We may update this Policy from time to time, and we will provide notice of any such changes to the Policy as required by law. The date the Policy was last updated is identified at the bottom of the page. We will notify you of changes to this Policy by updating the “last updated” date and posting the updated Policy on the Services. We may email or otherwise communicate reminders of this Policy, but you should check our Policy periodically to see the current Policy and any changes that have been made to it.

Contact Information

The Controller of the Company is Christopher Kemmann. To exercise your rights or ask questions or comments about this Policy or our privacy practices, contact us at any of the following:

Telephone Number - (423) 393-3039
Electronic Mail Address - support@sparrowsure.com
Physical Mail Address -

SparrowSure, Inc.5008 Falling Springs RoadValdosta, GA 31602-5019 Last Updated/Reviewed: August 4, 2025

CALIFORNIA PRIVACY POLICY

This California Privacy Policy does not apply to our collection and use of Personal Data from residents outside of California. Consumers residing in other locations should refer to the Sparrowsure Privacy Policy. This California Privacy Policy provides the information required by California law, such as the California Consumer Privacy Act (“CCPA”), the California privacy Rights Act (“CPRA”), and the California Online Privacy Protection Act (“CALOPPA”). This California Privacy Policy is intended to supplement the Sparrowsure Privacy Policy and the Sparrowsure Privacy Policy is hereby incorporated by reference. For residents of the State of California, to the extent that the Sparrowsure Privacy Policy conflicts with this California Privacy Policy, the terms of this California Privacy Policy shall govern.

How We Use Personal Information

We use your Personal Data for a variety of purposes, which are listed in the table below. If we need to use your Personal Data for an unrelated purpose, we will update this California Privacy Policy to explain any such new purpose. Below is a table identifying the personal information that we have collected from consumers over the past twelve (12) months.

Sensitive Personal Data Sensitive personal information is a subtype of Personal Data. Importantly, the CCPA only treats this information as sensitive personal information when we collect or use it to infer characteristics about a consumer. We do not use any Personal Data collected to make inferences regarding the characteristics of any consumer. Additional Categories of Other Purposes We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your Personal Data for a new or unrelated purpose. We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

Consumer Rights

The Right to Know You have the right to request that we disclose certain information to you about your collection and use of your Personal Data (the “Right to Know”), including the specific pieces of personal information we have collected about you (a “Data Portability Request”). Our response will cover the twelve (12) month period preceding the request, although we will honor requests to cover a longer period that do not extend past January 1, 2022, unless doing so would be impossible or involves disproportionate effort. You may exercise your Right to Know twice within any twelve (12) month period. Once we receive your request and confirm your identity, we will disclose to you:

The categories of Personal Data we collected about you, and sources from which we collected your Personal Data
The business or commercial purpose for collecting your Personal Data and, if applicable, selling or sharing your Personal Data.
If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of you Personal Data that we disclose for a business purpose to each category of persons, and sold or shared to each category of third parties.
When your Right to Know submission includes a Data Portability Request, a copy of your Personal Data subject to any permitted redactions.

The Right to Delete and Right to Correct You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions and limitations (the “Right to Delete”). Once we receive your request and confirm your identity, we will delete your Personal Data from our systems unless an exception allows us to retain it. We will also notify our service providers, or other recipients of your Personal Data to take appropriate action. You also have the right to request correction of Personal Data we maintained about you that you believe is inaccurate (the “Right to Correct”). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct Personal Data that our review determines is inaccurate and notify our service providers, or other recipients of your Personal Data to take appropriate action. Right to Limit Sensitive Personal Data Use and Disclosure to Permitted Sensitive Personal Data You have the right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA’s Permitted SPI Purposes (the “Right to Limit”). As we do not use or disclose sensitive personal information beyond the CCPA’s Permitted SPI Purposes, we do not currently provide this consumer right. To the extent that we collect and/or disclose your sensitive personal information in the future, upon receipt of your valid request, we will limit the use and disclosure of your sensitive personal information to the Permitted SPI Purposes. Personal Data Sales or Sharing Opt-Out and Opt-In Rights You have the right to request that businesses stop sell or sharing your Personal Data at any time (the “Right to Opt-Out”), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under sixteen (16) years old without first obtaining consent from consumers who are between the ages of thirteen (13) and fifteen (15) or the consumer’s parent or guardian for consumers under the age of thirteen (13) (the “Right to Opt-In”) We do not sell your Personal Data, and do not currently provide these consumer rights as it relates to the sale of your Personal Data. We cannot share your Personal Data after we receive your request to opt-out unless you later consent to the sharing of your Personal Data. Right to Non-Discrimination As required by the CCPA, we will not discriminate against you because you exercise your CCPA rights. Exercising the Consumer Rights To exercise any of your aforementioned rights (Right to Know, Right to Delete, Right to Correct, Right to Limit, Right to Opt-Out, and Right to Opt-In) please submit a verifiable request to us by either:

Calling us at - (423) 393-3039
Delivering electronic mail to - support@sparrowsure.com
Delivering physical mail to -

SparrowSure, Inc.5008 Falling Springs RoadValdosta, GA 31602-5019 Verification Process and Authorized Agents Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your Personal Data. You may designate an authorized agent on your Account. We may request specific information from you or your authorized agent to confirm your or their identity before we can process your request. We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information related to you. We will only use Personal Data provided in the request to verify the requestor’s identity or authority to make the request. We consider requests made through your password-protected Account with our Company sufficiently verified when the request relates to the Personal Data associated with that specific Account. For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer’s name, email address, or account information. Responding to Your Requests to Know, Delete, or Correct We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the ten-day timeframe, please contact support@sparrowsure.com. We endeavor to substantially respond to a verifiable request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reasonable extension period in writing. We will deliver our written response to your email. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the Personal Data that we hold about you, or we may have destroyed, deleted, or made you Personal Data anonymous in compliance with our record retention policies and obligations. Any disclosures we provide will cover information for the twelve (12) month period preceding the request’s receipt date. We will consider requests to provide a longer disclosure period that do not extend past January 1, 2022, unless providing the longer timeframe would be impossible or involves disproportionate effort. For Data Portability Requests, we will select a format to provide your Personal Data that is readily useable and should allow you to transmit the information from one entity to another without hindrance. We do not charge a fee to process or respond to your verifiable requests unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Responding to Your Requests to Limit or Opt-Out In response to your request to limit or opt-out, we will process your request, as soon as feasibly possible, but no later than fifteen (15) business days from the date we receive the request. We will only use Personal Data provided from your request to comply with the request. We will also notify our service providers, or other third parties with whom your Personal Data was shared of your request to limit or opt-out and instruct them to both (1) comply with your request, and (2) forward the request to their downstream recipients, if applicable. To the extent that you submit an effective request to limit or opt-out, we will wait at least twelve (12) months before asking you to reauthorize the use or disclosure of your sensitive Personal Data for purposes other than the Permitted SPI Purposes or Personal Data sales or sharing. However, you may change your mind and opt back in at any time by calling, emailing, or delivering physical mail to us at the aforementioned phone number, email address or physical address, as applicable.