Spark Business Connections - Data Protection & Privacy Notice

Effective date: March 2026

Last updated: 1st March 2026

1. Introduction

This Data Protection & Privacy Notice explains how Spark Business Connections collects, uses, stores, protects and shares personal data when you visit our website, apply for membership, create a member profile, attend an event, communicate with us, or otherwise use our services.

Spark Business Connections is a business name of Slua Ventures Limited. Spark Business Connections provides an invitation-only and/or application-based business membership platform focused on structured member interactions, business introductions, curated events, and professional relationship building.

This notice should be read together with our Terms of Service, Cookie Policy, membership terms, event terms, and any other privacy information we provide at the point where personal data is collected.

2. Who we are

For the purposes of data protection law, the data controller is:

Slua Ventures Limited
Trading as Spark Business Connections
Company Registration Number: 626553
Also associated with Spark Venture Funding
13 Herbert Place
Dublin 2
D02 YD32
Ireland

Email: info@sparkbusinessconnections.com
Phone: +353 1 44 33 944

Spark Business Connections does not have a separately appointed Data Protection Officer. Data protection queries should be directed to the general contact email above.

In this notice, "Spark Business Connections", "SBC", "we", "us" and "our" refer to Slua Ventures Limited trading as Spark Business Connections.

"You" and "your" refer to website visitors, applicants, members, guests, event attendees, speakers, sponsors, partners, suppliers, professional contacts and other individuals whose personal data we process.

3. Data protection principles

We process personal data in accordance with the General Data Protection Regulation, the Irish Data Protection Act 2018 and other applicable data protection and privacy laws.

We aim to ensure that personal data is:

• processed lawfully, fairly and transparently;
• collected for specified, explicit and legitimate purposes;
• adequate, relevant and limited to what is necessary;
• accurate and kept up to date where necessary;
• kept only for as long as necessary;
• processed securely; and
• handled in a way that supports accountability and good governance.

4. Personal data we collect

The personal data we collect depends on how you interact with Spark Business Connections.

4.1 Website visitors

When you visit our website, we may collect:

• IP address;
• browser type and version;
• device type;
• operating system;
• pages visited;
• time and date of visit;
• referral source;
• cookie identifiers;
• analytics information; and
• information submitted through website forms.

4.2 Membership applicants and members

When you apply for or hold membership, we may collect:

• full name;
• business name;
• job title or role;
• business sector or industry;
• business address;
• email address;
• phone number;
• website and social media links;
• professional biography;
• business description;
• profile photograph;
• company logo;
• membership application details;
• membership status;
• payment and billing details;
• attendance history;
• communication preferences;
• member interaction records; and
• information you choose to include in your member profile.

4.3 Event attendees, speakers and guests

For events, we may collect:

• attendee name;
• organisation;
• job title;
• contact details;
• ticket or booking information;
• payment status;
• dietary requirements;
• accessibility requirements;
• guest details;
• attendance records;
• photographs, video or audio captured at events;
• speaker biographies;
• presentation materials; and
• event feedback.

Where dietary or accessibility information includes health-related information, we will use it only where necessary to make appropriate arrangements for the event and will treat it with particular care.

4.4 Communications and enquiries

When you contact us, we may collect:

• name;
• email address;
• phone number;
• organisation;
• message content;
• correspondence history;
• support requests;
• complaint details; and
• records of our responses.

4.5 Sponsors, partners and suppliers

Where we work with sponsors, partners, service providers or suppliers, we may collect:

• business contact details;
• role and organisation;
• contract details;
• payment and invoice information;
• project or service records;
• due diligence information;
• communications; and
• relationship management information.

4.6 Information from third parties

We may receive personal data from third parties such as:

• existing members who refer or introduce you;
• event partners;
• professional contacts;
• publicly available business sources;
• company websites;
• LinkedIn or other professional platforms;
• payment providers;
• CRM, email, analytics or event management providers, including HubSpot, Mailchimp and Google Analytics where applicable; and
• service providers acting on our behalf.

We will only use third-party information where we have a lawful basis to do so.

