Who we are

Spark Legal and Policy Consulting[1] is a research consultancy specialising in EU cross border research projects on legal and policy issues. Our unique operating model incorporates teams of legal national experts across different countries who, together with our core team, deliver high quality research and expert analysis.

Our clients include the European Institutions, international law firms, legal publishers, consultancy firms and national governments.

Our UK entity (Spark Legal Network and Consultancy ltd) is a data controller registered with ICO with the certificate reference number ZA362945.

Type of personal data we process

Information you provide us with

We process data that you send us when we agree to collaborate in the context of a specific project, tender or event. This could be your CV or any other relevant document which may contain your personal information.

We also process data you provide us with when subscribing to our newsletter – this includes your name and email address.

Information we collect

On occasion, we collect publicly available information regarding individual experts, stakeholders and potential partners or clients in different fields. We may collect, for example, names, email addresses, affiliation, and field of expertise. Typically, we collect this information online from the websites of universities, centres of excellence, research institutes, consultancies, law firms, public institutions, legal journals, publishers, etc.

How we use your information

We use information for the purposes of conducting our business. This involves mainly three circumstances:

1. We use the information we collect / hold to contact you to enquire about your interest in collaborating with us on future projects. When collecting and holding your data, we rely on legitimate interests (in accordance with Article 6(1)(f) GDPR) to conduct business, which is a right recognised under Article 16 European Charter of Fundamental Rights.[2] For further details, please consult our Legitimate Interest Assessment (which can be obtained upon request to info@sparklegalpolicy.eu)
2. We use the information you provide us with in order to pursue a specific tender or other project acquisition process that you have agreed to participate in, including sharing your personal data with our consortium partners and clients (relying on your explicit consent to be included in the tender, according to Article 6(1)(a) GDPR);
3. We use, process and share with our clients the information we obtain from you (including your personal data) in the context of the performance of a project awarded to us (e.g. we may need your personal data in order to communicate project tasks and deadlines, or in order to proceed with the payment of freelance fees, etc.). In doing that, we rely on the agreement we have signed with you, in accordance with Article 6(1)b GDPR.
4. We use the information you provide us with in order to periodically send you our newsletter, to which you have subscribed (relying on your explicit consent to receive the newsletter, according to Article 6(1)(a) GDPR). We do not use the data you provided us with when subscribing for the newsletter for any other purposes and we do not share this data with any third parties.

We do not process your data for longer than is necessary to achieve the prescribed aim (i.e. to submit the tender and await its results, and – if successful – to complete the subsequent study). We store your contact details as long as you are a business contact to us, but you can opt out from this any time, by emailing us at info@sparklegalpolicy.eu.

We do not use your data for profiling or any automated decision-making processes.

Information that we share

As mentioned above, when necessary, we may share the information you have given us (e.g. your CV and other administrative documents) with our partners in a specific project (such as other consultancies) and with the client (e.g. other companies, or European Institutions).

Personal data which we collect may be stored and processed in any of the EEA countries where we operate. We do not transfer your data to any countries outside the EEA, subject to the exception of using Dropbox for Business for storing and processing data during projects / tenders and servers are located in the USA. Any personal data stored on Dropbox is erased after termination of projects / tenders, and our network database is located on a server within the EEA. We do not share your data in any other context.

Accessing, updating and / or removing your personal information

You are under no statutory obligation to share your data with us. You may request us to confirm what information we hold about you at any time. You also may request us to modify, update or delete such information. In order to do so, please contact us at info@sparklegalpolicy.eu.

Spark believes that its processing of your personal data will have no impact on you as the data subject, and we will only contact you in a professional capacity. However, if at any point you feel we have been in breach of data processing rules, you can lodge a complaint with a supervisory authority (UK: the Information Commissioner’s Office, ICO, https://ico.org.uk/concerns/, BE: The Privacy Commission, as replaced by the Data Protection Authority, https://www.privacycommission.be/fr).

Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

When you first visit our website, we ask you whether you allow us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

We use cookies in the following ways:

• • To track how you use our website;

• • To track your unique visitor session, e.g. whether you have seen specific messages we display on our website.

Changes to this policy

If we decide to introduce any significant changes to this privacy policy, we will publish them on our website (https://www.sparklegalpolicy.eu) and / or we will contact you directly. You are also always welcome to contact us at info@sparklegalpolicy.eu if you have any questions regarding this policy.