- interact with us;
- use our website www.bluespark.co.uk (“Our Site”).
Our privacy practices reflect applicable legal requirements, including the General Data Protection Regulation, or the GDPR (“Applicable Data Protection Law”).
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us using the details set out in the “How To Contact Us” section below.
Who we are
What is personal data?
Personal data is information that relates to an identified or identifiable natural person, this means a human being. Anonymous information, where you cannot find out who the data relates to, is not personal data.
What personal data do we collect about you?
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier and title.
Contact Data includes email address and telephone numbers.
Profile Data includes your username and password.
Usage Data includes information about how you use Our Site.
We may collect, use, store and transfer different kinds of personal data about you as set out below:
Information you give us: The information you give us may include your Identity and Contact Data by filling in forms or corresponding with us by post, phone, email or otherwise.
Information we collect about you: With regard to each of your visits to Our Site, we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from Our Site, (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Please see the “Cookies” section for further information.
How will we use the information about you?
We use the personal data we collect about you to:
- manage our relationship with you;
- to communicate with you in response to enquiries;
- to provide you with information about us and our Services,
- to provide the Services to you on request, and to fulfil our obligations in respect of the same;
- to maintain and administer Our Site, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve Our Site, to ensure that content is presented in the most effective manner for you and for your computer or device; or
- as part of our efforts to keep Our Site safe and secure and to prevent fraud;
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where the processing is necessary for the performance of a request you have made (including a request for one of our Services);
- Where we need to comply with a legal or regulatory obligation; or
- Where the processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Please note that we may process your personal data using more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us using the details set out in the “How To Contact Us” section below if you need details about the specific legal ground we are relying on to process your personal data on any given occasion.
Should we wish to use your personal data for other specific purposes that require your consent, we will contact you to request this.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by Applicable Data Protection Law.
Like many websites, Our Site may use ‘cookies’ from time to time.
For more information about the specific cookies we use, please see our Cookies Policy .
Disclosures of your personal data
We may disclose your personal data:
- to third parties as required for our everyday business purposes, including to our related companies, our business partners, suppliers, sub-contractors, and technical services providers, including to provide you with the Services you request;
- analytics and search engine providers that assist us in the improvement and optimisation of the Sites;
- if Blue Spark or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
- to competent authorities (including tax authorities), courts and bodies as required by law; or
- to protect the rights, property, or safety of Blue Spark or the site users, or for internal investigations and reporting. This may include exchanging information with other companies and organisation’s for the purposes of fraud protection.
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.
If we are required to transfer your personal data out of the European Economic Area (“EEA”), we will ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented in accordance with Applicable Data Protection Law, which may include that:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- We will undertake the transfer on the basis of a specific contract approved by the European Commission which give personal data the same protection it has in Europe (“Model Form Clauses”). For further details, and a copy of the text of these Model Form Clauses see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en; or
- Where we use service-providers based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us using the details set out in the “How To Contact Us” section below if you want further information about the specific mechanisms we use when transferring your personal data outside of the EEA in a given circumstance.
How long will you use my personal data for?
We will only retain your personal information 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.
For further information as to any specific retention periods that might apply to personal data we hold about you, please contact us using the details set out in the “How to Contact Us” section.
In some circumstances you can ask us to delete your personal data: see the “Your Legal Rights” section below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. If we do that, we may use this information indefinitely without further notice to you.
Third party websites
Your Legal Rights
In certain circumstances, you have rights under Applicable Data Protection Law in relation to your personal data. You may have the right to:
- 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 information we hold about you corrected, though we may need to verify the accuracy of the new information 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 situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. 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 personal data’s accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal 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 personal 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 Services to you and we may need to suspend or terminate your access to Our Site. We will advise you if this is the case at the time you withdraw your consent.
- Complaining to the UK data protection regulator if you are concerned about the way we have processed your personal data. The Information Commissioner’s Office (“ICO”) website sets out further details.
To exercise certain rights, we may ask you to confirm your identity and where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request.
If you wish to exercise any of the rights set out above, please contact us using the details set out in the “How To Contact Us” section below.
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.
How to contact us
– by email: email@example.com
– or write to us at: 2 East Point, Seal, Sevenoaks TN15 0EG