Privacy Policy

Effective: 11 February 2019

This Privacy Policy (the “Policy”) describes how we collect, use, and share your personal data, as well as your choices and rights with respect to that personal data.


This is the Policy of Offer, LLC (“SparkOffer,” “us,” “our,” or “we”). You can contact us using the information in the “Contact Us” section below.


This Policy applies to our “Service” which includes our website located at or other website where this Policy is posted (the “Site”), and the SparkOffer Software as a Service platform (the “Platform”).


This Policy is incorporated into the Terms of Use governing your use of our Service. Any capitalized term not defined in this Policy will have the definition provided in our Terms of Use.



We provide the Platform to, and process information on behalf of users of our Service that are party to or engaged in a potential real estate transaction (“Transaction Parties”), including sellers and/or sellers’ agents (“Seller”) and buyers and/or buyers’ agents (“Buyer”); Buyers’ agents, Sellers’ agents, and any third-party agents engaged in a transaction will be referred to as “Agents”.

Please note, this Policy reflects only how we process Personal Data as part of our Service. This Policy does not apply to Transaction Parties’ processing of your information once it is made available to them, including in their interactions with financial institutions, attorneys, or other parties in the purchase and sale process. Similarly, this Policy does not apply to information processed by other third parties, for example, when you visit a third-party website or interact with third-party services unless we process information from those parties.

Please review any third parties’ privacy policies for information on their privacy practices.


In order to provide our Service, we may collect and process information that relates to identified or identifiable individuals (“Personal Data”). For example, we may collect information such as:

We typically collect Personal Data and other information from you, and use it in the following ways:

When you use the Platform

When you register on the Platform, you may do so as a Buyer, Seller, or Agent. When you register, we collect certain Personal Data, including your name, email address, phone number, username/password, and any other Personal Data or other information you provide in the registration form.

As part of your use of the Platform, we collect certain additional information relating to transactions you conduct through the Platform. For Buyers, we will collect certain information relating to any offers or other proposed transactions made through the Platform, such as pre-approval documents and certain Financial Information, offer amounts, and property information (“Buyer Transaction Data”). For Sellers, we may collect information such as property address, price, offer thresholds, property photos, and transaction history, such as accepted/rejected offers  (“Seller Transaction Data”).

We primarily use the information provided in connection with your registration as necessary to provide and support our Service, to connect Buyers and Sellers, and to process your requests. In addition, we may aggregate and analyze anonymized data from users registered on or listings posted through our Service to provide market research to third parties. We may also use your Personal Data to contact you about service administration, your experience using the Service, to improve our Service, and for our other business purposes.


In the event you complete a payment transaction, e.g. when you register for an account or purchase a service through our Platform that requires payment, we will collect relevant Payment Data from you. The Payment Data we collect may vary depending on the form of payment. For example, in the event we process a card payment for purchases, we (or our third party service provider) may collect your payment card number, expiration date, name, security code, zip code/address, and other information which may be required by your card issuer. Regardless of the information we collect, we will use Payment Data only to process your payments or charge your account for purchases you make through our Platform.

When you sign up for SMS or Text Message Notifications

When you register for or otherwise provide your consent to receive promotional SMS/texts from our Platform, you grant us your consent to use your phone number to send you informational and/or promotional or marketing-related SMS or text messages. In such cases, we or our partners may send you offers to perform services (such as inspections) or other similar messages that may solicit third party services or other services which may be relevant to your transaction or our Service.

If you register for only transaction-related SMS/texts, you agree that we may use your phone number to send you updates, such as notice of receipt or acceptance of an offer, regarding the availability of key documents, important deadlines, other similar features related to a transaction processed through the Platform.

Standard messaging rates may apply.

Contact Us and User Surveys/Feedback

If you contact us through the Service (e.g. through the “contact us” form, or if you sign up for updates about our product) we may request your name, email address, phone number, organization and any other information you provide in a free text field. We may also run periodic surveys where you can use our Service to submit feedback about your experience with the Platform. When we do so, we may collect your name and email, information about your transaction, Platform features and usability, and other information requested during the survey.

