Privacy Policy

Last updated: January 2025

1. Introduction

Harness the Spark Ltd ("we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our coaching services and website.

We comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

2.1 Information You Provide

Contact Information: Name, email address, phone number, and postal address
Professional Information: Job title, company name, professional background
Coaching Information: Notes from sessions, goals, progress tracking, and any information you share during coaching
Payment Information: Bank details or payment card information for processing payments
Communication Data: Records of our correspondence and communication preferences

2.2 Information Collected Automatically

Usage Data: Information about how you use our website
Device Data: IP address, browser type, operating system
Cookies: We use essential cookies to ensure our website functions properly

3. Legal Basis for Processing

We process your personal data under the following legal bases:

Contract: To provide coaching services you've requested
Consent: For marketing communications and optional data processing
Legitimate Interests: To improve our services and maintain business records
Legal Obligations: To comply with tax and regulatory requirements

4. How We Use Your Information

We use your information to:

Provide and manage coaching services
Process payments and maintain financial records
Communicate with you about sessions and services
Send marketing communications (with your consent)
Improve our services and develop new offerings
Comply with legal and regulatory obligations
Protect against fraud and unauthorised access

5. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information. We may share your information with:

Service Providers: Third parties who assist in delivering our services (e.g., payment processors, email providers)
Professional Advisors: Accountants, lawyers, and other professional advisors
Legal Requirements: When required by law or to protect our rights
Business Transfers: In connection with a merger or sale of our business

6. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

Secure storage of physical and electronic records
Encryption of sensitive data
Regular security assessments
Limited access to personal data on a need-to-know basis

7. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes outlined in this policy, unless a longer retention period is required by law. Typically:

Coaching Records: 7 years after the end of our coaching relationship
Financial Records: 7 years for tax and accounting purposes
Marketing Data: Until you withdraw consent or request deletion

8. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

Access: Request a copy of your personal data
Rectification: Request correction of inaccurate data
Erasure: Request deletion of your data (subject to legal requirements)
Restriction: Request limited processing of your data
Portability: Receive your data in a structured format
Objection: Object to certain types of processing
Withdraw Consent: Withdraw previously given consent

To exercise any of these rights, please contact us using the details below.

9. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children.

10. International Transfers

Your information may be transferred to and processed in countries outside the UK. We ensure appropriate safeguards are in place to protect your data in accordance with this policy.

11. SparkHub Platform

When SparkHub launches, additional privacy considerations will apply. Beta users will receive supplementary privacy information regarding platform data collection and usage.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date.

13. Contact Information

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

Data Controller: Harness the Spark Ltd
Registered in England & Wales
Company Number: 12936448
VAT Number: 360902218
Registered Office: 3rd Floor, 86 - 90 Paul Street, London, EC2A 4NE

Contact Person: Lisa Gills
Email: lisa@harnessthespark.com
Website: www.harnessthespark.com

14. Complaints

If you're not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Website: ico.org.uk
Phone: 0303 123 1113