Legal
Cookie Policy
This Cookie Policy sits alongside and must be read together with the SparkRecall Terms and Conditions of Use and Privacy Policy. By using the Platform, you agree to our use of cookies as described in this Policy. You may withdraw or adjust your consent at any time via our Cookie Preference Centre.
1. What Are Cookies?
Cookies are small text files placed on your device (computer, tablet, or mobile phone) when you visit a website or use an application. They allow the Platform to recognise your device, remember your preferences, and collect information about how you interact with the Platform.
Similar technologies include:
- Local storage and session storage — browser-based storage used to retain session information
- Pixel tags / web beacons — small image files that track page visits and email opens
- Software Development Kit (SDK) trackers — used in mobile applications for analytics
References to "cookies" in this Policy include all such similar technologies unless otherwise stated.
2. Legal Basis for Cookie Use
Our use of cookies is governed by:
- The ePrivacy Directive 2002/58/EC as implemented by the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (Ireland)
- Regulation (EU) 2016/679 (GDPR) — for cookies that involve processing personal data
- The UK Privacy and Electronic Communications Regulations 2003 (PECR) and UK GDPR — for UK users
Strictly necessary cookies are placed on the basis of our legitimate interest in providing a functioning Platform. All other cookies require your prior, freely given, specific, informed, and unambiguous consent, which you may withdraw at any time.
3. Categories of Cookies We Use
3.1 Strictly Necessary Cookies
No Consent Required
These cookies are essential for the Platform to function. They cannot be disabled without breaking core functionality. They do not track you for marketing purposes.
| Cookie Name | Provider | Duration | Purpose |
|---|---|---|---|
| session_id | SparkRecall | Session | Maintains your login session |
| csrf_token | SparkRecall | Session | Prevents cross-site request forgery attacks |
| auth_token | SparkRecall | 30 days | Keeps you logged in between sessions |
| cookie_consent | SparkRecall | 12 months | Stores your cookie preferences |
3.2 Performance & Analytics Cookies
Consent Required
These cookies collect anonymised or pseudonymised data about how users interact with the Platform, helping us improve functionality and user experience. They do not identify you personally.
| Cookie Name | Provider | Duration | Purpose |
|---|---|---|---|
| _ga | Google Analytics | 2 years | Distinguishes unique users; anonymised |
| _ga_XXXX | Google Analytics | 2 years | Persists session state |
| _gid | Google Analytics | 24 hours | Distinguishes users |
| sp_analytics | SparkRecall | 12 months | Internal Platform usage analytics |
3.3 Functional Cookies
Consent Required
These cookies remember your preferences and personalisation choices to enhance your experience on the Platform.
| Cookie Name | Provider | Duration | Purpose |
|---|---|---|---|
| sp_prefs | SparkRecall | 12 months | Stores display and UI preferences |
| sp_lang | SparkRecall | 12 months | Remembers language preference |
| sp_theme | SparkRecall | 12 months | Remembers light/dark mode preference |
3.4 Marketing & Targeting Cookies
Explicit Consent Required — Opt-In Only
These cookies may be used to build a profile of your interests and show you relevant content or advertising. They are ONLY placed with your explicit prior consent. We do not currently operate advertising campaigns, but this section applies should we do so in future or via third-party integrations.
If at any point marketing cookies are activated, full details will be disclosed in the Cookie Preference Centre before consent is sought.
4. Third-Party Cookies
Some cookies are set by third-party services integrated into the Platform (for example, Google Analytics). SparkRecall does not control these third-party cookies. You can review the privacy and cookie policies of these providers directly:
- Google Analytics: policies.google.com/privacy
- Other third-party providers will be listed in the Cookie Preference Centre as and when they are integrated
5. Your Cookie Choices and Consent
5.1 Cookie Preference Centre
When you first visit the Platform, a cookie consent banner will appear. You may accept all cookies, reject non-essential cookies, or customise your preferences by category. Your choices are stored in the "cookie_consent" cookie for 12 months.
5.2 Withdrawing or Changing Consent
You may withdraw or change your cookie consent at any time by:
- Visiting our Cookie Preference Centre
- Clearing cookies in your browser settings (note: this will reset all preferences)
Withdrawal of consent does not affect the lawfulness of any processing carried out on the basis of consent before withdrawal.
5.3 Browser-Level Controls
Most browsers allow you to refuse or delete cookies via their settings. Please note that disabling strictly necessary cookies will impair Platform functionality. Common browser settings pages:
- Google Chrome: Settings → Privacy and security → Cookies and other site data
- Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data
- Safari: Preferences → Privacy → Manage Website Data
- Microsoft Edge: Settings → Cookies and site permissions
5.4 Opt-Out Tools
You may also opt out of certain third-party analytics cookies using:
- Google Analytics Opt-Out Browser Add-on: tools.google.com/dlpage/gaoptout
- Your Online Choices (EU): youronlinechoices.eu
- Network Advertising Initiative (NAI): optout.networkadvertising.org
6. Data Collected via Cookies
Data collected via cookies is processed in accordance with our Privacy Policy. Where cookies involve personal data, the lawful basis is either:
- Consent (Article 6(1)(a) GDPR) — for non-essential cookies
- Legitimate Interests (Article 6(1)(f) GDPR) — for strictly necessary cookies
Cookie data is retained only for the duration specified in the cookie tables above. Anonymised analytics data may be retained in aggregate form for longer periods for service improvement purposes.
7. International Transfers via Cookies
Some third-party cookies (such as Google Analytics) may result in data being transferred outside the EEA or UK. Where this occurs, appropriate safeguards apply as described in our Privacy Policy (Standard Contractual Clauses, adequacy decisions, or UK IDTAs).
8. Changes to This Cookie Policy
We may update this Cookie Policy from time to time, including as new cookies are introduced or third-party integrations change. Where changes are material, we will reset the cookie consent banner so you can review and re-confirm your preferences. The updated Policy will be posted on SparkRecall.com with a revised "Last Updated" date.
9. Contact Us
SparkRecall Limited
SparkRecall Ltd C/O LMS Accountants, Ecowise Building, Block 12, Ballybane Industrial Estate, Galway, Ireland
Email: team@sparkrecall.com
Supervisory Authorities
EU/Ireland: Irish Data Protection Commission (DPC) — www.dataprotection.ie
UK: Information Commissioner's Office (ICO) — www.ico.org.uk