We use information from user feedback/surveys in connection with the improvement of our Service, and in certain cases we may create and share aggregate, anonymous information to third party users, marketers, and other parties.

Marketing Communications

We may process information such as your name, email address, and certain information about the device you use when you sign up for, or open, marketing communications from us. We generally use this data as necessary to provide marketing communications such as emails or texts, and in order to tailor those communications to individuals’ preferences and requests. Additionally, we may process additional data about devices receiving those marketing communications to understand whether our emails are opened or other aspects of engagement with those communications.

Service Usage

Our Service may identify users by their IP address (e.g. to determine the city from which you access the Service). We may also create access and use logs relating to how users access and use the Service. These logs may include information such as the page served, the time, device identifiers, the source and type of browser making the request, operating system and version, the most recent page view, and other similar information. We use this data for purposes of system administration, security, to improve the stability of and user experience with our Site, and for other similar purposes.

Cookies and Similar Tracking Technologies

We, and certain third parties, may process data about you and your device (such as IP address, operating system information, web browser and version number, ISP or wireless internet provider, and other information about your connection to the internet or the device you are using) when you interact with cookies and similar technologies in use on our Service. We may receive this data from third parties to the extent allowed by the applicable partner. Please note that the privacy policies of third parties may apply to these technologies and information collected. We generally collect and use this data as follows:

Note: Some of these technologies can be used by us and/or our third-party partners to identify you across services, devices, sites, and services.

Other Sources of Personal Data

If we process Personal Data in connection with our Service in a way not described in this Policy, this Policy will still apply generally (e.g. with respect to your rights and choices) unless otherwise stated when you provide it. Note that we may, without your consent, also process your Personal Data on certain public interest grounds. For example, we may process Personal Data as necessary to fulfill our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest. Please see the “Data Sharing” section for more information about how we disclose Personal Data in extraordinary circumstances.


Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the following categories of recipients:

Transaction Parties

As part of our Platform, we help you coordinate with parties to real estate transactions. Accordingly, we may share your Personal Data and relevant information with appropriate Transaction Parties. For example, if you are a Buyer, your Agent may have access to your Buyer Transaction Data (including relevant Financial Information) at any time after you upload it to the Platform. Similarly, a Seller’s Agent will have access to Seller Transaction Data at any time after you upload it to the Platform. When a Buyer submits an offer or initiates any communication with the Seller, the Platform will share relevant Buyer Transaction Data with the Seller, and relevant Seller Transaction Data will be shared with the Buyer when the Seller responds to an offer or other communication.

Service Providers

In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests, we may share any Personal Data with service providers or subprocessors who provide certain services or process data on our behalf.


In order to streamline certain business operations, implement certain features/functions of our Site, share promotions and content we believe would be of interest to you, and develop products and services that better meet the interests and needs of our customers, we may share any Personal Data we process with any of our current or future affiliated entities, subsidiaries, and parent companies.

Corporate Events

All Personal Data we possess may be processed if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.

Legal Disclosures

In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required (including, without limitation, for law enforcement or national security purposes), to prevent or respond to a crime, to investigate violations of our Terms of Use, or in the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

Other Disclosures

We may disclose any Personal Data in accordance with your consent, or on certain public interest grounds. For example, we may process information as necessary to fulfill our legal obligations, assert our legal rights, to protect the vital interests of any individuals, or other matters in the public interest.

Data Sale

Generally, we do not sell, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate in any way your Personal Data to third parties in exchange for monetary or other valuable consideration, except that we may make any disclosure or otherwise process Personal Data in connection with our provision of the Service to Agents or at our users’ request, and we may make any of the disclosures described in the “Data Sharing” section below.


