Privacy Notice

In this Privacy Notice, we explain what data we collect on you and how we use this data. The purpose of this Privacy Notice is also to provide the information required by applicable data protection laws. This Privacy Notice was last updated on March 15, 2022.

1. Controller

Spark Sustainability Ab  (“Spark”, “we”, “us”, “our”)

Address: Lapinlahdenkatu 16, 00180 Helsinki 

E-mail: info@sparksustainability.com

2. Contact person in the matter

Amanda Rejström, CEO

Address: Lapinlahdenkatu 16, 00180 Helsinki

E-mail: amanda@sparksustainability.com

If you have any questions concerning the processing of your personal data, please shoot Amanda an e-mail!

3. What are the purposes and the legal basis for processing personal data?

We only process personal data if such data is necessary in order to carry out the following purposes:

• Providing our services
  When you use the lifestyle emission calculator on our website, we collect and process your personal data to provide this service, i.e. to show you your lifestyle carbon emissions and to give you tips on how to reduce them. In this case, the processing is based on the performance of a contract — i.e., the service contract between you as a user and Spark, which comes into force upon entering the calculator.
  
  We also use the data you enter into the calculator to obtain more accurate estimates for average lifestyle carbon emissions. This data processing is based on our legitimate interest to improve our service. 
  

• Developing and analysing our websites
  We collect and process data via cookies to develop the functionality, usability, and overall awesomeness of our website by analysing its usage and occuring problems. Some cookies are always necessary for the websites to function and some cookies are used for statistical purposes. We use Google Analytics to collect information about the usage of our website. We use this information to create reports of the usage and to develop the website. You may find more information about Google Analytics here. We use Hotjar in order to better understand our users’ experience and this enables us to build and maintain our service with user feedback. Hotjar stores information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the Hotjar’s privacy pages. The data processing using these services is based on our legitimate interest to get adequate information to improve the quality of our websites, and hence spark more climate action. You can deny the use of other than necessary cookies by changing your cookie preferences. 
  

• Marketing
  We use Facebook Pixel to measure, optimise and build audiences for our advertisement campaigns on Facebook as well as to target Facebook ads to users most likely interested in them. Facebook Pixel shows us how the users move between devices when they browse our websites and Facebook. You can find more information about Facebook Pixel here. We also use Google Ads to measure and target our advertising campaigns on Google’s services. You can read more about Google Ads here. This data processing is based on on your consent that you can give us by allowing the use of cookies by changing your cookie preferences.
  

• Recruiting
  If you want to become a part of our amazing team and send us a job application, we process your personal data for recruiting purposes. In these cases, the processing is based on our legitimate interest to get and store adequate information to carry out the recruitment process.
  

• Newsletter
  If you subscribe to our newsletter, we process your name and e-mail to send it to you. This processing is based on your consent, which you may withdraw at any time by clicking the unsubscribe link in our newsletters.
  

• Managing contacts
  We process your data and contact you to manage your possible contact request and/or to maintain the relationships with our community members, partners and other interest groups. In this case, the data processing is based on our legitimate interest to maintain good relationships with our community and processing contacts sent to us. 
  

You have the right to object to data processing that is based on legitimate interest. You can read more about this and your other rights in section 10.

4. Which are our regular sources of information?

Personal data are collected either directly from you or during the course of your service use. We collect and process data that: 

• you give us when you fill out and submit the contact form on our website
• you give us when you subscribe to our newsletter
• you provide us during a recruitment process
• you give us when you use the lifestyle emission calculator
• you give us when you contact us by other means (for example by e-mail or by phone)
• is collected through cookies and similar technologies when you visit our website or click on our advertisements on Facebook or on Google’s services

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5. What personal data do we collect?

We collect and process the following data:

• Name and contact details (such as e-mail and phone number)
• Data relevant for recruitment (such as your professional interests and skills, CV and other information that you wish to send us)
• Lifestyle emission calculator data (information that enables us to estimate and show you your lifestyle carbon emissions, such as information on how you live, travel and consume)
• Usage data, i.e. information on how our website or our ads are accessed and used (for example your IP address, browser type and version, the pages of our website that you visit, unique device identifiers and other diagnostic data)
  

You are not obliged to provide us with any other personal data than the technical data that is needed for the website to function. However, we may not be able to provide you our services, such as the lifestyle emission calculator or newsletter, or to contact you, if you decide not to provide us the necessary data to do so.