5. Special category personal data

We do not normally seek to collect special category personal data, such as health data, biometric data, political opinions, religious beliefs or trade union membership.

However, we may process limited special category data where:

• you voluntarily provide dietary or accessibility information for an event;
• processing is necessary to support your attendance or participation;
• we need to comply with a legal obligation;
• processing is necessary to establish, exercise or defend legal claims; or
• you have given explicit consent where required.

You should not provide special category personal data unless it is necessary for the relevant purpose.

6. How we use personal data

We may use personal data for the following purposes. Spark Business Connections do not externally share member records or marketing lists with third parties for their independent use. However, where lawful and appropriate, Spark may use contact and engagement information for subsequent Spark-related communications, including updates about relevant Spark services, events, opportunities and business activities.

6.1 Website operation and enquiries

• operating and maintaining the website;
• responding to enquiries;
• providing requested information;
• managing contact forms;
• improving website performance;
• analysing website usage; and
• protecting the website from misuse, fraud or security threats.

6.2 Membership administration

• reviewing membership applications;
• verifying eligibility and suitability;
• creating and managing member accounts;
• maintaining member profiles;
• administering membership access;
• processing membership renewals;
• handling payments and invoices;
• providing member communications;
• managing member benefits; and
• enforcing membership rules and standards.

6.3 Business introductions and member interactions

• facilitating business introductions;
• supporting structured member interactions;
• matching members based on stated business interests;
• arranging meetings, roundtables or member sessions;
• helping members identify relevant contacts; and
• maintaining records of introductions and interactions where appropriate.

6.4 Events

• managing event bookings;
• issuing confirmations and reminders;
• managing attendee lists;
• supporting venue, catering and accessibility arrangements;
• administering guest lists;
• managing event security and access;
• collecting feedback;
• producing event materials;
• promoting future events; and
• documenting events through photography or video where appropriate.

6.5 Marketing and communications

• sending newsletters, updates and event information;
• promoting relevant Spark Business Connections services;
• sharing business insights and member updates;
• managing communication preferences;
• running campaigns; and
• measuring engagement with communications.

We will comply with applicable direct marketing rules and will provide unsubscribe or preference options where required. Marketing communications may be managed using HubSpot, Mailchimp or similar tools.

6.6 Legal, compliance and business administration

• maintaining business records;
• complying with legal and regulatory obligations;
• responding to lawful requests from authorities;
• handling complaints and disputes;
• enforcing our Terms of Service;
• protecting our rights, members, staff and business;
• managing contracts and suppliers;
• accounting, audit and tax administration; and
• supporting business continuity, security and governance.

7. Lawful bases for processing

We rely on different lawful bases depending on the purpose of processing.

7.1 Contract

We process personal data where necessary to enter into or perform a contract with you, including:

• processing membership applications;
• providing membership access;
• managing event bookings;
• processing payments;
• delivering member benefits; and
• administering our Terms of Service.

7.2 Legitimate interests

We process personal data where necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms. These interests include:

• operating a professional membership community;
• assessing membership suitability;
• facilitating appropriate business introductions;
• managing events;
• maintaining member standards;
• preventing misuse of the platform;
• improving our services;
• protecting our business, members and reputation;
• maintaining appropriate business records; and
• communicating with business contacts.

7.3 Consent

We may rely on consent where required, including for:

• certain marketing communications;
• optional cookies and tracking technologies;
• use of certain photographs, testimonials or promotional materials where consent is appropriate;
• processing specific optional information; and
• any special category data where explicit consent is required.

Where we rely on consent, you may withdraw consent at any time. Withdrawal of consent does not affect processing that took place before consent was withdrawn.

7.4 Legal obligation

We process personal data where necessary to comply with legal obligations, including:

• tax and accounting requirements;
• company law obligations;
• data protection obligations;
• responding to lawful requests;
• maintaining records required by law; and
• complying with health, safety or venue obligations where applicable.

7.5 Vital interests

In rare cases, we may process personal data where necessary to protect someone's vital interests, for example in a medical or safety emergency at an event.

