Effective Date: March 18, 2026

Privacy Policy

Spark Scout, LLC. ("Spark Scout," "we," "us," or "our") respects your privacy and is committed to protecting personal information. This Privacy Policy explains how we collect, use, disclose, store, retain, and otherwise process personal information in connection with the Spark Scout platform, including our websites, mobile applications, software, interfaces, dashboards, tools, messaging systems, payment and escrow workflows, campaign management tools, profile pages, integrations, content hosting tools, and all related products and services (collectively, the "Platform").

This Privacy Policy applies to personal information collected from or about users of the Platform, including Brands, Agencies, Creators, visitors, applicants, invitees, collaborators, counterparties, support contacts, and others who interact with us in connection with the Platform. In this Privacy Policy, "you" and "your" refer to any individual or entity whose information we collect or process. If you use the Platform on behalf of a company, agency, client, brand, creator group, or other entity, you represent and warrant that you are authorized to provide information to us and to bind that entity, where applicable, with respect to this Privacy Policy.

By accessing or using the Platform, creating an Account, connecting a third-party service, communicating with us, or otherwise providing information to Spark Scout, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, you should not access or use the Platform.

This Privacy Policy is incorporated into and forms part of the Spark Scout Terms of Service. Capitalized terms not defined in this Privacy Policy have the meanings given in the Terms of Service.

If you have questions, requests, or concerns regarding this Privacy Policy or our privacy practices, you may contact us at legal@sparkscout.com.

1. The Short Version

Spark Scout is a platform built to connect Brands, Agencies, and Creators and to help them manage profiles, campaigns, communications, assets, payments, and related workflows. In order to provide the Platform, we collect information that you provide directly, information generated through your use of the Platform, information received from other users, and information obtained from third parties such as payment providers, analytics providers, social platforms, identity verification providers, and fraud prevention vendors.

We use this information to operate and improve the Platform, create and manage accounts and Spark Profiles, facilitate campaigns and communications, verify identities and business information, process transactions and payouts, support moderation and trust and safety functions, personalize user experiences, provide customer support, comply with legal obligations, and protect Spark Scout, our users, and the public.

We may share information with other users, service providers, payment and verification partners, compliance vendors, authorities, and others where necessary to operate the Platform, facilitate transactions, enforce our Terms, comply with law, or protect rights and safety.

Some information may be public or visible to other users depending on how you use the Platform. Information may also be processed in the United States and other countries. Depending on where you live, you may have rights to access, correct, delete, or limit certain uses of your information.

The rest of this Privacy Policy explains these practices in more detail.

2. The Information We Collect

We collect information in several ways, depending on how you use the Platform, what features you choose to access, what information you decide to share, what permissions you grant, and what services are connected to your Account.

Information You Provide to Us

You directly provide much of the information we collect. For example, when you register for an Account, build a Spark Profile, set up a team workspace, participate in a Campaign, communicate with another user, contact customer support, request verification, submit a proposal, create or generate content, upload or store content, configure billing or payout settings, or otherwise use the Platform, you may provide information such as your name, username, display name, email address, phone number, mailing address, company name, agency name, business role, authentication, portfolio information, social handles, linked URLs, profile photo, bio, pricing information, campaign interests, service offerings, work samples, ratings and reviews, preferences, communications, generated/uploaded/stored files, and other information associated with your use of the Platform.

If you use the Platform in a business capacity, we may collect business information such as entity name, tax identification number, state or country of formation, registration details, principal place of business, billing contact information, beneficial owner information, and authorized representative information. If you engage in transactions through the Platform, we may collect billing information, payout instructions, invoicing details, payment history, transaction information, tax forms, and related financial data, although certain sensitive financial data may be collected directly by our Payment Partners rather than by Spark Scout.

If we require identity verification, business verification, sanctions screening, fraud review, or due diligence, you may provide government-issued identification, passport or driver's license data, selfies, photographs, video verification, tax forms, proof of address, business certificates, banking documentation, beneficial ownership disclosures, and similar materials. We may also collect information you submit in connection with disputes, support tickets, appeals, moderation reviews, fraud investigations, or legal compliance matters.

If you contact us or communicate with other users through the Platform, we may collect the contents of those communications, including messages, attachments, voice notes where enabled, comments, feedback, and support history.

Information Collected Automatically

When you access or use the Platform, we and our service providers may automatically collect technical and usage information. This may include your IP address, device identifiers, mobile advertising identifiers, browser type, browser language, operating system, carrier, hardware model, app version, referring URLs, pages viewed, time spent on pages, clicks, scroll behavior, session events, timestamps, crash logs, error logs, diagnostics, and similar information about how you access and use the Platform.

