For Sparque B.V., the responsible handling of personal data is an essential criterion. Sparque B.V. is particularly committed to safeguarding and protecting the privacy of its customers and business partners. For this reason, we would like to inform you below about how we handle your personal data. We reserve the right to amend the content of this privacy policy from time to time. We therefore recommend that you review this document at regular intervals. The controller responsible for data processing within the meaning of the General Data Protection Regulation (GDPR) is:

SPARǪUE B.V.
Barchman Wuytierslaan 154
3818 LM Amersfoort
The Netherlands
Phone: +31 85 3019171
Email: info@sparque.ai

If you have any questions or comments about data protection, please contact the data protection officer of the data controller at:
DataProtectionOfficer@sparque.ai.

SPARǪUE B.V. processes your personal data because you use our services and/or because you provide it to us yourself. If you leave comments on the site, we collect the data shown in the comment form. Below is a summary of the personal data we process:

• Identification data: Your name, email address, phone number, company name, and department in which you work.
• Data on online behavior and information about your devices:
• Your IP address and device ID of your end device
• Data on activities on our website Data on your surfing behavior
• Other data: Information that you provide to us in the free text field when contacting us

Our website and service do not intend to collect data about website visitors who are under 16 years of age unless they have the permission of their parents or legal guardians. However, we cannot verify whether a visitor is over 16 years of age. We therefore recommend that parents be involved in their children’s online activities to prevent data about children from being collected without parental consent. If you believe that we have collected personal data about a minor without such consent, please contact us at info@sparque.ai and we will delete that data.

SPARǪUE B.V. processes your personal data for the following purposes:

Your personal data is processed in order to provide you with the services you have requested. This includes all steps necessary to fulfill our service obligations, including communicating with you, managing your account, and processing payments. The legal basis for this processing is the performance of a contract pursuant to Art. 6(1)(b) GDPR. We analyze your behavior on our website in order to continuously improve it and offer you products and services that match your preferences and interests. This analysis helps us to optimize the user-friendliness of our website and make personalized recommendations. The legal basis for this processing is our legitimate interest pursuant to Art. 6 (1) (a) GDPR in ensuring that our website is userfriendly and provides relevant content and offers.

a) If you submit a request by email
If you have any questions about our products or services, we offer you the option of contacting our customer service (by phone or email) in accordance with Art. 6 (1) (a) GDPR. The provision of your personal data to us is always voluntary. The purpose of collecting your personal data (title, first name, last name, company email address, company name) is to identify you and respond to your request. All personal data that you provide to us in an email request will be automatically deleted after 24 months, unless longer statutory retention periods apply.

b) Data processing for direct marketing
Data processing is based on your consent in accordance with Art. 6(1)(a) GDPR, provided that you have given your consent for direct marketing. We store your email address for the purpose of sending you product information by email and your telephone number for the purpose of contacting you. In addition, we use various data to provide information that is as personalized as possible, such as confirmations of receipt and reading of emails, the date and time of your visit to our website, and the products you have viewed. You can revoke your consent at any time by sending us a message to info@sparque.ai. All personal data that we process for the purpose of direct marketing will be stored until you withdraw your consent and in accordance with legal requirements. After receipt of your withdrawal, your data will be stored only to the extent and for the duration required by statutory retention obligations and will then be deleted.

c) How long do we store personal data?
SPARǪUE B.V. will only retain your personal data for as long as is strictly necessary to fulfill the purposes for which your data was collected.

d) Disclosure of personal data to third parties
SPARǪUE B.V. will only disclose personal data to third parties if this is necessary for the performance of our contract with you or to comply with legal obligations.

