PARTICIPANT PRIVACY NOTICE

This Participant Privacy Notice explains how MANAGEMENT SPARK uses your personal data when you are a Participant.


ABOUT US
Reference to "MANAGEMENT SPARK, we, us, our” in this Notice refers to MANAGEMENT SPARK BVBA. We are committed to treating your data fairly and transparently. We encourage you to contact us if you have any questions about this Notice.

ABOUT PARTICIPANTS
You are a Participant taking part in development, research or recruitment services that we offer. We ask you to sign in to your account and complete tasks, such as questionnaires about yourself and others. We may provide services to you at your own request or on behalf of the person who sponsors you to take part in our services, such as your employer.

DATA COLLECTED AND RECEIVED ABOUT YOU
We collect and receive the following types of data about you:

- “Task Data” – we ask that you share some data from your Participant Profile, including your name, email and gender pronoun preferences. We may also ask you for additional data during the task. For example, questions about your workplace performance, psychological preferences, competencies and responses to stress. We may also gather data about you from others. For example, a feedback questionnaire about you completed by your colleagues.
- “Other Participant Data” – we gather data about you necessary for you to use our services. For example, your sponsor may provide your contact details to us or you may interact with us via other methods, such as email.

HOW YOUR DATA IS USED
We collect your data for the following purposes:
- To provide services to you and your sponsor.
- To produce personalised reports and other analysis of your data.
- To respond to your requests.
- To provide you with communications relating to your tasks.
- To research, analyse and enhance our products and services, including to avoid bias and discrimination. 
- To conduct customer and market research.
- To support the maintenance, enhancement and security of our systems.
- For legal reasons, including our record keeping, to defend legal claims, comply with legal obligations and to prevent fraud and other illegal or harmful activities.

We process your data based on your consent. You have the right to withdraw your consent at any time and we will erase this data.

For details about how to exercise your rights, see ‘How to Exercise Your Data Rights’. 

HOW YOUR DATA IS SHARED

We share your data with some third parties with your consent:
- Team activities – when you complete tasks as part of a group activity, we may share your name and a basic summary of the results of your task with the group. For example, the group of people who take part in the same workshop as you.
- Feedback tasks about others – when you complete a task about another person we may share your name and your feedback with that person.
- Your sponsor – when you complete a task at the request of a sponsor, such as your employer or recruiter, we may share your data with that person. 

We also share your data with other third parties. We only share data where there are appropriate safeguards.
- The Lumina Learning Network – Lumina Learning LLP and other third parties who are typically termed ‘Lumina Learning Partners’, ‘Lumina Learning Strategic Alliances’ or ‘Lumina Learning Associates’ or ‘Lumina Learning Practitioners’. These third parties represent our business globally and perform some of our purposes on our behalf.
- Professional and service providers – third parties that help us run our business. For example, providers of tools like helpdesk software and providers of professional advice like legal, accounting and consultancy services. 
- Business sale or change of control – if the ownership of all or part of our business changes or if we enter administration, your personal data may be shared with the other parties involved. This includes where we take preparatory steps in connection with such activities.
- Legal obligations and defence of legal claims – we may share your data where we are subject to a legal obligation or if necessary to defend a legal claim against us.

INTERNATIONAL TRANSFERS OF YOUR DATA
Some third parties we share your data with are outside the European Economic Area (EEA).
We share data only when there are appropriate safeguards. Where possible, we use third parties located in countries that the EU Commission has approved as providing adequate safeguards, or third parties taking part in EU Commission approved schemes, such as the EU-U.S. Privacy Shield Framework. Where these options are not available, we ensure adequate safeguards by using model contract clauses provided by the EU Commission.

AGE LIMIT
Where you are under the age of 18, you can only take part in our services with the permission of your guardian. Please contact us and we will arrange to obtain this permission.

RETENTION OF YOUR DATA
We retain your data for as long as necessary for the purposes it is collected for. You always have the option to exercise your data rights.

HOW TO EXERCISE YOUR DATA RIGHTS
You have the right to access, rectify, port and in some cases erase your personal data.

We process your data based on your consent, meaning you have the right to withdraw your consent at any time and we will erase your data.

To exercise your rights, please contact us using the details below.

UPDATES TO THIS NOTICE
We may update this Notice from time to time. We will post updates here and notify you of any changes that materially affect you. 

COMPLAINTS
If you have concerns about how we have handled your personal data, you have the right to complain to a supervisory authority, including your local supervisory authority and our local supervisory authority: Commissie voor de bescherming van de persoonlijke levenssfeer. 

We encourage you to contact us directly to resolve issues using the contact details below. We commit to resolving your issue wherever possible.

CONTACT US
To contact us, please email tinne@managementspark.com