Privacy Policy
Last updated: 24 January 2024
Who we are
We are Spark Finance Ltd ("we", "us", "our", or "Spark"), an intermediary/broking service providing debt solutions to SME businesses. Our company number is 10128297 and our registered office is 18 John Stow House, London, England, EC3A 7JB. Our Information Commissioner's Office (ICO) registration number is ZA269538.
Spark is the data controller responsible for your personal data. This means we decide how and why your personal information is used. This Privacy and Cookie Policy (the "Policy") explains how we collect, use and share your personal data when you engage with us or use our services (the "Personal Data").
What personal information do we collect?
Personal data means any information that can identify an individual. It does not include anonymised data. We may collect, use, store and transfer different categories of personal data, including:
- Identity data: e.g. first name, last name, maiden name, marital status, title, date of birth, gender, passport copy, driving licence copy, utility bills.
- Contact data: e.g. residential address, billing address, email address, telephone numbers.
- Financial data: e.g. bank details, income and expenditure, statement of assets and liabilities.
- Background data: e.g. education and employment history.
- Transaction data: e.g. details about products and services you have arranged via Spark, your use of our Online Platform, IP address, and use of tracking pixels in email communications.
- Marketing and communications data: e.g. your marketing preferences and communication preferences.
- Health data: e.g. relevant medical information, especially where you are classified as a vulnerable customer.
We also collect and use Aggregated Data, such as statistical or demographic data. This is not considered personal data under data protection law if it cannot identify you. However, if Aggregated Data can indirectly identify you, it will be treated as personal data and handled accordingly.
Accuracy and failure to provide data
It is important that the personal data we hold about you is accurate and up to date. Please let us know if your information changes during your relationship with us.
If we are required by law or contract to collect personal data and you do not provide it, we may be unable to perform our contractual obligations and may have to cancel a product or service. We will inform you if this is the case.
How is your personal data collected?
We may collect your personal data in the following ways:
- Directly from you: e.g. through our website, contact forms, emails, phone calls or post.
- From companies (borrowers) and their advisers: where they provide your data during a credit proposal.
- From third parties and public sources: e.g. Companies House or other introducers with whom we have a business relationship.
Lawful bases for processing personal data
Under the UK GDPR, we only use your personal data where we have a lawful basis, such as:
- Consent: you have given us clear permission to process your data for a specific purpose.
- Contract: processing is necessary to enter into or perform a contract with you.
- Legal obligation: processing is required to comply with legal duties.
- Legitimate interests: processing is necessary for our (or a third party's) legitimate interests, provided those interests are not overridden by your rights.
In some cases, we may rely on more than one lawful basis depending on the specific purpose.
How we use your personal data
We may process your personal data for the following purposes:
- To provide finance solutions tailored to you or your business.
- To confirm affordability and suitability of products.
- To meet regulatory, compliance, and anti-money laundering (AML) requirements.
- To share information with our professional advisers and for legal proceedings.
- For marketing and business development purposes (where appropriate).
- To manage our website, Online Platform, and other digital services (including usage analysis and performance monitoring).
- To investigate complaints or respond to queries.
- To prevent and respond to fraud or illegal activity.
- If we sell or restructure our business, your data may be shared with potential buyers.
Use of professional networking platforms (e.g. LinkedIn)
If you submit your information through our website (for example, via contact forms), we may use the details you provide - such as your name, company, or job title - to identify and contact you via professional networking platforms such as LinkedIn. This contact is based on our legitimate interest in following up on your enquiry or providing relevant business information or services.
We will only use publicly available information on such platforms and will not use this method for unsolicited marketing. You have the right to object at any time to being contacted in this way by emailing us at info@sparkfinance.co.uk
Marketing consent
If you opt in to receive marketing communications, we may send you updates about our services, products, case studies, newsletters or invitations. We may contact you under the following bases:
- With your explicit consent.
- If you are an existing or prospective business contact and the law permits us to do so under legitimate interests.
We will never share your data with third parties for their own marketing purposes without your explicit consent. You can opt out of marketing at any time by clicking "unsubscribe" in any email or contacting us at: info@sparkfinance.co.uk
Alternative contact methods
If the phone number you provide is invalid or non-functional, we reserve the right to use publicly available information from your company website or other public sources to contact you. This may include email addresses, contact forms, or alternative phone numbers listed on your website.
Automated decision making (ADM)
We may use ADM in limited circumstances, such as:
- Where you've been notified and have 21 days to request reconsideration.
- Where it is necessary for contract performance and appropriate safeguards are in place.
- With your explicit consent, particularly when processing sensitive data.
We ensure adequate safeguards for your rights in any use of ADM.
Sharing your information
We may share your personal data with third parties where legally required, or when necessary to administer our services. These may include:
- Lenders on our panel (available upon request).
- Our IT service providers (hosted within the UK or EU).
- Legal or regulatory authorities as required by law.
Data security
We have implemented appropriate technical and organisational security measures to prevent your data from being accidentally lost, accessed or disclosed without authorisation. Access is restricted to individuals who have a business need to know and are bound by confidentiality obligations.
Data retention
We retain your personal data only as long as necessary for the purposes for which it was collected, including legal and regulatory compliance.
International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
Your rights under UK GDPR
You have the following rights:
- To access your personal data (data subject access request).
- To correct inaccurate or incomplete data.
- To request deletion of your data.
- To restrict or object to our processing.
- To withdraw consent at any time.
- To request data portability.
You also have the right to lodge a complaint with the ICO (www.ico.org.uk). However, we would appreciate the opportunity to resolve your concern before you contact them.
Changes to the privacy & cookies notice
This version was last updated on 24/01/24 and historic versions can be obtained by contacting us at info@sparkfinance.co.uk.
Contact us
To exercise your rights or raise a privacy concern, email us at info@sparkfinance.co.uk. We may ask for proof of identity before fulfilling your request.
Please note: all telephone calls are digitally recorded.
Cookies - Introduction
We use cookies and similar technologies on our website and emails to collect information as described in this Policy. A cookie is a small file stored on your device to enhance website functionality.
You can configure your browser to alert you when a cookie is being used. Blocking cookies may affect website performance or features.
Types of cookies used
First party cookies:
- Strictly necessary cookies - Essential for site navigation and functionality. Deleted when you close your browser.
- Functionality cookies - Enable enhanced features and remember your preferences.
Third party cookies:
- Google Analytics (GA) - Tracks user activity and preferences in an anonymised format. We do not use this data to identify individual users.
- Document tracking cookies - May be used to monitor engagement with sent documents. These may link to email addresses for identification.
We may combine cookie data with other personal data for service improvement purposes.
Cookie consent and control
By using our website, you consent to our use of cookies unless you disable them via your browser or opt-out tool. For more information, visit: www.allaboutcookies.org and www.youronlinechoices.com/uk/.