Spark Foundry UK (“we,” “us,” or “our”) offers media investment, strategy, insights and analytics, data and technology, commerce, performance marketing and content. This Privacy Notice sets out how we collect, use, share, and protect any information we collect through this website (“Website”). This Privacy Notice also explains the measures we take to safeguard your information and describes how you may contact us regarding our privacy practices.
Any data collected through this Website, including personal data (as defined under applicable data protection laws, referred to collectively as “Personal Data”), will only be used for the purposes set out in this Privacy Notice. Notwithstanding, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
When data is collected on this Website, Spark Foundry UK is acting as a data controller.
Please read this Privacy Notice thoroughly. If you disagree with the way personal information will be used, please do not use the Spark Foundry UK Website (this Website).
We may include links to other websites, including social media platforms. This Privacy Notice only covers this Website and does not apply to the data practices of other websites. We encourage you to read the privacy notices available on other websites you visit.
The following table describes the categories of Personal Data we collect.
Category of Personal Data
List of Personal Data processed
Contact Information and Identifiers
First name, last name, e-mail address, job title, company, country, online identifiers; IP address; mobile ad identifiers
Internet or other electronic network activity information (Technical data)
Browsing history; search history; online interests, such as information about categories of consumer interests derived from online usage; and information on a consumer's interaction with a website, application, or advertisement.
Location information from your device or IP address
Your verbatim communications to us or shared on the public areas of our site
Information that you directly send us by using the comment functionality on this Website
- Directly from you, for example, when you submit your contact information using a content download or subscription form, send us your questions or comments using the query form or make usage of your privacy rights.
The following table provides information about our purposes and legal basis for collecting your Personal Data:
Our Purposes for collecting and using your Personal Data
Basis for processing
To read and respond to your queries to us, sent using our online query form.
Depending on your request, we will rely on our legitimate interest or the performance of pre-contractual measures to respond to individuals’ queries.
When you contact us for the purposes of a data subject access request
We rely on our legal obligation to provide you a process to exercise your rights.
To contact you where you have indicated you wish to receive news and marketing material from us.
For visitors from the European Union, we rely on your consent, where you indicate that you want to receive marketing material from us.
Operating our Website, for example, operating, analyzing, improving, and securing our Website.
For visitors from the European Union, we rely on your consent to obtain your Personal Data through cookies.
For visitors from other geographies, we rely on our legitimate interest to improve our services and develop new products.
Our legitimate interest to support our internal operations and conduct research
In addition, we use analytics services, such as Google Analytics, to help us understand how users access and use the Website. We also we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google, LinkedIn, Twitter and Facebook that you may view on their platforms as well as on other websites.
As part of this process, we may incorporate tracking technologies into our own Website as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).
We also use audience matching services to reach people who have visited our Website or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a customer list to another party or incorporating a pixel from another party into our own Website, and the other party matching common factors between our data and their data or other datasets. For instance, we incorporate the Facebook pixel on our Website and may share your email address with Facebook as part of our use of Facebook Custom Audiences.
We will share your Personal Data for various business purposes with other entities of the Publicis Groupe.
We also may share any of the Personal Data we collect with the following
Sharing for Legal Purposes: In addition, we may share Personal Data with other parties in order to: (a) comply with legal process or a regulatory investigation (e.g. regulatory authorities’ investigation, subpoena, or court order); (b) enforce our Terms of Service, this Privacy Notice, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of other parties; and/or (d) protect the rights, property or personal safety of us, our platform, our customers, our agents and affiliates, its users and/or the public. We likewise may provide information to other companies and organizations (including law enforcement) for fraud protection, and spam/malware prevention, and similar purposes.
Sharing In Event of a Corporate Transaction: We may also share Personal Data in the event of a major corporate transaction, including for example a merger, investment, acquisition, reorganization, consolidation, bankruptcy, liquidation, or sale of some or all of our assets, or for purposes of due diligence connected with any such transaction.
Aggregate, Deidentified, or Anonymised Information: We may aggregate, de-identify and/or anonymise any information collected so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any other party, including advertisers, promotional partners, and sponsors, in our discretion, unless otherwise prohibited by applicable law
Subject to certain exceptions and the jurisdiction in which you live, if you are a resident of the EU, the GDPR provides you with specific rights regarding your Personal Data. This subsection describes your rights and explains how to exercise those rights regarding Personal Data that we hold about you. These rights include:
- The right of access:
You can access all Personal Data we hold about you, know the origin of this Personal Data and obtain a copy in an understandable format.
