We are Owl with a Spark Ltd, trading as Owl with a Spark (“we”, “us”, “our”).
We take the privacy and security of your personal data very seriously. This policy explains what personal data we collect about you, why we need it, how we use it and the rights you have regarding it. The policy applies to any personal data we collect from you, whether you provide us with that data by browsing our website or booking our coaching or consultancy services.
We will be the data controller of your personal data. This means we make decisions about what data to collect from you, what we will do with that data and where we will transfer it.
By visiting our website, you are agreeing to all of the terms in this policy, this includes (but is not restricted to) the acceptance of the use of essential cookies in accordance with the terms of this policy.
PART A: YOUR PERSONAL DATA
1. WHAT DATA DO WE COLLECT?
We may collect any or all of the following kinds of personal data from you:
· Information that you provide to us such as your name, address, date of birth, telephone number, email address and any feedback you give to us, including by phone, email, post, or when you communicate with us via social media.
· Information about the services that we provide to you (including for example, the things we have provided to you, when and where, what you paid, the way you use our products and services, and so on)
· Information required to make decisions about your requests for products and services we offer (for example undertaking coaching).
· Information about whether or not you want to receive marketing communications from us
· Information about any device you have used to access our services (such as your browser or IP address) and also how you use our services. For example, we try to identify how you use our website.
· Your contact details and details of the emails and other electronic communications you receive from us, and how you interact with them. For example, whether the communication has been opened, if you have clicked on any links within that communication. We do this because we want to make sure that our communications are useful for you, so if you don’t open them or don’t click on any links in them, we know we need to improve our services.
In summary:
· Contact Data – Billing address, postal address, email address, contact telephone number.
· Identity Data – Title, full name, sex and gender, date of birth, occupation.
· Marketing and Communications Data – Your preferences regarding whether or not you wish to receive marketing material from us.
· Technical Data – The internet protocol address you use to access our website, your log-in data, browser type and version, location, operating system and device type.
· Tracking Data – The clickstream that brought you to our website, geographic data and the frequency of your use.
· Transaction Data – Details about what services you or your employer have purchased from us in the past, when these services were provided and the price you paid for them.
· Usage Data – Information about how you navigate our website, how long you spend on each page and how often you visit.
We do not collect any data from you which is classified as “special category data.” In brief, special category data is personal information about you which relates to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We also do not collect data about criminal convictions or offences.
All our data is stored within Microsoft Office 365 and Sharepoint. No personal data is stored on hard drives of individual devices (e.g. laptop / PC / tablet) or transportable data storage such as USB devices.
2. HOW WE COLLECT YOUR DATA
We use different methods to collect data from and about you including through:
Direct Interactions
You may give us personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you sign up for the newsletter, book coaching sessions or arrange for us to provide consultancy services.
Interactions with Your Employer
Where your employer has asked Owl with a Spark to provide a service to you and/or any of your colleagues, we may receive contact data and identity data about you from your employer directly. Where this occurs, we will only use that data to contact you about the services we are able to offer.
Automated Technologies or Interactions
As you interact with our website, we will automatically collect tracking data, technical data and usage data about your device, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see part 2 of this privacy policy for further details about what cookies are and how we use them.
3. HOW WE USE YOUR DATA
Whenever we process your personal information we have to have something called a “legal basis” for what we do. The different legal bases we rely on are:
Where we rely on our own legitimate interests to process your data, those interests are:
a) To administer and protect our business;
b) To market our services and target our marketing more effectively; and
c) To use data analytics as a way of improving the user experience on our website.
4. WHO HAS ACCESS TO YOUR DATA?
We will never sell your personal data. However, we may share it with suppliers who provide services to our business.
We may use your information in the following ways:
Our service providers - we work with different companies so that they can help us provide the products and services you require from us or we think you might be interested in. These third parties may include:
Whenever we share your data with any third party, they will be subject to a contract which imposes strict obligations of confidentiality and compliance with UK data protection laws on them. If any of them are based outside the UK or a safe destination under data protection law, we will ensure that suitable contracts are put in place with them to keep your personal data secure whilst it is in their possession.
