PERSONAL INFORMATION
Personal information: The types of personal information or personal data we may collect about you include:
We may collect, hold, use and disclose personal information for the following purposes:
We may disclose personal information to:
Where we disclose your personal information to third parties, including data processors, we will request that the third party handle your personal information in accordance with this Privacy Policy.
These third parties will only process your personal information in accordance with written instructions from us and we require that the third party either complies with the privacy shield principles set out in the GDPR or another mechanism set out by applicable EU & Swiss data protection laws for the transfer and processing of personal information. When we refer to ‘processing’ in this clause and this Privacy Policy in general, we mean any operation or set of operations which is performed on personal information, whether or not by automated means, such as collecting, recording, organising, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available personal information.
Please note that we currently use the following third parties to process your personal information. Our carefully selected partners and service providers may process personal information about you on our behalf as described below:
Digital Marketing Service Providers: We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
By providing us with personal information, you consent to the disclosure of your personal information to third parties who are outside Australia and if you are an EU citizen, to third parties that reside outside the EU Where the disclosure of your personal information is solely subject to Australian privacy laws (and not subject to the GDPR), you acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.
Sensitive information is a sub-set of personal information that is given a higher level of protection under the Australian Privacy Principles. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information or biometric information.
We do not collect sensitive information as part of our services but if we ever do request sensitive information from you, we will always ask for your consent first and you will always have the option of refusing your consent and we will not collect the sensitive information from you.
Provided you consent, your sensitive information may only be used and disclosed for purposes relating to the primary purpose for which the sensitive information was collected.
Sensitive information may also be used or disclosed if required or authorised by law.
Controllers are defined by the GDPR as natural or legal persons, a public authority, agency or other body to which personal information or personal data has been disclosed, whether via a third party or not and who determines the purposes and means of processing personal information. We are a controller under the GDPR as we collect, use and store your personal information to enable us to provide you with our goods and/or services.
As a controller, we have certain obligations under the GDPR when collecting, storing and using the personal information of European Union (EU) citizens. If you are an EU citizen, your personal data will:
Specifically, we have the following measures in place, in accordance with the GDPR:
Where we are a processor, we have contracts containing certain prescribed terms in our contracts with controllers. Depending on circumstances, we can be a controller or processor or controller and processor. In addition to:
Choice and consent: Please read this Privacy Policy carefully. By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy. If you are under 16 years of age, you must have and have, and warrant to the extent permitted by law to us that you have, your parent or legal guardian’s permission to access and use the Site and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this Site or the products and/or services offered on or through it.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict how we process your personal information, we will let you know how the restriction affects your use of our Site or products and services.
Access and data portability: You may request details and copies of the personal information that we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party (referred to as data portability).
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Complaints: If you believe that we have breached the Australian Privacy Principles or an article of the GDPR and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact the Office of the Australian Information Commissioner if you wish to make a complaint.
Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures such as the pseudonymisation and encryption of personal information, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
We may use cookies on our Site from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.
We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
We may use Google Analytics to collect and process data. To find out how Google uses data when you use third party websites or applications, please see
www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time.
Our Site may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
We may, at any time and at our discretion, vary this Privacy Policy. We will notify you if we amend this Privacy Policy, by contacting you through the contact details you have provided to us. Any amended Privacy Policy is effective once we notify you of the change.
For any questions or notices, please contact our Privacy Officer, Russell Smith, at:
NEWBURY STREET Pty Ltd ABN 65632758368 trading as Spark Growth.
Email: info@sparkgrowthmarketing.com.au
Last update: 07 June 2023
We provide businesses with immediate access to high-quality marketing experts, innovative strategies, and top-tier services. Our unique model functions as your dedicated in-house marketing team, ensuring you receive the strategic guidance and hands-on support you need.
3/57 Market Street, Fremantle, WA, Australia 6160
info@sparkgrowth.com.au
(08) 6219 6711
sparkgrowth.com.au
Spark acknowledges and respects Aboriginal and Torres Strait Islanders as the traditional owners of this land. We pay our respects to Elders past, present and emerging.