Privacy Policy

This Privacy Policy is as of March 15th, 2019

Welcome to Spark (the” Site”). We understand that privacy online is important to users of our Site, especially when conducting business. This policy governs our collection, use, retention and disclosure of your personal information (as defined below) when you use the Spark Site and make use of the various services offered by SPARK including medical consultation, education and related services (collectively,” Services”). By using this site, you expressly consent and agree to this Privacy Policy.

This Privacy Policy should be read together with Spark’s Terms of Use.

“Personal Identifiable Information”

“Personal Information” means (i) any information that identities or can be used to identify, contact, or locate the person including name, address, phone number, fax number, email address, financial profiles, social insurance number, and credit card information, as further defined under the federal Personal Information Protection and Electronic Document Act (“PIPEDA”) and (ii) personal health information within the meaning of Ontario’s Personal Health Information Protection Act, 2004 (“PHIPA”), and includes information relating to your physical or mental health, as well as your health history, medical records, prescriptions and your health card number.

Collection of Personal Information:

Spark may collect Personal Information from all visitors or users of the Site for the purpose of registering visitor as a patient of Spark and providing Spark services. We will collect additional Personal Information for the purposes of providing services.

Personal Information we may collect includes:

  • Given name, surname, address, telephone number, residential address, mailing address, and other contact information;
  • Gender, date of birth, daily dosage, primary symptoms/conditions, and other information set out on your medical document and registration materials;
  • If applicable, insurance coverage and payment information;

Any personal information or data that has been collected in which all personal identifiers have been removed, such that the information could not reasonably be used to identify you, is not considered Personal Information. This type of anonymized information may be used for research purposes, evaluating market trends, data analytics and similar activities relating to our business.

Use of Personal Information:

We use information that we collect about you or that you provide to us, including any personal information:

  • To customize our Site and its contents to you;
  • To personalize your experience with the Services by informing you of products, programs, events, services, and promotions of Spark, our affiliates, our partners and/or third parties that we believe may be of interest to you;
  • To provide, maintain, administer, improve, or expand the Services, perform business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
  • To provide you with information, products, or services that you request from us;
  • To fulfill any other purpose for which you provide it;
  • To allow you to participate in interactive features on our Site;
  • To track and analyze trends and usage in connection with our Services;
  • To better understand who uses the Services and how we can deliver a better user experience;
  • To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
  • To prevent, detect, and investigate security breaches, fraud, and other potentially illegal or prohibited activities;
  • To enforce the legal terms that govern your use of the Services;
  • To protect our rights or property;
  • To administer and troubleshoot the Services;
  • At your discretion in connection with your participation in forums and other user-generated discussion; and
  • For any other purpose disclosed to you in connection with our Services.

If you do not want us to use your information to contact you about our own and third-parties’ goods and services that may be of interest to you, please adjust your user preferences in your account profile.

Disclosure of Personal Information:

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Online Privacy Policy, and we may disclose it to others without limitation for any purpose, in accordance with applicable laws and regulations.

We may disclose personal information that we collect, or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates so that they may use such information for the purposes described in this Privacy Policy.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
  • We may also disclose your Personal Information:
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • We may be required by law to disclose Personal Information to law enforcement bodies, provincial medical licensing bodies, and other regulatory or governmental bodies, or regulatory request.


Depending on a user’s browser settings, the Site may use cookies (a small text file that is stored on a user’s computer for record-keeping purposes) to deliver content according to the users’ preferences and to save the users’ password so that the user is not required to re-enter it while the user uses the Site. You have the option to modify, control or refuse to accept cookies from our Site from your browser setting. Some webpages from our Site may not function properly as a result. Spark uses internet protocol (IP) addresses to help identify users, gather broad demographic information about users of the Site, diagnose problems with Spark’s systems, and administer the Site.

Updating and Access to Your Personal Information:

It is important that the Personal Information we have in our records about you is accurate and current. If your Personal Information changes, you should notify us as soon as possible. If you want to review, verify or correct your Personal Information, please contact our Customer Care Team.

Links to Third-Party Websites:

We may provide links to third-party Websites for your convenience and information. If you access those links, you will leave the Site. Spark does not control those sites or their privacy practices, which may differ from the practices outlined in this Privacy Policy. Please review the privacy policies of every Website that you visit.

Third-Party Service Providers:

Your Personal Information may be shared with third-party information technology, data and payment processing and other service providers engaged by us who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf.

Changes to this Privacy Policy:  

From time to time, we may change and update this Privacy Policy – the information we collect, the way we use that information and the options you have as a visitor/user of this Site – by providing you with notice by email at the address you provided as part of your registration; providing you with the opportunity to review the amended Privacy Policy; and requiring that you accept the amended Privacy Policy prior to being permitted to continue to access and use the Site.

Spark Privacy Contact:

Should you have comments or questions about this Privacy Policy, you may contact us at: by indicating PRIVACY POLICY in the subject line of your message.