7.6 Legal claims

We may process personal data where necessary to establish, exercise or defend legal claims.

8. Cookies and analytics

Our website may use cookies, pixels, tags and similar technologies to operate the website, remember preferences, analyse usage, improve performance and support marketing activities.

Our website uses Google Analytics to help us understand website usage and improve website performance.

Some cookies are strictly necessary for the website to function. Others, such as analytics or marketing cookies, may require your consent.

Further information is provided in our Cookie Policy on the website and, where applicable, through our cookie banner.

9. Who we share personal data with

We may share personal data with the following categories of recipients where necessary and lawful:

• IT hosting and website providers;
• CRM providers, including HubSpot where applicable;
• payment processors, including Stripe where applicable;
• email marketing platforms, including Mailchimp where applicable;
• event registration platforms;
• analytics providers, including Google Analytics where applicable;
• professional advisers, including solicitors, accountants and auditors;
• venue operators and event service providers;
• catering providers, where dietary information is required;
• sponsors or partners, where clearly communicated and lawful;
• other approved members, where necessary for member profiles, introductions or structured interactions within the member platform;
• service providers acting on our behalf;
• regulatory, tax, law enforcement or public authorities where required by law; and
• potential purchasers, successors or advisers in connection with a business sale, restructuring, merger or investment process.

We do not sell personal data. Member profile information is visible only to approved members and is not made publicly available as an open directory.

Where we use processors to handle personal data on our behalf, we require them to process the data only on our instructions and to apply appropriate security and confidentiality safeguards.

10. Member directories, profiles and introductions

As part of Spark Business Connections, selected member information may be visible to other approved members only or used to facilitate introductions.

This may include:

• name;
• organisation;
• role;
• sector;
• business description;
• professional biography;
• profile photo;
• website or LinkedIn link;
• business interests; and
• contact details, where appropriate and permitted.

You should only include information in your profile that you are comfortable sharing within the membership environment.

We may restrict, edit or remove profile information where it is inaccurate, inappropriate, misleading, excessive or inconsistent with our membership standards.

11. Event photography, video and publicity

We may take photographs, video or audio recordings at events for legitimate business purposes, including event documentation, member communications, website content and social media content, including LinkedIn.

Event photography and video may be used on the Spark Business Connections website and, where appropriate, on Spark Business Connections LinkedIn activity. We do not currently intend to use event photographs routinely in printed materials unless this is clearly communicated.

We will operate an event photography opt-out process. If you do not wish to appear in event photography or video, please notify us before or at the event. We will take reasonable steps to accommodate your request, although we may not be able to remove you from wide crowd shots or footage where your appearance is incidental.

Before events where photography or video may be taken, we may also use signage, booking notices or event communications to remind attendees that photography or recording may take place.

12. International transfers

We store and process website and platform data in Ireland.

Based on our current operating model, we do not intentionally transfer Spark Business Connections member data outside the European Union.

If this changes in the future, or if any service provider processes personal data outside the European Economic Area, we will ensure that appropriate safeguards are in place, such as an adequacy decision, Standard Contractual Clauses, additional contractual, technical or organisational safeguards, or another lawful transfer mechanism under data protection law.

13. How long we keep personal data

We keep personal data only for as long as necessary for the purposes for which it was collected, including legal, accounting, tax, contractual, security and dispute-resolution purposes.

Retention periods may vary depending on the type of data and the reason we hold it.

Spark Business Connections does not yet maintain a separate formal retention schedule. Until a formal schedule is adopted, we will apply the indicative periods below and review retention on a reasonable and proportionate basis.

• website enquiry records: up to 24 months after the enquiry is resolved, unless a longer period is required;
• membership application records: successful applications are retained as part of the active member record; unsuccessful or withdrawn applications are retained only for a reasonable period unless needed for legal, dispute, fraud-prevention or business-record purposes;
• active member records: for the duration of membership;
• former member records: up to 7 years after membership ends where needed for contract, tax, accounting, legal or dispute purposes;
• invoices and accounting records: normally 6 to 7 years, depending on applicable legal requirements;
• event attendance records: up to 7 years where needed for contractual, payment, insurance or dispute purposes;
• marketing records: until you unsubscribe, object or the data is no longer required;
• consent records: for as long as needed to demonstrate compliance;
• security logs: for a limited period appropriate to the security purpose, unless required for investigation; and
• legal claims or dispute records: for as long as necessary to establish, exercise or defend legal claims.

