Privacy Policy

1. About This Policy

This Privacy Policy applies to all personal data collected through the SparkFlow platform (sparkflowengine.com), our mobile applications, our website, and any communications you have with SparkSupport Global Tech.

By using SparkFlow, you consent to the collection and use of information in accordance with this policy.

2. Who We Are

The data controller responsible for your personal data is:

3. Data We Collect

We collect the following categories of personal data:

3.1 Account and Identity Data

• Full name, job title, and department
• Work email address and phone number
• Organisation name and location
• Account login credentials (passwords are stored in encrypted form)

3.2 Usage and Platform Data

• Actions performed within the Platform (incident reports, inspections, approvals)
• Device type, browser, IP address, and operating system
• Session timestamps, page views, and feature usage logs
• Geolocation data when submitting field reports (with your permission)

3.3 Communications Data

• Enquiry and support messages sent to us by email or through the contact form
• Demo request details

3.4 HSE Operational Data

Content you upload as part of HSE workflows, including incident descriptions, photos, documents, and audit records. This data is owned by you and processed by us solely to deliver the service.

4. How We Use Your Data

We use your personal data for the following purposes:

• Service Delivery: To provision and operate your SparkFlow account and subscription.
• Support: To respond to queries, troubleshoot issues, and provide technical assistance.
• Communication: To send service notifications, updates, and security alerts.
• Improvement: To analyse usage patterns (in aggregated, anonymised form) and improve platform features.
• Legal Compliance: To comply with applicable laws, regulations, and court orders.
• Security: To detect and prevent fraud, abuse, and unauthorised access.

We do not use your personal data for unsolicited marketing without your explicit consent.

5. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contract: Processing is necessary to fulfil your subscription agreement with us.
• Legitimate Interests: For platform security, fraud prevention, and service improvement.
• Legal Obligation: Where we are required to process data to comply with UAE law.
• Consent: For optional features such as marketing communications or location-based reporting.

6. Data Sharing and Disclosure

We do not sell your personal data. We may share data with:

• Trusted Sub-processors: Cloud hosting, email, and infrastructure providers who process data on our behalf under strict data processing agreements.
• Your Organisation: Administrators within your organisation who have access rights to your account.
• Legal Authorities: Where required by law, court order, or government request.

All sub-processors are contractually required to protect your data and process it only as instructed by us.

7. International Data Transfers

SparkFlow is hosted on cloud infrastructure that may involve data transfer to countries outside the UAE. Where such transfers occur, we ensure appropriate safeguards are in place, such as data processing agreements with standard contractual clauses, consistent with UAE PDPL requirements.

8. Data Retention

We retain personal data for as long as your subscription is active and for a period thereafter as required by law or legitimate business need:

• Account data is retained for 30 days after subscription termination, then deleted.
• Operational HSE data is retained per your organisation's configuration and deletion requests.
• Financial and legal records may be retained for up to 7 years to comply with UAE Commercial Law.
• Support correspondence is retained for 2 years.

9. Cookies and Tracking

Our website uses cookies and similar technologies to:

• Maintain your login session
• Remember your preferences
• Measure website traffic and performance (using anonymised analytics)

You can control cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Platform.

10. Data Security

We implement industry-standard technical and organisational measures to protect your data, including:

• TLS encryption in transit and AES-256 encryption at rest
• Role-based access controls and multi-factor authentication options
• Regular security assessments and penetration testing
• Audit logging of all data access events

While we take all reasonable steps to protect your data, no system is completely immune to risk. Please notify us immediately at [email protected] if you suspect any security breach.

11. Your Rights

Under the UAE Personal Data Protection Law and applicable regulations, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Deletion: Request deletion of your personal data, subject to legal retention obligations.
• Portability: Request your data in a structured, machine-readable format.
• Objection: Object to processing based on legitimate interests.
• Withdrawal of Consent: Withdraw consent at any time for processing based on consent, without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.

12. Children's Privacy

SparkFlow is a professional B2B platform and is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe we have collected such data, please contact us immediately.

13. Third-Party Links

Our website and Platform may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies independently.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes via email or a prominent notice on the Platform. The "Last updated" date at the top of this page indicates when the policy was last revised.

15. Contact and Complaints

For privacy-related questions, requests, or complaints, please contact us:

You also have the right to lodge a complaint with the UAE competent supervisory authority if you believe your data protection rights have been violated.