Privacy Policy
Website, mobile app, connected devices, ecommerce and support
Effective date
2 August 2026
Last updated
2 August 2026
1. Controller and contact details
Sense Technology Group Limited, trading as Sparkery, is the controller of personal information covered by this policy. Company number: 15382298. Registered office: c/o Crowe U.K. LLP, St George\’s House, 56 Peter Street, Manchester M2 3NQ.
Sparkery\’s Data Protection Officer is Michael Lomas. Privacy enquiries, rights requests and data-protection complaints may be submitted through https://www.sparkery.com/support or support@sparkery.com.
2. Scope
This policy covers the Sparkery website, online store, mobile application, connected wearable devices, smart scales, AI-supported wellbeing features, Health Hub, customer support, competitions, marketing and Partner Programme administration.
Third-party websites, app stores, payment services and health platforms have their own privacy notices where they act as independent controllers.
3. Personal information we collect
Category
Examples
Identity and contact
Name, date of birth, email address, phone number, username, postal and delivery address.
Account and security
Login details, authentication records, account settings, permissions, fraud and security events.
Orders and support
Products, payments, delivery, returns, warranty, communications, complaints and support records.
Device and technical
Device type, operating system, IP address, app version, unique identifiers, Bluetooth status, pairing and synchronisation records, settings, logs, connectivity, device-memory status and location where permission is granted.
Usage and analytics
Website, app and connected-device interactions, pages, features, communications and campaign engagement.
Health and wellbeing
Activity, sleep, recovery, heart rate, heart-rate variability, weight, body-fat and other body-composition estimates, goals, trends and related inferences.
Marketing and research
Preferences, consent records, survey responses, competition entries and campaign data.
Partner Programme
Business contacts, Partner Code attribution, transaction quantities, values, commission and compliance records.
Health data is special-category personal information. Biometric data is special-category information only where it is processed for the purpose of uniquely identifying a person. Sparkery does not describe ordinary body measurements as biometric identification unless that use actually occurs.
4. How we collect information
Directly from you when you create an account, place an order, enter information, contact support, complete a survey or enter a competition.
Automatically from the website, app and connected products through logs, permissions, cookies and other storage or access technologies.
From the Sparkery band, smart scale and other devices that you connect to your account, including measurement data, device memory, pairing and synchronisation information.
From payment, ecommerce, fulfilment, delivery, fraud-prevention and support providers.
From Apple Health, Google Health Connect or another integration when you enable the relevant permission.
From a Partner Code or campaign record when you use a partner referral route.
5. Information you must provide and choices
Some information is required to create an account, fulfil an order, provide support, secure the service or comply with law. If required information is not provided, Sparkery may be unable to provide the relevant product or function.
Health-platform integrations, precise location, non-essential analytics, advertising and many personalised wellbeing features are optional. You can manage permissions and consent through the app, device, website or cookie settings. Withdrawing consent may disable the related feature but does not affect processing that was lawful before withdrawal.
6. Purposes, lawful bases and special-category conditions
Purpose
Create and administer accounts; provide app and connected-device functions
Personalise wellbeing insights, reports, goals and AI-supported coaching
Process orders, payments, delivery, returns and warranty claims
Provide support and service communications
Secure systems, prevent fraud and enforce terms
Analytics, research and service improvement
Marketing and advertising
Competitions, promotions and surveys
Legal compliance, disputes and records
Sparkery determines and documents the lawful basis and any Article 9 condition before processing. Explicit consent is requested through a clear affirmative statement, can be withdrawn and is recorded separately where appropriate.
7. Health and wellbeing information
Sparkery uses health and wellbeing information only for the features you choose, service administration, security, support and other stated purposes. Sparkery does not use it for medical diagnosis, emergency monitoring, insurance underwriting or employment decisions and does not give Partners access to identifiable customer health information.
Because fitness-tracker and body-composition information can reveal health status, Sparkery applies additional access controls, minimisation, retention and security safeguards. Where processing is likely to create a high risk, Sparkery should complete and maintain a data-protection impact assessment.
The Sparkery band is specified as having up to 30 days of device memory. Depending on use and synchronisation, measurement data may remain on the band until it is transferred, overwritten or the device is reset. Device-local retention is separate from the app and cloud retention periods described below.
8. AI-supported processing and automated decisions
Sparkery may use AI-supported tools to identify patterns, personalise general wellbeing guidance and produce summaries. Outputs may be inaccurate and do not constitute medical advice. The data and logic used depend on the feature and available inputs.
Sparkery does not currently intend to make decisions based solely on automated processing that produce legal or similarly significant effects. If that changes, Sparkery will provide required information and safeguards, including the ability to make representations, request human intervention and challenge the decision. Special-category information will be subject to the stricter legal conditions that apply.
9. Sharing personal information
Recipient type
Purpose and information shared
Cloud and infrastructure
Amazon Web Services and technical providers for hosting, storage, security, backups and service operation.
Ecommerce and payments
Shopify, Shopify Payments, Stripe, PayPal, Klarna and related fraud or payment providers for checkout and transactions.
Delivery and fulfilment
Carriers, warehouse and returns providers for delivery, tracking, returns and recalls.
Analytics and communications
Google Analytics, Klaviyo and approved communications providers, subject to consent and settings where required.
Advertising
Meta, Google advertising services and campaign providers where valid consent applies. Sparkery does not disclose identifiable health information for ordinary advertising.
