SPARK Privacy & Cookie Policy

Effective Date: 24 May 2025

1. Our Commitment to Your Privacy

At SPARK, we are committed to safeguarding your personal data and ensuring transparency in how we collect, use, and protect your information. This Privacy & Cookie Policy outlines how SPARK ("we", "our", "us") processes personal information across our website, mobile applications, NFC-enabled badges, and other digital platforms ("Platforms").

2. Who Controls Your Data

SPARK is the data controller responsible for the processing of your personal data under UK and EU data protection laws. This policy applies to all entities operating under the SPARK brand and covers data collected online and offline.

3. Contact Information

If you have questions about this policy or wish to exercise your data rights, you can contact us at:

4. What Information We Collect

We may collect the following categories of data:

• Identity Data: name, username, title, gender
• Contact Data: email, address, phone number
• Profile Data: digital badge settings, interests, bio, photos
• Transaction Data: payment info, purchase history
• Technical Data: device type, browser, IP address, login timestamps
• Usage & Behavioural Data: interactions with badges, tap history, site usage
• Marketing Data: communication preferences, social media engagement

5. How We Collect Data

We collect your personal data through:

• Direct input (e.g., form submissions, account creation)
• Automated tools (e.g., cookies, device logs)
• Third-party platforms (e.g., social media sign-ins, analytics providers)
• Publicly available sources

6. Why We Use Your Data

We use your personal data to:

• Create and manage your SPARK account
• Enable badge linking and NFC interactions
• Process payments and deliver products
• Communicate important updates or promotional offers
• Customize user experiences and improve platform performance
• Comply with legal obligations

7. Sharing Your Data

We do not sell your personal data. We may share it with:

• Trusted service providers (e.g., payment processors, delivery partners)
• Analytics and advertising partners (only with your consent)
• Legal authorities (if required)

8. Your Data Rights

You have the right to:

• Request access to your personal data
• Correct inaccurate or incomplete data
• Request deletion of your data
• Object to processing based on legitimate interests
• Withdraw consent for marketing
• File complaints with a data protection authority

9. Children's Privacy

Our platform is not intended for users under the age of 13. We do not knowingly collect data from children.

10. Data Security

We use secure protocols, access controls, and encrypted data storage to protect your personal data.

11. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes we collected it for, including any legal or accounting requirements.

12. International Transfers

If we transfer your data outside the UK or EEA, we ensure it is protected through legal mechanisms such as adequacy decisions or standard contractual clauses.

13. Changes to This Policy

We may update this policy occasionally to reflect changes in our services or laws. We encourage users to revisit this page regularly. Significant changes will be communicated directly.

If you have feedback or questions about our policy, please reach out at [email protected].