For the purposes of the Data Protection Act 1998 (the Act), Sparx is registered as a data controller (ICO registration number ZA006725). Our address is Oxygen House, Grenadier Road, Exeter, Devon, EX1 3LH.
Information we may collect from you
We may collect and process the following data about you:
- Information you give us. You may give us information about you by filling in forms or submitting your CV to our website sparx.co.uk (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site or submit your CV or any forms and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial information, personal description and photograph, and other personal information (including sensitive personal data) related to your work, education and employment history, activities and personal circumstances.
- 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;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); 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.
- Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide.
Uses made of the information
- Information that you give to us or that we collect about you. We may use this information in the following ways:
- to allow you to access and log into our site;
- to provide you with information, products and services that you may request from us;
- to provide you with other information that is similar to that which you have already enquired about or that we feel may interest you;
- to improve our site and ensure that content from our site is presented in the most effective manner for you and for your computer;
- to monitor and administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to allow you to participate in any interactive features of our service, when you choose to do so;
- to consider and process any enquiries, applications or CVs submitted by you for job opportunities advertised on our site or to match your details with any vacancies we or any companies within our group may have;
- as part of our efforts to keep our site safe and secure.
- Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
We may share your personal information with any companies within our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may disclose your personal information (including sensitive personal data) to any of our employees, directors, professional advisers, insurers, agents, suppliers or contractors in order to consider any enquiries, applications or CVs submitted by you for jobs within Sparx or with any companies within our group] and so far as is reasonably necessary for the purposes set out in this policy.
We may share your information with selected third parties including:
- Business partners and suppliers for the performance of any contract we enter into with them or you;
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If Sparx or substantially all of its assets are acquired by a third party, in which case personal data held by Sparx about its suppliers, customers and employees (including prospective employees) will be one of the transferred assets;
- If we are under a duty to disclose or share your personal data with any regulatory or law enforcement authorities, if required to do so;
- In order to exercise or defend our legal rights or in connection with any legal proceedings or anticipated legal proceedings;
Where we store your personal data
The majority of the data we collect will be stored and processed in the UK at our offices and in our secure data centre(s). We will only transfer your data outside of the European Economic Area where it is necessary for us to do so.
In order to ensure delivery of our personalised homework email to parents it is necessary for us to transfer some data to a US email delivery provider, PostMark. We have undertaken a detailed assessment of this provider and have concluded that they have good privacy safeguards and security features in place to prevent unauthorised access of data we send them.
We are continually improving our service and as such it is necessary for us to analyse and manage the performance of our code, user interface devices and internet connections. We use a system provided by a US based company, New Relic, to assist us with this analysis. We have undertaken a detailed assessment of this provider and have concluded that they have good privacy safeguards and security features in place to prevent unauthorised access of data we send them.
We will not process your personal data for marketing purposes without your express consent. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to opt out of such use by checking certain boxes on the forms we use to collect your data or at any time by contacting us at firstname.lastname@example.org.
Our site may, from time to time, contain links to and from the websites of our partner networks, 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. Please check these policies before you submit any personal data to these websites.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you. You may also be asked to provide suitable evidence to prove your identity.