Privacy Notice

1. Introduction and who we are

SPRK Capital Limited (“SPRK“, “we“, “our” or “us“) are strongly committed to being responsible custodians of the personal information you provide us and the personal information we collect in the course of operating our business.

This Privacy Notice explains how SPRK, as a data controller, may collect, use, share and protect information that we obtain about you directly or indirectly in accordance with applicable data privacy laws.

We take the security of personal information very seriously.

This Privacy Notice does not apply to, and SPRK is not responsible for, any third party websites which may be accessible through links from this website.

Scope of Privacy Notice

This Privacy Notice explains and describes:

When this Privacy Notice applies.
How we collect your personal data.
Legal basis for usage of your personal data.
How we use the personal data we collect.
How and when we may disclose personal data that we collect.
What happens if your personal data is transferred overseas.
How long we hold your personal data.
How we protect your personal data and keep it secure.
What cookies are and how we use them.
What happens when you access third-party services and content.
Your legal choices and rights.
The status of this Privacy Notice and any changes that are made to it.
How to request further information and our contact details and.

2. When this Privacy Notice applies

This Privacy Notice applies to the personal data we process:

as part of your, your company and/or your employing organisation’s use of any of our services (including our online services);
where you apply to us for a job or work placement; and
as part of your, your company and/or your employing organisation’s supply of services to us.

This Privacy Notice also applies to the personal data we process in relation to our website and online services, and any other website, mobile app or other online service created or hosted by us from time to time on which this Privacy Notice appears (together, our “online services“).

Please note that our online services make use of cookies and similar technologies, as described in more detail in section 10 (Cookies Policy) below.

3. How we collect your personal data

“Personal data” is any information that can be used to identify you or that we can link to you.

Where you use our services, we will collect personal data provided directly to us.

We collect personal data that you voluntarily provide to us, including:

when you complete forms online (this includes information you give us when you submit material (such as personal identification documents), request services, enter competitions, register for any of our offerings (including online offerings) or subscribe to our newsletters or other services);
when you participate in competitions, live chats and message boards;
when you communicate with us via email or other channels (including in person, by telephone or online), including to report a problem with our services or raise a query or comment;
when you sign up for or request that we send you newsletters, alerts, or other materials;
when you sign up for a webinar or event;
when you respond to our communications or requests for information; and
where our online services require that you enter a password or other information in order to access certain features.

The information you provide may include current and historical personal data such as: your name; your password and other credentials; contact details; title; personal identification documents (where we are obligated to gather personal data for anti-money laundering identification purposes); enquiry/complaint details; and the organisation with which you are affiliated.

If you are an owner or a director of a company applying for our services, we will collect personal data about you from:

third party identity verification providers. The information we will collect includes: your name; address history; electoral roll information; and whether any country court judgments have been entered against you; and
credit reporting agencies. The information we will collect includes: your personal credit score; your address history; other electoral roll information; and your registered ownership or directorships of other companies.

When you use our online services in any capacity, we collect details of visits, including, but not limited to, the volume of traffic received, logs (including, where available, personal information such as the IP address and location of your device and other technical information and identifiers about your device and the nature of the visit) and the resources accessed.

We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review.

If you apply for a job or work placement with SPRK then you may need to provide information such as your name; contact details; title; education and employment status and history (i.e. CV details); and references.

We may carry out screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks) and consider you for other positions.

We may also gather additional information about you from publicly available resources such as LinkedIn or other social or professional media platforms and collate this with the information that you provide to us. Without your personal data, we may not be able to progress considering you for positions with us.

If you supply services to us, we may collect personal data about your other dealings with us and, to the extent that you, your company or your employing organisation are a supplier to us, your dealings with our clients.

The information you provide may include current and historical personal data such as: your name; contact details; title; and the organisation with which you are affiliated; and any other information you provide to us in the course of providing and/or agreeing to provide the services.

4. Legal basis for usage of personal data

Where we process your personal data, we rely on the following legal grounds:

Performance of a contract: We may need to collect and process your personal data to enter into a contract with you or to perform a contract that you have with us. This could include an employment contract or a personal guarantee.

Legitimate interests: We may collect and process your personal data where we consider it to be in our legitimate interests, or those of a third party. Where we use your personal data for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you.

Our legitimate interests do not automatically override yours and we will not use your information if we believe your interests should override ours, unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details in section 12 (Your Rights) below.

Our legitimate interests include:

for our own direct marketing or continued communication;
the prevention of fraud;
our own internal administrative purposes;
personalisation of the service(s) we provide to you;
ensuring network and information security, including preventing unauthorised access to electronic communications networks and stopping damage to computer and electronic communication systems; and/or
reporting possible criminal acts or threats to public security to a competent authority.

Compliance with a legal obligation: We may be required to process your information for the purpose of complying with a legal obligation, including anti money laundering laws, employment laws, tax laws and other regulatory provisions applicable to SPRK as a provider of R&D credit services.

Consent: You may be asked to provide your consent in connection certain processing, for example, for our marketing purposes where you, your company or your employing organisation is not a client of SPRK.

