This Privacy Policy explains how Sparx Services, a practice of NovoCircle (operated by SFI Ventures, LLC) ("we", "us", "our"), collects, uses, stores, and protects personal data when you visit our website (sparxservices.com), submit an inquiry, or engage with our services. We are committed to protecting your privacy and handling your personal data in accordance with applicable US privacy laws, including the California Consumer Privacy Act (CCPA) where applicable.
1. Who we are
Sparx Services is a practice of NovoCircle, operated by SFI Ventures, LLC, a limited liability company registered in the State of Wyoming, USA. SFI Ventures, LLC is responsible for personal data collected through this website and our business activities.
If you have questions about how we handle your personal data, contact us at: privacy@sparxservices.com
2. Data we collect
We collect personal data in the following ways:
Information you provide directly
- Name and contact details (email address, phone number, job title, organization) submitted through our contact forms, partner inquiry form, or team expression-of-interest form
- Information provided in free-text fields, including descriptions of your EA practice, business needs, or professional background
- Email correspondence with members of our team
Information collected automatically
- Technical data including IP address, browser type and version, time zone, browser plug-in types and versions, operating system and platform, and other technology identifiers on the devices you use to access our website
- Usage data including pages visited, time spent on pages, links clicked, and referring URLs
- Cookie data as described in Section 9 below
Information from third parties
- Where you interact with our content on LinkedIn or other platforms, we may receive limited profile data subject to those platforms' privacy terms
- Where a partner or colleague introduces you to us, we may receive your name and contact details from that third party prior to any direct contact
3. How we use your data
We use personal data for the following purposes:
- To respond to inquiries — when you contact us via our website forms or email, we use your information to respond and provide the information or follow-up you have requested
- To manage client and partner relationships — where you become a client, delivery consultant, or reseller partner, we use your data to manage the commercial relationship, including invoicing, contracting, and communications
- To improve our website and services — we use aggregated and anonymized usage data to understand how our website is used and to improve our content and user experience
- To send relevant communications — with your consent, we may contact you with insights, service updates, or relevant content we believe may be of interest. You may withdraw this consent at any time
- To comply with legal obligations — where we are required to retain or process data to comply with applicable law, including tax, accounting, and regulatory requirements
- To manage CRM and sales operations — inquiry data is stored in our CRM system to enable follow-up and relationship management
4. Why we process your data
We process your personal data only for specific, legitimate purposes. Depending on the context, those purposes include:
- Responding to inquiries — we process contact and inquiry data to reply to your messages and provide the information you requested
- Performing contracts — where we have entered into or are preparing to enter into an agreement with you (as a client, delivery consultant, or partner), we process your data as necessary to fulfill that agreement
- Marketing communications — where you have given consent, we may send you relevant insights or service updates. You may withdraw consent at any time by contacting us or using the unsubscribe link in any email
- Legal and regulatory compliance — where processing is required to comply with applicable law, including tax and accounting obligations
5. Data sharing
We do not sell your personal data. We share personal data only in the following circumstances:
- Service providers — we use third-party tools including Salesforce (CRM), WP Engine (website hosting), Google Analytics (website analytics), and WP Mail SMTP (email delivery). These providers process data on our behalf under appropriate data processing agreements
- Delivery consultants — where you become a Sparx Services client, limited contact and project information may be shared with the delivery consultant(s) assigned to your engagement, who are bound by confidentiality obligations
- Legal requirements — we may disclose data where required by law, court order, or regulatory authority
- Business transfer — in the event of a merger, acquisition, or sale of assets, personal data may be transferred to the relevant third party subject to equivalent protections
6. International data transfers
We are based in the United States. If you are located outside the US and provide personal data to us, your data will be transferred to and processed in the United States. By submitting information through our website or engaging our services, you acknowledge this transfer.
Our key service providers, including Salesforce (CRM) and WP Engine (hosting), maintain their own data security standards and transfer mechanisms for international data flows. Where we engage service providers that process personal data of individuals in the EU or UK, we ensure appropriate safeguards are in place.
7. Data retention
We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Our general retention periods are:
- Inquiry data (no engagement) — 24 months from the date of last contact, after which data is deleted or anonymized
- Client and contract data — 7 years from project completion to comply with accounting and legal obligations
- Delivery consultant and partner data — for the duration of the relationship and 3 years thereafter
- Website usage data (Google Analytics) — 26 months, in line with our Analytics configuration
- Marketing consent records — retained until consent is withdrawn, then deleted within 30 days
8. Your rights
Depending on where you are located, you may have the following rights regarding your personal data:
- Right to know — you may request details about the personal data we collect, use, and share about you
- Right to access — you may request a copy of the personal data we hold about you
- Right to correction — you may ask us to correct inaccurate or incomplete personal data
- Right to deletion — you may ask us to delete your personal data, subject to certain legal exceptions
- Right to opt out of marketing — you may withdraw consent for marketing communications at any time using the unsubscribe link in any email or by contacting us directly
- California residents (CCPA) — if you are a California resident, you have additional rights under the California Consumer Privacy Act, including the right to opt out of the sale of personal information. We do not sell personal information.
- No automated decision-making — we do not use automated decision-making or profiling that produces legal or similarly significant effects
To exercise any of these rights, contact us at privacy@sparxservices.com. We will respond within 30 days. We may need to verify your identity before processing a request.
9. Cookies
Our website uses cookies — small text files stored on your device — to improve functionality and understand how the site is used. We use the following categories of cookies:
- Strictly necessary cookies — essential for the website to function (e.g., session management, form security tokens). These do not require consent
- Analytics cookies — we use Google Analytics 4 to understand aggregate usage patterns. These cookies are only set with your consent. You may opt out at any time via our cookie preferences or by installing the Google Analytics Opt-out Browser Add-on
- Functionality cookies — used to remember preferences such as cookie consent choices
You may manage your cookie preferences at any time by clicking the Cookie Settings link in the footer of this website. Withdrawing consent for analytics cookies will not affect your ability to use the site.
10. Security
We implement appropriate technical and organisational measures to protect personal data against unauthorized access, loss, destruction, or alteration. These include HTTPS encryption across the site, restricted access to CRM data, and processor due diligence for all third-party tools.
No transmission of data over the internet is completely secure. While we take all reasonable steps to protect your data, we cannot guarantee absolute security. If you believe your data has been compromised, please contact us immediately at privacy@sparxservices.com.
11. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or guidance from data protection authorities. The date at the top of this page indicates when the policy was last revised. We encourage you to review this page periodically. Where changes are material, we will take reasonable steps to notify you directly.
If you have questions or concerns about how we handle your personal data, or wish to exercise any of your rights, please contact us:
Email: privacy@sparxservices.com
Legal entity: SFI Ventures, LLC d/b/a Sparx Services by NovoCircle, Wyoming, USA
We will acknowledge your inquiry promptly and respond within 30 days.