Privacy Policy

Introduction

Spark Venture Funding ("Spark", "we", "us", or "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you use our platform and services.

This policy applies to all users of the Spark Venture Funding platform, including investors, project owners (companies raising funds), and visitors to our website.

We are committed to compliance with the General Data Protection Regulation (GDPR) and all applicable Irish and EU data protection laws.

1. Information We Collect

1.1 Information You Provide to Us

For Investors:

• Personal identification information (name, date of birth, nationality)
• Contact information (email address, phone number, postal address)
• Financial information (bank account details, payment information, investment history)
• Identity verification documents (passport, driver's license, proof of address)
• Tax information (PPS number, tax residency status)
• Employment and income information (for suitability assessment)
• Investment preferences and risk profile

For Project Owners:

• Company information (name, registration number, registered address)
• Director and beneficial owner information
• Business documentation (pitch materials, financial statements, business plans)
• Contact details for company representatives
• Bank account information for fund transfers
• Tax and regulatory compliance information

1.2 Information We Collect Automatically

• Device information (IP address, browser type, operating system)
• Usage data (pages visited, time spent, click patterns)
• Cookies and similar tracking technologies
• Log files and analytics data
• Communication records (emails, support tickets, chat logs)

1.3 Information from Third Parties

• Identity verification services (KYC/AML checks)
• Credit reference agencies
• Payment processors and financial institutions
• Companies House and other public registries

2. How We Use Your Information

2.1 To Provide Our Services

• Creating and managing your account
• Processing investment transactions and fund transfers
• Facilitating communication between investors and project owners
• Providing customer support and responding to inquiries
• Issuing shares through nominee structures

2.2 Legal and Regulatory Compliance

• Verifying your identity (KYC/AML requirements)
• Complying with Central Bank of Ireland regulations
• Preventing fraud, money laundering, and terrorist financing
• Meeting tax reporting obligations

2.3 Platform Improvement and Security

• Analyzing usage patterns to improve user experience
• Detecting and preventing security threats
• Troubleshooting technical issues

2.4 Marketing and Communications

• Sending investment opportunity notifications (with your consent)
• Providing updates on campaigns you've invested in
• Marketing our services (where you have opted in)

3. Legal Basis for Processing

• Contractual Necessity: To fulfill our obligations under our terms of service and facilitate investment transactions
• Legal Obligation: To comply with regulatory requirements, including KYC/AML obligations
• Legitimate Interests: To operate and improve our platform, prevent fraud, and ensure security
• Consent: For marketing communications and certain data processing activities where required by law

4. How We Share Your Information

4.1 Service Providers

• Payment processors and banking partners
• Identity verification and KYC/AML service providers
• Cloud hosting and IT infrastructure providers
• Legal and professional advisors

4.2 Nominee Companies

Your investment details are shared with our nominee company to facilitate share ownership and manage shareholder rights on your behalf.

4.3 Project Owners and Other Investors

Limited information (such as your name and investment amount) may be shared with companies you invest in and, where legally required, with other investors in the same company.

4.4 Regulatory and Law Enforcement

• Central Bank of Ireland
• Revenue Commissioners
• An Garda Síochána and other law enforcement agencies
• Courts and legal authorities when required by law

5. International Data Transfers

We primarily process and store data within the European Economic Area (EEA). Where we transfer data outside the EEA, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission and transfers to countries with adequate data protection.

6. Data Retention

• Active accounts: For the duration of your relationship with us
• Investment records: For at least 7 years after the investment is concluded
• KYC/AML records: For 5 years after the business relationship ends
• Financial records: As required by tax and accounting regulations
• Marketing data: Until you withdraw consent

7. Your Rights Under GDPR

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your data (subject to legal retention requirements)
• Right to Restrict Processing: Request limitation on how we use your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent for processing where consent is the legal basis
• Right to Lodge a Complaint: File a complaint with the Data Protection Commission (DPC)

To exercise any of these rights, contact us at privacy@sparkventurefunding.com. We will respond within one month.

8. Cookies and Tracking Technologies

• Essential Cookies: Enable core functionality (login, security, session management)
• Performance Cookies: Analyze how users interact with the platform
• Functional Cookies: Remember your preferences and settings
• Marketing Cookies: Deliver relevant advertisements (with your consent)

9. Security

We implement appropriate technical and organizational measures to protect your personal information, including encryption of data in transit and at rest, secure authentication, regular security assessments, and staff training. While we take all reasonable steps, no system is completely secure. You are responsible for maintaining the confidentiality of your account credentials.

10. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or prominent notice on our platform. Your continued use of our services after changes take effect constitutes acceptance of the updated policy.

12. Contact Information

Last Updated: March 2026