Where we are reliant upon your consent, you may withdraw this at any time by contacting us in accordance with section 14 (Contact and further information) below; however, please note that we will no longer be able to provide you with the products or services that rely on having your consent.

Exercising specific legal rights: We may process your information for the purpose of carrying out obligations and exercising specific rights in the field of employment and social security and social protection law.

5. How we use your personal data

Depending upon the circumstances in which we gather your personal data, we may use your information to provide you, your company or your employing organisation with services and information, or for any of the following purposes:

to negotiate, and then carry out our obligations arising from, any contracts entered into between you (as an individual) and us (performance of a contract);
to provide you, your company or your employing organisation with our services (as noted above) (our legitimate interests);
to respond to your enquiries (our legitimate interests);
to facilitate our internal business operations (our legitimate interests);
to maintain and develop our relationship with you (our legitimate interests);
for our business purposes, including data analysis, submitting invoices, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement (our legitimate interests);
to comply with our legal or regulatory obligations, including requests issued by government authorities (compliance with a legal obligation);
to respond to legal process (our legitimate interests);
to maintain and update our records including our database of contacts (our legitimate interests);
to provide you on an ongoing basis with information and services, including relevant marketing communications related to SPRK, and other information or materials, that you request from us or which we feel may interest you where you have indicated that you would like to receive these from us (your consent or our legitimate interests);
to evaluate, recruit, and hire personnel (performance of a contract and/or our legitimate interests);
to ensure that you as a prospective employee do not have any unspent convictions (exercising specific legal rights);
to help us to improve our services, products or online services (our legitimate interests);
to measure the popularity and effectiveness of services such as newsletters and seminar invitations, in order to improve what we offer to you and other recipients (our legitimate interests);
to ensure that content from our online services is presented in the most effective and secure manner for you and the device on which you are accessing our services, and to troubleshoot, and improve such online services (our legitimate interests);
to allow you to use or access interactive features or secure areas of our online services, when you choose to do so (our legitimate interests); and
for research, planning, service development, security or risk management (our legitimate interests).

We may not be able to do some or all of these things without your personal data.

6. Disclosure of your information

We may on the legal bases set out in this Privacy Notice share your personal information with the following:

law enforcement bodies or other government authorities;
different entities within SPRK’s group (limited to sharing for our internal administrative purposes such as billing, promoting our events and services, and providing you or your organisation with services);
third party service providers contracted to SPRK, who provide services that involve data processing, for example reference archival, web-hosting, analytics providers in connection with the operation of our online services, event hosting, information technology providers, auditing, credit reporting, identity verification, reference checking, professional advisory (including legal, accounting, financial and business consulting), mailing vendor, delivery, technology, website, research, banking, recruitment, payment, client contact, data processing, insurance, forensic, litigation support, marketing and security services;
another organisation to whom we may transfer our agreement with you, your company or your employing organisation, or if we or the assets of SPRK are merged with or acquired by a third party, or we expand or re-organise our business; or
an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger, acquisition, restructuring or insolvency of any part of our business.

We also provide anonymous statistical information about users of our websites and related usage information to reputable third parties, including analytics and search engine providers.

We own the database rights in the information collected via our online services. We do not sell, rent, or otherwise share information that reasonably identifies you or your organisation with unaffiliated entities for their independent use except as expressly described in this Privacy Notice or with your express prior permission.

7. International Transfers

We will not transfer personal data relating to you to a country which is outside the UK or European Economic Area (EEA) unless:

the country or recipient is covered by UK adequacy regulations under the UK GDPR Article 45;
appropriate safeguards have been put in place which meet the requirements of the UK GDPR Article 46 (for example, using the European Commission’s Standard Model Clauses (or any UK-specific replacement) and any appropriate due diligence for transfers of personal data outside the UK or the EEA); or
one of the derogations for specific situations under the UK GDPR Article 49 is applicable to the transfer. These include (in summary): the transfer is necessary to perform, or to form, a contract to which we are a party with you or with a third party where the contract is in your interests; the transfer is necessary for the establishment, exercise or defence of legal claims; you have provided your explicit consent to the transfer; or the transfer is of a limited nature and is necessary for the purpose of our compelling legitimate interests.

8. Retention of your data

We will not retain your information for any longer than we think is necessary. Information that we collect will be retained for as long as needed to fulfil the purposes outlined in this Privacy Notice.