You may also use your right to access your Personal Data to control the exactness of the data and have them rectified or deleted. You have no justification to provide to exercise your right to access;
- The right to rectification:
In order to avoid that inaccurate or incomplete Personal Data relating to you is process or shared, you can ask us to rectify them;
- The right to erasure:
You may request the erasure or deletion of the Personal Data we hold on you. This is not an absolute right since we may have to keep your Personal Data for legal or legitimate reasons. You may, for example, exercise your right to deletion in the following cases:
- if you have withdrawn your consent to the processing (see below);
- if you legitimately objected to the processing of your data (see below);
- when data is not or is no longer necessary for the purposes for which it was initially collected or processed;
- the data is processed unlawfully (e.g., publishing hacked data);
- The right to object to the processing of your Personal Data:
When we process your Personal Data based on our legitimate interest (to determine to which processing this applies, please refer to Section II of this Privacy Notice), you may at any time object to the processing of your Personal Data for reasons relating to your personal situation. We may nevertheless, on a case-by-case basis, reject such a request by pointing out the legitimate and imperious reasons justifying the processing of this data which prevail on your interests, rights and freedoms, or when this data is necessary to establish, exercise or defend a right before a Court.
- The right to restrict processing:
The right to limit the processing completes your other rights. This right means that the data processing relating to you and that we are performing is limited, so that we may keep this data, but we cannot use it or process it in any other manner. This right applies in specific circumstances, i.e.:
- if you challenge the exactness of your Personal Data. The processing is then limited for a period of time so that the agency may verify the exactness of the Personal Data;
- if the processing is unlawful and you object to the erasure of your Personal Data and request instead that its use be limited;
- if we do not need the Personal Data for the purposes mentioned above in Section I anymore, but you still need it to establish, exercise or defend rights before a Court; and
- in the cases where you objected to the processing which is based on the legitimate interests of the agency, you may ask to limit the processing for the time necessary for us to verify if we can accept your objection request (i.e., the time necessary to verify whether the legitimate reasons of the agency prevail over yours).
- Right to object to data processing for direct marketing purpose
You may unsubscribe or object, at any time and without any justification, to the reception of direct marketing communications. Simply either (i) click on the link in the footer of the communications you receive from us; or (ii) use the hyperlink above; or (iii) send us an email at the email address set out in the “Further Information” section below with the word unsubscribe in the subject field of the email.
- The right to data portability:
You may request to retrieve the Personal Data you provided us with, in a structured, commonly used and machine-readable format, for personal use or to share them with a third party of your choice.
This right only applies to Personal Data you provided us with, directly or indirectly, and which was processed through automated means, if this processing is based on your consent or the performance of a contract. Please check the list of our Personal Data processing activities’ legal grounds (in Section II of this Privacy Notice) to know whether our processing is based on the performance of a contract or on consent.
- The right to withdraw your consent to the processing of your Personal Data at any time:
You may read Section II of this Privacy Notice in order to identify the purposes for which the processing of your Personal Data is based on your consent;
If you are unsatisfied with the way we process your Personal Data or if your request has been rejected, you may also lodge a formal complaint with your local competent data protection authority.
Personal Data will be stored in accordance with our applicable data retention requirements and corporate policies. The retention period for Personal Data varies depending on the type of Personal Data and the purposes of processing it.
You can exercise your rights by using the email email@example.com. Subject to legal and other permissible considerations, promptly and in any event within one month from the data we receive your request. This timeframe can be extended by two months to take the complexity of the request or the number of requests received into account. In this case, we will inform you within one month from receiving your request, specifying the reasons for extending the response timeframe. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way. If we cannot fully address your request, we will contact you to let you know and explain the reason why your request was denied.
- Information from our clients
If Personal Data about you has been processed by us as a processor on behalf of a client and you wish to exercise any rights you have with such Personal Data, please inquire with our client directly. If you wish to make your request directly to us, please provide the name of our client on whose behalf we processed your Personal Data. We will refer your request to that client, and will support them to the extent required by applicable law in responding to your request.
California residents, under the California Consumer Privacy Act of 2018 (“CCPA”), have specific rights with regard to their Personal Data. This section describes how to exercise those rights and our process for handling those requests. (To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.)
Our website is intended to provide information and services to job applicants and business clients. You understand and agree that information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) Spark Foundry UK conducting due diligence regarding, or providing or receiving a product or service to or from your employer.
- Information from our clients
We also acknowledge that you may have rights under the CCPA in connection with the Personal Data we process on behalf of our clients. If Personal Data about you has been processed by us as a service provider on behalf of a client and you wish to exercise any of the rights described below, please provide the name of our client on whose behalf we processed your Personal Data. We will refer your request to that client and will support them to the extent required by applicable law in responding to your request.
California residents have the right to request that we disclose what categories of Personal Data that we collect, use, disclose, or sell about them. In particular, California residents may request:
- the specific pieces of Personal Data that we have collected about you
- the categories of Personal Data we have collected about you;
- the categories of sources from which the Personal Data was collected;
- the categories of Personal Data about you we disclosed for a business purpose or sold;
- the categories of third parties to whom the Personal Data was disclosed for a business purpose or sold; and
- the business or commercial purpose for collecting or selling the Personal Data.
- Right to request deletion of your Personal Data
You may also request that we delete any Personal Data that we collected from you. However, we may retain Personal Data for certain important purposes, as set out by law. When we receive and verify your request to delete your Personal Data we will proceed to delete the data unless an exception applies.
