Privacy Policy
Privacy Policy
Our work with care providers depends on trust, and trust depends on handling people’s information with care. This policy explains what we collect, why we collect it, and the rights you have. We’ve written it in plain English rather than legal jargon.
Who we are
Spark Care is a trading style of Spark Innovation Group Limited, a company registered in England and Wales (company number 14917066). Our registered office is Innovation House, 11 North Street, Pewsey, Wiltshire SN9 5ES.
We help care providers create safer, calmer, more responsive care environments through practical care technology and hands-on implementation support. In doing that, we handle personal information belonging to the people who visit our website, enquire about our services, work with us, and support us as suppliers or partners.
For the purposes of UK data protection law, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Spark Innovation Group Limited is the data controller for the personal information described in this policy. This means we’re responsible for deciding how and why your information is used.
Information we collect
The information we collect depends on how you interact with us. It may include:
Contact and enquiry details
- Your name, job title, and the organisation you work for
- Your email address, telephone number, and postal address
- The content of any enquiry, message, or request you send us
Customer and supplier information
- Records relating to services we provide or receive, including quotes, orders, and correspondence
- Contract, billing, and payment information
- Notes from meetings, calls, and site visits
Website and technical information
- Your IP address, browser type, and device information
- Pages you view and how you move through our site
- Information collected through cookies and similar technologies (see section 11)
Recruitment information
- If you apply to work with us, your CV, application, references, and related details
A note on sensitive information
Our website and general business activities are not designed to collect special category data (such as health information) about visitors or enquirers. Where our care technology processes information within a care setting, that’s handled separately and under agreement with the care provider. You can read more in section 6.
How we collect it
We collect information in a few straightforward ways:
- Directly from you when you contact us, complete a form on our website, request information, meet with our team, or enter into an agreement with us.
- Automatically when you use our website, through cookies and similar technologies.
- From other sources on occasion, such as publicly available business directories, professional networks, or introductions made by mutual contacts, where this is relevant to services we may be able to support you with.
How and why we use your information
We only use your personal information where we have a lawful basis to do so. The table below sets out the main reasons we process information and the lawful basis for each.
| What we use it for | Our lawful basis |
|---|---|
| Responding to your enquiries and requests | Legitimate interests, or steps taken at your request before entering a contract |
| Providing our services and managing our agreements with you | Performance of a contract |
| Managing supplier and partner relationships | Performance of a contract, or legitimate interests |
| Sending relevant updates and marketing (see section 12) | Consent, or legitimate interests where permitted |
| Improving and securing our website | Legitimate interests, and consent for non-essential cookies |
| Managing recruitment | Legitimate interests, and steps taken before entering a contract |
| Meeting our legal and regulatory obligations | Legal obligation |
Where we rely on legitimate interests, we’ve considered whether our use of your information is fair and proportionate, and we balance it against your rights and expectations. You can ask us more about this at any time.
Sharing your information
We don’t sell your personal information, and we never will. We only share it where there’s a clear reason to, and with appropriate safeguards in place. This may include:
- Trusted service providers who support how we operate, such as IT, hosting, customer relationship management, email, and analytics providers. They act on our instructions and are bound to protect your information.
- Technology and delivery partners, where this is necessary to provide a service you've asked for.
- Professional advisers such as accountants, insurers, and legal advisers, where needed.
- Regulators or authorities, where we're legally required to share information.
If our business is ever restructured, sold, or transferred, your information may be shared as part of that process, subject to the same protections set out here.
Care settings and client data
When we deliver technology within a care service, the care provider decides how information about the people they support is used. In those cases, the provider is the data controller and Spark Care acts as a data processor, handling information only on their instructions and under a separate data processing agreement.
Our monitoring technology is designed to support dignity and privacy in care. Where a solution involves monitoring, it’s provided without cameras or wearables, and the details of what’s collected and how it’s used are agreed with the provider as part of their own responsibilities and record keeping.
If you receive care in a setting that uses our technology
The care provider is responsible for explaining how your information is used and for handling requests about it. If you contact us, we’ll help by directing you to the right provider so your request reaches the people who can act on it.
How long we keep your information
We keep personal information only for as long as we need it for the purpose we collected it, or for as long as we’re required to keep it by law.
- Enquiry and contact records are kept for as long as we're in active discussion, and for a reasonable period afterwards.
- Customer, supplier, and financial records are kept in line with our legal and accounting obligations.
- Marketing information is kept until you ask us to stop or your details are no longer relevant.
When we no longer need your information, we’ll securely delete or anonymise it.
Keeping your information secure
We take the security of your information seriously and use appropriate technical and organisational measures to protect it against loss, misuse, and unauthorised access. This includes access controls, secure systems, and working only with providers who meet suitable standards.
No system can be guaranteed completely secure, but if a personal data breach ever occurs that’s likely to affect your rights, we’ll respond promptly and meet our obligations to notify the relevant people and authorities.
International transfers
We operate in the UK and Ireland, and some of the providers we work with may store or process information outside the UK. Where this happens, we make sure appropriate safeguards are in place, such as an adequacy decision or standard data protection clauses recognised under UK data protection law, so your information continues to be protected.
Your rights
Under UK data protection law, you have a number of rights over your personal information:
Be informed
To understand how your information is used, which is the purpose of this policy.
Access
To ask for a copy of the information we hold about you.
Rectification
To have inaccurate or incomplete information corrected.
Erasure
To ask us to delete your information in certain circumstances.
Restriction
To ask us to limit how we use your information.
Object
To object to certain uses, including direct marketing.
Portability
To receive your information in a portable format in some cases.
Withdraw consent
To withdraw consent at any time, where we rely on it.
To exercise any of these rights, please contact us using the details in section 15. We’ll respond within the timescales set out in law, and we won’t charge you unless a request is clearly unfounded or excessive.
Cookies
Our website uses cookies and similar technologies to help it work properly, to understand how the site is used, and to improve your experience. Some cookies are essential for the site to function. Others, such as analytics cookies, are only used where you’ve given your consent.
You can manage your cookie preferences through the cookie settings on our site, and you can control cookies through your browser at any time. Turning off some cookies may affect how parts of the site work.
Marketing
From time to time we may send you information about our services and relevant updates, where you’ve agreed to hear from us or where we’re permitted to contact you as an existing business contact.
You can ask us to stop sending marketing at any time, either by using the unsubscribe link in our emails or by contacting us directly. We’ll always act on your request promptly.
Links to other websites
Our website may include links to other websites that we don’t control. This policy applies only to Spark Care, so we’d encourage you to read the privacy policy of any other site you visit. We’re not responsible for how other organisations handle your information.
Changes to this policy
We may update this policy from time to time to reflect changes in how we work or in the law. When we do, we’ll update the date at the top of this page. Where changes are significant, we’ll take reasonable steps to let affected people know.
How to contact us
If you have any questions about this policy, or you’d like to exercise any of your rights, please get in touch. We’re always happy to help.
Contact us
Spark Care
Innovation House, 11 North Street,
Pewsey, Wiltshire SN9 5ES
Raising a concern
If you’re unhappy with how we’ve handled your information, we’d like the chance to put it right, so please contact us first.
The Information Commissioner's Office (ICO)
You also have the right to make a complaint to the ICO, the UK’s data protection regulator, at any time. You can reach them at ico.org.uk or by calling 0303 123 1113.