Privacy Policy

Data privacy is a big concern for most firms in today’s data-driven world, regardless of their size or industry. At
Sparkling Leads, we appreciate privacy and want our consumers to understand how we collect information and our
commitment to data protection. This privacy statement was written to help you understand how we manage your
personal and non-personal data.

What sources do we use to source information?

Sparkling Leads is committed to helping businesses build meaningful relationships with their customers. We collect
and keep a range of data for this, including personally identifiable information, contact information, company
information, social information, publicly available financial information, and more, in a variety of ways.
We collect information that allows us to identify individuals and improve our service when a user visits our
website. Domain names, IP addresses, and other information such as user-visited sites, survey information, and
email addresses are the only things we gather. Email notifications, promotional emails, e-newsletters, and login
credentials to related sites are all sent using this information.

Types of information that our site collects include:

If you visit our website or send us an email, we may collect the following information:

Personal Information
When you visit our website, we may request information from you, such as:
Name
Title
Company Name
Mailing Address
Phone Number
Email Address.

When you request or download material, sign up for a newsletter, event, or programme, or check in to a service or
application on our website, these details may be requested.
Your personal information may be used for any business purpose, such as managing your account and providing
services, sending notifications and organizational communications, responding to your requests, and sending
marketing and product updates. This information is also used to evaluate how our customers engage with our
website and services.

Non-Personally Identifiable Information

We may collect additional information about you if you visit our website but do not complete any sign-up
activities, such as:

The browser and operating system that were used to access our website, as well as the time zone and
other device information.
Your IP address is a number that identifies your computer on the internet (a number that your system
automatically assigns when you open the chrome and can be used to determine your general
geographical location)
Your click-stream data, as well as any URL referral data, is collected (such as any website or social media
network data that referred you to our website)
In what ways do we use your information?
We use the information you supply on our website for the following purposes:
Determine who could be interested in our services as possible clients or subscribers.
Providing you with the services for which you have signed up or subscribed
Answering your inquiries and requests.
Conducting market and customer research.
We’d like to share some information with you about our products and services.

What Are Cookies and How Do We Use Them?

What is a Cookie?

A “cookie” is a little piece of data sent by a web server to a web browser for storage and retrieval later. Cookies are
used by Sparkling Leads to remember a few personal preferences for future visits. These cookies help us identify
you faster and keep track of how much time you spend on our site.

What are we going to do with them?

You may see advertisements from third-party advertising companies when you visit our website. Our third-party
advertisers may place or recognize a unique “cookie” on your browser while delivering adverts. These companies
may use information about your visits to SparklingLeads.com and other websites to send you adverts for products
and services they think you’d like.
In order to improve the usability of our online site for our members and visitors, we collect and analyze statistical
data, which we share with third parties. However, this information is only gathered in the aggregate and does not

reveal any personal information about specific website visitors. The purpose of publishing this material is to attract
qualified clients to the SparklingLeads.com website.

Clauses Regarding Data Security and Confidentiality

We take great care to secure your privacy at Sparkling Leads at all times, whether we’re processing or storing your
personal information. We take every step to ensure that the data is kept private and secure. We use cutting-edge
servers that employ the most cutting-edge encryption technologies available. We may share your personal
information with partners whose products/services are relevant to you so that we can provide you with better
services while maintaining your relationship with us.
 Sparkling Leads ensures that all client data is kept confidential. The contents of tracking information
resulting from click-troughs, mails opened, messages read, or ecommerce conversions are likewise not
used, rented, sold, transferred, or otherwise made available to third parties. We provide an SSL
encrypted, password-protected interface for accessing and extracting customer data.
 All customer data is held in a carrier-class secure facility protected by firewalls and other security
mechanisms. These security measures are in place to protect visitor and client data from loss, misuse, and
unauthorized alterations.

Our Privacy Policy Has Changed

Any modifications to our privacy policy and practices will be posted on our website so that you are aware of what
information we collect, how we use it, and when we may share it. When changes to this Privacy Policy are
published on this website, they become effective.

