TrySparrow.com Inc. (“Sparrow”) provides a platform and related services to enable employer customers (“Customers”) to manage employee leaves of absence. Sparrow provides its services in part through its website at TrySparrow.com (the “Site”).

This Privacy Policy is intended to help you better understand how we process your personal information. It governs how Sparrow may collect, use, store and disclose the personal information we obtain through the Site and by operating Sparrow’s employee leave services, as well as other personal information we obtain in connection with the use of Sparrow’s social media pages (collectively, the “Services”). Your privacy is important to us, and we work hard to protect it. Please review this Privacy Policy carefully. By using the Services or submitting information through any aspect of the Services, you agree to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services.

1. Personal Data We Collect

We collect information that does or could be used to identify you (“Personal Data”). The information we collect and how it is used depends on how you use our Services and how you manage the privacy controls that may be available to you via the Services.

Personal Data Collected on Behalf of Our Customers:

If you are a Customer or an employee of a Customer who works to help that Customer manage employee leaves, Sparrow may collect the following Personal Data to respond to your requests, help a Customer decide whether to use the Services, and/or to use the Services:

• Name
• Job Title
• Company Name
• Email
• Phone
• Location

If you are an employee of a Customer for whom we are providing our Services to help the Customer manage your leave of absence, our performance of the Services requires an interactive process with an exchange of Personal Data and other information between Sparrow, the Customer, you, your medical providers, and the appropriate state agency or insurance provider processing your leave claim. We collect and process this information only as a processor/service provider for the applicable Customer, and only to provide Services to that Customer.

The Personal Data we collect about an employee to help administer their leave of absence on behalf of the applicable Customer may include, but is not limited to:

• Name
• Email
• Phone
• Location
• Social Security Number
• Date of Birth
• Medical information
• Employment history
• Employee compensation history to facilitate payment during paid leave
• Basic newborn child information, including SSN, as applicable
• Additional information, if any, required by applicable state agencies

Personal Data Users Provide to Us on Our Site or our Social Media Pages:

We collect Personal Data that you provide to us if you are on our Site and/or on our social media pages on sites like Instagram, Facebook, Medium, Twitter, and LinkedIn (“Social Media Pages”). The Personal Data collected during these interactions may vary based on what you choose to share with us, but it will generally include:

• Name
• Job Title
• Company Name
• Email
• Phone
• Location
• Content posted on the Sparrow Social Media Pages

If you apply through the Site for an open job listing at Sparrow, we will collect the information that you provide and this normally includes your name, contact information and location, your resume or CV, and any cover letter that you provide.

Personal Data We Receive Automatically From Your Use of the Site:

We collect certain information about your use of our Site. For example, we may monitor the number of people that visit the Site, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), which browsers people use to access the Site (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), and broad geographical information and navigation patterns. This includes things like:

• Log data, including your Internet Protocol (IP) address, browser type and settings, the date and time of your request, and how you interacted with the Site.
• Device information, including the name of the device, the operating system, and the browser you are using. Information collected may depend on the type of device you use and its settings.
• Usage Information, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.

Personal Data Collected by Cookies and Similar Tracking Technologies

We use cookies and similar technologies to operate and administer our Site, gather usage data on our Site and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies) and others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it) to help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more information about cookies and how to disable them see “Your Choices” below. Our use of cookies and similar technologies also includes the following:

• Email Pixels: We may use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.
• Analytics: We work with third party analytics providers who use cookies and other technologies to help us understand how our users engage with our Site. For example, we use Google Analytics, a web analytics service that uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

2. How We Use Your Personal Data

If you are an employee whose leave is being administered by your employer/our Customer with the use of our Services, please check with the Customer directly about the policies and settings it has in place with respect to how they handle the privacy and security of your personal information in connection with administering your leave.

Sparrow may use Personal Data to provide the applicable Services to the Customer and for the following purposes:

• To give you the ability to participate in the interactive features of our Services when you choose to do so;
• To respond to your inquiries, comments, feedback or questions and provide Customer and applicable employee support;
• To send administrative information to you, for example, information regarding the Services, and changes to our terms, conditions, and policies that apply to you;
• To analyze how you interact with our Site and Social Media Pages;
• To maintain and improve the content and functionality of the Services;
• To detect, investigate, and prevent security incidents, fraud, illegal activity, or misuses of our Services; and
• To comply with legal obligations (such as responding to court orders or other legal processes) and to protect our rights, safety or property, and that of our affiliates, you, other users, or other third parties that we work with to provide the Services.

Aggregate Information:

We may create and derive anonymized and aggregate data from your Personal Data that does not identify you, and use this anonymized and aggregate information to analyze the effectiveness of or improve our Services, and for other legitimate business purposes. We may share such information (for example, general user statistics) with prospective business partners. We may collect aggregate information through the Services, through cookies, and through other means described in this Privacy Policy. Such anonymized and aggregated information is not Personal Data.