We may also collect approximate geolocation based on IP address, and more precise location if you affirmatively grant location permissions through your device or browser settings. We may collect authentication and security logs, signals used to detect fraud or suspicious activity, and usage data relating to specific product features such as messaging, file storage, campaign tracking, AI tools, payment flows, search, recommendations, notifications, and integrations.

Cookies, SDKs, Pixels, and Similar Technologies

We and our service providers may use cookies, local storage, web beacons, pixels, tags, scripts, software development kits, and similar technologies to collect information about your browsing and usage activity. These technologies help us remember your preferences, keep you signed in, measure traffic, analyze engagement, personalize content, support security, understand campaign performance, and improve the Platform. They may also be used for attribution, referral tracking, and marketing measurement where permitted by law.

Information We Receive from Other Users

Other users of the Platform may provide information about you. For example, a Brand or Agency may invite you to a workspace, reference you in a Campaign, send you a proposal, leave a review, upload deliverables or correspondence involving you, tag you in content, report an issue involving you, or otherwise provide information about you in the course of using the Platform. Similarly, a Creator may submit Campaign materials, invoices, or content containing information about a Brand or Agency contact. We may receive, store, and process such information.

Information from Third Parties

We may receive information about you from third parties, including payment processors, payout providers, financial institutions, fraud prevention vendors, identity verification providers, sanctions screening tools, analytics providers, marketing partners, app stores, cloud hosting providers, communication service providers, business intelligence vendors, public databases, compliance providers, and other lawful sources.

If you register using, connect, or otherwise authorize a third-party account, such as a social media platform, calendar service, cloud storage service, authentication provider, or communications tool, we may receive profile data, account metadata, content, audience metrics, scheduling data, or other information from that service according to the permissions you grant and the settings you choose with that third party.

Sensitive Information

Depending on your use of the Platform, we may collect information that may be considered sensitive under some laws, including government identification data, financial account details, tax information, beneficial ownership details, sanctions screening results, verification materials, or information revealed in support or dispute documentation. We do not seek to use sensitive personal information to infer characteristics about you except as reasonably necessary to operate the Platform, verify users, detect fraud, process payments, comply with law, or support trust and safety functions.

3. Our Legal Basis for Using Personal Information

Where Applicable Law requires that we identify a legal basis for processing personal information, we rely on one or more of the following grounds.

We process information where necessary to provide the Platform to you, perform our contractual obligations, or take steps at your request before entering into a contract. We process information where necessary to comply with legal obligations, including tax, sanctions, fraud prevention, financial compliance, consumer protection, and lawful response obligations. We process information where necessary for our legitimate interests, such as operating, improving, securing, promoting, and supporting the Platform, preventing abuse, facilitating transactions, developing features, and protecting Spark Scout and its users, provided that those interests are not overridden by rights requiring a different outcome under applicable law. We may also process information based on your consent where required or where we choose to obtain consent, and you may withdraw consent in appropriate cases, subject to legal and operational limitations.

4. How We Use the Information We Collect

We use the information we collect for a wide variety of business, product, legal, security, and operational purposes.

We use information to create and administer Accounts, Spark Profiles, team workspaces, Campaigns, user communications, file storage, platform dashboards, notifications, recommendation systems, support functions, and other core Platform features. We use information to facilitate relationships and workflows between Brands, Agencies, and Creators, including matching, search, discovery, communications, campaign organization, proposal exchange, review systems, deliverable sharing, and other collaboration tools.

We use information to process or facilitate payments, refunds, payouts, escrow-related workflows, reserves, chargebacks, collections, reconciliation, tax reporting, and other financial operations in partnership with our Payment Partners. We use information to verify identity, verify business credentials, assess compliance status, confirm authority to act on behalf of an entity, detect fraud, screen against sanctions and restricted party lists, conduct trust and safety reviews, review suspicious activity, and support the integrity of the Platform.

We use information to personalize the Platform for you, including tailoring recommendations, rankings, search results, suggested connections, campaign opportunities, communications preferences, and user experience. We use information to maintain, troubleshoot, improve, and develop the Platform, including through analytics, quality assurance, bug fixing, performance monitoring, feature testing, and research. We may use information in connection with AI-powered tools or integrations to operate, maintain, improve, secure, and evaluate such tools, subject to this Privacy Policy and any feature-specific notices.

