Last Updated: August 16, 2025
Spark Roam Limited (“we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and share your personal information when you use our website, www.sparkroam.com, and our services (collectively, the “Services”).
We are a data controller and are responsible for your personal data. Our ICO registration number is ZB924785.
Our contact details:
- Full name of legal entity: Spark Roam Limited
- Company number: 13747268
- Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
- Email: hello@sparkroam.com
- Phone: +44 20 80 58 98 48
1. The Data We Collect About You
We may collect, use, store, and transfer different kinds of personal data about you. This includes:
- Identity Data: Your first name, last name, title, and/or company name.
- Contact Data: Your billing address, email address, and telephone numbers.
- Financial Data: Payment card details (though we do not store them directly), and other payment information.
- Transaction Data: Details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data: Your IP address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
- Usage Data: Information about how you use our website and Services, suchs as your browsing patterns and the pages you visit.
- Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, and information about your health).
2. How We Collect Your Personal Data
We use different methods to collect data from and about you, including:
- Direct interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- Purchase a product or service.
- Create an account on our website.
- Subscribe to our newsletter or other publications.
- Contact customer support.
- Automated technologies or interactions: As you interact with our website, we may automatically collect Technical and Usage Data. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our separate Cookie Policy for more details.
- Third parties or publicly available sources: We may receive personal data about you from various third parties, such as:
- Payment providers ([e.g., Stripe, PayPal]) that provide us with transaction data.
- Analytics providers ([e.g., Google Analytics]).
3. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- To perform the contract: To process your order, manage your account, and provide the Services you have requested. This is necessary for the performance of a contract with you.
- Legitimate interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, to improve our website, prevent fraud, and keep our systems secure.
- Legal obligation: Where we need to comply with a legal or regulatory obligation.
Here are some of the ways we use your personal data:
To register you as a new customer
Type of Data: Identity, Contact
Lawful Basis: Performance of a contract with you
To process and deliver your order, manage payments, fees, and charges
Type of Data: Identity, Contact, Financial, Transaction
Lawful Basis: Performance of a contract with you
To manage our relationship with you, including notifying you about changes to our terms or privacy policy
Type of Data: Identity, Contact
Lawful Basis: Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated)
To enable you to participate in a survey or provide a review
Type of Data: Identity, Contact, Usage
Lawful Basis: Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To improve our website, products/services, marketing, customer relationships, and experiences
Type of Data: Technical, Usage, Marketing & Communications
Lawful Basis: Necessary for our legitimate interests (to define customer types, to keep our website updated and relevant, to develop our business)
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of Data: Identity, Technical
Lawful Basis: Necessary for our legitimate interests (for running our business, network security, fraud prevention); Necessary to comply with a legal obligation
4. Marketing
We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
You have the right to withdraw consent to marketing at any time by following the opt-out links on any marketing message sent to you or by contacting us.
5. Disclosure of Your Personal Data
We may share your personal data with the parties set out below for the purposes mentioned above:
- Service providers: Third parties who provide services to us, such as payment processing ([e.g., Stripe]), email delivery, IT and system administration services.
- Professional advisers: Lawyers, bankers, auditors, and insurers who provide legal, banking, audit, or insurance services.
- Third-party providers of eSIMs: To provision your data plan, we must share limited information with our trusted partners, but only to the extent necessary to deliver the service.
- Regulators and other authorities: Who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International Transfers
Your personal data may be transferred outside the UK and European Economic Area (EEA) to our partners who operate in the countries where we provide our services. When we do this, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government.
- Where we use certain service providers, we may use specific contracts approved by the UK government which give personal data the same protection it has in the UK.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.
8. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
9. Your Legal Rights
Under UK data protection law, you have the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request the transfer of your personal data to you or a third party.
- Withdraw consent at any time where we are relying on consent to process your personal data.