Spark To Connect Ltd is committed to protecting your privacy and handling your personal data in a transparent and secure manner. This Privacy Policy explains how we collect, use, and protect your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and the Data Protection Act 2018.

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1. Who We Are

Spark To Connect Ltd is the Data Controller responsible for your personal data.

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Spark To Connect Ltd
Company number: 15180476
Registered office: 71–75 Shelton Street, London, WC2H 9JQ, United Kingdom
Email: info@sparktoconnect.com

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2. What Personal Data We Collect

We may collect and process the following personal data:

Identity and contact information

• Name

• Date of birth

• Address

• Email address

• Telephone number

• Parent or guardian contact details

Programme and application information

• Programme applications and registration details

• Educational information

• Programme participation records

Travel and logistics information

• Flight details and travel itineraries

• Arrival and departure information

• Accommodation details

• Emergency contact details

Dietary, medical, and welfare information

• Dietary requirements

• Allergies and medical information

• Accessibility requirements

Identity verification information

• Passport and visa information (where required)

Financial information

• Payment records and transaction confirmations
  (Payment details are processed securely by authorised payment providers.)

Media information (with consent)

• Photographs and video recordings

Technical information

• IP address

• Browser type

• Website usage information

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3. How We Collect Personal Data

We collect personal data when you:

• Submit an enquiry or application

• Register for a programme

• Complete registration, medical, or consent forms

• Communicate with us

• Attend our programmes

• Use our website

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4. How We Use Your Personal Data

We use your personal data to:

• Process and assess applications

• Deliver and administer our programmes

• Communicate with students and parents

• Arrange travel, accommodation, and logistics

• Provide appropriate meals and ensure health and safety

• Provide safeguarding and emergency support

• Process payments

• Maintain programme and attendance records

• Comply with legal and safeguarding obligations

• Improve our services

We do not sell your personal data.

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5. Legal Basis for Processing

We process personal data under the following lawful bases:

• Contract – to deliver our programmes

• Legal obligation – safeguarding and regulatory requirements

• Legitimate interests – programme administration and safety

• Consent – photography, marketing, and optional services

Consent may be withdrawn at any time.

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6. Special Category Data

Some data we collect, such as dietary requirements, allergies, and medical information, is classified as special category data.

We process this data only where necessary to:

• Protect student health and safety

• Provide appropriate care, meals, and accommodation

• Meet safeguarding and legal obligations

This data is processed securely and with restricted access.

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7. Children's Data

Our programmes are designed for students aged 15–18. We process children's personal data with enhanced safeguards and require parental or guardian consent where applicable.

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8. Sharing Your Data

We may share personal data with trusted service providers who help deliver our programmes, including:

• Microsoft 365 (email and secure storage)

• Monday.com (programme management)

• Adobe Sign (agreement processing)

• Flywire, Stripe, Wise (payment processing)

• Website hosting providers

These providers process data only on our instructions and in accordance with data protection law.

We may also share data where required by law or safeguarding obligations.

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9. International Data Transfers

Some service providers may process data outside the UK or European Economic Area. Where this occurs, appropriate safeguards are in place to protect your personal data.

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10. How We Protect Your Data

We use appropriate security measures to protect personal data, including:

• Secure storage systems

• Access controls and permissions

• Staff training and confidentiality

• Secure technology infrastructure

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11. How Long We Keep Your Data

We retain personal data only as long as necessary for programme delivery, safeguarding, legal, and administrative purposes.

Retention periods are reviewed regularly.

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12. Your Rights

You have the right to:

• Access your personal data

• Correct inaccurate data

• Request deletion of your data (where applicable)

• Restrict or object to processing

• Withdraw consent

• Request transfer of your data

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To exercise your rights, contact:
info@sparktoconnect.com

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You also have the right to lodge a complaint with the UK Information Commissioner’s Office:
https://ico.org.uk

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13. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will always be available on our website.

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14. Contact

Spark To Connect Ltd
71–75 Shelton Street
London, WC2H 9JQ
United Kingdom

Email: info@sparktoconnect.com