Privacy Policy

Last update: 1 Jan 2022

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Responsible body, scope

The responsible body within the meaning of the General Data Protection Regulation (GDPR) and other national data protection laws of the member states as well as other data protection regulations is Sparkr, KVK: 83164472, Niasstraat 1, Utrecht (hereinafter referred to as the service provider).The protection of personal data is our top priority. With this policy we would like to inform you about which personal data we collect on our websites and how we handle them.

Legal basis for data collection

We collect data in accordance with Article 6 (1) (a) GDPR.In the context of data processing that is not carried out by us, we only work with companies that have either adapted their data processing to the rules of the GDPR or are obliged to a comparable level of data protection under agreements such as the EU-US Privacy Shield.

Data collection and use in general form on our website

When you visit our website, usage-related data is generated about your experience on the website. However, we do not assign this data to you personally. The data collection serves the sole purpose of continuously improving and further developing the quality of our services, for which we create anonymized analyses of user behaviour. After you have finished your visit with us, we will only save your IP address in anonymised form for the period stipulated by law.

No sharing of data

We do not pass on or sell information about our customers to any other business or organisation. The only exception to this is where we are legally obliged to do so to comply with a current judicial proceeding, a court order or legal process served on our website.

Online tools

We use MailerLite to send out our fortnightly newsletter. If you sign up for the newsletter MailerLite will process your data. You can read their comprehensive privacy policy.If you sign up to the newsletter, we will only ever use your email address to send you the newsletter—never for any other purpose. We will not share your email address with any third party. You can unsubscribe from the newsletter at any time—an unsubscribe link is included at the bottom of each newsletter. You can also make a request to find out what data we are storing, namely:your email address, andthe date you signed up for the newsletter.

We use Calendly to schedule appointments.The processing of this data is necessary for the registration for the test and its implementation and is therefore of legitimate interest to us. All data collected in this context will be deleted by us immediately as soon as they are no longer required to achieve the respective purpose for which they were collected. This applies subject to such data, the storage of which is required by law.As users of the Calendly website, we have no knowledge of the content of the data transmitted to Calendly or its use by Calendly. You can find further information here.

Rights of data subjects

If your personal data is processed, you are the “data subject” and you have the following rights towards us as the person responsible:

Right to information
You have the right to receive confirmation from us free of charge as to whether we are processing personal data relating to you. If this is the case, you have a right to information about this personal data and to further information, which you can find in Art. 15 GDPR. You can contact us by post or email.

Right to rectification
You have the right to request us to correct any incorrect personal data concerning you without delay. You also have the right to request the completion of incomplete personal data – also by means of a supplementary declaration. You can contact us by post or email.

Right to erasure
You have the right to request the immediate deletion of your personal data if one of the requirements of Art. 17 GDPR is met. You can contact us by post or email.

Right to restriction of processing
You have the right to demand that we restrict processing if one of the requirements of Art. 18 GDPR is met. You can contact us by post or email.

Right to be informed
If you have asserted the right to correction, deletion or restriction of processing against the person responsible, the person responsible is obliged to notify all recipients to whom the personal data concerning you have been disclosed of this correction or deletion of the data or restriction of processing, unless this turns out to be impossible or involves a disproportionate effort.You have the right vis-à-vis the person responsible to be informed about these recipients.

Right to data portability
You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format and you have the right to transmit this data to another person responsible without hindrance from us, if the requirements of Art 20 GDPR are present. You can contact us by post or email.

Right to object to processing due to our legitimate interest
Insofar as we exceptionally process personal data on the basis of Art. 6 Paragraph 1 Letter f) GDPR (i.e. due to legitimate interests), you have the right at any time for reasons arising from your particular situation to object to the processing of your personal data to lodge an objection with us. If we cannot prove any compelling legitimate reasons for further processing that outweigh your interests, rights and freedoms, or if we process the relevant data from you for the purpose of direct marketing, we will then no longer process your data (see Art . 21 GDPR). You can contact us by post or email. A technical process that you use is also considered a contradiction in this sense, for example clear technical information that your web browser transmits to us (“Do-Not-Track” message).

Right of withdrawal if consent has been given
You have the right to revoke your consent to the collection and use of personal data with effect for the future at any time. You can contact us by post or email. This does not affect the legality of the processing carried out on the basis of the consent up to the point of revocation.

Automated decision-making including profiling
You have the right not to be subject to a decision based solely on automated processing – including profiling – which has legal effects on you or which significantly affects you in a similar manner. Unless the decision is necessary for the conclusion or performance of a contract between you and us, it is permissible on the basis of legal provisions of the Union or of the member states to which we are subject and these legal provisions contain appropriate measures to safeguard your rights and freedoms as well as yours legitimate interests or the decision is made with your express consent.We do not make such automated decision-making.

Voluntary provision of the data
If the provision of personal data is required by law or contract, we will always point this out when collecting the data. In some cases, the data we collect is required for the conclusion of a contract, namely when we otherwise cannot or cannot sufficiently fulfil our contractual obligation towards you. There is no obligation for you to provide the personal data. However, failure to provide it may mean that we cannot perform or offer a service, action, measure or similar requested by you or that it is not possible to conclude a contract with you. If you would like to exercise one of the rights described above, you are welcome to contact us by email at: hello [@]

Right to lodge a complaint with a supervisory authority
Without prejudice to other rights, you have the right to lodge a complaint with a supervisory authority for data protection, in particular in the Member state of your place of residence, your place of work or the place of the alleged infringement, if you are of the opinion that the processing of your personal data violates data protection law.

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