- Right to nondiscrimination.
We do not sell any Personal Data as the term ‘sell’ is used in the CCPA.
- Shine the Light
Customers who are residents of California may request (i) a list of the categories of Personal Data disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in the “Further Information” section below and specify that you are making a “California Shine the Light Request.”
- How to exercise your CCPA privacy rights
California residents may exercise their CCPA privacy rights by sending an email to firstname.lastname@example.org, or by contacting us at:
Phone: (312) 220-5959
Address: 35 W Wacker Dr Chicago, IL, 60601-1723 United States
For security purposes (and as required under California law), we will verify your identity – in part by requesting certain information from you – when you request to exercise your California privacy rights. For instance, if you request categories or specific pieces of Personal Data we have collected about you, you may need to confirm your possession of an identifier (such as an email address) or to provide a piece of identification that confirms you are the person you claim to be.
If we are unable to complete your request fully for any reason, we will provide you additional information about the reasons why we could not comply with your request.
You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.
Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of Personal Data that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of Personal Data for monetary consideration by the business to a third party for the third party to license or sell the Personal Data to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at email@example.com
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.
For example, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can learn about Google’s privacy practices by going to www.google.com/policies/privacy/partners/.
Depending on the choices you made when providing us with your Personal Data and in compliance with applicable data protection laws, we may send you direct marketing communications. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Further Information” section below with the word unsubscribe in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about transactions, servicing, or our ongoing business relations.
The Website is intended for general audiences and is not directed at children. We do not knowingly collect Personal Data (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected Personal Data in violation of COPPA, contact us at firstname.lastname@example.org We will remove the Personal Data in accordance with COPPA. We do not knowingly “sell,” as that term is defined under the CCPA, the Personal Data of minors under 16 years old who are California residents.
We use a variety of methods, such as firewalls, intrusion detection software and manual security procedures, designed to secure your data against loss or damage and to help protect the accuracy and security of information and to prevent unauthorized access or improper use. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. If you think that the Website or any Personal Data is not secure or that there has been unauthorized access to the Website or your Personal Data, please contact email@example.com immediately.
Due to the international nature of our business, your Personal Data may be transferred outside the European Union.
Your Personal Data may be transferred to the US or any country which is not considered to have the same level of data protection as in the EU. However, we ensure all data transfers comply with applicable legal requirements by executing standard contractual clauses. Should you wish to know more about how your Personal Data is protected or wish to request a copy of the contractual protections please contact firstname.lastname@example.org.
Cookies are small pieces of text or code sent to your device when you visit the Website. Cookies are used to optimize the viewing experience, count visitors to a webpage, troubleshoot any problems, keep websites secure, and better serve content. The following cookies are used on the Website:
- Functional and required cookies are always used to allow our hosting platform, to securely serve this Website to you.
- Analytics and performance cookies are used on the Website to view site traffic, activity, and other analytics data.
Overall, cookies help us provide you with a better Website, by enabling us to monitor which pages you find useful and which you do not. You can choose to accept or decline cookies.
If you follow us on social media (for example, through our accounts on LinkedIn, Facebook, Twitter or Instagram), we will also collect Personal Data about you in order to understand our followers better and understand the public response to our products and services. We may use this information to contact you or send you marketing information which we think may be of interest to you/ engage in social listening to identify and assess what is being said about us publicly to understand industry trends and market sentiment. Any information you provide to us when you engage with our content (such as through our brand page or via Facebook Messenger) is treated in accordance with this Privacy Notice. Also, if you publicly reference us or our Website on social media (such as by using a hashtag associated with us in a tweet or post), we may use your reference on or in connection with our Website.
We provide social media plug-ins on the Website to allow you to easily share content from our Website through social media, and in doing so, we may receive your Personal Data from the social media platform that you have authorized to share with us. When you share content using these buttons, a new page will pop up from the relevant social media platform. If you’re already logged into your account on that social media platform, then you will probably be automatically logged into this pop-up page, so that you don’t have to log in again. If, however, you are not logged in (or if you are not registered with the social media platform), the page will ask you for your information.
We have no control over how social media platforms use your Personal Data and they may independently collect information about you when you leave our Website. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to read the privacy notices on the various social media platforms you use.
Find out more about how these social media platforms use your Personal Data:
Any changes to this Privacy Notice will be promptly communicated on this page and you should check back to see whether there are any changes. Continued use of the Website after a change in the Privacy Notice indicates your acknowledgement and acceptance of the use of Personal Data in accordance with the amended Privacy Notice.
This Privacy Notice has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at email@example.com
If you consider that we are not complying with this Privacy Notice, if you have any questions in relation to this Privacy Notice, or have questions about your rights and choices, please contact firstname.lastname@example.org Data subjects in Europe may also lodge a formal complaint with their competent data protection authority.
If you have any questions about Spark Foundry UK's data practices or you wish to exercise your rights or know about the contractual protections in place, please contact the Publicis Chief Data Privacy Officer on email@example.com
Updated: 30th June 2022