Privacy Policy
Learn how we collect, use, and protect your information. Read our full privacy policy to understand your rights and our data practices.
Privacy policy
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1. Introduction
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1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers, customer personnel, prospective customers, subscribers or followers, as well as any third-party suppliers or partners.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Our business incorporates privacy controls which affect how we will process your personal data. You can choose to subscribe to our direct marketing communications on our website, or you can unsubscribe at any time from our direct marketing communications via the unsubscribe button on any of our direct marketing emails. If you have any other questions or need further assistance regarding your privacy preferences, please contact us.
1.4 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.5 In this policy, "we", "us" and "our" refer to Violet Spark Ltd. For more information about us, see Section 13.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2.2 We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer. If any of your log-ins are used in our services, such as social media accounts, other marketing platforms or related services, we may obtain elements of the contact data from the relevant social media account provider.
2.3 We may process your website user account data ("account data"). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website. If any of your log-ins are used in our services, such as social media accounts, other marketing platforms or related services, we may obtain elements of the account data from the relevant social media account provider.
2.4 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
2.5 We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.6 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
2.7 We may process customer registration data. This data may include names, email addresses, company addresses, phone numbers, and account preferences shared with us during registration or agreement of services. The source of this data is through our website, payment processes, or through communications.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations - We may process your personal data for the purposes of operating our website, creating and managing advertising campaigns, analysing marketing performance, communicating with clients, providing social media marketing services, generating invoices and ensuring payment for services rendered. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.3 Publications - We may process account data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for processing is consent obtained where applicable for the publication of client testimonials, case studies, or success stories on our website or social media, sharing client-generated content, such as images or videos as part of our marketing campaigns, or displaying client logos or affiliations on our website marketing materials to showcase our client portfolio, only with your consent. Additionally, the legal basis may also include our legitimate interests, namely the publication of content in the ordinary course of our operations to showcase our services and expertise, or the performance of a contract between you and us and/or taking the steps, at your request to enter into such a contract.
3.4 Relationships and communications - We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
3.5 Direct marketing - We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email. The legal basis for this processing is consent obtained from individuals who actively opted in to receive direct marketing communications, with the choice to unsubscribe at the bottom of any marketing communications email. Alternatively, we may rely on our legitimate interests, particularly in promoting our business and communicating marketing messages and offers to our website visitors and service users. We ensure that any direct marketing activities conducted under legitimate interests are balanced against the rights and freedoms of individuals.
3.6 Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
3.7 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.8 Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.9 Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.10 Legal claims - We may process your personal data where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.11 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
4.2 Your personal data (such as contact or account data, transaction or usage data, or communication data) will be held in our website database OR on the servers of our hosting service providers, or alternatively on the company’s internal drives. We maintain compliant security measures and adhere to data protection regulations to safeguard personal data.
4.3 We may disclose contact or account data, transaction data, or communication data to subcontractors or services insofar as reasonably necessary for processing orders, providing support services, fulfilling contractual obligations, or other relevant business purposes.
4.4 Financial transactions relating to our website and services are handled by our payment services providers (we use Anna Money, or other providers like Wix Payments or Stripe). We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at:
https://anna.money/privacy-policy, https://www.wix.com/about/privacy or https://stripe.com/gb/privacy.
4.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
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5. International transfers of your personal data
5.1 You acknowledge that personal data that you submit for publication (with your consent [see section 3.3]) through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Contact data will be retained for a minimum period of three years following the date of the most recent contact between you and us, or for as long as needed to fulfill business objectives.
(b) Account data such as account log-ins will be immediately deleted within 30 days following the end of a contract of services to ensure security. Other account data will be retained for a minimum period of one year following the date of closure of the relevant account, and for a maximum period of two years following that date.
(c) Transaction data will be retained for a minimum period of six years following the date of the transaction, and for a maximum period of seven years following that date to comply with tax regulations.
(d) Communication data will be retained for a minimum period of one year following the date of the communication in question, and for a maximum period of three years following that date, or for as long as needed to fulfill business objectives.
(e) Usage data, will be retained for one year following the date of collection, and for a maximum period of two years or for as long as needed to fulfill business objectives.
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Your rights
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7.1 In this Section 7, we have listed the rights that you have under data protection law.
7.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
7.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-the-public/.
7.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
8. About cookies
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8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
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8.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
9.1 We use cookies for the following purposes:
(a) authentication and status - we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website (cookies used for this purpose are: authentication cookies, remember me cookies, security cookies, user interface customization cookies, analytics cookies).
(b) shopping cart - we use cookies to maintain the state of your shopping cart as you navigate our website (cookies used for this purpose are: session cookies, cart identifier cookies, cart item cookies).
(c) personalisation - we use cookies [to store information about your preferences and to personalise our website for you (cookies used for this purpose are: preference cookies, language cookies, theme cookies).
(d) security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: authentication cookies, session cookies, security tokens).
(e) advertising - we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: targeting cookies, advertising cookies, tracking pixels).
(f) analysis - we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: analytics cookies, performance cookies, tracking cookies).
(g) cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: preference cookies, consent management cookies).
10. Cookies used by our service providers
10.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
10.2 We use Google Analytics and Wix. Both sites gather information about the use of our website by means of cookies.
The information gathered is used to create reports about the use of our website.
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10.3 You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.
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10.4. You can find out more about Wix use of information by visiting
https://www.wix.com/about/privacy
11. Managing cookies
11.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).
11.2 Blocking all cookies will have a negative impact upon the usability of many websites.
11.3 If you block cookies, you will not be able to use all the features on our website.
12. Amendments
12.1 We may update this policy from time to time by publishing a new version on our website.
12.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
12.3 We may notify you of any significant changes to this policy by email.
13. Our details
13.1 This website is owned and operated by Violet Spark Ltd.
13.2 We are registered in England and Wales under registration number 14387576, and our registered office is at: 2nd Floor College House, 17 King Edwards Road, Ruislip, London, United Kingdom, HA4 7AE.
13.3 Our principal place of business is at: 2nd Floor College House, 17 King Edwards Road, Ruislip, London, United Kingdom, HA4 7AE.
13.4 You can contact us:
(a) by post, to the postal address given above; or
(b) using our contact form published on our website: Contact Us
14. Data protection Contact
14.1 If you have any concerns about our use of your personal information, you can make a complaint to us at our contact details in the section above.
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You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
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ICO Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
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