Privacy Policy

Privacy Policy – Sparrow Social Limited

Introduction Social

Sparrow Social Limited (referred to as “Sparrow Social”, “we”, or “our”) is a New Zealand-based company (Company No. 9370206, NZBN 9429053134998) providing social media content creation, scheduled posting, analytics, and targeted marketing services. We operate as a white-label digital marketing agency serving clients in New Zealand and internationally. We are committed to protecting your privacy and handling personal information in compliance with the New Zealand Privacy Act 2020, the EU/UK General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA) as amended by the CPRA. This Privacy Policy explains what personal data Sparrow Social collects, how we use it, the legal bases for processing, how we protect and share data, and the rights and choices available to our clients and users. By engaging our services or using our website, you agree to the practices described in this Policy. We encourage you to read this Privacy Policy carefully.

Personal Data We Collect

We may collect personal information from you (or your business) in a few ways: directly from you, automatically through our services, and from third parties. The types of data we collect include:

  • Contact Information: Your name, company, role, email, phone, and address.

  • Marketing & Profile Information: Preferences, feedback, social media usernames, profile details, and engagement analytics.

  • Technical & Usage Data: IP address, device identifiers, browser type, pages visited, links clicked, cookies, and log data.

  • Third-Party & Partner Data: Information shared via social media platforms, business partners, or agencies providing client/customer lists.

We only collect what is relevant and necessary. We do not knowingly collect data from children.

How We Use Personal Data

We use personal data to:

  • Deliver Services: Create and manage content, run campaigns, and provide analytics.

  • Communicate & Support: Send updates, respond to inquiries, and manage accounts.

  • Marketing & Promotions: Send newsletters or promotional materials (with consent where required).

  • Analytics & Improvements: Analyze usage, improve services, and generate anonymized statistics.

  • Compliance & Legal: Meet legal obligations, prevent fraud, and protect rights.

We do not sell your personal data, and we don’t use it for automated decision-making with legal or significant effects.

Legal Bases for Processing (GDPR/UK)

We process data under these bases:

  • Consent: e.g., marketing emails or optional cookies.

  • Contract Performance: To deliver agreed services.

  • Legal Obligation: For tax, accounting, or lawful requests.

  • Legitimate Interests: Analyze usage, improve services, and generate anonymized statistics.

We do not sell your personal data, and we don’t use it for automated decision-making with legal or significant effects.

Cookies & Tracking Technologies

We use cookies, pixels, and similar tools to improve our website, analyze traffic, and run marketing campaigns.

  • Consent: Required where law mandates (e.g., EU/UK cookie banners).

  • Opt-Out: You can disable cookies in your browser or through opt-out industry sites.

  • Third-Party Cookies: Platforms like Google Analytics or Meta Pixel may place their own cookies; their policies apply.

Third-Party Services and Disclosure

We may share personal data with:

  • Service Providers: Hosting, email, payment, analytics, and marketing software partners.

  • Social Media Platforms: When managing your accounts or ads on your behalf.

  • AI & Tools: For copywriting, design, or scheduling (minimal data is shared).

  • Business Transfers: If Sparrow Social is acquired or merged.

  • Legal Requirements: When compelled by law, court orders, or to protect rights and safety.

We require all service providers to protect your data and only process it for our purposes.

Data Security

We use safeguards including encryption, access controls, monitoring, and secure hosting. If a breach occurs, we will notify affected individuals and authorities where required.

No method of storage or transfer is 100% secure, but we continually update practices to minimize risk.

Data Retention

We retain personal data only as long as needed for its purpose or as required by law.

  • Client data is kept for the duration of the relationship plus legal retention periods.

  • Prospective client and marketing data is retained until you opt out or after inactivity.

  • Analytics data is anonymized or aggregated after a reasonable period.

When data is no longer needed, we securely delete or anonymize it.

International Data Transfers

We are based in New Zealand, recognized by the EU as providing adequate protection. We may also transfer data internationally when using third-party services.

Safeguards may include:

  • Standard Contractual Clauses (for EU/UK transfers).

  • Contracts requiring recipients to meet NZ-equivalent protections.

  • Your consent or instructions.

We ensure adequate protection for all transfers.

Your Privacy Rights

Depending on your jurisdiction, you may have rights such as:

Under NZ Privacy Act:

  • Access, correction, deletion, objection to marketing, and complaint rights.

Under GDPR/UK:

  • Access, rectification, erasure, restriction, portability, objection, and withdrawal of consent.

Under CCPA/CPRA (California):

  • Right to know, delete, correct, opt out of sale/sharing, limit sensitive data use, and non-discrimination.


You may exercise these rights by contacting us.

Children’s Privacy

Our services are not directed at children under 16. We do not knowingly collect their data. If such data is found, we will delete it.

Governing Law & Complaints

This Policy is governed by New Zealand law, but we recognize rights under other jurisdictions. You may complain to:

  • NZ Office of the Privacy Commissioner.

  • EU/UK Data Protection Authorities.

  • California Privacy Protection Agency or other US regulators.

We encourage contacting us first to resolve concerns.

Changes to This Privacy Policy

We may update this Policy from time to time. Material changes will be notified via website or email. Continued use of services indicates acceptance.

Contact Us

Sparrow Social Limited

Attn: Privacy Officer

4 Motoi Place, Ngongotaha

Rotorua 3010, New Zealand

Email: henrygers@hotmail.com