About SPARC
Privacy Statement
SPARC Executive Development and Consulting
Our Ethical Foundation
Grounded in Professional Standards
SPARC's approach to data privacy is grounded in the professional codes of ethics that govern our practice. As an ICF-credentialed coaching firm and the exclusive U.S. partner of the Academy of Executive Coaching — which holds triple accreditation from the ICF, EMCC Global, and the Association for Coaching — we are bound by two foundational codes of ethics that set the standard for confidentiality, data stewardship, and professional conduct in the coaching profession.
ICF Code of Ethics (2025)
Published by the International Coaching Federation, this code establishes ethical obligations for all ICF credential holders, including standards for confidentiality, informed consent, and the responsible use of technology and AI in coaching practice. View the full code
Global Code of Ethics for Coaches, Mentors, and Supervisors
Jointly authored by EMCC Global and the Association for Coaching, this code provides an international ethical framework for coaching, mentoring, and supervision practice, including standards for maintaining confidentiality and managing the boundaries of the professional relationship. Available via EMCC Global and the Association for Coaching
This privacy statement reflects our commitment to the principles set forth in both codes.
About Us
Who We Are
SPARC Executive Development and Consulting ("SPARC," "we," "us," or "our") operates the website sparcinsights.com. We are committed to protecting your privacy and handling your personal information with care and transparency.
Randolph, VT
Email: mathew@sparcinsights.com
Phone: (518) 253-1591
Data Collection
Information We Collect
We collect personal information in the following ways:
Information You Provide Directly
When you use our contact forms, register for programs such as the Coaching Skills Certificate, or subscribe to our newsletter, we may collect your name, email address, phone number, organizational affiliation, and any additional details you choose to share in a message or inquiry.
Payment Information
When you purchase a program or service through our online store, payment is processed through Squarespace Commerce and its integrated payment providers (such as Stripe). We do not store your full credit card number or payment credentials on our servers. Payment processors receive only the information necessary to complete your transaction.
Assessment and Coaching Engagement Data
In the course of delivering our executive coaching, leader development, and coach training services, we use third-party assessment platforms that collect and process personal information separately from our website. These include Gallup CliftonStrengths, the Leadership Circle Profile, and programs delivered in partnership with the Academy of Executive Coaching (AoEC).
When you participate in an assessment or program, the relevant platform may collect your name, email address, assessment responses, and in some cases demographic information such as age, gender, and race or ethnicity. The Leadership Circle Profile, as a 360-degree assessment, also collects feedback from evaluators you or your organization have selected. Evaluator identities are kept confidential and are not disclosed in your results, with the exception of your direct manager's feedback, which is identified by role.
This assessment data is collected, stored, and processed by the respective platform provider. SPARC receives access to your results in order to support your coaching or development engagement. Each platform maintains its own privacy policy governing how your data is handled (see "Third-Party Services" below).
Information Collected Automatically
When you visit our website, certain information is collected automatically through cookies and similar technologies, including your IP address, browser type, operating system, referring URL, pages visited, and time spent on the site. This information is collected through Squarespace Analytics and Google Analytics.
Data Use
How We Use Your Information
We use the information we collect for the following purposes:
- Responding to your inquiries and contact form submissions
- Processing program registrations and payments
- Sending our newsletter and occasional updates about SPARC programs and services (only when you have opted in)
- Understanding how visitors use our website so we can improve its content and functionality
- Facilitating assessments and development programs through third-party platforms
- Sharing participant data with accrediting bodies (ICF, EMCC Global, and the Association for Coaching) as required for program accreditation and credentialing
- Fulfilling legal and regulatory obligations
We do not sell, rent, or trade your personal information to third parties for marketing purposes.
Tracking
Cookies and Tracking Technologies
Our website uses cookies and similar technologies to support site functionality and analytics.
Essential Cookies
These are required for the website to function properly, including session management and security features provided by Squarespace.
Analytics Cookies
These help us understand how visitors interact with our site. We use Squarespace Analytics and Google Analytics, which collect anonymized usage data such as pages viewed, session duration, and general geographic location. Google Analytics may set its own cookies; you can learn more about Google's data practices at google.com/policies/privacy/partners.
How to Manage Cookies
Most web browsers allow you to control cookies through their settings. You can choose to block or delete cookies, though this may affect your experience on our site. Where required by the ePrivacy Directive or similar regulations, our website presents a cookie consent banner that allows you to accept or decline non-essential cookies before they are placed on your device.
Partners & Platforms
Third-Party Services
We use the following third-party services in connection with our website and professional services:
Squarespace
Hosts our website and provides built-in analytics, form handling, and commerce functionality. Privacy policy
Google Analytics
Provides website traffic analysis. Data collected is used solely to understand site usage patterns. Privacy policy
Google Fonts
May be loaded on our site to display web typography. When your browser requests these fonts, Google may receive your IP address. Google's privacy policy applies.
Apple iCloud
Used in connection with certain business operations. Privacy policy
Payment Processors
Such as Stripe, integrated through Squarespace Commerce. These processors are PCI-DSS compliant and receive only the information necessary to process your payment.
