Privacy Policy

Privacy Statement

CR Spark (collectively and individually referred to as “CR Spark”), (“we,” “us” or “our”), respects your right to data privacy and will keep secure and confidential all personal and sensitive information that you may provide to us, and/or those that we may collect from you (“Personal Data”).

This privacy policy describes (1) the Personal Data CR Spark collects, (2) how that information is processed, and (3) the steps you could take if you want to exercise your rights as a data subject.

This privacy policy applies to all websites and mobile applications (mobile and web-based) owned by CR Spark.

Please note that your web browser or client software may transmit certain information to the servers that host the websites you visit. The information may include the unique number assigned to your server or internet connection, the capabilities and features of your computer, your geographic location, and your movement within and interaction with the website or application, including what pages you look at and what information you download. When you visit the CR Spark website, our servers collect such information. CR Spark uses this information to generate aggregate statistics about its website’s visitors.

Why We Process with Personal Data

We collect, use, store, retain, disclose, dispose, and process your Personal Data to fulfill specific purposes which we inform you, our data subjects, through privacy notices and statements, forms and other relevant media or documents.

In general, we process your Personal Data for any of the following purposes:

To provide information about our products and services which may be of interest to you.
To respond to your requests and queries when you communicate with us through chat channels, voice calls, emails, contact boxes, or other forms of messaging.
To perform functions necessary to deliver CR Spark products and services.
To respond to specific inquiries, requests or manage future interactions.
To monitor the quality of our products and services.
To ensure your safety and security.
To generate statistical insights.
To conduct research and analysis (through surveys or polls) to improve customer experience or satisfaction.
To create photo or video documentation for events which are used for reporting and other internal purposes, such as promotional activities and advertisements in social media pages and websites, etc.
To personalize CR Spark’s websites and applications and generate information on possible improvements thereon.
To comply with legal and regulatory requirements; and,
To perform other processes or disclosure that may be required under law or regulations.
CR Spark may also use your Personal Data depending on the nature of your business with us:

A.) When you want to become a part of our team:

To consider and evaluate your suitability for employment.
To communicate with you about your employment application.
When hired, to process Personal Data necessary for your employment including, but not limited to, payroll, benefits application, allowances, refunds and reimbursement processing, tax processing, retirement benefits, and other relevant purposes that demand processing of your Personal Data (e.g., to execute business transactions directly related and/or incidental to your job, business travels, anniversaries, social activities, emergencies, etc.).
While employed, for your performance evaluation and career development including seminars, trainings, workshops, and compliance monitoring.
Upon separation, to process your exit clearance, exit interview, and preparation of your final pay; and
To comply with legal and regulatory requirements based on labor laws.
To perform Know-Your-Employee (KYE) screenings and background investigation as required under any applicable regulations.

If you are not hired, we will obtain your consent to retain your Personal Data one (1) year from the date of your application so we could offer potential employment for future job openings that would fit your skill set or competencies.

Protecting Your Personal Data

We take reasonable steps to ensure that the Personal Data we collect, use, or disclose is accurate, complete, and up to date. We strictly enforce this Privacy Policy within CR Spark, and we have implemented technological, organizational, and physical security measures to protect your Personal Data from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration, or destruction. We put in effect safeguards such as the following:

We keep and protect your Personal Data using secured servers behind a firewall.
We employ encryption on computing devices and physical security controls.
We restrict access to your Personal Data to qualified and authorized personnel who hold your Personal Data with strict confidentiality.
Personal Data that you provide to us through our website and applications can only be accessed and processed by authorized personnel through secure connections and environments.
We employ standard physical safeguards and measures such as fire suppression systems, role-based room access, and the like.

Retention of Personal Data

Generally, we adhere to the following Personal Data retention standards:

If the data subject has an existing employment contract and business with CR Spark, the Personal Data will be retained all throughout the contract period and ten years after its completion.
If the data subject has no existing contract but has existing business with CR Spark, the Personal Data will be retained during the business and ten years after its fulfillment.
If the data subject has no existing contract and business with CR Spark, the Personal Data will be retained for a period of ten years.

Personal Data are stored in secure facilities and are retained in accordance with the above parameters, industry standards, laws, and regulations, unless you request that your Personal Data be deleted from our systems, databases, and hardcopies within a reasonable time, and subject to limitations stated in relevant laws and rules. Once deleted, your Personal Data will no longer be searchable or included in anonymous searches and will be completely removed from all storage locations. The Data Privacy Officer may, however, choose not to grant access or correct information based on the request to comply with relevant laws and regulations. The DPO will give the individual a written notice that sets out the reason for the refusal.

CR Spark has no control and therefore cannot enforce the same amount of security on any of the devices and applications that you use to access our site or applications, or to send us your Personal Data. We are therefore not responsible for the security and protection of information that may have been intercepted prior to our receipt of your Personal Data. Personal Data are stored in secure facilities and are retained in accordance with the above parameters, industry standards, laws, and regulations, unless you request that your Personal Data be deleted from our systems, databases, and hardcopies within a reasonable time, and subject to limitations stated in relevant laws and rules. Once deleted, your Personal Data will no longer be searchable or included in anonymous searches and will be completely removed from all storage locations. The DPO may, however, choose not to grant access or correct information based on the request to comply with relevant laws and regulations. The DPO will give the individual a written notice that sets out the reason for the refusal.

Updates to the Privacy Policy

CR Spark may revise this Privacy Policy as the need arises or when dictated by issuances of the Costa Rican Data Protection Authority (‘PRODHAB’), the enforcement by PRODHAB and compliance by the Republic of Costa Rica or any amendment to the Law on the Protection of Persons Regarding the Processing of their Personal Data No. 8968 of 2011 (‘the Law’) and Executive Decree No. 37554-JP of October 30, 2012, Regulating Law No. 8968 (‘the Executive Decree’), as amended by Decree No. 40008-JP (‘the Decree’). Any change to this Privacy Policy shall be duly posted on this website and will take effect immediately. Data subjects are encouraged to periodically check for such updates. Changes shall not be retroactively applied and will not alter how we handle Personal Data previously collected without obtaining your consent, unless required by law.