1) Introduction
Growth Spark Digital LLC (“we”, “us”, “our”) is committed to protecting your privacy. This policy explains what we collect, how we use it (including where our service uses AI and automation), when we share it, and your rights under UK/EU data protection law.
By using our websites, tools and services (the “Service”), you agree to this policy.
For terms governing use of our Service, see our Terms & Conditions.
2) Data We Collect
2.1 Personal / Identifying
- Name, email, phone, postal address
- Company details, role/position
- Billing details (handled via payment processors)
- Login credentials
2.2 Usage, Technical & Metadata
- IP address, device, OS, browser
- Pages visited, timestamps, referrers, error logs
- Cookies, pixels, beacons, session identifiers
2.3 Content & Input Data
- Messages, files, form entries, uploads you submit
- AI outputs generated during your use
- Feedback on AI outputs and usage history of AI features
2.4 Third-Party / Integration Data
- Data we receive when you connect third-party tools (e.g., CRM, calendars, messaging)
2.5 Aggregated / De-identified
- Analytics and insights that do not identify individuals
3) How We Use Your Data (incl. AI)
- Provide, maintain and secure the Service
- Authenticate accounts and deliver support
- Generate AI-assisted content and responses you request
- Monitor performance, detect/prevent abuse and fraud
- Analytics, reporting and Service improvement
- Communications: emails, notifications, service updates
- Legal compliance and enforcement
3.1 Automated / AI Decisioning
Where AI assists with responses or recommendations, you remain in control: you can review, correct or override outputs. We do not use solely automated decisions that produce legal or similarly significant effects without human involvement.
3.2 Training & Improvement
We may use de-identified data to improve models and the Service. We avoid using identifiable content for model training without your explicit consent. You can opt out (see section 6).
5) Retention & Deletion
We keep personal data only as long as needed for the purposes described or as required by law. When no longer needed, we delete or anonymise it. Model artefacts or aggregated statistics may be retained without raw personal data.
6) Your Rights (GDPR/UK)
- Access your data
- Rectification of inaccuracies
- Erasure (“right to be forgotten”)
- Restriction of processing
- Objection (incl. to direct marketing/profiling)
- Portability (structured, machine-readable)
- Withdraw consent where processing relies on consent
- Opt-out of AI training use of your data
- Complain to the ICO (UK) or relevant authority
To exercise these rights, email [email protected]. We may need to verify your identity.
7) International Transfers
Your data may be processed outside the UK/EEA. We use appropriate safeguards (e.g., Standard Contractual Clauses) where required.
8) Security
- Encryption in transit/at rest where feasible
- Access controls and role-based permissions
- Monitoring, logging, and regular reviews
- Secure deletion/disposal practices
No method is 100% secure, but we act promptly to mitigate issues.
10) Changes to this Policy
We may update this policy as we add features or modify AI processing. For material changes, we’ll post the new version and notify active users where appropriate. Continued use means you accept the changes.
11) Children
Our Service is not directed to children. We do not knowingly collect data from children under the age required by law. If you believe we have such data, contact us to delete it.
12) Contact
Growth Spark Digital LLC
1207 Delaware Ave #1846, Wilmington, Delaware 19806, USA
Email: [email protected]
You may also contact the UK Information Commissioner’s Office (ICO) if you believe your privacy rights have been infringed.
