Privacy Policy

Who we are and what this policy covers

Welcome to the Privacy Policy of Certainly Stuff Ltd, trading as Wildfire ("Wildfire", "we", "us", or "our").

We are committed to protecting your privacy and your personal data in compliance with the United Kingdom General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 ("PECR"), the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), and other applicable data protection and privacy laws.

This Privacy Policy explains how we collect, use, and protect personal data in the following contexts:

• visits to and interactions with our website at getwildfire.gg and its subdomains, excluding spark.getwildfire.gg (the "Site");
• marketing communications, newsletters, and sales contacts sent or received by us;
• mobile messaging (SMS and WhatsApp) services where you have opted in;
• brand, agency, and community-partner relationships managed outside the Spark platform.

This policy does not cover:

• the Spark SaaS application, which is the subject of a separate privacy policy made available within the Spark application and to Spark account holders directly;
• the collection of personal data by third-party platforms on which Wildfire campaigns may run (including but not limited to Discord, Reddit, and other community platforms), each of which operates under its own privacy policy and terms of service;
• the practices of brands, agencies, or community partners with whom we contract.

Certainly Stuff Ltd is the data controller responsible for personal data processed under this Privacy Policy.

• Email: info@getwildfire.gg
• Post: Certainly Stuff Ltd, Old Pockford, Vann Lane, Chiddingfold, Godalming, GU8 4XU, United Kingdom

You have the right to lodge a complaint with the UK Information Commissioner's Office ("ICO") at any time. We would, however, appreciate the opportunity to address your concerns first. Residents of the European Economic Area may contact their local supervisory authority. Residents of US states with applicable privacy laws may exercise their rights as described in section 11 below.

"Personal Data" means any information relating to an identified or identifiable individual. We may collect, use, store, and transfer the following categories of personal data; not every category will be collected from every individual.

We do not knowingly collect through this Site:

• special category personal data (data revealing racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health data, or data concerning sex life or sexual orientation);
• information about criminal convictions or offences;
• personal data of individuals under the age of 18 (see section 13).

If you provide us with personal data about another person (for example, a colleague), you confirm that you have their permission to do so and that they have been informed of this Privacy Policy.

We will only process your personal data where we have a lawful basis to do so. The bases we rely on are set out below.

Where we rely on legitimate interests, we will balance our interests against yours and tell you what those interests are, where required.

The principal purposes for which we use your personal data, and the legal bases we rely on, are set out in the table below.

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another compatible purpose. If we need to use your personal data for an unrelated purpose, we will notify you and explain the lawful basis on which we can do so.

You may choose to receive Wildfire campaign and event alerts by mobile message. Where you do so:

1. Opt-in and verification. You provide your mobile number, complete a CAPTCHA challenge, and verify ownership by entering a one-time code (valid for ten minutes). The code is stored only as a cryptographic hash.
2. Types of messages. Transactional alerts about campaign launches, milestones, or essential service notices. We will not send marketing content by SMS or WhatsApp unless you separately opt in to receive it.
3. Legal basis. Processing relies on your explicit consent under Article 6(1)(a) UK GDPR and applicable provisions of PECR. For US residents, processing complies with the Telephone Consumer Protection Act ("TCPA") and equivalent state law.
4. Opt-out. You can disable mobile messaging at any time by replying STOP to any message, using the unsubscribe link in any message, or emailing us. We will honour opt-out requests within 24 hours.
5. Third-party messaging provider. Messages are delivered by Twilio Inc. Your phone number and message metadata are shared with Twilio solely for this purpose under Standard Contractual Clauses.
6. Carrier charges. Message and data rates may apply, as imposed by your mobile carrier.
7. Retention and security. Verified numbers are stored encrypted at rest and are deleted or anonymised within thirty days of opt-out or account deletion.

Our Site uses cookies and similar technologies to operate and improve our services. A cookie is a small text file placed on your device when you visit a website.

We use the following categories of cookies:

• Strictly necessary cookies. Required for the Site to function (for example, security and load balancing). These cannot be disabled without breaking core functionality.
• Analytics cookies. Help us understand how visitors use the Site so we can improve it (for example, Google Analytics).
• User-experience cookies. Help us understand how visitors interact with specific pages (for example, Hotjar heatmaps and session recordings).
• Marketing cookies. We do not currently use third-party advertising cookies on the Site. If this changes, we will update this Privacy Policy and seek your consent before deployment.

You can manage non-essential cookies through the cookie banner shown on first visit, by adjusting your browser settings, or by visiting the relevant third-party opt-out pages. Disabling cookies may affect Site functionality.

The following third-party service providers process personal data on or through this Site. Where personal data is transferred outside the UK or EEA, we rely on the safeguards described in section 9.

We may engage additional service providers from time to time. Where we do so and where their processing materially changes the picture described above, we will update this Privacy Policy. Sub-processors used by the Spark platform are disclosed in the separate Spark privacy policy.

Your personal data may be processed in countries outside the United Kingdom and the European Economic Area, including the United States. Where we transfer personal data outside the UK or EEA, we rely on one of the following safeguards:

• an adequacy decision by the UK government or the European Commission;
• the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or the EU Standard Contractual Clauses, as appropriate;
• the UK-US Data Bridge or the EU-US Data Privacy Framework, where the recipient is certified;
• other lawful safeguards permitted by applicable law.

