GDPR Privacy Notice
This is privacy notice of Spark Communications Ltd.
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
- Who we are and important information
- The personal data we collect about you
- How we collect your personal data
- How we use your personal data
- Who we share your personal data with
- International transfers
- Data security
- Data retention
- Your legal rights
- Changes to this notice and your duty to inform us of changes
- Queries, requests or concerns
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website.
This website is not intended for children and we do not knowingly collect data relating to children.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Spark Communications Ltd is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice). Our contact details are Spark Communications Ltd, 3rd Floor, Century House, London W1D 1LN. Telephone
For all data matters contact Ana Williams or Kewal Varia on +44 (0) 207 436 0420.
Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We do not collect, use, store and transfer different kinds of personal data about you when you use our website. We only collect, use, store or transfer personal data that you provide by the methods outlined in section 3. for processing necessary for the performance of a contract or for compliance with a legal obligation.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We use different methods to collect data from and about you including through:
- Directly. You may give us your identity, contact and financial data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you become a supplier, client, interviewee, employee or request marketing data to be sent to you.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us by post: Spark Communications Ltd, 3rd Floor, Century House, 100-102 Oxford Street, London, W1D 1LN.
- Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Aggregate Information Usage
We may collect non-personally identifiable information, such as IP host address, pages viewed, browser type and other data, and may aggregate any information collected in a manner which does not identify any individual ("Aggregate Information").
We may use Aggregate Information to improve and enhance your experience on the Site and for our market research activities. For example, we may share Aggregate Information with unaffiliated third parties, such as business partners and clients, in an aggregate, anonymous form, which means that the shared information will not contain nor be linked to any Personal Information.
As you use the Internet, a trail of electronic information is left at each Web site you visit. This information, which is sometimes referred to as "clickstream data," can be collected and stored by a Web site’s server. Clickstream data can tell us the type of computer and browsing software you use and the address of the Web site from which you linked to the Site. We may collect and use clickstream data as a form of Aggregate Information to anonymously determine how much time visitors spend on each page of our Site, how visitors navigate throughout the Site and how we may tailor our Web pages to better meet the needs of visitors. This information will be used to improve our Site and our services. Any collection or use of clickstream data will be anonymous and aggregate, and will not intentionally contain any Personal Information.
Change of purpose
We will only use your personal data for the purposes for which we collected it.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties – Our employees for performance of a contract.
- External Third Parties Service acting as processors based in the UK who provide IT and systems administration.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors based in the UK who require reporting under certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your data outside of the European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by emailing [email protected]. By law we have to keep basic information about our customers including contact, identity, financial and transaction data for seven years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable 9i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact Kewal Varia by post Spark Communications, 3rd Floor, Century House, 100-102 Oxford Street, London, W1D 1LN.
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
This version was last updated on 24th of May and historic versions can be obtained by contacting us.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact Kewal Varia by post Spark Communications, 3rd Floor, Century House, 100-102 Oxford Street, London, W1D 1LN.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.