Privacy Policy

1.1 Sparq is incorporated in Meydan Free Zone, Dubai, United Arab Emirates, with registered office at Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, UAE. The Platform is available at https://sparq.ae/. You can contact us about privacy matters at privacy@sparq.ae.

1.2 Sparq determines the purposes and means of processing personal data in connection with the operation of the Platform, including account registration, subscriptions and visitor interactions. Partners generally determine independently how they assess Applications and administer Placements, and are responsible for their own processing.

1.3 We process personal data in accordance with applicable data protection and privacy laws, including Federal Decree-Law No. 45 of 2021 Concerning the Protection of Personal Data (“UAE PDPL”), where applicable, and laws protecting children’s personal data.

2.1 From Members, we may collect names, dates of birth, contact details, education, qualifications, experience, skills, CVs, profile photographs, eligibility information, preferences, Applications, interview or Placement status, feedback and support correspondence. Where matching functionality is used, we may also process related results.

2.2 For Members aged 16 or 17, we collect relevant parent or guardian details, consent and payment-authorisation records, and proportionate information needed to verify age, identity or legal authority. We retain identity documents only where necessary and lawful.

2.3 From Partner representatives, we may collect names, roles, business contact details, organisation information, trade-licence or authority evidence, account credentials, listings and candidate-assessment activity.

2.4 We may collect technical information when you visit or use the Platform, including IP addresses, device and browser details, security events, cookies or similar identifiers and usage information. Where you register or use our services, we may also collect login records, subscription and billing status, payment-provider references, support messages and Platform activity. Payment-card details are generally processed by our payment provider; the information available to Sparq depends on the payment arrangements.

2.5 We do not ordinarily require sensitive personal data. Where it is necessary, we will explain why and apply the lawful basis and safeguards required.

3.1 We process personal data to operate and secure our Platform, respond to enquiries, administer accounts and subscriptions, verify eligibility and guardian permissions, process payments, prevent misuse and comply with legal requirements. Depending on the activity, processing may rely on consent or another lawful ground under applicable law.

3.2 We process profile, Opportunity and Application information to operate the Platform, enable Applications, share relevant information with Partners, send status updates and record Placement status. Matching or recommendations, if implemented, may also use relevant profile and Opportunity information.

3.3 We process support, security, complaints and safeguarding information to respond to requests, protect users, investigate suspected misconduct, comply with legal obligations and establish, exercise or defend legal rights, where permitted by applicable law.

3.4 We may analyse Platform use and improve functionality where lawful and appropriately disclosed. Direct marketing, non-essential tracking, targeted advertising and unrelated AI model training using identifiable Member data require a suitable lawful basis, transparency and any separate permissions required by applicable law. Account registration or guardian consent does not automatically authorise these activities.

3.5 Where we rely on consent, it may be withdrawn using the contact details in section 1, without affecting earlier lawful processing. Withdrawal may prevent us from providing a feature where the data is necessary. We may continue processing where another lawful basis permits or requires it.

4.1 If the Platform uses automated matching or AI-assisted recommendations, these may help Members explore Opportunities. Partners make their own selection decisions.

4.2 Where external providers process personal data for these functions, we will apply the relevant contractual, security, transparency and international-transfer safeguards.

4.3 Member information, particularly children’s information, is not automatically available for unrelated AI training, advertising or profiling. Any such use requires an appropriate lawful basis, clear notice and safeguards or permissions required by applicable law.

4.4 Where solely automated decisions significantly affect individuals, we will apply any rights and safeguards required by applicable law, including rights to human review or challenge where available.

5.1 When a Member submits an Application, relevant profile, CV and Application information may be shared with authorised personnel of the Partner offering the Opportunity to assess the Application and arrange interviews or a Placement. Access to Member information is limited according to the relevant Platform permissions.

5.2 We use service providers to support hosting, authentication, Platform administration, communications, payments and customer support. If matching or AI-assisted functions are implemented, relevant technology providers may also process personal data. We share only the information needed for the relevant service and apply appropriate contractual and security safeguards. Information about material providers and their processing will be made available where required by applicable law.

5.3 We may disclose information to advisers, insurers, competent authorities or other recipients where legally required or otherwise lawfully justified, and in connection with a lawful business transfer subject to appropriate protections.

5.4 We do not sell personal data, including to Partners or advertisers.

5.5 Partners generally determine independently how they use and retain information received for Opportunities and Placements and must provide their own privacy information where required. Sparq remains responsible for its own processing.

6.1 Our hosting, payment, communications and other service providers may store or access personal data in the UAE and in other countries, depending on their locations, infrastructure and support arrangements. This may include access by authorised personnel outside the UAE. The countries and providers involved will depend on the services actually used by the Platform.

6.2 Where personal data is transferred or accessed outside the UAE, we will assess the applicable legal requirements and use a permitted transfer route and safeguards, as required. You may contact privacy@sparq.ae for further information about relevant transfers and safeguards.

6.3 We use appropriate technical and organisational measures to protect personal data, including access controls, authentication and security and incident-response procedures.

7.1 The Platform is intended for Members aged 16 and over at registration. Individuals under 16 cannot register. Members aged 16 or 17 must complete the parent or guardian acceptance and payment-authorisation process described in the Member Terms and Guardian Consent.

7.2 We apply age-appropriate privacy, access and safety safeguards required by applicable law, including any restrictions on advertising or profiling involving children.

7.3 A parent or guardian may contact privacy@sparq.ae about a minor’s personal data, privacy rights or withdrawal of guardian permission. Withdrawal may restrict the minor’s account but does not automatically erase records that must lawfully be retained.

8.1 We keep personal data for as long as needed for the purposes described in this Privacy Policy, taking account of the nature of the data and applicable legal obligations. Account and profile information is generally retained while the account remains active and for a proportionate period afterwards; Application and Placement records are retained as needed for Platform administration, safeguarding and disputes; and payment, consent and security records are retained for relevant accounting, evidential and legal requirements. We review retention needs and delete or anonymise data when no longer required, unless continued retention is lawful and necessary.

8.2 Depending on the circumstances and applicable law, you may request access to or correction or erasure of your personal data, restriction or cessation of processing, portability, or withdrawal of consent. Rights may also apply to qualifying automated decisions. These rights are subject to applicable conditions and exceptions.

8.3 To exercise a right or raise a complaint, contact privacy@sparq.ae. We may verify identity or guardian authority and will respond as required by applicable law.

8.4 Where available under applicable law, you may complain to the competent data protection authority.

9.1 Our Cookie Policy explains the cookies and similar technologies used on our Platform and the available choices.

9.2 We send necessary service communications about accounts, security, Applications, subscriptions and payments. Promotional communications are subject to applicable permissions and opt-out requirements.

9.3 We may update this Privacy Policy to reflect changes in law or our processing and will provide notice or seek fresh permission where required.