Privacy Policy

1. Who we are and the scope of this policy

Sparks Accounting LTD is the controller of the personal information covered by this policy. We decide why and how that information is used for our accountancy, tax, payroll, VAT and company-support services. This policy applies to people who visit our website, ask us about a service, communicate with us or become a client.

• Company: Sparks Accounting LTD, company number 10507277.
• Registered office: 67 Meridian Centre, Havant, England, PO9 1UN.
• Privacy contact: info@sparks2.co.uk.
• Telephone: 07904 986644 / 02392 008665.

2. Information we collect

We collect only information that is relevant to an enquiry, an agreed service, a legal or professional obligation, or the secure operation of our business. The information depends on the service you ask us to provide.

• Contact and identity information: name, email address, telephone number, postal address, date of birth, nationality, company name, website, timezone and how you heard about Sparks.
• Company and tax information: company registration number, incorporation date, Corporation Tax and PAYE references, VAT information, personal UTR, accounting package, account status, requested services and agreed pricing.
• Onboarding and professional-clearance information: details of a previous accountant, HMRC agent-authorisation status, 64-8 administration, welcome-pack preferences, responsible account manager and service history.
• Accounting, VAT and payroll information: records and documents needed for the agreed work, payroll and employment-status information, VAT scheme details, financial records and company-administration information.
• Documents and communications: files or images you supply, correspondence, consultation notes, website enquiries, call or message details, payment notes and marketing preferences.
• Technical and usage information: limited device, browser, security, cookie and website-usage information generated when you use our website or client-management tools.

3. How we receive information

Most information comes directly from you, from someone authorised to act for you, or from records and documents you give us. Where it is necessary for an agreed service, we may also receive information from your previous accountant, HMRC, Companies House, your bank or software provider, payroll or accounting systems, professional advisers or another party you have authorised.

4. Why we use information and our lawful bases

We use personal information to respond to enquiries, arrange consultations, assess whether we can act, onboard clients, provide the agreed accountancy, tax, payroll, VAT and company services, manage HMRC authorisations and professional clearance, maintain records, manage fees, meet legal and professional obligations, protect our systems and send permitted marketing communications.

• Contract: to take steps at your request before an engagement and to provide the services set out in an agreed engagement letter or terms of business.
• Legal obligation: to meet applicable tax, accounting, anti-money-laundering, regulatory, record-keeping and reporting duties.
• Legitimate interests: to administer and protect our business, respond to enquiries, maintain client relationships, improve our services and prevent fraud or misuse.
• Consent: for optional marketing and non-essential cookies where consent is required. You can withdraw consent at any time.

5. Portallo, HighLevel and LeadConnector

We use Portallo to operate elements of our website, client relationship management, forms, enquiries, workflows and agreed communications. Portallo is configured for Sparks as a white-label sub-account on the HighLevel/LeadConnector platform. When these providers process personal information for Sparks, Sparks remains the controller. Portallo provides website, configuration and operational support as a service provider, while HighLevel and LeadConnector provide the underlying platform and may use approved sub-processors to deliver it.

• These providers process personal information only as needed to provide the platform and related support, subject to the applicable contractual and data-protection safeguards.
• The information stored in these systems can include contact details, client-service records, tax and company references, documents, messages, workflow status and the other categories listed in this policy.
• Do not send passwords, bank credentials or Companies House authentication codes through ordinary email, WhatsApp or social-media messages. Use an approved secure route where Sparks asks you to provide highly confidential information.

6. Who we share information with

We do not sell personal information. We share it only where necessary for the purposes described above, where you ask us to, or where the law requires it.

• HMRC, Companies House and other public authorities where required for an agreed service or by law.
• Portallo, HighLevel/LeadConnector and their approved sub-processors, plus IT, hosting, email, communications, accounting, payroll, document-management, payment and professional-service suppliers.
• Your previous accountant, bank, software provider, professional adviser, insurer or another party you authorise, where this is necessary for professional clearance or the service you ask us to provide.
• Regulators, law-enforcement bodies, courts or advisers where we have a legal duty or it is necessary to establish, exercise or defend legal claims.

7. International transfers

Some of our technology providers, including the HighLevel/LeadConnector platform and its approved sub-processors, may process information outside the United Kingdom. Where a restricted international transfer takes place, we use a lawful transfer mechanism and appropriate safeguards. Depending on the transfer, this may include an adequacy decision, approved standard contractual clauses with the UK Addendum or International Data Transfer Agreement, or a recognised data-privacy framework.

8. How long we keep information

We keep information only for as long as necessary for the purpose collected, to meet legal and professional obligations, and to deal with any complaint, investigation or dispute. Unsuccessful enquiries are normally reviewed for deletion after 12 months from the last meaningful contact. Client records are normally kept for the engagement period and six years after the relevant tax, accounting or reporting period, unless a longer period is required or justified.

9. Security

We use proportionate technical and organisational measures to protect information, including role-based access, restricted staff access, secure systems, documented procedures and confidentiality obligations. No online service can be guaranteed completely secure, so please use only the secure method we specify for confidential documents or credentials and tell us promptly if you believe your information has been misused.

10. Your rights and how to complain

Subject to applicable law, you may ask for access to, correction of, deletion of or restriction of your personal information. You may object to certain processing, withdraw consent or request a portable copy of information you supplied. To make a request, email info@sparks2.co.uk. We may need to verify your identity before acting. If you are unhappy with our response, you may complain to the UK Information Commissioner’s Office.

11. Marketing and automated decisions

We send electronic marketing only where permitted by law. You can opt out at any time through the unsubscribe option in a message or by contacting us. Service communications about an active engagement, deadlines, documents or invoices are not marketing. We do not use solely automated decision-making that produces legal or similarly significant effects about you through this website or our Portallo/HighLevel client-management workflows.

12. Cookies, external links and changes

Our Cookie Policy explains how we use cookies and similar technologies. Our website may link to external services such as WhatsApp, Instagram, Facebook, HMRC and Companies House; their privacy practices are governed by their own policies. We may update this policy when our services, systems, suppliers or legal obligations change. The current version and its effective date will always be published on this website.