MENU PRIVACY POLICY SPARK44 Last Updated 04 October 2019 We respect the privacy of every person who visits www.spark44.com (the “Site”) and who uses the services that we promote on our Site (our “Services”) and we are committed to ensuring a safe online experience. We also respect the privacy of every person whose personal information we may process as a result of providing the Services to others or who applies to work at Spark44. PURPOSE OF THIS POLICY This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information. This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it. This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties. Who are we? The Site and our Services are operated by Spark44 Limited, (“we”, “us” or “our”). Spark44 Limited is the data controller responsible for your personal information. Spark44 Limited is an English company with registered company number: 07535381 and whose registered office is at The White Collar Factory, 1 Old Street Yard, London, England, EC1Y 8AF. HOW TO CONTACT US? If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by: Sending an e-mail to AvaneshS@Spark44.com Calling us on: +44 (0)7557 488 618. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT? Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us deliver our Services; (iii) help us improve the Services and develop and market new services; (iv) send you marketing communications; (v) carry out requests made by you on the Site; (vi) investigate or settle inquiries or disputes; (vii) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (viii) enforce our agreements with you; (ix) protect the rights, property or safety of us or third parties, including our other clients and users of the Site and visitors at our offices; (x) provide support for the provision of our Services; (xi) recruitment purposes; and (xii) use as otherwise required or permitted by law. In particular, we use your personal information for the following purposes: Fulfilment of services We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services. We use the contact details you have provided to us so that we can fulfil the supply of services you have engaged us to provide. Who do we share your personal information with for this purpose? We will share, where relevant, your personal information (e.g. name and job title, contact information including email address, other information relevant to provision of our Service, or any personal information that you provide to us as part of our providing the Services) with the following categories of third parties: Web hosting, optimisation and management companies who assist us with the hosting, operation, optimisation and maintenance of our Site and the administration of your account with us. Please note this list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to provide the products and services as effectively as we can. What is our legal basis? It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we provide the products and services you have requested in the most effective and efficient way that we can. Site insight and analysis Where you have given your consent (where lawfully required), we use log files and other technologies to collect minimal personal information from the computer hardware and software you use to access the Site, or from your mobile. This includes the following: an IP address to monitor Site traffic and volume; the type of browser and operating system you used; the date and time that you visited the Site; a session ID to track usage statistics on our Site; referring website addresses. Our web pages and e-mails contain “web beacons” or “pixel tags” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag. In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications. Please see our Cookie Policy for further information. By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Services. This allows us to learn what pages of our Site are most attractive to our visitors. Who do we share your personal information with for these purposes? We share your personal information with a variety of third party service providers to assist us with client insight analytics, such as Salesforce. Other providers are described in our Cookie Policy. What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other clients. E-mail marketing We use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services (see the ‘Site Insight and Analysis’ section above for more details of the information collected and how it is collected) and/or your name and email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so. Who do we share your personal information with for these purposes? We share your personal information with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you. What is our legal basis? Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details. Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so. Business administration and legal compliance We use your personal information for the following business administration and legal compliance purposes: to obtain IT support; to comply with our legal obligations; to enforce our legal rights; protect rights of third parties; and in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets. Who do we share your personal information with for these purposes? We will share your personal information with professional advisers such as IT support providers, lawyers and accountants and/or governmental or regulatory authorities. What is our legal basis? Where we use your personal information in connection with IT support, to enforce our legal rights, to protect the rights of third parties or as part of a business transition, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order. Where we share your sensitive personal information, we shall obtain your consent to do so. What is our legal basis? Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for Spark44. We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent which shall be obtained at the time we collect your personal information following the instructions provided. Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details. HOW DO WE OBTAIN YOUR CONSENT? Where our use of your personal information requires your consent, you can provide such consent: at the time we collect your personal information following the instructions provided; or by informing us by e-mail, post or phone using the contact details set out above in this Privacy Policy. OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES Our Site uses certain pixels, beacons, log files and other technologies of which you should be aware (“Cookies”). For more information on our placement of Cookies on the Site, please refer to our Cookie Policy. If you click on a video, the video will either be played on Youtube player or Vimeo (it will be clear which player is used when the video begins to play). We understand that content made available on Youtube and Vimeo may contain certain Cookies which will be placed on your device when you click play. For more information on the placement of Cookies by these third parties, please refer to their websites. THIRD PARTY LINKS AND SERVICES Our Site contains links to third party websites and services. There are links from spark44.com pointing to different external websites including Vimeo, Youtube, Google, Jaguar, Land Rover and to ClearCompany. Please remember that when you use a link to go from our Site to another website or you request a service from a third party, this Privacy Policy no longer applies. Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies and you should contact the appropriate third party if you have any questions. We do not monitor, control, or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy notices and practices. This Privacy Notice applies solely to personal information collected by us through our Site and/or the supply of our products and services and does not apply to these third party websites and third party service providers. TRANSFERS OUTSIDE THE EEA Where necessary in order to deliver our services, we will transfer personal information to countries outside the EEA. When doing so, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the EEA. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR? Regarding personal information we have processed in connection with the supply of our products and services to any client, we will retain personal information relevant to that supply of products or services for as long as necessary in order to provide the products and services and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability. Regarding any other personal information we have processed, we will retain relevant personal information for as long as we have a reason to use it following the date of our last interaction with the relevant individual and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability. If any personal information is only useful for a short period (e.g. for a specific marketing campaign), we may delete it at the end of that period. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from: unauthorised access; improper use or disclosure; unauthorised modification; and unlawful destruction or accidental loss. All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS? You have the following rights in relation to the personal information we hold about you: Your right of access If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee. Your right of rectification If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. Your right to erasure You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. Your right to restrict processing You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. Your right to data portability With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice. Your right to object You can ask us to stop processing your personal information, and we will do so, if we are: relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or processing your personal information for direct marketing. Your rights in relation to automated decision-making and profiling You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us. Your right to withdraw consent If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. Your right to lodge a complaint with the supervisory authority If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113. CHANGES TO THIS PRIVACY POLICY We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information. Cookie Policy Last Updated 04 October 2019 This cookie policy (“Cookie Policy”) is intended to inform you how we use “cookies” and similar technologies on our website at https://spark44.com/ (“Site”) and to assist you in making informed decisions when using our Site. Please take a moment to read and understand this Cookie Policy. This Cookie Policy should also be read in conjunction with our Privacy Policy. WHAT ARE COOKIES? Cookies and similar technologies are very small text documents or pieces of code, which often include an anonymous unique identifier. When you visit a website or use a mobile application, a computer asks your computer or mobile device for permission to store this file on your computer or mobile device and access information from it. Information gathered through cookies and similar technologies may include the date and time of visits and how you are using the particular website or mobile application. We use first and third party cookies on our Site and/or in our emails. First party cookies are cookies placed by us to collect information about you. However, certain cookies available on our Site and/or in our emails are placed by third party website operators. This means that the information about you collected by those third party cookies will be shared with the relevant third party. For your ease we have included links to the For more details on cookies and similar technologies, please visit All About Cookies. For the purposes of the remaining sections of this Cookie Policy, we will refer to all technologies using the above features as “cookies”. HOW LONG DO COOKIES LAST? All cookies have expiration dates that determine how long they stay in your browser: Session Cookies – these are temporary