Privacy Policy

1. Introduction

Sparky ("we", "our", "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform.

This policy applies to users in the United Kingdom and complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

1A. Data Controller

For the purposes of UK data protection law, the data controller is Sparky. We are responsible for deciding how we hold and use personal information about you.

If you have any questions about this Privacy Policy or how we handle your data, please contact us through the app.

2. Information We Collect

Personal Information (Customers)

When you use Sparky as a customer, we collect:

• Name and contact information (phone number, email address)
• Address and location data (to match you with nearby electricians)
• Job details and problem descriptions
• Payment information (processed securely through Stripe)
• Communication history with electricians through our platform (including SMS and call recordings)

Electrician Verification Information

When Electricians register on our platform, we collect and verify professional credentials and qualifications:

• NICEIC or NAPIT registration details: Registration number, certificate information, and registration status
• Professional qualifications: Certificates, training records, and qualification dates
• Business information: Business name, trading name, business address, and VAT number (if applicable)
• Public liability insurance: Insurance certificate details and coverage amounts (we verify Electricians have appropriate insurance)
• Service area and specializations: Geographic coverage, types of electrical work performed, and areas of expertise
• Availability and pricing: Working hours, call-out fees, and hourly rates set by the Electrician
• Stripe Connect information: Bank account details for payment processing (stored securely by Stripe)

We verify this information directly with NICEIC or NAPIT registries and retain copies of certificates and registration documents. This verification is necessary to ensure all Electricians on our platform meet UK regulatory requirements for electrical work.

Usage Information

We automatically collect:

• Device information and identifiers
• App usage data and interactions
• IP address and location data
• Log files and analytics data

3. Legal Basis for Processing

Under UK GDPR, we process your personal data based on the following lawful bases:

• Contract Performance: Processing is necessary to perform our contract with you (matching you with electricians, facilitating services, processing payments)
• Legitimate Interests: We have legitimate interests in operating our platform, preventing fraud, improving our services, and communicating with you about your bookings
• Legal Obligation: We must process certain data to comply with legal requirements (tax, financial regulations, safety reporting)
• Consent: Where required, we obtain your consent for specific processing activities (marketing communications, optional features)

4. How We Use Your Information

We use your information to:

• Verify and onboard Electricians: Check NICEIC/NAPIT registration, validate professional qualifications, and ensure compliance with UK electrical regulations
• Connect you with qualified electricians in your area using location-based matching
• Facilitate communication: Enable phone calls (via ElevenLabs) and SMS messaging (via Twilio) between customers and electricians
• Record and analyze interactions: Call recordings and transcripts are used for quality assurance, dispute resolution, and training our AI matching system
• Process payments securely with hold-then-capture flow
• Provide customer support and respond to your inquiries
• Detect and prevent fraud, security threats, and illegal activity
• Improve our platform, services, and user experience through analytics
• Send important updates about your bookings and account
• Comply with legal obligations (tax, financial regulations, safety reporting)
• Enforce our Terms of Service
• Resolve disputes, investigate complaints, and troubleshoot problems

5. Information Sharing and Disclosure

We share your information only in the following circumstances:

With Electricians

When you request a quote or book a job, we share your name, contact details, address, postcode, and job description with the matched electrician(s). This is necessary to perform the service you requested.

With Service Providers (Data Processors)

We use third-party service providers who process data on our behalf under strict data processing agreements:

• Convex (database and backend): Stores all platform data including user accounts, job requests, and messages
• Clerk (authentication): Manages user authentication and account security
• Stripe (payment processing): Processes payment transactions and stores payment method details
• ElevenLabs (voice calls): Facilitates automated phone calls to electricians, processes call recordings and transcripts
• Twilio (SMS): Sends and receives text messages between customers and electricians
• Vercel (hosting and analytics): Hosts our website and collects basic analytics

Legal and Safety Disclosures

We may disclose information when:

• Required by law, regulation, or legal process
• Necessary to respond to lawful requests from public authorities
• Needed to enforce our Terms of Service or protect our rights
• Required to protect the safety, property, or rights of users or the public
• In connection with a business transaction (merger, acquisition, or sale)

We do not sell, rent, or trade your personal information to third parties for marketing purposes.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information. This includes encryption, secure data storage, and access controls. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

6. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law.

Typical retention periods:

• Account information: Retained for the duration of your account, plus 6 years after closure (for legal and tax purposes)
• Job records and communication: Retained for 6 years after job completion (for dispute resolution and legal compliance)
• Payment records: Retained for 7 years (HMRC requirement)
• Call recordings: Retained for 90 days unless needed for dispute resolution or legal purposes
• SMS messages: Retained for 6 months after job completion
• Analytics data: Aggregated and anonymized after 2 years

When we no longer need your information, we securely delete or anonymize it.

7. Your Rights Under UK Data Protection Law

Under UK GDPR, you have the following rights:

• Right of Access: Request a copy of the personal information we hold about you (commonly called a "Subject Access Request" or SAR)
• Right to Rectification: Request correction of inaccurate or incomplete information
• Right to Erasure ("Right to be Forgotten"): Request deletion of your information, subject to legal retention requirements
• Right to Restrict Processing: Request that we limit how we use your information in certain circumstances
• Right to Data Portability: Receive your information in a structured, machine-readable format and transfer it to another service
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time
• Rights Related to Automated Decision-Making: We do not currently use fully automated decision-making that produces legal effects

How to Exercise Your Rights: To exercise any of these rights, please contact us through the app. We will respond to your request within one month, or inform you if we need additional time (up to three months for complex requests).

Right to Lodge a Complaint: You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) if you believe we have not handled your data properly. Visit ico.org.uk or call 0303 123 1113.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to improve your experience, analyze usage patterns, and ensure platform functionality.

Types of cookies we use:

• Essential Cookies: Required for authentication, security, and core platform functionality (these cannot be disabled)
• Analytics Cookies: Help us understand how users interact with our platform (Vercel Analytics)
• Functional Cookies: Remember your preferences and settings

You can control non-essential cookies through your browser settings. However, disabling certain cookies may affect platform functionality and your user experience. For more information on managing cookies, visit aboutcookies.org.

9. Children's Privacy

Our platform is not intended for users under 18 years of age. We do not knowingly collect personal information from children.

10. International Data Transfers

Some of our service providers are located outside the United Kingdom, which means your personal data may be transferred to and processed in countries that may not offer the same level of data protection as the UK.

When we transfer your data internationally, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses (SCCs): We use UK-approved Standard Contractual Clauses with our service providers to ensure your data receives adequate protection
• Adequacy Decisions: Where possible, we use service providers in countries deemed adequate by the UK government
• Additional Safeguards: We implement technical and organizational measures including encryption, access controls, and regular security audits

After transfer, your data remains subject to UK GDPR protections and the contractual safeguards we have in place with our service providers.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes through the app or by email. Continued use after changes are posted constitutes acceptance of the updated policy.

12. Third-Party Links

Our platform may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these third parties. We encourage you to review the privacy policies of any third-party sites you visit.

13. Contact Us and Data Protection Queries

If you have questions about this Privacy Policy, how we handle your data, or wish to exercise your rights, please contact us through the app or visit our About page.

We aim to respond to all data protection queries within 48 hours and resolve Subject Access Requests within one month.