PRIVACY POLICY FOR SPARKLE IVS

The aim of this privacy policy is to establish the framework for processing personal data in Sparkle IVS (hereinafter ‘Sparkle’). The privacy policy also serves to ensure ongoing control of compliance with the requirements of current legislation.

SCOPE

This privacy policy applies throughout Sparkle as well as to the cooperation partners who carry out tasks on our behalf.

The privacy policy applies to the personal data that you entrust us with when registering with Sparkle or enquiring abot our services. It also applies to the data we collect via Sparkle’s website, www.sparklesecurity.net.

Sparkle is the data controller of your personal data. All enquiries to Sparkle regarding personal data protection can be directed to:

Rasmus Theede

CEO and Chief Pragmatism Officer

Klosterstræde 9, st. | 1157 København K

Denmark

Mobile: +45 2990 8030

www.sparklesecurity.net

WHICH PERSONAL DATA DO WE COLLECT AND WHY?

We process personal data under the current rules set out in the EU General Data Protection Regulation. This means, for example, that we only process personal data for lawful, fair and legitimate purposes that we can document.

We collect, store and process only the personal data necessary for the stated purpose of the processing. Accordingly, we take active measures to keep the collection and processing of personal data to an absolute minimum.

We limit our personal data processing to ensure we do not process it in a manner incompatible with the original intent. We also ensure that personal data is stored for no longer than necessary to fulfil the purpose of the processing. When the need for the personal data ceases, we make sure either to erase it in accordance with our erasure rules or take other technical and organizational measures such as anonymization that can prevent you from being identified on the basis of the data.

WHAT DATA DO WE COLLECT?

When you visit sparklesecurity.net, we automatically collect data about you and your use of sparklesecurity.net, for example, what type of browser you use, the search terms you use on sparklesecurity.net, your IP address (including your network location) and information about your computer. Sparkle’s cookie policy also applies when you use sparklesecurity.net to optimize the user experience and website functionality.

When you subscribe to our newsletter, we collect information about your name, e-mail address and mobile phone number, if you have one. This enables us to achieve our legitimate interest in being able to send newsletters to you.

RECIPIENTS OF PERSONAL DATA

We may disclose data to external cooperation partners that process the data on our behalf. We use external cooperation partners to help us technically operate our systems and improve the website, to distribute newsletters and to conduct targeted marketing, including retargeting, as well as to give you the opportunity to rate our company and products. These companies are data processors that act on our instruction and process data for which we are the data controller. The data processors may not use the data for any purpose other than to satisfy the agreement with us, and they are subject to the associated confidentiality requirements. We have entered into written data processor agreements with all the data processors that process personal data on our behalf.

Some of these data processors, for example, Google Analytics, represented by Google LLC, and Facebook Inc., are based in the USA. The guarantees necessary for transmitting data to the USA are secured through the data processor’s certification under the EU-US Privacy Shield; see Article 45 of the EU General Data Protection Regulation. To the extent that we use any non-EU-based data processors other than those mentioned, we will at all times observe the transmission guarantees in effect.

RECORDS OF PROCESSING ACTIVITIES

We keep a record of the personal data processing operations that we carry out and actively ensure this record is kept up-to-date. We use the record, for example, to fulfil our duty to provide documentation to the Danish Data Protection Agency and as a basis for assessing the risks that the processing of your personal data poses to you, as a data subject.

YOUR RIGHTS

We do our utmost to make it easy for you to exercise your rights, for instance, by processing personal data in a transparent and informed manner. We also help you exercise your rights, and will address your request to exercise your rights regardless of whether we are required to meet your request.

You can contact Sparkle to obtain access to the data we process about you and can likewise have any inaccurate personal data about you rectified. If you want to exercise your right to have personal data erased, to restrict or object to the processing of your data, or wish to exercise your right to data portability, please feel free to contact us.

The right to withdraw your consent

If you have given consent to the processing of your personal data, you are entitled to withdraw your consent at any time by contacting us.

Complaints

If you wish to complain about our personal data processing, you can contact us at privacy@sparklesecurity.net. You can also lodge a complaint with the Danish Data Protection Agency, Borgergade 28, 5th floor, 1300 Copenhagen K, Denmark, tel.: +45 3319 3200, e-mail: dt@datatilsynet.dk

UPDATING OUR DATA PROTECTION POLICY

We take great care with your personal data, for which reason we may need to update this data protection policy.