Sparkli HR (“we,” “us” or “our”) respects your privacy and is committed to protecting it through compliance with this policy and applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
This policy (“Policy”) describes how we collect, use, maintain, and disclose your information when you use our website www.sparkly.hr (the “Website”) and associated software platform sparklyhr.app (collectively, the “Sparkly Platform”).
1. Scope of This Policy
This Policy applies to personal data we collect:
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When you visit or interact with the Sparkly Platform.
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When you contact us via email, forms, or other digital means.
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When you engage with our services, content, or advertisements.
This Policy does not apply to:
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Offline data collection unless otherwise specified.
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Third-party services, websites or applications that link to or are accessible from our Platform.
2. Legal Basis for Processing (EU-GDPR)
We process your personal data under one or more of the following legal bases:
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Performance of a contract (Art. 6(1)(b) GDPR)
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Legitimate interests (Art. 6(1)(f) GDPR)
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Your consent (Art. 6(1)(a) GDPR)
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Compliance with legal obligations (Art. 6(1)(c) GDPR)
3. Information We Collect
We may collect and process the following categories of information:
a) Information You Provide
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Full name, email address, personality related details, and contact details.
Company information, and company contact details.
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Information submitted via forms, support queries, feedback, or account setup.
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User contributions posted to our platform or shared with other users.
b) Automatically Collected Data
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IP address, device type, operating system, browser type.
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Usage details, location data, and traffic logs via cookies and similar technologies.
You can manage cookie preferences through your browser settings.
4. How We Use Your Information
We use your personal data to provide the service Sparkly Platform is built for:
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Provide, maintain, and improve the Sparkly Platform.
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Communicate with you, including for support or account management.
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Personalize your user experience.
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Comply with legal or contractual obligations.
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Send you marketing messages if you have consented to receive them.
5. Disclosures of Your Data
We may disclose your data:
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To Sparkly HR team members, contractors, or third-party service providers operating under our instruction and GDPR-compliant agreements.
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In the context of a business transaction (e.g., merger or acquisition).
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Where required by law or government request.
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To enforce our agreements or protect rights, safety, and security.
We do not sell your personal data.
You have visibility of who has access to your personal data from 3-rd party service providers.
You can revoke given permission at any suitable time, understanding then that the service received earlier may be halted.
6. Data Transfers Outside the EU
Our primary goal is to keep all the data in EU/EEA, using only 3-rd party service providers operating in EU/EEA.
When your data is transferred outside the EU/EEA, we ensure appropriate safeguards are in place, such as:
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European Commission adequacy decisions.
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Standard Contractual Clauses (SCCs).
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Binding Corporate Rules (BCRs), if applicable.
7. Data Retention
We retain your personal data only as long as necessary for the purposes it was collected or as required by law.
You may request deletion at any time (see Section 9).
8. Your Rights Under GDPR
You have the following rights:
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Right to access your data.
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Right to rectification of inaccurate or incomplete data.
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Right to erasure (“right to be forgotten”).
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Right to restrict processing.
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Right to data portability.
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Right to object to processing based on legitimate interest or direct marketing.
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Right to withdraw consent at any time where processing is based on consent.
To exercise your rights, contact us at support@sparkly.hr.
If you believe your rights under GDPR are violated, you have the right to lodge a complaint with your local Data Protection Authority (DPA).
9. Data Security
We implement technical and organizational measures to protect your data from loss, unauthorized access, or misuse.
However, please note that no system can be guaranteed 100% secure.
You are responsible for maintaining the confidentiality of your password and account access.
10. Cookies and Tracking Technologies
We use cookies to enhance your experience. You can manage cookie settings via your browser.
Some functionality may be affected if you disable cookies.
11. Changes to This Policy
We may update this Policy from time to time. Any material changes will be communicated on our Website or via email where appropriate. Your continued use of the Sparkly Platform after updates constitutes your acceptance.
12. Contact Us
If you have questions or wish to exercise your data rights, contact us at:
Sparkly HR
Email: support@sparkly.hr
Website: www.sparkly.hr
Tallinn, Estonia (EU)