About the Policy
Spark Growth uses the information collected from you to provide quotations, make telephone contact and to email you marketing information which the agency believes may be of interest to you and your business. In you making initial contact you consent to Spark Growth maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services. Spark Growth also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, Spark Growth will be acting on the instruction of its client, and will work hard to ensure that the client is fully GDPR compliant.
Some personal data may be collected about you from the forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to personally-identifying information like Internet Protocol (IP) addresses. Spark Growth may from time to time use such information to identify its visitors. Spark Growth may also collect statistics about the behaviour of visitors to its website.
Any information Spark Growth holds about you and your business encompasses all the details we hold about you and any sales transactions including any third-party information we have obtain about you from public sources and our own suppliers such as credit referencing agencies.
Spark Growth will only collect the information needed so that it can provide you with marketing services, this agency does not sell or broker your data, although coincidentally there may be times when your information could be contained in data that Spark Growth has purchased from a third-party list broker, on behalf of a client.
Spark Growth may on occasions pass your Personal Information to third parties exclusively to process work on its behalf. Spark Growth requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. Spark Growth do not broker or pass on information gained from your engagement with the agency without your consent. However, Spark Growth may disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The agency may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of Spark Growth, its clients and/or the wider community.
Spark Growth will process personal data during the duration of any contract and will continue to store only the personal data needed for six years after the contract has expired to meet any legal obligations. After six years any personal data not needed will be deleted.
Your Rights as a Data Subject
At any point whilst Spark Growth is in possession of or processing your personal data, all data subjects, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
In the event that Spark Growth refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
Spark Growth at your request can confirm what information it hold about you and how it is processed
You can request the following information:
- Identity and the contact details of the person or organisation (Spark Growth) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Spark Growth or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (ICO).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access what Personal data is held, identification will be required Spark Growth will accept the following forms of ID when information on your personal data is requested:
A copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Spark Growth is dissatisfied with the quality, further information may be sought before personal data can be released.
260 Spadina Avenue, Suite 301
New York Office
32 West 22nd Street, 3rd Floor
New York NY 10010