Privacy Policy.

Spark Growth Limited T/A Spark Health is committed to protecting and respecting your privacy.
We would like you to know that we will only use your personal information where necessary in order to provide our services.
This Policy explains why and how we collect your personal information, how we use it, how we protect it, who has access to it and for what purpose and what rights you have in relation to our use of your personal information.

Who are we?

We're Spark Growth Limited T/A Spark Health, a private company limited by shares (no. 12041095). The registered address is LGF, 27 Gloucester Place, London, W1U 8HU.
Any questions regarding this Policy or our privacy practices should be sent to hello@spark-health.com.

What personal information do we collect and why?

The information we collect will depend upon your interaction with us. We have grouped our interactions into the following categories:

1. Commercial Clients
   In relation to existing, potential or past commercial clients, we will hold the necessary information to enable us to maintain our contractual and legal obligations in relation to the delivery of the services commissioned from us. This is likely to include your business contact details (name, email address and telephone number) and your job title. For legal purposes only, we will hold this information for six years from the date the commercial relationship ceases.
2. Employees

   If you are an employee, we will collect the following personal information from you for remuneration, taxation, pension and benefits, training, and employee records purposes:

   • Name
   • Address
   • NI number
   • Identity documentation
   • Contact details
   • Bank details

   We will hold this data for the duration of your employment and seven years thereafter, in order to meet our legal obligations.

3. Prospective Employees

   If you have applied for a vacancy with us, we will hold your personal information in order to process your application. The information we hold is likely to include:

   • Name
   • Address
   • Contact details
   • CV/application form (or equivalent)

   If you are unsuccessful in obtaining a role with us, unless you give us your specific consent to retain your personal information for future opportunities, we will not keep your personal information once the role has been filled, you can be assured that all the details we hold on you will be deleted at this stage. If you are successful in obtaining a role with us, your personal information will be treated in accordance with our section above titled 'Employees'

4. Suppliers

   If the organisation you represent is a supplier or other business providing services to us, we will hold your personal information for a legitimate business interest. It is likely that you either provided this information to us with a business card or we obtained it from publicly available sources. This information might include:

   • Name
   • Contact details (email address and telephone number)
   • Organisation you represent

How is your information collected?

We obtain the majority of the personal information we hold via direct interaction with you e.g. you may give us your name and contact details directly or on our website, or by filling in forms or corresponding with us by phone or email.

There are some circumstances where we obtain personal information from third parties (e.g. recruitment consultants or directly from our commercial clients). In these instances, we will ensure the third party has complied with all legal requirements in obtaining the personal data they provide to us.

How we use your personal information?

We will only use your personal data where the law allows us to. We have set out in the table below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Who has access to your information?

We will only share your personal information to the extent necessary to allow us to provide our services for the purposes set out in the table above. We will never share your personal data with third parties for marketing purposes. What information we share and with whom will depend upon our interaction with you.

We may pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to provide invoice processing or payroll services). We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may also transfer your personal information to a third party as part of a sale of some, or all of our business and assets or as part of any business restructuring or reorganisation, or if we're under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take all steps to ensure that your privacy rights continue to be protected.

Your legal rights

In certain circumstances, you have rights under data protection laws in relation to your personal data as follows:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  a) if you want us to establish the data's accuracy;
  b) where our use of the data is unlawful, but you do not want us to erase it;
  c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at hello@spark-health.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

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

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

How you can update your information

The accuracy of your information is important to us. If your personally identifiable information changes, please email hello@spark-health.com.

Cookies

Like many other websites, our website uses cookies. 'Cookies' are small pieces of information sent to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual. For example, we use the following cookies:

• Google Analytics – this allows us to look at really useful data about the visitors we have had to our website. To read more about Google’s cookies visit here.
• Careers & Contact Forms – if you use our online contact/application forms we will use a cookie to remember who you are. During the application process you are redirected to a third party and this cookie allows us to register that you have returned to our website once you have completed the process.
• YouTube/Vimeo – if our website contains videos then some cookies may be used for tracking views etc. These cookies are implemented if you press play though.

This helps us to improve our website and communications and deliver a better, more personalised service.

It is possible to switch off cookies by setting your browser preferences. For more information on how to switch off cookies on your computer, visit www.aboutcookies.org or www.allaboutcookies.org. Turning cookies off may result in a loss of functionality when using our website.

Complaints

We aim to meet the highest standards when collecting and using personal data and take any complaints received very seriously. We encourage you to bring to our attention any unfair, misleading or inappropriate collection or use of your data.

How to Contact Us

Further details on any aspect of this policy and its implementation can be obtained by emailing hello@spark-health.com.

We keep this Policy under regular review. This Policy was last updated in March 2020, but historic versions can be obtained by contacting us. We may change this privacy policy from time to time by amending this page.