1) Introduction
Growth Spark Digital (“we”, “us”, “our”) respects your privacy and is committed to protecting personal data.
This Privacy Policy explains how we collect, use, store and share personal data when you use our website, contact us, book a call, use one of our demos, or use services we provide to our clients, including AI receptionist, live chat, voice AI, SMS, WhatsApp, automation, CRM and lead reactivation services.
By using our websites, demos, tools or services, you agree to this Privacy Policy.
For terms governing use of our services, please see our Terms & Conditions.
2) Who We Are
Growth Spark Digital is a trading name used by Chris Shannon to provide AI receptionist, automation and marketing technology services.
Our services may include:
- AI receptionist and voice call handling
- Website live chat and chatbot services
- SMS, WhatsApp and email automation
- CRM setup and workflow automation
- Missed enquiry handling and lead follow-up
- Database reactivation and old lead follow-up campaigns
- Review request and reputation automation
3) Data We Collect
3.1 Data You Provide Directly
- Name
- Email address
- Phone number
- Company name
- Job title or role
- Billing or payment details, handled by payment processors
- Messages you send through forms, chat, WhatsApp, SMS, email or phone
- Information you provide when booking a call or requesting a demo
3.2 Call, Chat and Messaging Data
Where our AI receptionist, live chat, SMS, WhatsApp, call handling or automation services are used, we may process:
- Call recordings, where enabled
- Call transcripts
- Call summaries
- Caller name and contact number
- Property or job address
- Postcodes
- Job details or enquiry details
- Urgency, availability and callback information
- Messages sent by website chat, Facebook, SMS, WhatsApp or other channels
This information is used to help our clients respond to enquiries, follow up with customers, capture job details and improve their enquiry handling process.
3.3 Client Lead Data
If a client provides us with customer or lead data for automation, follow-up or database reactivation, this may include:
- Names
- Phone numbers
- Email addresses
- Previous enquiry details
- Quote requests
- CRM notes or status information
- Campaign or lead source information
Clients are responsible for ensuring they have a lawful basis, consent or other valid permission to provide this data to us and to contact those individuals.
3.4 Usage, Technical and Analytics Data
- IP address
- Device type
- Browser and operating system
- Pages visited
- Referral source
- Time and date of visits
- Cookies, pixels, tracking identifiers and similar technologies
- Interaction with emails, forms, chat widgets or demo pages
3.5 Third-Party Integration Data
Where our services connect with third-party tools, we may process data from or through those tools, such as CRM platforms, calendars, phone systems, email systems, payment processors, messaging platforms, analytics tools, advertising platforms or AI providers.
4) How We Use Your Data
We use personal data to:
- Provide, operate and improve our services
- Set up AI receptionist, live chat, CRM and automation systems
- Answer, route, transcribe and summarise calls
- Respond to website chat, SMS, WhatsApp, email or phone enquiries
- Send call summaries, enquiry summaries and notifications to our clients
- Send service updates, reminders or follow-up messages
- Run database reactivation or old lead follow-up campaigns where instructed by a client
- Process payments and manage subscriptions or trials
- Provide customer support
- Monitor system performance and troubleshoot errors
- Prevent fraud, abuse, misuse or security issues
- Comply with legal obligations
4.1 AI and Automation
Some of our services use AI or automation to help respond to calls, messages, chats and enquiries. AI may generate replies, ask questions, summarise conversations, classify enquiries, create CRM notes or trigger follow-up actions.
AI outputs may occasionally be incomplete, inaccurate or misinterpret information. Our clients are responsible for reviewing important enquiries and deciding how to respond. AI should not be treated as a replacement for professional judgement.
4.2 Call Recordings and Transcripts
Where call recording or transcription is enabled, calls may be recorded, transcribed and summarised so that the business can review the enquiry and follow up properly.
Callers should not share highly sensitive information unless necessary for the enquiry.
4.3 Database Reactivation and Lead Follow-Up
Where a client asks us to contact previous leads or old enquiries, the client is responsible for confirming that the data was lawfully collected and that they have a valid basis to contact those individuals.
We act on the client’s instructions when running these campaigns.
5) Lawful Basis for Processing
Depending on the circumstances, we may process personal data under one or more lawful bases, including:
- Contract - to provide services you or our clients have requested
- Consent - where consent is required, such as some marketing or communication activities
- Legitimate interests - to operate, improve and secure our services, respond to enquiries and support business communications
- Legal obligation - where we must comply with laws, regulations or lawful requests
6) Client Responsibilities
When a client uses our services to contact, message, call, follow up with or reactivate their own leads, the client is responsible for:
- Ensuring they collected the data lawfully
- Ensuring they have the right to contact the person
- Providing accurate customer or lead data
- Complying with UK GDPR, PECR, consumer protection rules and other applicable laws
- Honouring opt-outs, unsubscribe requests and “do not contact” requests
- Reviewing AI-generated outputs before relying on them for important decisions
We may refuse or suspend campaigns that appear unlawful, misleading, spam-like or likely to breach data protection or communication rules.
8) Retention and Deletion
We keep personal data only for as long as reasonably necessary for the purpose it was collected, including service delivery, legal, accounting, reporting, security and support purposes.
Call recordings, transcripts, chat logs, SMS messages, WhatsApp messages and CRM notes may be retained while a client account remains active or while needed for support, audit, dispute resolution or legal compliance.
When data is no longer needed, we will delete it, anonymise it or securely archive it where appropriate.
9) Your Rights
Depending on your location and the circumstances, you may have rights under UK GDPR, EU GDPR or other applicable data protection laws, including:
- The right to access your personal data
- The right to correct inaccurate data
- The right to request deletion
- The right to restrict processing
- The right to object to processing
- The right to data portability
- The right to withdraw consent where consent is used
- The right to object to direct marketing
- The right to complain to a data protection authority
To exercise your rights, email [email protected].
If your data was processed on behalf of one of our clients, we may need to pass your request to that client because they may be the data controller.
10) International Transfers
Your data may be processed outside the UK or EEA, including in the United States and other countries where our service providers operate.
Where required, we use appropriate safeguards such as contractual protections, data processing agreements or Standard Contractual Clauses.
11) Security
We take reasonable steps to protect personal data, including:
- Access controls
- Role-based permissions where available
- Secure authentication
- Encryption in transit where supported
- Monitoring and logging
- Limiting access to data where possible
No system is completely secure. If we become aware of a security incident, we will take appropriate steps to investigate, reduce harm and notify affected parties or regulators where required.
13) Marketing Communications
We may contact businesses or individuals where permitted by law, including in response to enquiries, demo requests, existing business relationships, legitimate interest or consent-based marketing.
You can opt out of marketing communications at any time by using unsubscribe options where provided or by contacting us at [email protected].
14) Children
Our services are intended for businesses and are not directed at children. We do not knowingly collect personal data from children. If you believe we have collected such data, please contact us so we can delete it.
15) Changes to this Policy
We may update this Privacy Policy from time to time as our services, systems or legal obligations change.
The updated version will be posted on this page with a new “Last updated” date. Continued use of our website or services after changes are posted means you accept the updated policy.
16) Contact
Growth Spark Digital
Email: [email protected]
If you are in the UK, you also have the right to contact the Information Commissioner’s Office (ICO) if you believe your privacy rights have been infringed.