Health integrations
Apple Health, Google Health Connect and other platforms at your direction and subject to the permissions you enable.
Professional and legal
Insurers, auditors, lawyers, accountants, regulators, law enforcement and courts where reasonably necessary or legally required.
Corporate transactions
A genuine buyer, investor, lender or successor, subject to confidentiality and appropriate safeguards.
Sparkery does not sell personal information. Service providers acting as processors are required to use information only on documented instructions, protect it and assist with legal obligations. A provider acting independently is responsible for its own processing under its privacy notice.
10. Partner Programme information
Partners normally receive only aggregated or transaction-level sales quantities, values, Partner Code attribution and commission information needed to administer the programme. They must not receive identifiable health information. Where additional personal information is shared, Sparkery and the Partner must establish the correct controller or processor arrangement before sharing begins.
11. International transfers
Some providers may process information outside the United Kingdom. Sparkery uses a lawful transfer mechanism and carries out the assessment required by current UK law. Safeguards may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, approved binding corporate rules or another valid mechanism, together with supplementary protections where appropriate.
12. Retention
Record
Typical retention approach
Account and service data
For the account relationship and normally deleted or anonymised within 365 days after valid account closure or deletion request, unless a shorter period applies or longer retention is justified.
Health and wellbeing data
For as long as the relevant feature is active and consent or another valid condition applies, then deleted or anonymised in accordance with account settings and legal retention needs.
Orders, tax and accounting
Normally up to six years after the relevant financial year or transaction, and longer where a dispute, investigation or legal duty requires it.
Warranty, complaints and support
For the warranty or complaint period and a reasonable period afterwards to establish, exercise or defend legal claims.
Security and fraud logs
For a proportionate period based on risk, normally between 12 months and six years where an incident or legal claim requires it.
Marketing and consent records
Until you opt out, plus a suppression record and evidence of consent for as long as needed to demonstrate compliance.
Device-local measurement memory
The Sparkery band may hold up to 30 days of measurement data according to its product specification. Data may be cleared through synchronisation, overwrite, reset, servicing or disposal.
Retention may be extended where law, tax, product safety, fraud prevention, litigation hold, regulator request or security needs require it. When retention ends, information is securely deleted or irreversibly anonymised.
13. Security
Sparkery uses proportionate technical and organisational measures designed to protect information, including role-based access, encryption where appropriate, secure Bluetooth pairing and synchronisation controls, logging, supplier due diligence, backups, vulnerability management, incident response and staff confidentiality. No system is completely secure, so users should also protect credentials, devices and email accounts.
14. Your data-protection rights
Ask for access to personal information and information about its use.
Ask for inaccurate or incomplete information to be corrected.
Ask for erasure or restriction where legal conditions are met.
Receive certain information in a portable format.
Object to processing based on legitimate interests and object at any time to direct marketing.
Withdraw consent at any time without affecting earlier lawful processing.
Request safeguards relating to significant automated decisions, including human intervention and a review where applicable.
Sparkery may verify identity, request clarification and apply legal exemptions. Subject access searches will be reasonable and proportionate. The response period may be paused where additional information is reasonably needed to identify the information or confirm the request.
15. Data-protection complaints
You may make a data-protection complaint through https://www.sparkery.com/support or support@sparkery.com. Explain what happened, the information involved and the outcome you seek. Sparkery will provide a clear electronic route for complaints, acknowledge a complaint within 30 days, investigate appropriately and communicate the outcome without undue delay, as required by current UK data-protection law.
You may also complain to the Information Commissioner\’s Office. Sparkery asks that you contact it first where possible so the issue can be investigated, but this does not remove your right to contact the ICO.
16. Marketing
Sparkery may send service and transaction messages where necessary. Marketing email, text or similar communications are sent only where consent or another PECR-permitted basis applies. You can unsubscribe using the message link or contact support. Sparkery keeps a suppression record so it can respect the opt-out.
17. Cookies and storage or access technologies
The website, app and connected services may use cookies, pixels, local storage, SDKs, identifiers and similar technologies. Non-essential analytics and advertising technologies are used only with valid consent where required. See the Cookie Policy and the live Cookie Settings tool for categories, providers and choices.
18. Children
Sparkery is intended for users aged 16 or over and is not directed to children under 16. A user under 18 should involve a parent or guardian where appropriate. If Sparkery learns that information was collected from a child contrary to this policy, it will investigate and take appropriate deletion or safeguarding action.
19. Changes to this policy
Sparkery may update this policy to reflect changes in law, services, providers or technology. The updated version and effective date will be published. Where a change materially affects consent-based processing, Sparkery will provide additional notice or request renewed consent where required.
20. ICO contact
Information Commissioner\’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Telephone: 0303 123 1113. Website: https://ico.org.uk.
21. Subprocessors
We engage certain third-party service providers (“subprocessors”) to help us provide our services and process personal data on our behalf. We maintain an up-to-date list of these subprocessors, including their purpose and location, at our Trust Center: https://app.eu.vanta.com/c/wearesense.com/trust-center/view/subprocessors. We encourage you to check this page periodically for the most current information, as we may add or replace subprocessors from time to time in accordance with this policy.
Legal entity: Sense Technology Group Limited │ Company no. 15382298 │ VAT no. GB 471 2294 96
Registered office: c/o Crowe U.K. LLP, St George\’s House, 56 Peter Street, Manchester M2 3NQ
Trading address: Unit 7, Blackburn Road, Simonstone, Burnley, Lancashire, BB12 7FS
