Who we are
We are Spark Finance Ltd ("we", "us", "our", or "Spark"), an intermediary/broking service providing debt solutions to SME businesses. Our company number is 10128297 and our registered office is 18 John Stow House, London, England, EC3A 7JB. Our Information Commissioner's Office (ICO) registration number is ZA269538. We are authorised and regulated by the Financial Conduct Authority, firm reference number 958123. We are a credit broker, not a lender.
Spark is the data controller responsible for your personal data. This means we decide how and why your personal information is used. This Privacy and Cookie Policy (the "Policy") explains how we collect, use and share your personal data when you engage with us or use our services (the "Personal Data").
What personal information do we collect?
Personal data means any information that can identify an individual. It does not include anonymised data. We may collect, use, store and transfer different categories of personal data, including:
- Identity data: e.g. first name, last name, maiden name, marital status, title, date of birth, gender, passport copy, driving licence copy, utility bills.
- Contact data: e.g. residential address, billing address, email address, telephone numbers.
- Financial data: e.g. bank details, income and expenditure, statement of assets and liabilities.
- Background data: e.g. education and employment history.
- Transaction data: e.g. details about products and services you have arranged via Spark, your use of our Online Platform, IP address, and use of tracking pixels in email communications.
- Marketing and communications data: e.g. your marketing preferences and communication preferences.
- Health data: e.g. relevant medical information, especially where you are classified as a vulnerable customer.
Aggregated data
We also collect and use Aggregated Data, such as statistical or demographic data. This is not considered personal data under data protection law if it cannot identify you. However, if Aggregated Data can indirectly identify you, it will be treated as personal data and handled accordingly.
Accuracy and failure to provide data
It is important that the personal data we hold about you is accurate and up to date. Please let us know if your information changes during your relationship with us.
If we are required by law or contract to collect personal data and you do not provide it, we may be unable to perform our contractual obligations and may have to cancel a product or service. We will inform you if this is the case.
Where a field on one of our enquiry forms is marked as required, we need it in order to assess your enquiry or to pass it to a lender, and we will not be able to progress the enquiry without it.
How is your personal data collected?
We may collect your personal data in the following ways:
- Directly from you: e.g. through our website, contact forms, emails, phone calls or post.
- From companies (borrowers) and their advisers: where they provide your data during a credit proposal.
- From third parties and public sources: e.g. Companies House or other introducers with whom we have a business relationship.
- From the Companies House register: some of our enquiry forms let the person completing the form select their name from the list of officers registered for their business.
Lawful bases for processing personal data
Under the UK GDPR, we only use your personal data where we have a lawful basis. The table below sets out what we use your personal data for and the lawful basis we rely on in each case. In some cases we rely on more than one lawful basis for the same purpose, and where that is so we have said which.
| Purpose | Lawful basis | Notes |
|---|---|---|
| Sharing your finance enquiry with lenders so they can assess whether they are able to offer you finance, and so they can contact you about it | Contract, Article 6(1)(b), where you are the borrower. Legitimate interests, Article 6(1)(f), where the borrower is a company or LLP and you are its officer or representative | Where we rely on legitimate interests, our interest is in providing the introduction service you have asked us for. You have the right to object — see ‘Your rights’. |
| Responding to your enquiry, verifying your business and dealing with your queries | Contract, Article 6(1)(b), or legitimate interests, Article 6(1)(f) | — |
| Providing finance solutions tailored to you or your business, and confirming affordability and suitability of products | Contract, Article 6(1)(b), or legitimate interests, Article 6(1)(f) | — |
| Obtaining information about your business from credit reference agencies | Legitimate interests, Article 6(1)(f) | We do not carry out personal credit checks. A lender may do so at an advanced stage with the relevant individual's express permission. |
| Meeting regulatory and compliance requirements, and anti-money laundering requirements where they apply to the product concerned | Legal obligation, Article 6(1)(c) | We do not carry out customer due diligence or anti-money laundering checks on invoice finance enquiries submitted through our online enquiry form. |