Gallup CliftonStrengths
Used as part of our leadership development services. Your name, email address, and assessment responses are collected and stored by Gallup. Results remain on Gallup's platform until you request removal, and you may control sharing settings through your Gallup account. Privacy statement
Leadership Circle Profile
Used as part of our executive coaching and leader development services. The platform may collect your name, email, assessment responses, and demographic information including age, gender, and race or ethnicity. This demographic data is considered "special category data" under GDPR and is collected only with explicit consent. Evaluator feedback is anonymized, with the exception of the direct manager role. Where SPARC administers this assessment on behalf of a sponsoring organization, the engagement agreement addresses the basis for processing this sensitive data. Privacy notice
Academy of Executive Coaching (AoEC)
Our partner for accredited coach training programs. Your contact details and program participation data may be shared with the AoEC and accrediting bodies — the International Coaching Federation (ICF), the European Mentoring and Coaching Council (EMCC Global), and the Association for Coaching (AC) — for program accreditation and credentialing. Privacy statement
Zoom
Used for virtual program delivery and meetings. Zoom may collect your name, email address, IP address, and device information. Privacy statement
Customer Relationship Management (CRM)
SPARC uses a CRM platform to manage client relationships, communications, and program records. Information stored may include your name, email, phone number, organizational affiliation, and records of your engagement with SPARC services. Access is limited to authorized SPARC personnel.
Accrediting Bodies
Participant data from SPARC's accredited programs may be shared with the International Coaching Federation (ICF), EMCC Global, and the Association for Coaching (AC) for program accreditation, credential verification, and audit compliance. These organizations maintain their own privacy policies.
We encourage you to review the privacy policies of these third-party services, as their practices are governed by their own policies rather than ours.
Our Commitment
Confidentiality
SPARC takes seriously its obligation to protect the privacy and confidentiality of all client information, including assessment results, coaching conversations, and evaluator feedback. Assessment results are shared only with the individual participant and, where applicable, with the sponsoring organization as agreed upon at the outset of the engagement. In multi-rater assessments such as the Leadership Circle Profile, individual evaluator identities are never disclosed to the participant. All SPARC coaches and practitioners are bound by the ethical standards of the International Coaching Federation, which include strict confidentiality requirements.
Retention
Data Retention
We retain your personal information only for as long as is necessary to fulfill the purposes described in this statement, or as required by law. Coaching and assessment engagement records are retained for up to seven years following the conclusion of the engagement, consistent with professional liability and tax record requirements. Contact form submissions and email inquiries are retained for the duration of our business relationship and a reasonable period thereafter. Payment records are retained for up to seven years as required for accounting and tax purposes. Newsletter subscriber information is retained until you unsubscribe. Assessment data held on third-party platforms (Gallup, Leadership Circle, AoEC) is subject to each platform's own retention policies as described in the "Third-Party Services" section.
Your Privacy
Your Rights
Depending on your location, you may have certain rights regarding your personal information.
For All Visitors
You may request access to the personal information we hold about you, ask us to correct inaccurate information, request deletion of your personal information, and unsubscribe from our newsletter at any time using the link provided in each email.
Additional Rights for Visitors in the EEA and United Kingdom
Under the General Data Protection Regulation (GDPR), you also have the right to request restriction of processing of your personal information, object to processing based on legitimate interests, request a portable copy of your data in a structured, commonly used format, withdraw consent at any time where processing is based on consent, and lodge a complaint with your local data protection supervisory authority (such as the Information Commissioner's Office in the UK or the relevant authority in your EEA member state).
Legal Basis for Processing (GDPR)
Where GDPR applies, we process your personal information on the following legal bases. We rely on your consent when you subscribe to our newsletter or submit a contact form. We rely on contractual necessity when processing payments and delivering programs you have registered for. We rely on legitimate interests when analyzing website usage to improve our services, supporting the effective delivery of contracted coaching and development services, and maintaining professional accreditation records, provided these interests do not override your rights. We rely on legal obligations when retaining records as required by applicable law.
Exercising Rights with Third-Party Assessment Platforms
In addition to the rights you may exercise with SPARC, you may also exercise data rights directly with the third-party platforms used in our services. Gallup allows you to manage your CliftonStrengths sharing settings and request data deletion through your Gallup account. Leadership Circle and the AoEC each support individual rights requests in accordance with GDPR. Contact information for each platform is available through the privacy policy links provided in the "Third-Party Services" section above.
Protection
Data Security
We take reasonable administrative, technical, and organizational measures to protect your personal information from unauthorized access, loss, misuse, or alteration. Our website is served over HTTPS, and payment processing is handled by PCI-DSS compliant providers. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.
Minors
Children's Privacy
Our website and services are not directed at individuals under the age of 16. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take steps to delete that information.
International
International Data Transfers
SPARC is based in the United States. If you access our website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country. By using our website, you acknowledge this transfer. Where GDPR applies, we will ensure appropriate safeguards are in place for any transfer of personal data outside the EEA.
Technology
Use of AI Tools
SPARC may use artificial intelligence tools to support business operations, content development, and administrative efficiency. Any use of AI tools is subject to our confidentiality obligations and internal security practices. Client data is not entered into publicly accessible AI systems, and any AI tools used in connection with client work are selected with data privacy and confidentiality as primary considerations. SPARC does not use AI for automated decision-making that produces legal effects or significantly affects individuals.
Where the stakes are real.
Contact Us
If you have questions about this privacy statement or how we handle your personal information, we welcome the conversation.
Connect with SPARC.We may update this privacy statement from time to time to reflect changes in our practices or applicable law. When we make material changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this statement periodically.