Privacy Policy

Welcome to eSpark SIT ("Company", "we", "our", "us"). We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, username or similar identifier, title, and company name.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Project Data includes information about projects you discuss with us, requirements, specifications, and business needs.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

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:

• To provide our services: Including project development, consulting, support, and maintenance
• To manage our relationship with you: Including notifying you about changes to our terms or privacy policy
• To improve our website: We continually strive to improve our website offerings based on the information and feedback we receive from you
• To process payments: For services rendered and products purchased
• Marketing communications: To send you information about our services that may be of interest to you (with your consent where required)
• To comply with legal obligations: Including tax and regulatory requirements
• Business analytics: To understand how our services are used and to improve our offerings
• Security and fraud prevention: To protect our business and your data from unauthorized access

We do not sell, trade, or rent your personal identification information to third parties.

We may share your personal information in the following situations:

Service Providers: We may share your information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Legal Requirements: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process.

With Your Consent: We may disclose your personal information for any other purpose with your consent.

Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.

All third parties with whom we share your data are required to maintain appropriate security measures and are prohibited from using your personal data for any purpose other than that for which it was provided.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure.

Our security measures include:

• Encryption: We use SSL/TLS encryption for data transmission
• Access Controls: Limited access to personal data on a need-to-know basis
• Secure Infrastructure: Cloud infrastructure with industry-standard security certifications
• Regular Security Audits: Periodic assessment of our security measures
• Employee Training: Regular training on data protection and security best practices
• Incident Response: Procedures for detecting and responding to data breaches
• Data Backup: Regular backups to prevent data loss
• Firewall Protection: Network security measures to prevent unauthorized access

Despite our safeguards, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

Right to Access: You have the right to request access to your personal data (commonly known as a "data subject access request").

Right to Correction: You have the right to request correction of the personal data we hold about you.

Right to Erasure: You have the right to request erasure of your personal data in certain circumstances.

Right to Object: You have the right to object to processing of your personal data where we are relying on a legitimate interest.

Right to Restrict Processing: You have the right to request restriction of processing of your personal data in certain circumstances.

Right to Data Portability: You have the right to request the transfer of your personal data to you or to a third party.

Right to Withdraw Consent: Where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time.

If you wish to exercise any of these rights, please contact us using the contact information provided below.

We use cookies and similar tracking technologies to track the activity on our website and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier.

Types of Cookies We Use:

• Essential Cookies: Required for the operation of our website
• Analytics Cookies: Help us understand how visitors interact with our website
• Functionality Cookies: Enable enhanced functionality and personalization
• Advertising Cookies: Used to deliver relevant advertisements to you

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website.

Third-Party Tracking: We may use third-party service providers such as Google Analytics to monitor and analyze the use of our website. These third parties have their own privacy policies addressing how they use such information.

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, 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 unauthorized 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, and the applicable legal, regulatory, tax, accounting or other requirements.

Retention Periods: • Client project data: Duration of project + 7 years for accounting purposes • Marketing communications: Until you unsubscribe or request deletion • Website analytics: 26 months • Support tickets: 3 years after resolution • Employment data: Duration of employment + 7 years

Our website may contain links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy policy of every website you visit.

Our website is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

We may update our privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on this page and updating the "Last Updated" date at the top of this privacy policy.

You are advised to review this privacy policy periodically for any changes. Changes to this privacy policy are effective when they are posted on this page.

We will notify you via email and/or a prominent notice on our website, prior to the change becoming effective if the changes are significant.

If you have any questions about this privacy policy, please contact us:

Email: privacy@esparksit.com Phone: +1 (XXX) XXX-XXXX Address: [Your Company Address]

Data Protection Officer: Email: dpo@esparksit.com

We aim 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.