| Preventing and responding to fraud or illegal activity, and detecting abuse of our enquiry forms | Recognised legitimate interests, Article 6(1)(ea) | See ‘Recognised legitimate interests’ below. |
| Sending you marketing communications | Consent, Article 6(1)(a), together with the conditions in the Privacy and Electronic Communications Regulations 2003 | You can withdraw consent at any time. |
| Managing our website, Online Platform and other digital services, including usage analysis and performance monitoring | Legitimate interests, Article 6(1)(f), and consent where cookies or similar technologies require it | — |
| Investigating complaints and responding to queries | Legal obligation, Article 6(1)(c), and legitimate interests, Article 6(1)(f) | — |
| Keeping records of what you were told and what you confirmed when you submitted an enquiry | Legal obligation, Article 6(1)(c), and legitimate interests, Article 6(1)(f) | We are required to be able to demonstrate our compliance. |
| Sharing information with our professional advisers, and for legal proceedings | Legitimate interests, Article 6(1)(f), and legal obligation, Article 6(1)(c) | — |
| Sharing information with a potential buyer if we sell or restructure our business | Legitimate interests, Article 6(1)(f) | — |
Recognised legitimate interests
For a small number of purposes, including preventing fraud and crime, the UK GDPR provides a lawful basis of recognised legitimate interests under Article 6(1)(ea). Where we rely on it, we do not have to carry out the balancing test that applies to ordinary legitimate interests, but your other rights are unaffected.
Our legitimate interests assessments
Where we rely on legitimate interests under Article 6(1)(f) we have carried out an assessment weighing our interests against your rights and freedoms. You can ask us for a summary of the relevant assessment using our data protection contact details above.
How we use your personal data
We may process your personal data for the following purposes:
- To provide finance solutions tailored to you or your business.
- To confirm affordability and suitability of products.
- To meet regulatory, compliance, and anti-money laundering (AML) requirements where those requirements apply to the product concerned. We do not carry out customer due diligence or AML checks on invoice finance enquiries submitted through our online enquiry form.
- To share information with our professional advisers and for legal proceedings.
- For marketing and business development purposes (where appropriate).
- To manage our website, Online Platform, and other digital services (including usage analysis and performance monitoring).
- To investigate complaints or respond to queries.
- To prevent and respond to fraud or illegal activity.
- If we sell or restructure our business, your data may be shared with potential buyers.
Use of artificial intelligence
We use artificial intelligence ("AI") tools to help us deliver our services efficiently, including:
- Transcribing and summarising calls.
- Processing and analysing documents you provide.
- Matching you to suitable finance products and lenders.
- Supporting compliance and Know Your Customer (KYC) checks.
- Conducting market research and general analysis.
AI processing and safeguards
We rely on the same lawful bases set out above (typically contract, legal obligation and legitimate interests) for this processing. Some of your personal data may be shared with third-party AI providers who act as our data processors and are bound by appropriate contractual and security safeguards. Where any such provider is located outside the UK or EEA, we ensure an appropriate legal safeguard (such as Standard Contractual Clauses) is in place. AI supports our decision-making but does not replace it. We do not make any decision that produces legal or similarly significant effects on you based solely on automated processing. You have the right to request human review of, or object to, any automated processing. See "Your rights" below.
Use of professional networking platforms (e.g. LinkedIn)
If you submit your information through our website (for example, via contact forms), we may use the details you provide - such as your name, company, or job title - to identify and contact you via professional networking platforms such as LinkedIn. This contact is based on our legitimate interest in following up on your enquiry or providing relevant business information or services.
We will only use publicly available information on such platforms and will not use this method for unsolicited marketing. You have the right to object at any time to being contacted in this way by emailing us at info@sparkfinance.co.uk.
Marketing consent
If you opt in to receive marketing communications, we may send you updates about our services, products, case studies, newsletters or invitations. We may contact you under the following bases:
- With your explicit consent.
- If you are an existing or prospective business contact and the law permits us to do so under legitimate interests.
