Privacy Policy

This Privacy Policy (together with our Terms and Conditions and any other documents referred to on it describes how Spark Global t/a Simera Ltd. at 3rd Floor, 14 Hanover Street, Hanover Square, London W1S 1YH, United Kingdom (“Spark Global t/a Simera Ltd ”, “we’, “us”) will process any personal data we collect from you, or which  you provide to us, in the course of using (the “Website”) and any other existing or future Simera services to which you are granted access (the “Services”). Our white-label Community Marketplace platform working in Partnership with Harrow Council is (the "WebSite"). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Data Protection Act 1998 (the "Act")

We make every effort to ensure that our practices, procedures and systems comply with the relevant data protection legislation and we are registered as a data controller for the purposes of the Act (Registration Number: Z1559617). We shall only use your personal data in accordance with the legal requirements, principles and best practice recommendations of the Act, which grants you various rights in respect of the processing of your personal data. For more details about your rights under the Act, the rules we have to adhere to in collecting and storing your information, and how you can check your data records, please visit . You have a right to receive a copy of the information we hold about you by sending your request in writing, together with an administration fee of £10, to us at c/o Spark Global t/a Simera Ltd. at 3rd Floor, 14 Hanover Street, Hanover Square, London W1S 1YH, United Kingdom, United Kingdom.


When you access the Website or use our platform, there are a number of ways in which you provide information and other data to us. In order to use the Site, you must first complete the registration form and all details required in it. During registration you are required to give your contact information (such as name and email address) including your PostCode to verify if you are resident and/or Local Business based in Harrow Borough. This information is used to contact you about those deals & products on the Site in which you have expressed an interest. It is optional for you to provide other demographic information, including that relating to your social networks which will enable us to access publicly available data, but this is encouraged so we can provide a more personalised experience of the Site. You may also be asked to provide optional personal information so that we can profile the type of services that are relevant for you.

By accessing the Website or using the Services, you consent to us processing and collecting this data, on the terms and for the reasons which are explained below.


Once you have closed your account, we will delete all your stored information within 28 days, unless we require it to close business. Your email address will, however, be retained to stop users from setting up a second account using the same email address. We will not use your email address for any other purposes such as communicating with you once you have closed your account or future marketing purposes for us or any third parties.


As is true of most websites, it will be possible to gather information about your computer or device such as your IP address, browser type, referring/exit pages, and operating system. This information may be used to:

  • drive future product development in line with customer platform and technology use;
  • respond to customer service requests;entertainment, travel, gifts & electronics
  • send out a newsletter or occasional product alerts or marketing communications;
  • improve the Website or Services and our marketing efforts; and/or
  • respond to your questions and concerns.
Certain features of the Website (such as uploading or downloading content) may need to access information on your computer or device in order to work. By using such functionality, you consent to Simera accessing your device and information. If we can, we will ask you before the Website accesses your device or information.


You have the ability to view and amend the personal data that we hold about you through our website. In addition you have the right to ask for a copy of any personal information that we hold about you, to correct any inaccuracies and to update any out-of-date information. You can also ask us not to send you direct marketing communications (however please note that we may continue to send you service-related (i.e. non-marketing) communications whilst you hold an account with Harrow Deals). You can manually delete any information on your account except the email address. Alternatively, you can terminate your account and all details will be deleted after 7 days except the email address. If you wish to exercise any of these rights, or wish to object to our use of your personal information, please write to us at [email protected] and [email protected] . If you wish to know how we use your information then contact us on [email protected]


Except as described below, we will not share your information with any third parties.
We may disclose the information you provide us:

  • to any of our group companies (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 736 of the UK Companies Act 1985);
  • as required by law, any applicable regulation to protect the rights, property, or safety of ourselves or others. This may include disclosing to other companies and organisations in connection with fraud protection and credit risk reduction;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • if we are involved in a merger, acquisition, or sale of all or a portion of its assets, to any prospective seller or buyer of all (or part of) our business or assets. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information;
  • in cases where you follow links from our Website to other banks to create bank accounts with them. The information about your bank account in these circumstances will only be accessible by the bank and by us;
  • You can always unsubscribe it after logging-in via Your Account by clicking the Communication Preferences section.
While we do not intend to pass your information to a third party for them to use in their own direct marketing, in any event we will never do so without your express consent.
Please note that if you click on, or follow, any links from the Website or our deals or products to external deals websites, our privacy policy will no longer apply. Please check the privacy policies of any such external website or app before submitting any personal data, as we cannot accept any responsibility or liability in relation to them.


The security of your personal information is important to us. All information you provide to us is stored on our secure servers. Data is stored with Rapid Switch (company of iomart Hosting Ltd) on servers based in the UK. Any payment transactions will be encrypted using COMODO encryption. We will retain your information for as long as your account is active or as needed to provide you services via the Website or our Services. Once your account has been deleted, we will only retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you wish to cancel your account or request that we no longer hold your personal information, contact us at [email protected].

