BLUE SPARK WEBSITE PRIVACY POLICY

Effective Date:  [February 22, 2016]

[Blue Spark Energy Inc.] Blue Spark (“Blue Spark”, “we”, “our” or “us”) are committed to protecting and respecting your privacy.

Blue Spark provides access to the Blue Spark website, www.bluesparkenergy.net, and related URLs (the “Website”). If you do not agree to any of the provisions of this Privacy Policy, you should not use the Website.

1. SCOPE OF POLICY

This Privacy Policy, together with our Terms, available at [www.bluesparkenergy.net] (and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be collected, stored, used and disclosed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting the Website you are accepting and consenting to the practices described in this Privacy Policy.

2. COLLECTING INFORMATION

Personal information provided by you:

In general, you may visit our Website without submitting any personal information; however, you may submit your personal information to us by filling forms on the Website, including, without limitation, when contacting Blue Spark via the page: [http://www.bluesparkenergy.net/#contact_us]. “Personal information” refers to any information that you provide in connection with your use of the Website by which you can be personally identified. Personal information may include but is not limited to such things as your name, e-mail address, company and any other information which might reasonably be used to identify you. We only obtain personal information from you when you submit it to us, provide it through the Website or correspond with us by phone, e-mail or otherwise.

For example, you may choose to contact us regarding career opportunities, customer service issues or questions about this site, and we will use your personal information to help respond and for customer service purposes. Please note that you may not be able to use some features and services of the Website if you choose not to provide such information when requested.

Non-personal information we may collect automatically:

With regard to each of your visits to our Website, we may automatically collect information on how you use the Website, including:

    1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
    2. information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), content you viewed or searched for, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.

We may also receive information about you if you use any of the other websites we operate or the other services we provide.

3. COOKIES

When you visit or interact with our Website, we (or our third party service providers) may use cookies and other types of web technologies to collect technical and usage information. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We link the information we store in cookies to any personal information you submit while on our site. Most Internet browsers allow you to disable, turn the cookie feature off, or reject cookies entirely by changing the settings on your Internet browser. Changing these settings may affect your ability to use certain features and functions of the Website.

[For detailed information on our use of cookies please contact us via the following page: http://www.bluesparkenergy.net/#contact_us.]

4. USING YOUR INFORMATION

We may use information you give to us or that we collect from you in the following ways:

    1. to provide you with information, products and/or services that you request from us;
    2. to provide you with information about goods or services we offer that are similar to those in respect of which you have enquired or purchased;
    3. to assist Blue Spark in its development of the Website and other products and services;
    4. to ensure that content from our Website is presented in the most effective manner for you and for your computer;
    5. to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
    6. as part of our efforts to keep our Website safe and secure.

Where applicable, we will seek your express consent to send you information, including by way of commercial electronic messages. This consent is sought by [Blue Spark Energy Inc.] at [903 8 Ave SW #300, Calgary, AB T2P 0P7], and you can contact us via the following page: [http://www.bluesparkenergy.net/#contact_us]. If you wish to opt-out from receiving any communications from us, you may do so by clicking ‘Unsubscribe’ within the applicable communication.

Please be aware that, even if you have opted out of receiving marketing communications from us, we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the services we provide to you, or if you contact us with an inquiry.

5. DISCLOSURE OF YOUR INFORMATION

Our general policy is that we will not sell, trade, disclose, share or otherwise transfer to outside parties your personal information, unless you give us your consent or direct us to do so, or unless required by law. We may, however, share the information you provide to us or that we collect about you:

with selected third parties, including:

    1. any member of our group, which means our subsidiaries and our ultimate holding company and its subsidiaries;
    2. [advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;]
    3. [analytics and search engine providers that assist us in the improvement and optimisation of our site,]

and in limited circumstances, including:

    1. in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
    2. if Blue Spark or substantially all of Blue Spark’s assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
    3. in furtherance of building and developing the features and functionality of the Website and other services;
    4. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms & Conditions and other agreements; and
    5. to protect the rights, property, or safety of Blue Spark, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Where we transfer your personal information to a third party service provider to assist us to provide products and services, we require them to conform to our privacy standards and to allow us to audit them for compliance.

6. WHERE WE STORE YOUR DATA

The information collected by Blue Spark is hosted in [Canada] and is subject to [Canadian law]. If you are accessing our Website from other jurisdictions, please be advised that you are transferring your personal information to us in [Canada] where data protection and privacy laws may be less stringent than the laws of your country.  BY USING OUR WEBSITE, YOU CONSENT TO THE TRANSFER AND USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. The data that we collect from you may be transferred to, and stored in [Canada], and your personal information may therefore be subject to the laws of [Canada]. It may also be processed by staff operating outside [Canada] who work for us. By submitting your personal data, you agree to this transfer, storing or processing.

7. SECURITY AND RETENTION

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. We protect the personal information within our custody or control with appropriate organizational, technological and physical safeguards.

[We store personal information in electronic and physical files that are secure, and our security measures include secure on- and off-site storage, restricted access to records and data processing equipment, password protocols, and encryption and security software.  We conduct audits and monitor compliance with our privacy practices.]

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

In the event that we believe that the security of your personal information in our possession or control may have been compromised or could be at risk, we may seek to notify you. If a notification is appropriate, we would endeavour to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.

We only retain personal information for as long as is necessary for the purpose for which it was collected. When we no longer are required to retain the information, we will destroy, erase, or de-identify the information. Legal requirements, however, may require us to retain some or all of the personal information we hold for a period of time that is longer than that for which we might otherwise hold.

8. THIRD PARTY SITES AND SERVICES

The Website may contain links to other sites and services operated by third party service providers. Your use of third party services shall be solely between you and the third party, and subject to the applicable terms and conditions from such third party. You acknowledge and agree that we are not responsible or liable for the availability or accuracy of, and we do not endorse, such websites or resources or the content, products, or services on or available from such websites or resources. You acknowledge sole responsibility for and assume all risk arising from your use of any such third party websites or services.

9. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be amended from time to time. Any such changes will be notified via email, notification on the home page, and/or by highlighting the update next to the link to this Privacy Policy.

10. ACCESS, CORRECTION AND ACCOUNTABILITY

We will strive to keep all personal information in our files complete, up-to-date and accurate.

You or a person authorized on your behalf has the right to request to see and obtain a copy of your personal information and to request changes or corrections to inaccurate or incomplete information.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [Blue Spark Energy Inc., 903 8 Ave SW #300, Calgary, AB T2P 0P7], or sent to Blue Spark via the following page: [http://www.bluesparkenergy.net/#contact_us].