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We take the privacy of your Personal Data very seriously and are committed to protecting the confidentiality of the information entrusted to us. We act in accordance with applicable data protection law.


The use of the website of Spark+ General Partner S.à r.l. ("Spark+ GP") is possible without any indication of Personal Data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable. This Privacy Policy is designed to help you understand what information we collect, why and how we use it, with whom we share it (if at all) as well as how we store, process, and protect it.


Data Processing & Contact

You can contact us at:

Spark+ General Partner S.à r.l.
18 rue Robert Stümper
L-2557 Luxembourg


Cookies & Your Rights

This website uses cookies. Cookies are small files stored on a user’s computer or mobile device when visiting a website, which enable the user to navigate between pages easily, to remember the user’s preferences, and eventually to improve the user experience.

Two forms of cookies are used on this website:

  • Temporary cookies, which are automatically removed once the browser is closed. These cookies enable us to retain information throughout our site, eliminating the need for you to input the same details every time you navigate to a different page.

  • Long-term cookies, which stay on the user’s device for a period of 12 months or until the user decides to remove them. These cookies aid us in identifying you as a distinct visitor when you revisit our website. They also help us recall your user type (such as investor status) and gather aggregated, anonymous data for analytical purposes. This information assists us in discerning how visitors interact with our site, which in turn aids in enhancing our website's layout and functionality.


It's important to note that the cookie information is not used to identify you personally. Furthermore, you can disable the use of cookies on our website by adjusting the settings of your internet browser. This will allow you to refuse the activation of cookies permanently. Additionally, you can delete previously established cookies using your browser or other software tools at any time. This can be done in all commonly used internet browsers. However, if you choose to turn off cookies in the browser you're using, some features of our website might not function as intended.


General data and information

When someone visits Spark+ GP's website, either manually or through an automated system, we gather a range of generic data and details. This information is recorded in the server's log files and can include: (1) the versions and types of browsers used, (2) the operating system of the device accessing our site, (3) the website that directed a user to our site (known as referrers), (4) the specific pages viewed on our site, (5) the date and time of the visit, (6) the Internet Protocol (IP) address, (7) the internet service provider used to access our site, and (8) any other relevant data that might be useful should our IT systems come under attack.


We don't use this general data to identify individuals. Instead, it serves several purposes: (1) ensuring our website content is displayed correctly, (2) fine-tuning our website's content and its promotion, (3) maintaining the ongoing functionality and reliability of our IT infrastructure, and (4) giving law enforcement the details they might need should a cyber-attack occur. We statistically evaluate the gathered data in an anonymous format. Our goal with this analysis is to enhance our company's data privacy and security measures, ensuring the utmost protection for any personal data we handle. It's crucial to note that this generic data is stored separately from any personal data shared by visitors.


We typically refrain from utilizing automated decision-making or profiling as outlined in Article 22 GDPR. Should there be instances where we employ such methods, we will notify you explicitly if legally mandated to do so.

Data Usage & Data Sharing

Within Spark+ GP, any department needing your information to meet our contractual and legal commitments will be granted access. On occasion, we might share your information with trusted third-party partners to ensure the effective delivery of top-quality services and products. Consequently, your data might be transmitted to countries outside of the European Economic Area (EEA). Nevertheless, if personal data is transferred outside the EEA, it will strictly be based on adequacy decisions or other suitable safeguards, notably the standard data protection clauses set by the European Commission.


Additionally, we might reveal information if legally mandated or if needed to adhere to regulatory demands, judicial processes, court orders, or other lawful procedures. We may also disclose personal data if there's a valid reason to do so. This could include sharing information with third parties in line with standard anti-money laundering practices, KYC protocols, our investor due diligence standards, or similar requirements imposed by third parties.

Data Storage & Protection

Spark+ GP retains and manages Personal Data only for the duration required to fulfill the storage purpose or as mandated by European regulators or other legislative authorities under laws or regulations applicable to us.

Protecting data is crucial given its significance as a business asset. This protection corresponds to both its associated risks and its intrinsic value. We have implemented robust physical, technical, and organizational measures to shield your Personal Data from undue interference, loss, unauthorized access, modification, or disclosure. Techniques such as firewalls, intrusion detection, anti-virus systems, and password-secured log-ins are employed to thwart any unauthorized breaches. We routinely assess the efficiency of these protective measures. Moreover, we've instituted systems to promptly identify, address, and recover from any detrimental incidents.

Only authorized individuals have access to Personal Data, and measures are in place to prevent its misuse or illegal sharing. Those with permission to view this data are bound by confidentiality. For enhanced data protection, we might employ methods like pseudonymization, obfuscation, or anonymization.


If you engage with sections of our website or utilize our services, you bear the responsibility for keeping your login details confidential, if applicable. It's essential to note that no online data transmission is 100% secure. While we exert every effort to safeguard your Personal Data, we cannot assure the absolute security of any data you share on our website. Such sharing is at your discretion and risk.


Privacy Rights

If Spark+ GP processes Personal Data, every individual has the right to:

  • Access their data as stated in Article 15 GDPR (Article 8 FADP)

  • Rectify their data as per Article 16 GDPR (Article 5 FADP)

  • Erase their data according to Article 17 GDPR (Article 5 FADP)

  • Limit data processing under Article 18 GDPR (Articles 12, 13, 15 FADP)

  • Object to data processing as outlined in Article 21 GDPR (Article 4 FADP)

  • Transfer their data, if applicable, as detailed in Article 20 GDPR.

Moreover, if relevant to you, you also possess the right to file a complaint with a suitable data privacy oversight body, as referenced in Article 77 GDPR.


You have the liberty to retract any consent you've given us for data processing at any given time. This includes revoking permissions given to us prior to the enactment of the GDPR, meaning before May 25, 2018. It's important to acknowledge that any such withdrawal will only impact future data processing. Any processing that took place prior to the revocation remains unaffected.


Data protection provisions about third-party applications (Google Analytics, YouTube, Vimeo)

Spark+ GP may incorporate Google Analytics functionality, which includes an anonymization feature. Google Analytics is a tool used for analyzing website traffic, which allows for the tracking, collection, and evaluation of data regarding the actions of website visitors. This includes details like the referring website a user came from, the specific pages they viewed, and the duration and frequency of their visits. Such analytics primarily help in enhancing a website's user experience and assessing the return on investment for online advertising.

To function, Google Analytics sets a cookie on the user's device. As mentioned earlier, you have the option to configure your browser to block cookies, thereby preventing Google Analytics from setting a cookie on your device. Additionally, any Google Analytics cookies already present can be removed using browser settings or other software.


Moreover, Spark+ GP has embedded YouTube components on its platform. According to YouTube’s data usage guidelines and the Google Privacy Policy (available at, data is only gathered from visitors when they actively engage with the content (like playing a video). Merely accessing a webpage with a YouTube video doesn't initiate data transfer. However, if you play a video, your IP address is shared with YouTube.


The same data-sharing principle is in place for the Vimeo Video Hosting Service, which Spark+ GP also utilizes.

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