Privacy Policy

Last updated: 20 May 2026

This Privacy Policy explains how Kula as trading name of Spark Growth Ltd ("Kula", "we", "us" or "our") collects, uses, shares and protects personal data when you use the platform available at joinkula.co.uk and any associated services (together, the "Platform").

We are the data controller for the personal data described in this policy.

Because we operate in both the UK and the EU/EEA, we comply with the UK GDPR, the EU GDPR and the Data Protection Act 2018.

1. Who this policy applies to

Kula is a platform where content creators, talent agencies, brands and media agencies come together to write briefs, source creators, and produce content for advertising campaigns. This policy applies to all of these users, as well as to visitors to our website. Where different rules apply to different types of user, we say so.

2. The personal data we collect

We collect the following categories of personal data:

Information you give us when you register and use the Platform

  • Identity and contact details: name, email address, phone number, job title, and the organisation you represent.
  • Account credentials: username and a securely hashed password.
  • Profile information: for creators, this includes your portfolio, content samples, areas of specialism, rates, social media handles and audience information you choose to share.
  • Brief and campaign information: the briefs you write, proposals you submit, messages you exchange with other users, and details of campaigns you participate in.

Payment information

  • When payments are processed between parties on the Platform, we and our payment processor collect billing details and transaction records. Card and bank details are handled directly by our payment processor and are not stored by us in full. See section 6.

Information we collect automatically

  • Technical data: IP address, browser type, device information, operating system and time zone.
  • Usage data: pages visited, features used, and how you interact with the Platform.
  • Cookies and similar technologies: see section 9.

Information from third parties

  • Where you sign in or connect through a third-party service (for example a social media account), we receive limited information from that service in line with your settings there.

We do not intentionally collect special category data (such as health, ethnicity or political opinions). Please do not submit such data through free-text fields unless necessary.

3. How and why we use your data

We use personal data only where we have a lawful basis to do so under data protection law. The table below sets out our purposes and the corresponding lawful basis.

A note on AI matching

We use automated tools to help match creators to briefs and to surface relevant opportunities. These tools support human decision-making and are not used to make decisions producing legal or similarly significant effects about you without human involvement. You can contact us at any time to ask how a particular match was generated.

Where we rely on legitimate interests

Where we rely on legitimate interests, we have weighed our interests against your rights and freedoms. You can ask us for more detail about this balancing assessment, and you have the right to object (see section 10).

4. Marketing

If you have opted in, or where the law otherwise permits, we may send you marketing about Kula features, opportunities and updates. You can opt out at any time by clicking "unsubscribe" in any marketing email or by contacting us. Opting out of marketing does not stop service messages that are necessary to operate your account.

5. How we share your data

Kula is a collaborative platform, so some sharing between users is inherent in how it works:

  • Between users: when you write a brief, submit a proposal, share a portfolio or message another party, the relevant information is shared with the users you are collaborating with. Creator profiles and content you publish are visible to brands, agencies and other relevant users.
  • Service providers (processors): we use trusted third parties to run the Platform, including hosting, payment processing, email delivery, analytics and customer support. They act on our instructions under written contracts and may only use your data as we direct.
  • Professional advisers and authorities: we may share data with advisers, regulators or law enforcement where required by law or to protect our rights.
  • Business transfers: if Kula is involved in a merger, acquisition or sale of assets, your data may be transferred as part of that transaction. We will notify you of any such change.

We do not sell your personal data.

6. Payments

Payments on the Platform are processed by [PAYMENT PROCESSOR — e.g. Stripe], a third-party payment provider. When you make or receive a payment, your payment details are provided directly to the processor and handled under their own privacy policy and security standards (including PCI-DSS). We receive confirmation and transaction records but do not store full card numbers. Please review the processor's privacy policy for details of how they handle your data.

7. International transfers

Some of our service providers are located outside the UK and EEA. Where we transfer personal data internationally, we ensure an appropriate safeguard is in place, such as:

  • a UK or EU adequacy decision for the destination country; or
  • Standard Contractual Clauses (with the UK International Data Transfer Addendum where relevant); or
  • another lawful transfer mechanism.

You can contact us for a copy of the relevant safeguards.

8. How long we keep your data

We keep personal data only for as long as necessary for the purposes set out in this policy. In general:

  • Account data is kept for as long as your account is active and for a reasonable period afterwards.
  • Transaction and payment records are kept for at least six years to meet legal and tax obligations.
  • Marketing data is kept until you opt out, after which we suppress your details so we do not contact you again.

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

9. Cookies

We use cookies and similar technologies to operate the Platform, remember your preferences, keep you signed in, and understand usage. Some cookies are strictly necessary; others (such as analytics and marketing cookies) are used only with your consent. You can manage your preferences through our cookie banner or your browser settings. For full details, see our [Cookie Policy] (add a link if you publish a separate cookie notice).

10. Your rights

Under UK and EU data protection law you have the right to:

  • access the personal data we hold about you;
  • request rectification of inaccurate data;
  • request erasure in certain circumstances;
  • restrict or object to certain processing, including direct marketing;
  • data portability — receive certain data in a portable format;
  • withdraw consent at any time where we rely on consent; and
  • not be subject to a solely automated decision with legal or similarly significant effects.

To exercise any of these rights, contact us at privacy@joinkula.co.uk. We will respond within one month. Exercising your rights is free in most cases, and we will not treat you differently for doing so.

11. How we protect your data

We use appropriate technical and organisational measures to protect personal data, including encryption in transit, access controls, and regular security reviews. No system is completely secure, but we work to protect your information and will notify you and the relevant regulator of a personal data breach where the law requires.


12. Children

The Platform is intended for business users and is not directed at children. We do not knowingly collect data from anyone under 18. If you believe a minor has provided us with personal data, please contact us.

13. Changes to this policy

We may update this policy from time to time. We will post the updated version here with a revised "Last updated" date and, where changes are significant, notify you directly.

14. Contact us

For any questions about this policy or your personal data, contact:

Spark Growth Ltd at The Old Church, Oxford Street, Ramsbury, Marlborough, United Kingdom, SN8 2PG.

Email: privacy@joinkula.co.uk