Information Collection and Use

We are committed to protecting the privacy of the users of our Website. We are the sole owner of the information collected on the Website. We will not sell, share, or rent this information to others in ways different from those disclosed in this statement. We collect information from you at several different points on the Website, and may collect information from other companies, such as demographic and navigation data and information and data about you available on other websites or databases. By submitting your information you consent to the use of that information as set out in this policy. If we change our privacy policy we will post the changes on this page, and may place notices on other pages of the Site/Mobile Product, so that you may be aware of the information we collect and how we use it at all times. Continued use of the Site/Mobile Product will constitute your agreement to any such changes. When you submit personal information in connection with making a payment via the Site, such personal information is encrypted and protected with encryption software which lets your browser automatically encrypt data before you send it to us. While on a secure page the lock icon on the bottom of Web browsers such as Netscape Navigator and Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when you are just ‘surfing’. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy however the data we collect from you may be transferred to our platform development partners who are located or maintain facilities, including destinations outside the European Economic Area (“EEA”). By providing information to the Site/Mobile Product you expressly consent to such information being transferred or stored outside of the EEA. Unfortunately, the transmission of information via the internet is not completely secure and although we take all reasonable steps to protect your personal data, we cannot guarantee the security of it. Any transmission of personal data to the Site is at your own risk.


We may contact you from time to time about Harrow Deals platform, including marketing messages relating to our products and services, in line with your marketing contact preferences. We will do this electronically, for example by email.

Our council partner’s (Harrow Council) may actively contact you about the deals and products of specially selected parties that may be of interest to you, in line with your marketing contact preferences. However, we may contact you with such information about the deals and products from time and again. All such communications will come from Spark Global t/a Simera Ltd.

You may tell us at any time if you do not wish to receive marketing messages from us by contacting us at [email protected] or by following any unsubscribe instructions we may include in the email messages we send to you.

Registered users may also contact Spark Global via support tickets under Your Account section after logging in to the platform.


The Website may make use of location data sent from your mobile device. You can turn off this functionality at any time by turning off the location services settings for Harrow Deals on your mobile device. If you use these services, you consent to us and our partners’ and licensees’ transmission, collection, maintenance, processing and use of your location data and queries to provide and improve location-based and road traffic-based products and services. You may withdraw this consent at any time by turning off the location services setting on your mobile device.


We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Website prior to the change becoming effective. We encourage you to periodically review the Website for the latest information on our privacy practices.

This Privacy Policy and all changes made hereto as described in the previous paragraph remains effective unless and until we inform you otherwise via a push notification through the Website, through email (sent to the e-mail address specified in your account) or by means of a notice on our website [email protected] prior to the expiration of this Privacy Policy.


Information about our use of cookies

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer (if you consent to us using cookies). Cookies contain information that is transferred to your computer's hard drive.

The Website, our third party service providers, advertisers and partners may use cookies to enhance your online experience of using the Website and distinguish you from other users of the Website. Such use of cookies also allows us to improve the Website.

Types of Cookies

Essential cookies

These cookies let you use the different parts of the Website. Without them services that you want cannot be provided.
Some examples of how we use these cookies are:

  • Signing into an account on the Website;
  • Remembering previous actions such as text entered into a registration form when navigating back to a page in the same session;
  • Remembering security settings which restrict access to certain content e.g. to help with parental control cookies.
Functional Cookies

These help us to personalise the Website to you. For example, remembering your preferences and settings so that we will remember them using functional cookies to give you [options/ information]on the Website personalised to you.
Some examples of these cookies are:

  • Flash cookies, which are stored on your hard drive, not your browser. These are useful for things e.g. pausing something;
  • Remembering if you visited the Website before so that messages for new visitors to the Website are not displayed to you when you return to the Website;
  • Remembering settings applied to the Website such as colour, font size and layout.
Performance Cookies

These help us understand how people are using the Website, so we can make it better and allow us to try new things to improve your experience on the Website. The information gathered does not identify any individual and is aggregated.
Some examples of how we use these cookies are:

  • To collect information about which web pages visitors go to most often so we can improve the online experience;
  • To collect information about the platforms that referred visitors to our Website;
  • Error management to make sure that the Website is working properly;
  • Testing designs to help improve the look and feel of our Website.

We use this information to help run our Website more efficiently, to gather broad demographic information and to monitor the level of activity on our Website.

Content Sharing and Social Networking Cookies

These cookies enable users to share pages and content through third party social networking and other platforms. The companies that serve these cookies may also use your information to serve targeted advertising on other platforms.

Blocking Cookies

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Website.
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit or
Except for essential cookies, all cookies will expire after 365 days.
By accessing the Website, you consent to our use of cookies as described above.

Updating/Removal of Personal Information

If any information regarding you requires to be corrected, updated or changed it is your responsibility to advise us of the required amendments. If you inform us that you no longer desire our service, we shall correct, update or remove your personal data provided to us. Please note, an archive copy of any information provided to us may be retained by us for our records and for audit purposes.


If you have any questions or comments about this Privacy and Cookie Policy, you can contact us by email at the following email address: [email protected]. You can also use this address if you wish to request a copy of the personal data we hold about you.

Last updated on : 16th May, 2018