When determining the relevant retention periods, we will take into account factors including:

our contractual obligations and rights in relation to the information involved;
legal obligation(s) under applicable law to retain data for a certain period of time;
statute of limitations under applicable law(s);
our legitimate interests;
(potential) disputes; and
guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your personal data where we no longer require your information for the purposes collected. We will keep basic data to identify you and retain it solely for preventing further unwanted processing. Unless we are required or permitted by law to hold on to your information for a specific retention period, we may retain your information as follows:

for users of our services (i.e. those to whom we make loans), we will retain user information (such as names, addresses, personal identification documents, information we obtain from identity verification providers and credit reporting agencies and any information from communications that we have with you) for 6 years from the expiry of the loan or other contact that we enter into with you;
for users of our online services only (i.e. those whom we do not make loans as a result): we will retain:
- information collected by cookies (such as IP addresses) for up to 2 years (i.e. the period that cookies on our website hold this information – see section 10 (Cookies Policy)); and
- information included in all other communications for 1 year from the end of the communication;
for subscribers to our newsletter or other marketing communications, we will retain personal information for 1 year from the date that you unsubscribe to our newsletter and all other marketing communications;
for registrants for webinar or other event registrants, we will retain personal data for 1 year from the date of the event; and
for prospective employees:
- if you are an unsuccessful applicant, we will retain your personal information for 1 year from the date of your application; and
- if you are a successful applicant, we will retain your personal information for a period set out in our employee privacy notice.

9. Security

We take steps to hold information securely in electronic or physical form.

Our information security policy is supported by a variety of processes and procedures, and we store information in access-controlled premises or electronic databases requiring logins and passwords. All employees, officers or contractors of SPRK and third-party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third-party data storage providers to comply with appropriate information security industry standards.

Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such we cannot guarantee the security of your data transmitted to our online services which is at your own risk.

If you communicate with us using non-secure web platforms, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient.

Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure.

You can help us to keep your information secure by ensuring that any username or password in relation to our online services is kept strictly personal to you and not made available to any other person. You should stop using your username and password and notify us immediately if you suspect that someone else may be using your user details or password.

10. Cookies Policy

Our website and services delivered online use cookies and other similar technologies, for example, to distinguish you from other users when you browse our website(s) or use our online services and to allow us to improve our online services.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site.

We may, for example, collect information about the type of device you use to access our online services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on our online services, the web pages you view immediately before and after you access our online services, whether and how you interact with content available on our online services, and the search terms you enter on our online services.

SPRK’s website sets cookies which remain on your computer for differing times. Some expire at the end of each session, and some remain for longer so that when you return to our website, you will have a better user experience.

Which cookies we use

Detailed below are the cookies we use and why and how long they last.
Google Analytics utma: expires after 2 years

Control of cookies

Web browsers allow you to exercise some control of cookies through the browser settings. Most browsers enable you to block cookies or to block cookies from particular sites. Browsers can also help you to delete cookies when you close your browser. You should note however, that this may mean that any opt-outs or preferences you set on our website will be lost. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org which includes information on how to manage your settings for the major browser providers

11. Online services – Links to third party sites, services and content

In addition to our online services, which we control directly, we also use and provide links to websites which are controlled by third parties, which may include:

Twitter, LinkedIn and Instagram, where we have certain SPRK accounts and profiles.
Facebook, where we have a social page.

If you use or follow a link to any of these third-party websites, please be aware that these websites have their own privacy policies and that we cannot accept any responsibility for their use of information about you.

Our online services may include integrated content or links to content provided by third parties (such as video materials). This Privacy Notice does not address the privacy, security, or other practices of the third parties that provide such content.

We engage third parties that support the operation of our online services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms. Please see section 11 (Cookies Policy) above for more information.

12. Your Rights

You have the following rights under data protection legislation:

right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one detailed summary of the personal information that we hold about you at no cost, but for any further copies of such detailed summaries, we reserve the right to charge a reasonable fee based on administration costs); and
right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete; and
In certain circumstances, you will also have the following rights:
right to erasure/”right to be forgotten”: the right to withdraw your consent to our processing of the data (if the legal basis for processing is based on your consent) and the right to request that we delete or erase your personal information from our systems (however, this will not apply if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);
right to restriction of use of your information: the right to stop us from using your personal information or limit the way in which we can use it;
right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another party, where technically feasible; and
right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or for marketing purposes.

Where you have consented to our processing of certain personal data, you can at any time withdraw such consent. Please note that where you withdraw your consent we will no longer be able to provide you with the products or services that rely on having your consent. You can also exercise this right at any time by contacting us using the contact details at the end of this Privacy Notice.

If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with your relevant local supervisory authority. In the UK, this is the Information Commissioner’s Office. You may submit a complaint to the Information Commissioner’s Office, details of which can be found at https://ico.org.uk/global/contact-us.

If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.

13. Status of this statement

As technologies and information governance practices develop, and data privacy laws (and surrounding guidance) evolve, we may need to revise this Privacy Notice. You should therefore review this page regularly to ensure that you are aware of any changes to its terms.

We will post any Privacy Notice changes on this page and, if the changes are significant or may materially impact upon your rights, we will provide a more prominent notice or contact you by other means (including, for certain services, email notification of Privacy Notice changes).

14. Contact and further information

To find out more about SPRK please visit https://www.sprkcapital.co.uk/.

If you have any questions, concerns or comments about this Privacy Notice, or want to submit a written complaint about how we handle your personal data, please contact us via any of the following means:

Our contact details are as follows:

Contact address: Sprk Holdings, 30 Newman St, London, W1T 1PT
Email: info@sprkcapital.co.uk
Tel: 0800 002 5100

The Data Privacy Officer for SPRK is Simon Champ

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