We use information to communicate with you, including sending service messages, support responses, security notices, transactional communications, policy updates, verification requests, payment alerts, legal notices, and other operational communications. We may also use information for marketing purposes, including sending newsletters, promotional messages, event invitations, product announcements, and platform-related communications, subject to your preferences and Applicable Law.

We use information to comply with legal obligations, enforce our Terms and policies, investigate complaints, respond to lawful requests, resolve disputes, protect the rights, safety, and property of Spark Scout and others, and support legal claims or defenses. We also use information to create aggregated, pseudonymized, anonymized, or de-identified insights, reports, benchmarks, and analytics for product, research, operational, marketing, and business purposes, to the extent permitted by law.

5. Direct Marketing

We may use your information to send you direct marketing communications about Spark Scout, the Platform, product updates, new features, promotions, events, or related offerings we believe may be relevant to you. These communications may be sent by email, in-app notification, push notification, SMS where enabled, or other means permitted by law.

Where required, we will obtain your consent before sending certain marketing communications. In other cases, we may rely on a lawful basis such as legitimate interests where permitted. You can opt out of marketing emails by using the unsubscribe link included in the message or by contacting us at legal@sparkscout.com. Opting out of marketing communications will not prevent us from sending you transactional, security, support, or other non-marketing communications.

6. How Long We Keep Personal Information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to provide the Platform, complete transactions, maintain records, resolve disputes, prevent fraud, support moderation and trust and safety functions, enforce our agreements, protect Spark Scout and others, and comply with legal, regulatory, tax, accounting, and operational requirements.

Retention periods vary depending on the type of information, the context in which it was collected, the nature of your relationship with Spark Scout, whether the information is needed to support open transactions or disputes, whether legal claims are anticipated, and whether the information must be preserved for tax, fraud prevention, sanctions compliance, moderation, or security purposes.

Even after account closure, we may retain some information for a period of time for compliance, enforcement, fraud prevention, chargeback defense, safety, legal preservation, and legitimate business continuity. We may also retain anonymized or de-identified information indefinitely to the extent permitted by law.

7. Children

The Platform is intended for adults and is not directed to individuals under 18 years of age. We do not knowingly collect personal information from children under 18 through the Platform. If we learn that we have collected personal information from a child in violation of applicable law, we may delete that information and take appropriate steps regarding the associated account or content. If you believe a child has provided us information in violation of this Policy, please contact us at legal@sparkscout.com.

8. Sharing Personal Information with Third Parties

We share personal information with third parties only as reasonably necessary to operate the Platform, facilitate transactions, support users, comply with law, protect the Platform, or otherwise as described in this Privacy Policy.

We may share information with other users of the Platform where necessary for the operation of the Platform and the relationships it is intended to facilitate. For example, Spark Profiles, portfolio materials, messages, transaction information, reviews, proposals, campaign data, and related user content may be visible to or exchanged with other users according to the relevant feature, workflow, or privacy settings. Information you publish publicly or choose to share with other users may be copied, saved, or used by those users, and Spark Scout cannot guarantee how other users will handle information you share.

We share information with service providers, contractors, and vendors that help us operate the Platform. These may include hosting providers, payment processors, customer support tools, fraud prevention vendors, cloud storage providers, communication vendors, analytics and diagnostics providers, AI service providers, identity verification vendors, sanctions screening vendors, legal and accounting advisers, marketing service providers, and other operational partners. These parties may process information on our behalf or in support of services you request, subject to contractual and legal safeguards where applicable.

We may share information with Payment Partners and financial institutions in connection with payment authorization, transaction processing, payouts, reserves, refunds, chargebacks, tax reporting, anti-fraud measures, anti-money laundering review, and financial compliance. We may share information with trust and safety providers, compliance vendors, legal authorities, regulators, law enforcement, or courts where required by law, where necessary to protect rights or safety, or where reasonably necessary to investigate fraud, abuse, sanctions violations, chargebacks, disputes, security incidents, or violations of our Terms and policies.

We may disclose information in connection with a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar business transaction, subject to customary protections and legal requirements. We may also disclose information with your consent, at your direction, or as otherwise permitted by law.

Finally, we may share aggregated, de-identified, pseudonymized, or anonymized information that does not identify you personally, subject to Applicable Law.

9. Where We Process Personal Information

Spark Scout is based in the United States. Personal information may be stored, processed, accessed, and transferred in the United States and in other jurisdictions where Spark Scout, its affiliates, service providers, or partners operate. Those jurisdictions may have data protection laws that differ from those of your place of residence.