Marketing:

If you provide us with your contact information as part of an inquiry about our Services, we may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. You may opt out of marketing from us at any time. See Your Choices below.

3. Sharing And Disclosure Of Personal Data

We may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

Vendors and Service Providers:

To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers. Per our instructions, Sparrow requires that these parties will only access, process or store Personal Data in the course of performing their duties to us and only to the extent necessary to provide these services to us.

Permitted Third Parties and Customer Administrators on Behalf of a Customer:

On behalf of a Customer and under the terms of our agreement with a Customer, we may share Personal Data with permitted third parties solely to provide the Services (e.g. employee’s medical provider or the appropriate state agency or insurance provider processing an employee’s leave claim). In addition, if you are an employee of a Customer that uses our Services to process your leave, your administrator may have the ability to access and control your account and Personal Data. Please refer to your organization’s internal policies if you have questions about this.

Business Transfers:

We may transfer personal information to our successor as part of any merger, sale of our company assets, or the acquisition of all or a portion of our business by another company, including without limitation, as part of a reorganization, bankruptcy or receivership.

Legal Requirements:

If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability. Sparrow will only disclose your Personal Data to third parties necessary to fulfill the obligations of our agreement with the Customer and to provide our Services and as otherwise set forth in this Privacy Policy. Sparrow will not sell your Personal Data.

4. Data Retention

We keep Personal Data only for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so in order to provide the Services to you, or as required by law (e.g. for legal, regulatory, or compliance purposes), whichever is the longer and for the duration of any period necessary to establish, exercise or defend any legal rights. In order to determine the most appropriate retention periods for your Personal Data, we consider the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal data, and applicable legal requirements.

5. Your Choices

Update Your Information

If you have an account with us, please log in to your account or contact us at support@trysparrow.com if you need to change or correct your Personal Data.

Cookies:

Most web browsers are set to accept cookies by default, but if you prefer, you can set your browser to not accept cookies. Please note that if you set your browser to limit cookies, you may not be able to benefit from the full content or functionality of the Site or the Services. If you access the Site and/or the Services on your mobile device, you may not be able to control tracking technologies through the settings.

Marketing:

You may opt out of marketing communications from us by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us at hi@trysparrow.com. If you opt out, you will no longer receive marketing communications but we may continue to contact you regarding administrative matters like management of your account and responding to your requests.

If you are not a Customer or the employee of a Customer where we are required to use your information to administer the Customer’s account or to process leaves for that Customer, then you may opt out of our Services at any time by ceasing to use our Services. If you are an employee of a Customer, you should contact your employer if you want to:

• Access and/or receive a copy of your Personal Data
• Rectify, erase, restrict, or withdraw the use of your Personal Data. These rights are not absolute and they do not always apply in all cases.

In certain circumstances where we are not administering a Customer account, providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data as we mention above.

Please understand that we try to request only that information necessary for us to fulfill our duties when processing employee leaves, if you do not provide us with access to the necessary information, we may not be able to file or manage the leave process for the applicable employee.

If you wish to exercise any of your rights above or have any concerns about how we use your data, please contact us at support@trysparrow.com

6. Children

We do not knowingly collect any Personal Data from children under the age of 13 and our Services are not directed to children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to Sparrow through the Services please contact us and we will endeavor to delete that information from our databases.

7. Links to Other Websites

The Site may contain links to other websites not operated or controlled by Sparrow, including our Social Media Pages (“Third Party Sites”). The use of the information that you share with Third Party Sites by those Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed those sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

8. Security

We maintain industry standard administrative, physical, and technical safeguards reasonably designed to protect the security of Personal Data from unauthorized access, use, modification, and disclosure. However, no Internet or e-mail transmission is ever fully secure or error free.

9. International Transfers

Sparrow is based in the United States. The personal information that we collect is sent to and stored on secure servers located in the United States. Such storage is necessary in order to process the information. Information provided to us or collected by us likely will be transferred to and processed in the United States by us or our agents and contractors. The data protection laws of the United States or other countries may not be as comprehensive or equivalent to those in your country of residence.

10. Changes to the Privacy Policy

Sparrow may change or update this Privacy Policy from time to time. When we do, we will post an updated version on our Site. If you are a registered user of the Services, as a Customer or an employee of a Customer and if a revision meaningfully reduces your rights, we will notify you via the email that we have on file for you. Please review this Privacy Policy regularly to stay informed about our information practices.

11. Contact Us

Sparrow welcomes your questions or comments regarding this Privacy Policy. You may contact Sparrow at privacy@trysparrow.com.