Your Rights

Subject to our rights to limit or deny access/disclosure under applicable law, you have the following rights in your Personal Data. We may require that you provide additional Personal Data to exercise these rights, e.g. information necessary to prove your identity. You may exercise your rights by contacting us using the information in the “Contact Us” section. We will not discriminate against you, e.g. by charging a different price, or providing a different quality of service, if you choose to exercise these rights.

Please note: except in limited circumstances, we are unable to directly fulfill rights requests or receive complaints regarding Personal Data to the extent processing is at the discretion of, or otherwise controlled by Transaction Parties or other third parties (such as financial institutions, lenders, etc.). Please contact these parties directly for data rights requests that relate to such Personal Data, and we will assist the third party to the extent necessary in the fulfillment of your request.


You may receive a list of the categories and specific elements of Personal Data that we process and you may request a list of the parties that have received Personal Data from us for the purposes set forth in this Policy, each to the extent required and permitted by law.


You may correct any Personal Data that we hold about you to the extent required and permitted by law. You may be able to make changes to much of the information you provided directly via the Service via your account settings menu.


To the extent required by applicable law, you may request that we delete your Personal Data from our systems.

Data Export

To the extent required by applicable law, we will send you a copy of your Personal Data in a common portable format of our choice.

Regulator Contact

You have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.

California Rights

Residents of California (and others to the extent required by applicable law) may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year, may direct us to stop selling or disclosing Personal Data for certain purposes (if we have done so), and may request: (1) the categories of Personal Data it has collected about that consumer; (2) the categories of sources from which the Personal Data is collected; (3) the business or commercial purpose for collecting or selling Personal Data; (4) the categories of third parties with whom the business shares Personal Data; and (5) the specific pieces of Personal Data it has collected about that consumer.

Your Choices

You have the following choices regarding the Personal Data we process:

Consent & User Data

If you provide your opt-in consent to processing to the Platform, you may withdraw your consent to our processing at any time, to the extent required by law. Similarly, if you upload any user content (e.g. Financial Data), you can delete data you have uploaded through the system by accessing your account preferences. Note, however, you may be required to close your account in order to withdraw consent where your consent is necessary to perform essential aspects of the Service.

Direct Marketing

You have the choice to opt-out of or withdraw your consent to marketing communications. You may have a legal right not to receive such messages in certain circumstances, in which case, you will only receive direct marketing communications if you consent. You may exercise your choice via the links in our communications or by contacting us re: direct marketing.

Cookies & Similar Tech

If you do not want information collected through the use of cookies and similar technologies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. You must opt out of third party Service directly via the third party. For example, to opt-out of Google’s analytic and marketing Service, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out. To learn more about how to opt out of Google’s use of cookies for advertising or retargeting, visit Google’s Ads Settings, here. Please note, at this time, our Site does not respond to your browser’s do-not-track request.

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologiesto collect data on our users’ behaviour and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

Other Processing

You may have the right under applicable law to object to our processing of your Personal Data for certain purposes, including without limitation, situations where we process in accordance with our legitimate interests. You may do so by  contacting us  re: data rights requests. Note that we may not be required to cease processing based solely on an objection.


We implement and maintain reasonable security measures to safeguard the Personal Data you provide us. However, we sometimes share Personal Data with third parties as noted above, and we do not have control over third parties’ security processes. Please note, we do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.


We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically, and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.


Our Service is neither directed at nor intended for use by minors. Further, we do not knowingly collect Personal Data from minors. If we learn that we have inadvertently done so, we will promptly delete it. Do not access or use the Service unless you are 18 years old or older.


If you are accessing our Service from outside of the United States, any information provided will be transferred to us or our service providers in the United States. Regardless of where your information is collected or transferred, the information will be treated in accordance with this Policy. You consent to such transfer through your use of the Service.


This policy may change from time to time. We will post the most current version of this policy on our website with the effective date. Your continued use of the Service means you consent to the terms of any new Policy.


1 Mauchly, Irvine, CA 92618

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