Privacy

We collect and process information about individuals (i.e. ‘personal data’) for business purposes, provision of our services, marketing, and business administration. This includes personal data relating to our clients, suppliers, business consultants and other third parties.

Compliance with data protection law is essential to ensure that personal data remains safe, our business operations are secure, and the rights of individuals are respected. We are a Controller under data protection law, meaning it decides how and why it uses personal data. This Policy explains our procedures for complying with data protection law in relation to personal data.

We are committed to protecting the privacy and security of your personal information, in accordance with the applicable data protection laws, including the General Data Protection Regulation, together with the “Data Protection Laws”.

Information we may collect from you

We may collect and process data about you in the following circumstances:

We hold the names, job titles, employer details and professional contact details for various business contacts, including client contacts, supplier contacts, consultants and interested parties who have contacted us in the pursuit of business interests regarding our company and services;
If you contact us via our web site, we will keep a record of that correspondence;
details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, for whatever purpose and the resources that you access;
If you are or were a job applicant, we will process the personal information you provided for the legitimate purposes of your application and determination of the suitability for the role in question;
Information that you provide if you report a problem with our site.

We will never retain personal information for any longer than is necessary for the purposes we need to use it for.

Uses made of the information

We use information held about you in the following way:

To fulfil contractual obligations with our clients;
In pursuit of legitimate interests of managing the day-to-day operation of our business;
To promote our services to business contacts;
To ensure that content from our site is presented in the most effective manner for you and for your computer.

When we wish to send you information about our services, and you do not currently use our services, we may collect your contact details, for example, your name, email address and job title. This information may be provided directly by you, when you express interest in our website, or may be obtained through trusted third parties where you have opted in to have your details shared.

Your rights

Under data protection law, you have certain rights when it comes to how we handle your personal data. For example, an individual has the following rights:

The right to make a ‘subject access request’: this entitles you to receive a copy of the personal data we hold about you, together with information about how and why we process it and other rights which you have (as outlined below).
The right to request that we correct incomplete or inaccurate personal data that we hold about you.
The right to withdraw any consent which you have given.
The right to request that we delete or remove personal data that we hold about you 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 exercised your right to object to processing (see below).
The right to object to our processing of your personal data for direct marketing purposes, or where we are relying on our legitimate interest (or those of a third party), where we cannot show a compelling reason to continue the processing.
The right to request that we restrict our processing of your personal data. This enables you to ask us to suspend the processing of personal data about them, for example if you want us to establish its accuracy or the reason for processing it.
The right to request that we transfer to you or another party, in a structured format, your personal data which you have provided to us (also known as the right to ‘data portability’). The applicability of this right depends on the legal grounds on which we process it.
The right to challenge a decision based solely on profiling/automated processing, to obtain human intervention, and to express your point of view.

Please make all requests to exercise privacy rights in writing to privacy@sparkbrighterthinking.com.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing. We will ensure that any transfer of your data will be subject to appropriate safeguards, such as a European Commission approved contract (if appropriate) that will ensure you have appropriate remedies in the unlikely event of a security breach.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.

Disclosure of your information

We may disclose your personal information to any member of our group, which means our direct and indirect subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 (AGI Global Cooperatief).

We may disclose your personal information to trusted third parties:

in the context of the possible sale or restructure of our business;
in the pursuit of legitimate business interests, we may work with third party marketing companies and may share your details with them to promote services and capabilities;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use;
within our approved vendor list, subject to the appropriate Data Protection Agreements;
We may also work with additional third parties including, for example, electronic analytics, advertising networks, analytics providers, search information providers, and may receive certain information about you from them.

Links

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. We recommend that you check these policies before you submit any personal data to these websites.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy below.

IP addresses

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to identify aggregate visitor information. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@sparkbrighterthinking.com.

Cookie Policy

For the purpose of this policy “we”, “us”, “Spark Brighter Thinking”, “ASG” is AGI Global Cooperatief company (and “our” should be construed accordingly) and “you” refers to any person who uses our website.

What is a Cookie?

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

Use of Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. We do not associate any cookie data gathered from this site with any personally identifying information from any source. By continuing to browse the site, you are agreeing to our use of cookies.

Different Types of Cookies

We use the following cookies:

Session Cookies: A session cookie enhances the user experience when using the site. These enable you to carry out some essential functions on our site. They also help by minimising the need to transfer information across the internet. They are not stored on your computer and they expire when you terminate your browser session.
Google Analytics: This web analytics service provided by Google Inc. helps us to analyse how visitors are using our site. Information analysed includes: how many visitors there are to our site, for how long each visitor stays on our site and which pages the visitor visits.
The information generated by Google Analytics about your use of our site will be transmitted to and stored by Google on their servers. Google will use this information for the purpose of evaluating your use of our site, compiling reports on website activity and providing other services relating to website activity.
We may also use cookie information to serve reminder ads about Spark during future browsing sessions.

Third Party Cookies

Please note that third parties (including, for example, the web host) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Consent

If you continue to use our website we will assume that you are happy to receive all cookies from our website. However, if you would prefer to change your cookie settings, you can do so at any time—see below ‘Opting-Out’.

Opting-Out

You have the option to block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Turning cookies off

Internet browsers normally accept cookies by default. However, most browsers let you turn off either all or third-party cookies. What you are able to do depends on which browser you are using. If you do not accept our use of cookies as set out above, please set your browser to reject cookies. However, please be aware that this may impair or limit your ability to use our website. The option to do this is usually found in the options, settings or preferences menu of your browser or mobile device.

You may opt-out of Google’s analytics cookies by visiting Google’s opt-out page – https://tools.google.com/dlpage/gaoptout.

Click on the links below to find out how to change your cookie settings in:

Updating our Cookie Policy

We may update our use of cookies from time to time and consequently, we may update this Cookies Policy. We, therefore, recommend that you check this Cookies Policy regularly.

Further Information on Cookies

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

Queries

If you have any questions or comments regarding this Cookie Policy, please go to privacy@sparkbrighterthinking.com.