Spark Alliance UK Ltd (“Spark Alliance”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use and protect personal data when you visit our website at spark.club (the “Website”), contact us, or deal with us in a business capacity.
1. Who we are
Spark Alliance UK Ltd is a company registered in England and Wales (company number 16935061), based in London. We are the controller of your personal data for the purposes of the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.
Contact: info@sparkclub.co.uk
2. Information we collect
We aim to collect only the personal data we need.
Website visits: when you visit the Website, certain technical information is processed automatically to deliver and secure it. This may include your IP address, browser type, operating system, the date and time of access, and the pages you request.
Enquiries: if you contact us by email or through the contact form on the Website, we process the information you provide, such as your name, email address, company, job title and the contents of your message.
Business contacts: if you represent a client, manufacturer, supplier, partner or other organisation we work with or may work with, we may hold your business contact details (name, job title, company, work email and telephone number) and records of our communications. We may obtain these directly from you, from your organisation, from introductions, or from publicly available professional sources such as company websites and LinkedIn.
We do not use the Website to collect personal data for advertising or behavioural profiling.
3. How we use personal data and our lawful bases
| Purpose | Lawful basis |
|---|---|
| Operating, maintaining and securing the Website, and preventing misuse, fraud or security incidents | Legitimate interests (keeping the Website available and secure) |
| Responding to enquiries and managing our communications with you | Legitimate interests (responding to people who contact us), or steps taken at your request before entering into a contract |
| Developing and managing business relationships with clients, manufacturers, suppliers and partners | Legitimate interests (running and growing our business), or performance of a contract |
| Complying with legal and regulatory obligations | Legal obligation |
| Establishing, exercising or defending legal claims | Legitimate interests |
We do not sell personal data, and we do not make decisions about you based solely on automated processing.
4. Cookies and similar technologies
The Website does not use advertising or analytics cookies. We may use strictly necessary cookies or similar technologies where required for the Website to work securely and properly. For more information, please see our Cookie Policy.
5. Who we share personal data with
We share personal data only where necessary, with:
- service providers acting on our behalf, including Webflow (Website hosting) and our email and IT providers;
- other Spark Alliance offices (including in Switzerland and Italy), where needed to respond to you or manage a business relationship;
- professional advisers, such as lawyers and accountants; and
- regulators, law enforcement or other authorities where required by law.
We require our service providers to protect personal data and to use it only on our instructions.
6. International data transfers
Some of our service providers, and other Spark Alliance offices, are located outside the UK. Switzerland and the countries of the European Economic Area are recognised under UK law as providing adequate protection for personal data. Where we transfer personal data to other countries, such as the United States, we rely on appropriate safeguards. These include UK adequacy regulations (for example, the UK Extension to the EU–US Data Privacy Framework) or the International Data Transfer Agreement or Addendum issued by the Information Commissioner’s Office.
7. Data retention
We keep personal data only for as long as necessary for the purposes described in this policy, or as required by law. As a guide:
- Website technical logs are kept for the period set by our hosting provider, typically up to 12 months;
- enquiry correspondence that does not lead to a business relationship is kept for up to 2 years; and
- records relating to business relationships are kept for up to 6 years after the relationship ends, in line with legal and accounting requirements.
8. Security
We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access.
9. Your rights
Under UK data protection law, you have the right to:
- request access to your personal data;
- ask us to correct inaccurate data;
- ask us to delete your data;
- ask us to restrict how we use it;
- object to processing based on our legitimate interests, including any direct business communications; and
- request data portability, where applicable.
To exercise these rights or ask about our privacy practices, contact us at info@sparkclub.co.uk. We will respond within one month.
You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk or on 0303 123 1113. We would welcome the chance to address your concerns first, so please contact us before going to the ICO.
10. Changes to this Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our Website, our activities or legal requirements. The latest version will always be available on this page.