Privacy Policy

By accessing or using this website, you agree to the terms of this Privacy Policy, as outlined below. By engaging in this site and providing your data, you confirm that you are over 13 years of age.

1. INTRODUCTION

This Privacy Policy outlines how The Sparkle Project processes the personal data that is collected through www.thesparkleproject.co.uk automatically or when you provide information through filling in a form on this site to make an enquiry, book a free consultation or sign up to our monthly newsletter.

The term 'The Sparkle Project', 'The Website', 'us', 'we' or 'our' refers to the owner of the website. The term 'you' refers to the user or viewer of our website.

Sinéad Mangan,  is the owner of this site and is responsible for your personal data.

2. CONTACT INFORMATION

Trading Name: The Sparkle Project

Owner: This business and website is managed by Sinéad Mangan

Email address: sineadmangan@thesparkleproject.com

3. PERSONAL DATA THAT WE COLLECT

The Sparkle Project processes certain types of personal data which may include the following. Please note: Personal data means any information that may allow you to be identified and does not include anonymised data.

  • Identity Data: Full name, gender, job title, profession, your business name and the purpose of your business.

  • Contact Data: Email address, telephone number, Skype Address, Social media handles, postal address, billing address.

  • Sensitive Data: Details about your general health in relation to the goals you wish to set within a health coaching service.

  • Financial Data: Bank account and payment card details (encrypted through Stripe or Paypal if an online payment is made)

  • Technical Data: Internet protocol addresses IP, web browser type and version, operating system, browser plug-in types and versions, time zone, location.

  • Usage Data: Information about how you use our website (automatically collected).

4. PERSONAL DATA WE DO NOT COLLECT

We do not collect any Sensitive Data about you which includes information about your racial or ethnic origin, political opinions, religious beliefs, trade union activities, sexual life, or details of criminal offences.

5. HOW WE COLLECT YOUR PERSONAL DATA

Direct communications and online forms: In order to make a general enquiry, to sign up to our monthly email newsletter or to book a free consultation on this site, you may be asked to provide data which includes your name and email address. You may also be asked about your general health in relation to the goals you wish to set within a health coaching service (although sharing this information through this website is optional and doesn't impair your ability to work with me).

Automatically collected data. This includes Technical Data and Usage Data. We may also receive information through cookies. Please see our cookie policy for further details.

Data from third parties. In order to fulfil functions of this site we may, on occasion need to share data with the following third parties: 

  • Google Analytics: Collects Technology Data and Usage Data to help us ensure your experience using this site functions to the best of its ability. 

  • Mail chimp: Collects Contact Data (email and name) to fulfil your optional request to receive our monthly email newsletter.

  • Stripe and PayPal: May collect Financial Data, Contact Data and Information Data in order to process payments for services. Please note: Payments details are encrypted using SSL technically (typically you will see a lock icon or green address bar (or both) in your browser when using this technology).

  • Advisers, consultants and technicians. This may include IT specialists, lawyers, bankers, auditors and insurers and accountants.

  • Regulators and authorities. For example Revenue Commissioners or other authorities in Ireland that require reporting of processing activities in certain circumstances.

6. HOW YOUR PERSONAL DATA IS USED

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

  • Internal record keeping

  • Answering enquiries 

  • Marketing (if you have optionally signed up to our email newsletter)

  • Booking consultations and using services

  • Taking payments of services

All data will only be used for the purpose in which it is collected. 

7. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

  • Service providers who provide IT and system administration services.

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • Revenue Commissioners, regulators and other authorities based in Ireland and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

8. INTERNATIONAL TRANSFERS

Some of the third party service providers The Sparkle Project uses are not based within the European Economic Area (EEA). This means that your data will involve transfer outside the EEA.

If we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or

  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at sineadmangan@thesparkleproject.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

9. KEEPING DATA SECURE

We will use technical and organisational measures to safeguard your Data, for example:

  • We store your Data or secure servers

  • Payment details are encrypted using SSL technically (typically you will see a lock icon or green address bar (or both) in your browser when using this technology).

Technical and organisational measure include measures to deal with any suspected data breach. If you suspect any misuse or loss of unauthorised access to your Data, please let us know immediately by contacting us via sineadmangan@thesparkleproject.com.

10. DATA RETENTION  

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until your request that the Data be deleted.

For enquiries, your data will be deleted within 6 months of your enquiry being made, or until your enquiry has been adequately dealt with.

For website design and copywriting clients, your data will be deleted after 6 months your project completion.

Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

11. YOUR LEGAL RIGHTS

You have the following rights in relation to your Data:

  • Right to access. The right to request (i) copes of the information we hold out you at any time or (ii) that modify, updates or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive". Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

  • Right to correct. The right to have your Data rectified if it is inaccurate or incomplete.

  • Right to erase. The right to request that we delete or remove your Data from  our systems.

  • Right to restrict our use of your Data. The right to "block" us from using your Data or limit the way in which we can use it.

  • Right to data portability. The right to request that we move, copy or transfer your Data.

  • Right to Object. The right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set above or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via sineadmangan@thesparkleproject.com.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For Ireland, this is the Data Protection Commission Their contact details can be found on its website at https://www.dataprotection.ie.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period in which we hold it.

12. LINKS TO OTHER WEBSITES

This website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other website prior to using them.

13. COOKIES

This Website may place and access certain Cookies on your computer. The Sparkle Project uses Cookies to improve your experience of using the Websites and to improve our range of products and services. The Sparkle Project has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current EU Cookie Law.

You can disable cookies from the browser you use to access this site. For more information about the cookies we use, please see our cookie policy.