Data Protection Policy

For a better understanding of this policy, it should be clarified that:

• The ‘data controller’: SparkleIT
• The ‘subcontractor’: means any natural or legal person who processes personal data through SparkleIT.
• The ‘data subjects’: refers to all of SparkleIT’s clients or contacts.
• Recipients”: refers to the natural or legal persons who receive personal data from SparkleIT. Data recipients can be either SparkleIT employees or external organisations (partners, exhibitors, banks, stakeholders, etc.).

In order to use the services on the SparkleIT website, the communication of certain information is mandatory. Failure to provide this information will result in SparkleIT being unable to process your request to use a service or for information about that service.
SparkleIT collects personal data both online and offline and this Policy applies whatever the means of collecting your personal data.
The personal data collected about you is used by SparkleIT for the following purposes in particular:

• to enable you to use SparkleIT services and support;
• to allow you to access all the functionalities available on SparkleIT’s websites;
• to allow you to request information about SparkleITservices;
• to identify your needs in order to provide you with the most appropriate services;
• allow you to use the site in an interactive and personalised way;
• any other purpose associated with those listed above;

By providing your email address or telephone number, you expressly authorise SparkleIT to use it with other useful personal data to send you commercial or marketing messages.
SparkleIT may also use your e-mail address or telephone number for other purposes, namely to notify you of important changes related to these services.

All personal data collected is kept for a limited period depending on the purpose for which it is processed and the duration of storage provided for in the legislation in force.
As an indication:

• Cookies: 13 months;
• Technical data: 1 year from collection;
• Data for advertising purposes: 6 months to 1 year from collection, according to the calendar;
• Bank details: Deleted after a transaction has taken place, unless expressly agreed by the customer and if the transaction is contested: kept 13 months on file after the debit date;
• Anti-money laundering: 5 years from collection.

Personal data will never be sold, shared or communicated to third parties by SparkleIT, except in the cases provided for below.
Your personal data may be communicated to third parties acting on our behalf, within the framework of specific processing and in accordance with the purposes for which they were initially collected.
These Third Parties are obliged to process them in accordance with this Policy. They are not authorised to sell them or disclose them to other third parties.
However, personal data may be disclosed to third parties if we are compelled to do so by law or by a regulatory provision or if such disclosure is necessary in the context of a legal claim or litigation.
Once the time limits have elapsed, the data will either be deleted or retained after being anonymised, particularly for statistical use. They may be kept in the event of pre-litigation or litigation.

Our concern is to preserve the quality, confidentiality and integrity of your personal data.
To ensure the security and confidentiality of the personal data we collect, we use technical means (resources protected by standard devices such as firewalls, protected shared networks, adapted physical hosting, etc.) and organisational means (restricted and named access control, procedures, security policy, etc.).
Before processing your personal data, we take all reasonable measures to protect it against any loss, misuse, unauthorised access, disclosure, alteration or destruction.
Persons with access to your personal data are subject to a duty of confidentiality and secrecy, subject to disciplinary measures and/or other sanctions if they fail to respect their obligations.
However, despite our efforts to protect your personal data, SparkleIT cannot guarantee the infallibility of this protection against all errors that may arise after the transmission of personal data, given the inevitable risks of an internet transmission and which are beyond any reasonable possibility of control.
You must also be careful to prevent any unauthorised access to your personal data. You are responsible for the confidentiality of information transmitted via the SparkleIT website.

In the case of authorised transfers within the European Union, the protection of your personal data, in accordance with European legislation, is guaranteed by the signing of Conventions with entities located in the European Union or by other mechanisms recognised by the legislation in force.

In accordance with the applicable regulations, you have different rights:

• Right of access: You can obtain information about the processing of your personal data as well as a copy of that personal data.
• Right of rectification: If you consider that your personal data is inaccurate or incomplete, you can demand that it be modified accordingly.
• Right to erasure: you can demand the erasure of personal data within the limits permitted by the regulations.
• Right to restriction of processing: you can request that the processing of your personal data be restricted.
• Right to object: you can object to the processing of your personal data on special grounds.

You have the absolute right to object to the processing of your personal data for commercial promotion purposes, including the profiling associated with such prospecting.

• Right to data portability: where applicable, you have the right to have the personal data you have provided returned to us or, where technically possible, transferred to a third party.
• Right to define instructions regarding the storage, deletion or communication of your personal data, applicable after death.
• Right to withdraw consent: if you have given your consent to the processing of your personal data, you have the right to withdraw your consent at any time.

You can exercise the above rights by post to:
SparkleIT, Praça da Liberdade, Piso1, Fração2, 4900-040 Viana do Castelo
In accordance with the applicable regulations, you have the right to lodge a complaint with the competent supervisory authority, which is the CNPD (National Data Protection Commission) in Portugal.

This Personal Data Protection Policy may be updated according to SparkleIT’s needs and circumstances or if the law and regulations so require.

Information on our cookie policy and computer security is available on our website.

SparkleIT may collect and process your location data to provide enhanced functionality, such as geofencing, presence detection, and automation based on your whereabouts. The location data is only collected when you have granted explicit permission through the SparkleIT Companion App, and it is processed locally within your device or home network, without being stored on external servers.

You can adjust your preferences for location data collection within the app. SparkleIT offers several options, including:

• High Accuracy Mode: Allows real-time, precise location updates.
• Zone-Based Tracking: Limits location updates to defined zones (e.g., “Home” or “Office”).
• Privacy Mode: If enabled, this mode restricts location tracking to only notify about zone entries and exits, without saving exact GPS coordinates.

You have control over your location settings at any time, and data is only shared within your SparkleIT instance to support automations and notifications.

SparkleIT is committed to protecting your personal and sensitive information. This section outlines how we access, collect, use, and share your data:

1. Data Access and Collection:
   • Types of Data Collected: SparkleIT may collect personal information, such as your name, email address, location data, and usage data, which helps us provide and improve our services.
   • Sensitive Data: SparkleIT may access sensitive data, such as health information, only if you provide explicit consent.
   • Third-Party Sharing: SparkleIT does not share your personal or sensitive data with third parties except when necessary to provide core app functionalities, such as integration with third-party devices. In such cases, we ensure that data sharing complies with applicable data protection laws.
2. Secure Data Handling:
   • SparkleIT employs industry-standard security measures to protect your data from unauthorized access, alteration, or destruction. Data is encrypted during transmission and at rest to safeguard your privacy.
3. Data Retention and Deletion Policy:
   • Retention: SparkleIT retains your data only as long as necessary to fulfill the purposes for which it was collected or as required by law.
   • Deletion: You may request deletion of your data at any time through the app’s settings. Once a request is received, SparkleIT will securely delete the data within a reasonable timeframe.