cookies that expire (and are automatically erased) whenever you close your browser. Persistent Cookies – these usually have an expiration date and so stay in your browser until they expire, or until you manually delete them. COOKIES USED ON OUR SITE We use the following types of cookies on our Site: Essential Cookies – Essential cookies are those cookies which are essential for the operation of a website. Essential cookies include cookies such as login cookies and shopping cart cookies. Functionality Cookies –These cookies recognise you when you return to a website, they remember your preferences and they provide enhanced, more personalised features. Analytics/Performance Cookies –Analytics cookies, along with other information, allow websites to calculate the aggregate number of people using a website and which features of a website are most popular. This information is generally used to improve the website. Social Media Cookies –These cookies are used to personalise your interaction with social media, such as Twitter, Facebook, Tumblr and YouTube. Such cookies recognise users of those social media sites when you view social media content on the website. They also allow you to quickly share content across social media, through the use of simple “sharing” buttons. Some websites may also contain features that enable you to use your social media account to sign in and create/maintain an account with the website you are visiting and to enable the website operator to store your content. This involves the use of cookies. Targeting Cookies –Targeting cookies (also known as advertising cookies) deliver adverts that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement on a website and help measure the effectiveness of advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. The table below sets out more information about the individual cookies we may use on our Site and the purposes for which they are used. Cookie Name Purpose Duration _ga This is a Google Analytics cookie. It registers a unique ID that is used to generate statistical data on the use of our Site. More information about Google Analytics can be found here 2 years from set/update _gid This is a Google Analytics cookie. It registers a unique ID that is used to generate statistical data on the use of our Site. More information about Google Analytics can be found here Session _gat This is a Google Analytics cookie. It is used to throttle the request rate on our Site. More information about Google Analytics can be found here Session _dc_gtm_UA-99188936-1 This is a Google Tag Manager cookie to support Google Analytics. It is used to help us monitor the use and performance of our website. It is also used to throttle the request rate on our Site. More information about Google Tag Manager can be found here Session _utma This is a Google Analytics cookie. It is used to determine new and returning visitors. More information about Google Analytics can be found here 2 years from set/update _utmb This is a Google Analytics cookie. It is used to determine new sessions/visits. More information about Google Analytics can be found here 30 minutes from set/update _utmz This is a Google Analytics cookie. It is used to determine the traffic source, medium, campaign name and campaign term which delivered the user to our website. More information about Google Analytics can be found here 6 months from set/update _utmv This is a Google Analytics cookie. It is used for storing visitor-level custom variable data. More information about Google Analytics can be found here 2 years from set/update _utmt This is a Google Analytics cookie. It is used to throttle the request rate on our Site. More information about Google Analytics can be found here 10 minutes _utmc This is a Google Analytics cookie. It is used in combination with _utmb to identify new sessions/visits for returning visitors. More information about Google Analytics can be found here Session _utmt_b This is a Google Analytics cookie. It is used to limit the amount of data recorded by Google on high traffic websites. More information about Google Analytics can be found here Session _utmt_c This is a Google Analytics cookie. It is used to limit the amount of data recorded by Google on high traffic websites. More information about Google Analytics can be found here Session CONSENT TO USE COOKIES Non-essential Cookies – We may only store and access non-essential cookies on your device with your permission. You are not obliged to give consent to our use of non-essential cookies. Further, if you give your consent and then change your mind you can block or delete them (see below). Essential Cookies – Please note that we do not need your consent to store and access essential cookies on your device, although you can still block or delete them (see below). REFUSING, BLOCKING AND DELETING COOKIES You can block the use of cookies altogether by activating the relevant settings in your browser. For more information on cookie management and blocking or deleting cookies for a wide variety of browsers, visit All About Cookies. Please be aware that in order to use some parts of our Site you will need to allow certain essential or functional cookies. If you subsequently block or delete those cookies, some aspects of our Site may not work properly and you may not be able to access all or part of our Site. COOKIES USED IN EMAILS Please note that any emails you receive from us may contain cookies or similar technologies to help us to see if recipients have opened an email and understand how recipients have interacted with it. Once you click on an email that contains a cookie, your contact information may subsequently be cross-referenced to [the source email] and/or the relevant cookie. If you have enabled images, cookies may be set on your computer or mobile device. Cookies will also be set if you click on any link within the email. LET'S TALK CAREERS Maite Ortiz Maiteo@spark44.com CONTACT AN OFFICE We welcome a conversation if you believe Spark44 is right for you. Copyright © Spark44 2021. All rights reserved. | Privacy Policy