Marketing preferences
We will never share your data with third parties for their own marketing purposes without your explicit consent. You can opt out of marketing at any time by clicking "unsubscribe" in any email or contacting us at: info@sparkfinance.co.uk.
Alternative contact methods
If the phone number you provide is invalid or non-functional, we reserve the right to use publicly available information from your company website or other public sources to contact you about your enquiry. This may include email addresses, contact forms, or alternative phone numbers listed on your website.
Automated decision making (ADM)
We may use ADM in limited circumstances, such as:
- Where you've been notified and have 21 days to request reconsideration.
- Where it is necessary for contract performance and appropriate safeguards are in place.
- With your explicit consent, particularly when processing sensitive data.
ADM safeguards
We ensure adequate safeguards for your rights in any use of ADM. A lender to whom we introduce your enquiry may apply automated screening or scoring when it assesses the enquiry, and where we know that to be the case we will tell you on the enquiry form and the lender's own privacy notice will explain it.
Sharing your information
We may share your personal data with third parties where legally required, or when necessary to administer our services. These may include:
- Lenders on our panel (available upon request). This is necessary in order to provide the service you have asked us for. Lenders may contact you about your enquiry, and may download some or all of the information we provide.
- Our IT service providers (hosted within the UK or EU).
- Third-party AI providers, as described under ‘Use of artificial intelligence’ above.
- Legal or regulatory authorities as required by law.
Call recording
All telephone calls to and from Spark are digitally recorded. We do this so that we have an accurate record of what was discussed, to train and monitor our staff, to resolve disputes and complaints, and to meet our regulatory obligations. We rely on our legitimate interests and, where applicable, on our legal obligations. Recordings, transcripts of them, or other material reflecting conversations may be used in resolving a dispute or a complaint. Calls may be transcribed and summarised using AI tools, as described under ‘Use of artificial intelligence’ above.
Data security
We have implemented appropriate technical and organisational security measures to prevent your data from being accidentally lost, accessed or disclosed without authorisation. Access is restricted to individuals who have a business need to know and are bound by confidentiality obligations.
Data retention
We retain your personal data only as long as necessary for the purposes for which it was collected, including legal and regulatory compliance.
International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
Your rights under UK GDPR
You have the following rights:
- To access your personal data (data subject access request).
- To correct inaccurate or incomplete data.
- To request deletion of your data.
- To restrict or object to our processing.
- To withdraw consent at any time.
- To request data portability.
- To request human review of, or object to, decisions based on automated processing.
Complaints
You also have the right to lodge a complaint with the ICO (www.ico.org.uk). However, we would appreciate the opportunity to resolve your concern before you contact them.
Changes to the privacy & cookies notice
This version was last updated on 09/09/26 and historic versions can be obtained by contacting us at info@sparkfinance.co.uk.
Contact us
To exercise your rights or raise a privacy concern, email us at info@sparkfinance.co.uk. We may ask for proof of identity before fulfilling your request.
Please note: all telephone calls are digitally recorded.
Cookies - Introduction
We use cookies and similar technologies on our website and emails to collect information as described in this Policy. A cookie is a small file stored on your device to enhance website functionality.
You can configure your browser to alert you when a cookie is being used. Blocking cookies may affect website performance or features.
Types of cookies used
First party cookies:
- Strictly necessary cookies - Essential for site navigation and functionality. Deleted when you close your browser.
- Functionality cookies - Enable enhanced features and remember your preferences.
- Google Analytics (GA) - Tracks user activity and preferences in an anonymised format. We do not use this data to identify individual users.
- Document tracking cookies - May be used to monitor engagement with sent documents. These may link to email addresses for identification.
Cookie data
Google Analytics and document tracking cookies are third-party cookies. We may combine cookie data with other personal data for service improvement purposes.
Cookie consent and control
By using our website, you consent to our use of cookies unless you disable them via your browser or opt-out tool. For more information, visit: www.allaboutcookies.org and www.youronlinechoices.com/uk/.