6. Is the data disclosed to third parties and who are the recipients? 

We store and process data mainly at Heroku, which is a third party service provider and part of Salesforce. To find out more about how they protect the data, click here.

Our website is built with Webflow, which is a third party service provider. You can find Webflow’s privacy policy here. 

We use SendGrid, a tool provided by Twilio, to manage our newsletters. Thus, we store and process the names and e-mails of our newsletter subscribers in SendGrid. You can find Twilio’s privacy policy here.

We use Google Analytics, which is an analytics tool provided by Google. To find out more about how Google protects the collected information, click here.

We also use Facebook Pixel and Google Ads, which are advertisement tools provided by Facebook and Google. You can find out more about how they protect your information here (for Facebook Pixel) and here ‍(for Google Ads).

As a main rule, we do not disclose personal data to other third parties. Despite this, we may be required to disclose data on you to third parties, such as authorities, in individual situations like when the disclosure is mandatory under applicable laws.

7. Is the data transferred outside the European Union or European Economic Area?

Data collected via Google Analytics or Google Ads is stored on Google's servers, which are located all over the world. All other data is stored and otherwise processed within the European Union or European Economic Area.

8. For how long will we store the personal data?

We only keep personal data for as long as is necessary for the purposes for which the personal data is processed. 

As a general rule, contact persons’ and job applicants’ personal data is stored for the time needed to manage the contact, the duration of the business relationship or the duration of the recruitment process or employment relationship. However, you may always request for data erasure or rectification before these general times. 

Also, as general rules, newsletter subscribers’ data is stored until you unsubscribe from the newsletter. Data collected via the lifestyle emission calculator is deleted after 26 months from collecting the data, after we have created anonymous statistics based on the data. The data collected via cookies is deleted after 26 months from collecting the data. 

9. How do we keep the data safe?

Spark takes appropriate technical and organisational measures to protect personal data against unauthorised access and accidental or unlawful destruction, alteration, disclosure, transfer or all other unlawful forms of processing. 

We process all personal data confidentially. The right of access to personal data is limited so that access rights are provided only to persons who require access in order to be able to perform their duties. 

We do not process any data manually and we do not have a manual register. 

10. What are your rights as a data subject?

If you have any questions concerning the processing of your personal data or you would like to make a request concerning your rights, do not hesitate to contact the person mentioned in section 2 of this Privacy Policy. As a data subject, you have the following rights:  

10.1. Right to request access and rectification of personal data

You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, when that is the case, access to the personal data. You also have the right to obtain the rectification of inaccurate personal data concerning you without undue delay. 

10.2. Right to request erasure of personal data

In general, you also have the right to obtain the erasure of personal data concerning you. However, we may not be able to erase your data in individual cases such as when the data is necessary for a purpose defined in this Privacy Notice or storing it is required by law. 

10.3. Right to withdraw your consent

If we have collected and processed your personal data with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

10.4. Right to restrict or object to data processing

Even when the data processing is based on legitimate interest, you have the right to object to processing. You can also ask us to restrict processing of your personal data. 

10.5. Right to data portability

When the data processing is based on consent or a contract, you have the right to receive the personal data that you have provided us in a structured, commonly used and machine-readable format and, if desired, transmit that data to another controller.

10.6. Right to lodge a complaint with a supervisory authority

If you think that we don’t process your personal data appropriately, you can contact the person mentioned in section 2. If you think that our processing of personal data relating to you infringes applying data protection regulations, you can also complain to a data protection authority. In Finland, this authority is The Office of the Data Protection Ombudsman and you can find the contact details here.

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11. Changes to this Privacy Notice

We may update this Privacy Notice due to the development of our websites. In such cases, an updated Privacy Notice is available on the website: https://www.sparksustainability.com/privacy. 

We at Spark Sustainability value not only our planet, but also Your privacy. The purpose of this Privacy Notice is to describe exactly how we use your data, and how you can change that if you wish to. Spark collects personal data via our website. More specifically, we collect data regarding contact requests, recruitment, advertising and our newsletter. We also use analytics on our website in order to get more specific information of its usage and hence to improve our service — we want it to spark as much climate action as possible!

You can find the Privacy Notice regarding the Carbon Donut application here: https://www.sparksustainability.com/carbon-donut-privacy-policy.