GDPR

Compliance References

General Data Protection Regulation (“GDPR”), is the main legislation in Europe that seriously affects
the whole personal data processing activities. Whilst, bringing drastic changes for the companies
like; monetary fines up to % 4 of the global turnover or 20 Million Euros, it is extending the rights of
the data subjects as well; like “right to be forgotten” claims. In such dynamic realm where privacy
will be “by design” the core principle shall be providing more control to the owners over their
personal data.

As explicit consent is the primary pre-requisite for data processing, “legitimate interest” is one of
exceptions of it and is the most flexible lawful basis for processing.

As it is flexible and fragile, we are handling it with care! We are following the related European
governmental and independent regulatory bodies closely and have meticulously adapted their
principles to our operations, in line with their guidelines

SO, WHAT IS LEGITIMATE INTEREST?

An ‘interest’ can be considered as ‘legitimate’, as long as the Controller can pursue this interest in a
way that complies with data protection and other laws.

Legitimate interest has been defined both in Article 6 1(f) of GDPR and its Recital 47. Especially the
marketing purposes are avidly defined as legitimate in Recital 47 as follows; “…The processing of
personal data for direct marketing purposes may be regarded as carried out for a legitimate
interest.”

However, this does not automatically mean that all processing for marketing purposes is lawful on
this basis. You still need to show that your processing passes the necessity and balancing tests.

When looking at the balancing test, you should also consider factors such as:

• whether people would expect you to use their details in this way.

• the potential nuisance factor of unwanted marketing messages; and
• the effect your chosen method and frequency of communication might have on more
vulnerable individuals, like children.
Given that individuals have the absolute right to object to direct marketing under Article 21(2), it is
more difficult to pass the balancing test if you do not give individuals a clear option to opt out of
direct marketing when you initially collect their details (or in your first communication, if the data
was not collected directly from the individual).

The legitimate interests can be your own interests or the interests of third parties. They can include
commercial interests, individual interests or broader societal benefits.

You must balance your interests against the individual’s. If they would not reasonably expect the
processing, or if it would cause unjustified harm, their interests are likely to override your legitimate
interests.

CAN WE USE LEGITIMATE INTERESTS FOR BUSINESS TO BUSINESS CONTACTS?

“Yes” indeed. This type of processing will be lawful as well, on the basis of legitimate interests, but
you need to apply the 3-part Legitimate Interest Assessment test.

You can consider using legitimate interests as your lawful basis for such processing. However, you
need to identify your specific interest underlying the processing and ensure that the processing is
actually necessary for that purpose.

Assuming you can meet these first two parts of the three-part test, you also need to consider the
balancing test. You may find it is straightforward as business contacts are more likely to reasonably
expect the processing of their personal data in a business context, and the processing is less likely to
have a significant impact on them personally.

For more information regarding the legitimate interest principle and its assessment test with the
related documentation, which we have also strictly followed and implemented in our business

operations please visit; https://dma.org.uk/uploads/misc/59ca0f2e17ef3-dpn-li-
guidancepublication_59ca0f2e17e5a.pdf or please feel free to send your inquiries to us via e-mail.

WE ARE FULLY GDPR COMPLIANT AND TO STAY LIKE THIS WE…
• We have checked that legitimate interests are the most appropriate basis,

• We understand our responsibility to protect the individual’s interests.
• We have conducted a legitimate interest’s assessment (LIA) and kept a record of it, to ensure that
we can justify our decision.
• We have identified the relevant legitimate interests.
• We have checked that the processing is necessary and there is no less intrusive way to achieve the
same result.
• We have done a balancing test, and are confident that the individual’s interests do not override
those legitimate interests.
• We only use individuals’ data in ways they would reasonably expect, unless we have a very good
reason.
• We are not using people’s data in ways they would find intrusive or which could cause them harm,
unless we have a very good reason.
• We do not process special category and children’s data.
• We have considered safeguards to reduce the impact where possible.
• We are promoting our clients to offer an “opt out”.
• We keep our LIA under review, and repeat it if circumstances change.
• We include information about our legitimate interests in our privacy information and terms of
use.