Copies of the safeguards in place are available on request to info@getwildfire.gg.

You have the following rights in relation to your personal data:

• Right to be informed about how we use your personal data, which is what this Privacy Policy is for.
• Right of access to your personal data (commonly known as a "data subject access request").
• Right to rectification of inaccurate or incomplete personal data.
• Right to erasure of your personal data in certain circumstances ("right to be forgotten").
• Right to restrict processing of your personal data in certain circumstances.
• Right to data portability, allowing you to obtain and reuse your personal data in a structured, commonly used, and machine-readable format.
• Right to object to certain processing, including direct marketing and processing based on legitimate interests.
• Rights in relation to automated decision-making and profiling. We do not use automated decision-making with legal or similarly significant effects in connection with this Site.

To exercise any right, please email info@getwildfire.gg. We will respond within one month of receiving your request, although we may extend this period by a further two months in complex cases (in which event we will inform you within the first month).

You also have the right to lodge a complaint with the ICO (ico.org.uk) or your local EEA supervisory authority. We would appreciate the opportunity to address your concerns first.

This section applies to residents of US states whose privacy laws grant rights in relation to personal information, including California, Colorado, Connecticut, Utah, Virginia, Texas, and others as applicable from time to time. The rights described below are summarised; the precise scope of each right depends on the law of the state in which you reside.

Categories of personal information collected and disclosed

In the 12 months preceding the date of this Privacy Policy, we have collected the categories of personal information described in section 3 above. We have disclosed personal information for business purposes to the service providers listed in section 8.

Sources of personal information

We collect personal information directly from you, from your interactions with our Site and communications, and from service providers acting on our behalf.

Purposes of processing

We process personal information for the purposes described in section 5 above.

Sale and sharing of personal information

We do not sell personal information, and we do not share personal information for cross-context behavioural advertising as those terms are defined under CCPA/CPRA. We have not done so in the 12 months preceding the date of this Privacy Policy.

Your rights

Where applicable under your state's law, you have the right to:

• Know what personal information we collect about you, how we use it, and to whom we disclose it.
• Access a copy of the personal information we hold about you.
• Correct inaccurate personal information.
• Delete personal information we have collected from you, subject to permitted exceptions.
• Opt out of the sale or sharing of personal information (noting we do not sell or share, as described above).
• Limit the use and disclosure of sensitive personal information. We do not collect sensitive personal information through this Site.
• Non-discrimination in connection with exercising your rights.
• Appoint an authorised agent to make a request on your behalf.

How to exercise your rights

To make a request, email info@getwildfire.gg with the subject line "Privacy Rights Request" and identify the state in which you reside. We may need to verify your identity before responding. We will respond within the timeframes required by applicable law.

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy or as required by law. Typical retention periods are:

• Marketing contacts: for as long as you remain subscribed, plus up to 24 months thereafter for suppression list purposes.
• Customer and partner contacts: for the duration of the business relationship plus up to seven years thereafter for accounting, tax, and limitation-period purposes.
• Mobile messaging numbers: deleted or anonymised within 30 days of opt-out or account deletion (see section 6).
• Site analytics data: retained in identifiable form for up to 26 months and aggregated or anonymised thereafter.
• Recruitment enquiries: for up to 12 months from the date of application unless you consent to longer retention.

Where personal data is no longer required, we will securely delete or anonymise it.

This Site is directed exclusively at business contacts and is intended for use by individuals aged 18 or over in a professional capacity. We do not knowingly collect personal data from anyone under the age of 18 through this Site.

More broadly, Wildfire's services are not directed at children under the age of 13. We do not knowingly collect, use, or disclose personal data from children under 13. Where campaigns delivered through Wildfire's network reach platforms that may include older minors (13 and above), we operate within the age and content policies of those platforms and require, by contract, that participating brands and community partners do not target children under 13 and apply age-appropriate content and consent practices in line with applicable law (including the Children's Online Privacy Protection Act in the United States and the UK Age Appropriate Design Code).

If you believe that we have inadvertently collected personal data from a person under the relevant age threshold, please contact us at info@getwildfire.gg and we will take prompt steps to delete the data.

We employ technical and organisational measures appropriate to the risk of processing, including:

• encryption in transit (TLS) and at rest for sensitive data stores;
• least-privilege access controls and role-based authentication;
• multi-factor authentication for administrative accounts;
• regular security testing, including periodic penetration testing of our infrastructure;
• staff training on data protection and information security;
• a documented incident response process.

No method of transmission or storage is 100% secure. If you believe your interaction with us is no longer secure, please contact us immediately at info@getwildfire.gg.

Our Site may include links to third-party websites, plug-ins, and applications. Clicking those links or enabling those connections may allow third parties to collect or share data about you. We do not control those sites and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.

We keep this Privacy Policy under regular review. Updates will be posted on this page with a new "Last Updated" date. Where changes are material, we will notify you by appropriate means (which may include email or a prominent notice on the Site). Continued use of the Site after a change has taken effect constitutes acceptance of the revised Privacy Policy.

If you have any questions about this Privacy Policy or our data protection practices, please contact us:

• Email: info@getwildfire.gg
• Post: Certainly Stuff Ltd, Old Pockford, Vann Lane, Chiddingfold, Godalming, GU8 4XU, United Kingdom