Privacy Policy

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

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

• To respond to inquiries — when you contact us via our website forms or email, we use your information to respond and provide the 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 it
• To send relevant communications — with your consent, we may contact you with insights, service updates, or relevant content. You may withdraw this consent at any time
• To comply with legal obligations — 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: responding to inquiries; performing contracts (as a client, delivery consultant, or partner); marketing communications where you have given consent (withdrawable at any time); and legal and regulatory compliance.

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), processing data on our behalf under appropriate data processing agreements
• Delivery consultants — where you become a 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 — where required by law, court order, or regulatory authority
• Business transfer — in the event of a merger, acquisition, or sale of assets, 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.

7. Data retention

• Inquiry data (no engagement) — 24 months from the date of last contact, then 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
• 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 rights to know, access, correct, and delete your personal data, and to opt out of marketing communications at any time. California residents have additional rights under the CCPA, including the right to opt out of the sale of personal information — we do not sell personal information. We do not use automated decision-making or profiling that produces legal or similarly significant effects. To exercise any of these rights, contact privacy@sparxservices.com. We will respond within 30 days and may need to verify your identity first.

9. Cookies

Our website uses cookies to improve functionality and understand how the site is used: strictly necessary cookies (no consent required), analytics cookies (Google Analytics 4, set only with your consent), and functionality cookies (e.g., remembering your consent choices). You may manage your cookie preferences at any time. 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, including 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; 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. Where changes are material, we will take reasonable steps to notify you directly.

12. Contact and complaints

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.