Please note that we may disclose your personal data to a third party where:
a) We need to do so to comply with any applicable law, regulation, legal process or governmental request;
b) We believe, in good faith, that we need to disclose personal data about you in order to prevent harm to any person;
c) We need to do so to investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud, safeguarding or security issues;
d) To establish or defend legal claims; or
e) If we sell, transfer or merge our business or any part of it. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
5. RETENTION AND DELETION OF DATA
We will keep your personal information for the purposes set out in this privacy policy and in accordance with the law and relevant regulations. We will never retain your personal information for longer than is necessary. In most cases, our retention period will come to an end 7 years after the end of your relationship with us. It is not always possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the purpose for which we collected that data originally. However, we may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
All Owl with a Spark data is held in Microsoft 365. Microsoft has a Data Handling Standard policy for that specifies how long customer data is retained after deletion. There are generally two scenarios in which your data is deleted:
· Active Deletion: Owl with a Spark has an active subscription and a user or administrator deletes data, or administrators delete a user.
· Passive Deletion: Owl with a Spark’s subscription ends.
Further details of retention and deletion of data by Microsoft Office 365 in the above scenarios can be found here
6. THE RIGHTS YOU HAVE REGARDING YOUR PERSONAL DATA
Under certain circumstances, you have rights under data protection law in relation to your personal data. You have the right to:
a) Request access to the personal data we hold about you;
b) Request corrections to any of the personal data we hold, if it is inaccurate;
c) Ask us to erase your personal data;
d) Object to the way in which we process your personal data; or
e) Request transfer of your personal data in a commonly-used file format.
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 could refuse to comply with your request in these circumstances. If you wish to exercise any of the rights set out above, please contact us. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.
7. THE INFORMATION COMMISSIONER’S OFFICE
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK regulator for data protection issues. Details of how to do this can be found on their website, which you can access by clicking here. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
PART B: WEBSITE COOKIES
ABOUT COOKIES
Our websites uses local storage (such as cookies) to provide you with the best possible experience and to allow you to make use of certain functionality. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree.
Cookies serve to distinguish you from other users of the website. They may allow us to remember that you have visited our website before, or to tailor it for use on your device. They also help us understand our visitors better (e.g. by letting us analyse how visitors are directed to our website, what the most popular pages are, and what devices are used most often to browse the website). If you would like to learn more about cookies and how they work, you can click here for more information.
2. COOKIES OUR WEBSITE USES
Whilst visiting either of our websites you accept and consent to the use of the following cookies and terms. Our website uses a range of different cookies:
dps_site_id
(This cookie is used to identify the site ID of the user, helping to maintain session information for the user's visit. It enhances user experience by enabling website functionalities to be personalized.)
_scc_session
(This cookie is used to maintain an anonymized user session by the server.)
_tccl_visitor
(This cookie is used to track and analyse the behaviour of visitors on the website to improve user experience and functionality.)
_tccl_visit
(This cookie is used to track a visitor's navigation and behavior on the website to understand visitor usage patterns, optimize user experience, and enhance site performance.)
3. MANAGING YOUR COOKIES
You can block certain types of cookie on your browser directly.
By blocking all cookies, it will have a negative impact upon the usability of many websites, including our own. If you block cookies, you may not be able to use all the features on our website.
To opt-out of most Marketing Cookies used by services such as Google and Facebook, then visit the below links and follow the instructions on screen:
https://www.youronlinechoices.eu/
https://optout.networkadvertising.org/?c=1#!/
PART C: CONTACT INFORMATION
FOR GENERAL CONTACT
If you have any queries regarding our Privacy and/or Cookie Policy, then please feel free to get in touch using one of the contact methods below:
Telephone Number: 07703365643
Email address: helen@owlwithaspark.com
Postal address: 8 London Road, St Pauls, Bristol, BS2 9QE
FOR DATA CONTACT
If you would like information on the data, we currently store on yourself, this includes any requests for updating, deleting or supplying the data. Then please get in touch using the below details.
Telephone Number: 07703365643
Email address: helen@owlwithaspark.com
Postal address: 8 London Road, St Pauls, Bristol, BS2 9QE