If you access the Platform from outside the United States, you acknowledge that your information may be transferred to and processed in the United States and elsewhere, subject to this Privacy Policy and Applicable Law. Where required by law, we will implement appropriate safeguards for cross-border data transfers.

10. Cookies and Similar Technologies

We use cookies and similar technologies to operate the Platform, remember preferences, authenticate users, analyze traffic, measure campaign performance, support fraud prevention, enhance security, personalize experiences, and support marketing and attribution efforts.

These technologies may include browser cookies, local storage, SDKs, pixels, web beacons, scripts, device identifiers, and similar mechanisms. Some are essential to make the Platform function properly. Others help us understand how the Platform is used, diagnose problems, evaluate feature adoption, improve performance, or measure marketing effectiveness.

You may be able to manage cookies and tracking technologies through browser settings, device settings, or consent tools where provided. If you disable certain cookies or technologies, some parts of the Platform may not function properly.

11. Do Not Track

Some browsers transmit "Do Not Track" signals. Because there is no universally accepted standard for responding to such signals, Spark Scout may not respond to browser-based Do Not Track signals except where required by Applicable Law. Where legally required, we may honor recognized browser-based opt-out preference signals for applicable data uses.

12. External Links and Third-Party Features

The Platform may contain links to third-party websites, products, services, and social media features. If you follow links to external sites or interact with third-party services, your information may be governed by the privacy policies and terms of those third parties, not this Privacy Policy. Spark Scout is not responsible for the content, privacy, security, or data practices of third-party websites, services, or integrations.

13. Security

We implement reasonable administrative, technical, organizational, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, destruction, or loss. These measures may include access controls, encryption where appropriate, network protections, logging, incident response procedures, contractual vendor controls, and internal policies.

However, no security system is perfect, and no method of transmission over the internet or method of storage is completely secure. As a result, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your credentials and for notifying us promptly if you suspect unauthorized access to your Account or information.

14. Deleting or Updating Personal Information

We take reasonable steps to keep personal information accurate and up to date and to provide mechanisms for users to access and update certain information associated with their Accounts. You may be able to update some information directly through your Account settings or Spark Profile. You may also contact us to request access, correction, or deletion, subject to Applicable Law.

If you request deletion of your personal information, we will evaluate your request and respond in accordance with applicable law. In some circumstances, we may retain certain information despite a deletion request, including where necessary to complete transactions, maintain records, comply with legal obligations, detect or prevent fraud, resolve disputes, enforce agreements, or protect Spark Scout, users, and the public.

If you delete User Content or close your Account, copies may remain viewable in backups, logs, records, shared conversations, cached pages, archived environments, or in data stored by other users who accessed or copied that content. Proper access and use of content shared through the Platform remains governed by our Terms of Service and applicable law.

15. Specific Provisions for EU, EEA, and UK Users

If you are located in the European Union, European Economic Area, or the United Kingdom, additional rights may apply under applicable data protection law.

For purposes of those laws, Spark Scout, LLC. may act as a controller with respect to personal information processed under this Privacy Policy, except where Spark Scout acts strictly on behalf of another controller or customer under a separate agreement.

Subject to applicable conditions and exceptions, you may have the right to request access to your personal information, request correction of inaccurate data, request deletion of personal information, request restriction of processing, object to certain processing, request portability of information you provided to us, and withdraw consent where processing is based on consent. You may also have the right to object to certain profiling or direct marketing processing.

You may exercise these rights by contacting us at legal@sparkscout.com. We may need to verify your identity before fulfilling a request. We may also refuse or limit requests where legally permitted, including where doing so would adversely affect the rights of others, interfere with fraud prevention or legal compliance, or require disproportionate effort under applicable law.

If you believe that our processing violates applicable data protection law, you may have the right to lodge a complaint with a supervisory authority in your jurisdiction.

16. Specific Provisions for U.S. Residents

If you are a resident of a U.S. state with an applicable privacy law, you may have certain rights, subject to exceptions and limitations. These may include the right to know whether we process your personal information, the right to request access to certain personal information, the right to request correction of inaccurate information, the right to request deletion of certain personal information, the right to request portability of certain information, and the right to opt out of certain uses or disclosures that may constitute targeted advertising, sale, or profiling under applicable law.

Spark Scout does not sell personal information for money in the traditional sense. However, certain disclosures involving analytics, attribution, marketing technologies, or advertising-related measurement may be characterized as "sharing" or targeted advertising under some U.S. privacy laws. If Spark Scout engages in such activity in a way that triggers opt-out rights, we will provide mechanisms to exercise those rights as required by law.

