Draft — to be reviewed by a lawyer
Who is responsible
The controller is Spark Technology, Mülgaustraße 222, 222, 41199 Mönchengladbach, Odenkirchen, Germany, [email protected].
This policy covers this website, the customer portal and the licensing service the control panels check in with. It does not cover the video services our customers run: they run the software on their own servers, their viewers' data stays there, and each customer is responsible for it and for its own privacy policy.
What we process
- Visits to this website: our servers log each request (IP address, time, page, browser) to run and protect the site. The website sets no cookies and uses no tracking or analytics.
- The contact form: your name, email address, company and message, sent to us by email. The website keeps a message only until it is emailed to our team, and at most 7 days.
- Customer accounts: the name and email address of the people who sign in, your company's name, billing address and VAT ID, and the sign-in data (the password is stored only as a hash; two-factor authentication if you turn it on).
- Billing and payments: subscriptions, invoices and payments. Card and bank details are entered with our payment providers, which tell us only the result and a reference.
- Licence check-ins: each installation's licence, software version, the counts the plan limits (such as subscriptions and servers), its domain and the address it connects from. No personal data of our customers' viewers is sent.
- Branded apps: the names, images and store details you give us to build your apps. We process them on your behalf, under our data processing agreement.
Why, and on what legal basis
Where the EU General Data Protection Regulation (GDPR) or Brazil's General Data Protection Law (LGPD) applies, we process personal data on these bases:
- to perform our contract with you or take steps before it: accounts, licences, check-ins, billing, support and apps;
- to meet legal obligations, such as keeping invoices and accounting records;
- for our legitimate interests in running secure services, preventing abuse and fraud, and answering enquiries, such as server logs and the contact form.
Who receives data
- Stripe, for card and SEPA Direct Debit payments;
- CoinGate, for cryptocurrency payments;
- Resend, which sends our emails;
- the providers that host our servers, and tax advisers and authorities where the law requires it.
Our service providers process data only on our instructions. Some of them are outside your country; where data leaves the EU or Brazil, it does so with the safeguards the law requires, such as standard contractual clauses.
How long we keep data
We keep account and licence data while you are a customer and delete it when it is no longer needed, unless the law requires us to keep it longer: invoices and accounting records are kept for the periods tax law sets, which can be up to ten years. Server logs are kept for a short time, and contact enquiries for as long as needed to answer them.
Your rights
You may ask for access to your data, its correction or deletion, its restriction, and a copy in a portable form, and you may object to processing based on our legitimate interests. You may also complain to a data protection supervisory authority, in particular in the country where you live or work, or in ours; in Brazil this is the ANPD.
To use your rights, write to us at [email protected].
Cookies
This website sets no cookies. The customer portal uses only the cookies it needs for signing in and for security.
Changes
We update this policy when our services or the law change. The current version is always on this page.