These periods are indicative and may be adjusted depending on legal, operational or risk requirements.

14. Data security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration, disclosure or destruction.

The Spark Business Connections website and platform are hosted in Ireland. Member introductions are logged on the platform.

Security measures may include:

• access controls;
• password and authentication controls;
• role-based permissions;
• secure hosting arrangements;
• encryption where appropriate;
• system monitoring;
• data backups;
• staff confidentiality obligations;
• supplier due diligence;
• contractual controls with processors;
• incident management procedures; and
• periodic review of security practices.

No online platform, email system or internet transmission can be guaranteed to be completely secure. You should take care when deciding what information to share online or through electronic communications.

15. Your data protection rights

Subject to applicable law and certain conditions, you may have the following rights:

• Right to be informed about how your personal data is used;
• Right of access to obtain a copy of your personal data;
• Right to rectification of inaccurate or incomplete data;
• Right to erasure in certain circumstances;
• Right to restrict processing in certain circumstances;
• Right to data portability in certain circumstances;
• Right to object to certain processing, including processing based on legitimate interests and direct marketing;
• Right to withdraw consent where processing is based on consent;
• Right not to be subject to certain solely automated decisions that produce legal or similarly significant effects; and
• Right to complain to a supervisory authority.

These rights are not absolute and may be subject to exemptions or limitations under data protection law.

16. How to exercise your rights

To exercise your data protection rights, please contact us using the details below:

Email: info@sparkbusinessconnections.com
Phone: +353 1 44 33 944
Address: Spark Business Connections, Slua Ventures Limited, 13 Herbert Place, Dublin 2, D02 YD32, Ireland

We may ask you to provide information to verify your identity before responding to a request.

We will respond to valid requests within the timeframe required by law, normally within one month. In some cases, this period may be extended where permitted by law, for example where a request is complex or where we have received multiple requests.

17. Direct marketing preferences

You can opt out of marketing communications at any time by:

• clicking the unsubscribe link in a marketing email;
• following preference management instructions included in the communication; or
• contacting us at info@sparkbusinessconnections.com.

Opting out of marketing does not prevent us from sending necessary service communications, such as membership, event, payment, security or legal notices.

18. Complaints

If you are unhappy with how we handle your personal data, please contact us first so that we can try to resolve the issue.

You also have the right to lodge a complaint with the Irish Data Protection Commission:

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland
Website: www.dataprotection.ie

19. Children

Spark Business Connections is a professional business membership service and is not intended for children.

We do not knowingly collect personal data from children. If we become aware that a child has provided personal data to us, we will take appropriate steps to delete it unless we are legally required to retain it.

20. Automated decision-making

We do not currently use personal data for solely automated decision-making that produces legal or similarly significant effects.

We may use basic filtering, segmentation or matching tools to help manage membership applications, communications, member interests, event invitations or introductions. Any significant membership decision will involve appropriate human review.

21. Links to other websites

Our website, emails, member platform or event materials may contain links to third-party websites or services.

We are not responsible for the privacy practices, content, security or data protection standards of third-party websites or services. You should review the relevant privacy notices before providing personal data to third parties.

22. Changes to this notice

We may update this Data Protection & Privacy Notice from time to time to reflect changes in our services, legal obligations, technology, data processing activities or business practices.

Where changes are significant, we will take reasonable steps to bring them to your attention, such as by website notice, email or platform notification.

The latest version will be available on our website.

23. Contact details

For questions about this notice or how we process personal data, please contact:

Spark Business Connections
A business name of Slua Ventures Limited
13 Herbert Place
Dublin 2
D02 YD32
Ireland

Email: info@sparkbusinessconnections.com
Phone: +353 1 44 33 944