We will not discriminate against you for exercising privacy rights in a manner prohibited by law. To exercise applicable rights, contact us at legal@sparkscout.com. We may verify your identity and may require additional information to process your request. If you use an authorized agent, we may require proof of authorization and additional verification.

If your state law provides an appeals process and we deny your privacy request, you may appeal that decision by contacting legal@sparkscout.com.

17. Specific Provisions for International Users Generally

If you access the Platform from outside the United States, you understand that your information may be processed in jurisdictions with data protection standards that differ from those of your country. By using the Platform, you acknowledge such transfers and processing to the extent permitted by law.

Where required by Applicable Law, Spark Scout may rely on contractual safeguards, data transfer mechanisms, or other lawful bases for international transfers.

18. AI, Automated Processing, and Decision Support

The Platform may use automated systems, algorithms, and AI tools to support search, matching, recommendations, moderation, fraud prevention, ranking, quality evaluation, workflow automation, and product improvement. These tools may process profile information, transaction data, behavior signals, content, metadata, and user activity.

Such tools are intended to support platform operations, trust and safety, personalization, and efficiency. They may influence what users see, how profiles are surfaced, which opportunities are suggested, or whether certain activity is flagged for review. However, Spark Scout may also involve human review in connection with trust and safety, moderation, compliance, disputes, or account enforcement.

If applicable law grants you rights relating to certain automated decision-making, you may contact us to inquire about those rights.

19. Mobile App and Device Permissions

If you use the Spark Scout mobile application, the app may request access to device features such as the camera, microphone, photo library, storage, files, notifications, or location. We request such permissions only to provide platform functionality, such as uploading content, sending messages, enabling notifications, participating in collaboration workflows, verifying identity, or supporting other services you choose to use.

You can manage permissions through your device settings. Disabling permissions may limit the availability or performance of certain features.

If the mobile app uses analytics SDKs, crash reporting tools, attribution tools, or similar mobile technologies, those tools may collect device identifiers, app events, usage metrics, performance data, and related information to support app operations, measurement, debugging, and security.

20. Aggregated, Anonymized, and De-Identified Data

We may aggregate, anonymize, pseudonymize, or de-identify personal information and other data collected through the Platform and use or disclose such information for analytics, benchmarking, product development, industry reporting, trust and safety insights, marketing, and other lawful business purposes. Where required by law, we will maintain such data in de-identified form and will not attempt to re-identify it except as permitted.

21. Business Transfers

If Spark Scout is involved in a merger, acquisition, reorganization, financing, sale of assets, bankruptcy, or similar transaction, personal information may be disclosed to counterparties, advisers, investors, lenders, or successors in connection with evaluating or completing the transaction, subject to appropriate protections where required.

22. Security Incidents

If Spark Scout becomes aware of a security incident involving personal information, we may investigate, contain, remediate, document, and disclose information relating to the incident as necessary to support response efforts, comply with law, protect affected individuals, preserve evidence, or cooperate with authorities. Where required by law, we will provide notifications to affected individuals or regulators.

23. Retention of Public Records, Dispute Materials, and Moderation History

Because Spark Scout is a multi-sided platform that supports profiles, communications, campaigns, moderation, and transactions, we may retain records relating to public content, reviews, ratings, reports, disputes, moderation actions, fraud investigations, payment investigations, compliance reviews, and related platform history as reasonably necessary to protect platform integrity, prevent abuse, defend legal claims, comply with law, and preserve institutional knowledge regarding trust and safety matters.

24. California Shine the Light Notice

To the extent applicable, California residents may request information about certain categories of personal information disclosed to third parties for their direct marketing purposes during the preceding calendar year, if any. Requests may be submitted to legal@sparkscout.com.

25. Nevada Privacy Notice

Nevada residents may have the right to submit certain requests regarding the sale of covered information under Nevada law. Spark Scout does not currently sell covered information for monetary consideration as defined by Nevada law. Requests may be submitted to legal@sparkscout.com.

26. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time. If we do, we will post the updated version on the Platform and revise the Last Updated date. If required by law, we will provide additional notice or obtain consent for material changes. We encourage you to review this Privacy Policy periodically.

Your continued use of the Platform after any updated Privacy Policy becomes effective constitutes your acknowledgment of the updated Policy to the extent permitted by law.

27. Contact Us

If you have questions, requests, complaints, or concerns regarding this Privacy Policy or our privacy practices, or if you wish to exercise rights available to you under applicable privacy law, you may contact us at:

Spark Scout, LLC.
Privacy Rights & Legal: legal@sparkscout.com
Support: support@sparkscout.com