SPARK NINETY PRIVACY POLICY
We are committed to keeping your personal data safe and secure, and handling it in accordance with our legal obligations. This Privacy Policy sets out in detail the purposes for which we process your personal data, who we share it with, what rights you have in relation to that data and everything else we think it's important for you to know. Please see below for full information about how your personal data is collected and processed when you use the Spark Ninety website.
1 What is this platform? Who's in control?
The Spark Ninety website is operated by Spark Ninety Limited, a company registered in England and Wales, with company number 11248585. This Privacy Policy applies to users of the Spark Ninety website.
2 What data do we collect and where from?
2.1 We collect some data directly from you as an individual when you register to download reports from the Spark Ninety website (“Account Data”). This data includes:
2.1.1 your full name;
2.1.2 your email address;
2.1.3 the name of the company you work for.
2.2 We also collect information that you voluntarily provide to us when you contact us with queries, complaints, comments or praise (“Voluntary Data”).
2.3 We collect and analyse information about how you use the Spark Ninety website using cookies and similar technology (“Technical Data”). Technical Data may include your viewing history, IP addresses, device identifiers, and information about how long you have stayed on certain pages or what pages you have clicked on.
3 What do we use your data for?
3.1 It is important that you understand how and why we use the personal data that we collect about you. This section sets out the different purposes for which we process personal data and which types of personal data we need for each purpose.
3.2 Managing your account and providing you with our services –
3.2.1 We use your Account Data to contact you occasionally with messages about our services, for example to alert you to new publications or insights, or to invite you to events.
3.2.2 We use your Voluntary Data to enable us to respond to queries, complaints or comments that you have and to make sure that these are appropriately dealt with. If Voluntary Data you provide includes any special categories of personal data (such as information about your health, race or religion), you must make sure before you provide this that you are happy for us to use that Voluntary Data for the purposes set out in this Privacy Policy.
4 What is our legal basis for using your data?
4.1 Data protection law says that we must tell you the legal basis that we rely on to process your personal data for the purposes that we have notified to you. This section tells you what that legal basis is in relation to each of the purposes set out above.
4.2 We process your personal data for all of the purposes identified under Section 3 above on the basis that it is in our legitimate interests, or the legitimate interests of third parties with whom we share your data, to carry out these activities.
4.3 You have the right to object to us processing your personal data for the purposes set out above. Unless we can show that we have a compelling legitimate reason to continue processing your personal data, we will stop processing it.
5 Who do we share your data with?
5.1 We do need to share your personal data with some third parties in some circumstances. This includes where we use third party suppliers to perform various services for us. When we share your personal data with third parties, we enter into contracts to ensure your personal data is kept secure, is only used for the defined purpose, and is then deleted in accordance with our data retention requirements. The third party suppliers we share your personal data with are as follows:
5.1.1 technology solutions providers;
5.1.2 legal advisors who may need to manage or litigate a claim;
5.1.3 analytics providers who help us analyse data;
5.1.4 public authorities or other third parties where we are required by law to do so.
5.2 We will also share your personal data with third parties in the following circumstances:
5.2.1 where you have specifically consented to us sharing your data with a particular third party; and
5.2.2 where we are required or permitted to do so by law or to protect or enforce our rights or the rights of any third party.
5.3 We do not transfer or store your personal data outside the United Kingdom (“UK”) and European Economic Area (“EEA”). If we do carry out any further transfers of your data outside the EEA, we will inform you and we will ensure that the recipient provides an adequate level of protection of your personal data.
6 How long do we keep your data for?
6.1 We will only hold your Account Data for as long as is necessary. How long is necessary will depend upon the purposes for which we collected the personal information (see section 4 above) and whether we are under any legal obligation to keep the personal information (such as in relation to accounting or auditing records or for tax reasons). We may also need to keep personal information in case of any legal claims.
6.2 Any Voluntary Data you submit to us will be retained for a period of two years from submission, after which it is anonymised or deleted.
7 What rights do you have?
7.1 You have several rights under data protection law. These rights and how you can exercise them are set out in this section. We will normally need to ask you for proof of your identity before we can respond to a request to exercise any of the rights in this section and we may need to ask you for more information, for example to help us to locate the personal data that your request relates to.
7.2 We will respond to any requests to exercise your rights as soon as we can and in any event within one month of receiving your request and any necessary proof of identity or further information. If your request is particularly difficult or complex, or if you have made a large volume of requests, we may take up to three months to respond. If this is the case we will let you know as soon as we can and explain why we need to take longer to respond.
7.3 A right to access your information
7.3.1 You can access all of your Account Data by sending a request to info@sparkninety.com.
7.3.2 You also have a right to ask us to send you a copy of your Account Data and all other personal data that we hold about you (subject to some exceptions). A request to exercise this right is called a "subject access request" (SAR) and must be made in writing to: info@sparkninety.com;
7.3.3 We do not accept subject access requests made via third parties without a letter of authorisation from you sent directly to us confirming that you authorise the third party to act on your behalf. We do not accept SAR requests from platforms where we are required to set up an account in order to provide the response to the SAR.
7.4 A right to object to us processing your information
7.4.1 You have a right to object to us processing any personal data that we process where we are relying on legitimate interests as the legal basis of our processing.
7.4.2 If we have compelling legitimate grounds to carry on processing your personal data, we will be able to continue to do so. Otherwise, we will cease processing your personal data.
7.4.3 You can exercise this right by emailing info@sparkninety.com.
7.5 A right to have inaccurate data corrected
7.5.1 You have a right to ask us to correct inaccurate data that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct your personal data as soon as possible.
7.5.2 You can update your own personal data at any time by emailing info@sparkninety.com and submitting a request to change your details.
7.6 A right to have your data erased
7.6.1 You have a right to ask us to delete your personal data in certain circumstances, for example if we have processed your data unlawfully or if we no longer need the data for the purposes set out in this Privacy Policy.
7.7 A right to have processing of your data restricted
7.7.1 You can ask us to restrict processing of your personal data in some circumstances, for example if you think the personal data is inaccurate and we need to verify its accuracy, or if we no longer need the data but you require us to keep it so that you can exercise your own legal rights.
7.7.2 Restricting your personal data means that we only store your personal data and don't carry out any further processing on it unless you consent or we need to process the data to exercise a legal claim or to protect a third party or the public.
8 What about linked websites?
We are not responsible for the privacy policies and practices of other websites even if you accessed the third party website using links from the Spark Ninety website. We recommend that you check the policy of each website you visit and contact the owner or operator of such website if you have concerns or questions.
9 How can you contact us?
If you have any questions or concerns about this Privacy Policy and/or our processing of your personal data, you can get in touch with us at info@sparkninety.com.
10 What if you have a complaint?
You have a right to complain to the Information Commissioner's Officer (“ICO”), which regulates data protection compliance in the UK, if you are unhappy with how we have processed your personal data. You can find out how to do this by visiting www.ico.org.uk.
11 What if this policy changes?
We may make changes to this Privacy Policy from time to time. Any changes we make will be posted on this page. We may also notify you by email if significant changes are made.