Privacy Policy

Sparkland Trading Corporation (“Sparkland Trading Corporation”, "we", "us" or "our"), a BVI business company incorporated and registered in the British Virgin Islands with company number 2107982 whose registered office is at Craigmuir Chambers Road Town, VG1110, British Virgin Islands.

This privacy policy describes how we collect and use personal data about you in connection with the use of www.sparkland.io (the Website) by you, in accordance with the British Virgin Islands Data Protection Act 2021 (the DPA).

It applies to the users of the Website (“user”, "you", or "subject").

We are committed to protecting the privacy and security of your personal data.

Sparkland Trading Corporation is a "controller". This means that we are responsible for deciding how we hold and use personal data about you. We are required under the DPA to notify you of the information contained in this privacy policy.

We may update this policy at any time by publishing the updated version on the Website.

Data Protection Principles

We will comply with data protection law, which says that the personal data we hold about you must be:

Used lawfully.
Collected only for valid purposes that we have explained to you and not used in a way that is incompatible with those purposes.
Relevant to the purposes we have told you about and limited only to those purposes.
Accurate and kept up to date.
Kept securely.

The kind of information we hold about you

Personal data, or personal data, means any information about an individual from which that person can be identified. It does not include data where the person's identity has been removed (anonymous data).

Category of personal data	Description
Contact form data	First name Last name Email address Message contents
Job applications data	First name Last name Email address Resume/CV LinkedIn profile data Personal website data
Additional Personal Data	When you use the Website or interact with our support team, you may choose to provide or you may be requested to provide additional personal data.
Automatically collected data	Location data (region) IP address Web beacons/pixel tags Information about your device (device identifier, name, type, version and model, technical parameters of the device operation) Mobile operating system Wi-fi network data Browser or mobile application details The history of user's activity on the Website Other cookies

How is your personal data collected?

The personal data collected by us through the Website is collected directly from you via the electronic forms or, in the case of automatically collected data, by you interacting with the Website.

How we will use information about you

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 it is required for the proper functioning of the Website.
Where we are taking steps to enter into a contract with you, or where we need to perform the contract we have entered into with you.
Where we need to comply with a legal obligation.

We may also use your personal data in the following situation, which is likely to be rare - where we need to protect your vital interests (or someone else's interests).

Situations in which we will use your personal data

We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. The common situations in which we will process your personal data are listed below.

Situation where pesronal data is used	Legal obligation	Other
Making a decision about your engagement		✔
Determining the terms on which you work for us		✔
Checking you are legally entitled to work in the location	✔
To monitor your use of our information and communication systems	✔	✔
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution	✔	✔

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.

If you fail to provide personal data

If you fail to provide certain information when requested, we may not be able to make a hiring decision or allow you to proceed with the use of the Website.

Change of purpose

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 law.

Sensitive data

We do not actively collect any sensitive personal data via the Website (such as racial origins, political opinions, health or biometric data). However, you may voluntarily provide us with such data.

As we do not know in advance the potentially sensitive nature of the personal data you may provide to us, you must be aware that we may not be able to request your consent with such processing.

If we receive sensitive data from you via the Website, and we determine that there is no basis for processing of such sensitive data by us, we will cease the processing of sensitive data and will delete any such data stored by us.

Do we need your consent?

We do not need your consent if we use your personal data in accordance with our written policy to carry out our legal obligations.

In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of any contract with us that you agree to any request for consent from us.

We do not need your consent where the purpose of the processing is to protect you or another person from harm or to protect your well-being and if we reasonably believe that you need care and support, are at risk of harm and are unable to protect yourself.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means. However, we will notify you in writing if this position changes.

Data sharing

We may have to share your data with third parties, including third-party service providers and other entities in the group. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal data outside the BVI. If we do, you can expect a similar degree of protection in respect of your personal data.

Why might you share my personal data with third parties?

We will share your personal data with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate lawful reason for doing so.

Which third-party service providers process my personal data?

Third parties include third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal data about you for the following purposes: BambooHR, GreenHouse for hiring and human resources managing.

How secure is my information with third-party service providers and other entities in our group?

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When might you share my personal data with other entities in the group?

We will share your personal data with other entities in our group as part of our regular reporting activities on company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.

What about other third parties?

We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal data with a regulator or to otherwise comply with the law.

Transferring information outside the BVI

We will only transfer your personal data outside of the BVI where there is proof of adequate data protection safeguards, or we have your consent.

Data security

We have put in place measures to protect the security of your information. Details of these measures are available above.

Third parties will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Additionally, we limit access to your personal data to those employees, agents, consultants and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data retention

How long will you use my information for?

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, 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.
The applicable legal requirements.

In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, in which case we may use that information without further notice to you.

Rights of access, correction and restriction

Your rights in connection with personal data

Under certain circumstances, by law you have the right to:

Request access to your personal data (commonly known as a 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.
Object to processing of your personal data where we are processing your personal data for direct marketing purposes.

You may have to pay a fee to access your personal data. This will be in accordance with applicable law and we will notify you of such fee (and how it can be paid) if we receive a request from you.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection queries

If you would like to do any of the following:

withdraw your consent to processing of your personal data,
to review, verify, or correct your personal data, or
object to the processing of your personal data,

please contact info@sparkland.io

You have the right to make a complaint at any time to the BVI's Office of the Information Commissioner, responsible for data protection issues in the BVI.

Changes to this privacy policy

We reserve the right to update this privacy policy at any time by publishing the updated version on the Website. We may also notify you in other ways from time to time about the processing of your personal data.