e) Data transfer outside the European Economic Area
We store your data within the European Economic Area (“EEA”) as far as possible. Occasionally, some of the data we collect may be transferred to or stored at a location outside the EEA, for example because one of our third-party service providers is located there. When this happens, we ensure that it is done in a secure and lawful manner. This means that Sparque B.V. will then, as far as possible, choose parties based in countries that offer a similar level of protection to Europe. The European Commission (EC) decides which countries meet this requirement by means of an adequacy decision. For example, the Commission has decided that organizations based in the United States that participate in the Data Privacy Framework offer at least a good level of data protection. Some of the parties with which Sparque B.V. works are based in the United States and are certified accordingly.

a) Google Analytics
If you have given your consent in the cookie banner, we use Google Analytics 4 (GA4), a web analytics service provided by Google, on our website to statistically evaluate the use of our website, measure reach, and continuously optimize our online offering. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ireland Limited is part of the Google group of companies. It cannot be ruled out that personal data may also be transferred to affiliated companies, in particular Google LLC in the USA, and processed there when using Google Analytics 4. Within the scope of Google Analytics 4, usage data (e.g., pages accessed, interactions), technical information (e.g., browser type/version, operating system, device characteristics), and pseudonymous online identifiers are processed in particular. A direct personal reference (e.g., name) is not required for this; however, a personal reference cannot be completely ruled out due to the processing of technical identifiers. Google Analytics 4 uses cookies for this purpose, which enable pseudonymous recognition of your browser and
collect statistical information about the use of our website. In connection with the use of Google Analytics 4, personal data may be transferred to third countries (in particular the USA). Appropriate safeguards in accordance with the provisions of the GDPR are used for these transfers. Where applicable, transfers are based on the EU adequacy decision for the EU-U.S. Data Privacy Framework (DPF). In addition, the EU standard contractual clauses pursuant to Art. 46 GDPR have been agreed as additional safeguards. Processing is carried out exclusively on the basis of your consent pursuant to Art. 6 (1) lit. a GDPR or § 25 (1) TDDDG. Personal data is automatically deleted in Google Analytics 4 after 14 months. You can revoke your consent at any time with future effect by accessing the cookie settings on our website and changing your selection. For more information about data processing by Google, please visit:
https://policies.google.com/privacy.

b) Hubspot
For our online marketing activities, we use an integrated software solution from HubSpot
Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 (“HubSpot”), with servers located in
Europe, on our websites. Data processing is based on your consent in accordance with Art.
6 (1) (a) GDPR or § 25 (1) TDDDG, provided that you have given your consent via our cookie
banner. We use HubSpot to statistically evaluate the use of our website on a session-bysession basis and to improve our online offering. For this purpose, HubSpot uses cookies,
which are used in particular for session recognition and the recording of page views within
a session. In the course of processing, technical information about your device (e.g.,
browser type, operating system,
language settings) may also be processed. The data is always processed in
pseudonymized form. However, a personal reference cannot be completely ruled out
via technical identifiers. Data processing by HubSpot may also take place outside the EU
or the EEA (in particular in the USA). For such transfers, appropriate safeguards are used
in accordance with Art. 46 GDPR (in particular EU standard contractual clauses), unless
an adequacy decision is applicable.
You can revoke your consent at any time with future effect via the cookie settings.
Further information on data processing by HubSpot can be found at:
https://legal.hubspot.com/privacy-policy

c) Google Tag Manager
Our website uses Google Tag Manager, which is provided by Google (Google Ireland Ltd., Gordon
House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 43C 1001). Google Tag Manager is a
solution that allows website tags and other elements to be managed via a single interface.
When you visit the website using Google Tag Manager, an HTTP request is first sent to Google.
Google.
This transmits device information and personal data—such as your IP address and
information about your browser settings—to Google. We use Google Tag Manager to
facilitate electronic communication by providing information to third-party providers,
including via programming interfaces. Google Tag Manager implements the respective
tracking codes of third-party providers without us having to do so ourselves.
modify the source code of the website. Instead, integration takes place via a container
that inserts so-called placeholder code into the source code. Google Tag Manager also enables
the exchange of user data parameters in a specific order, in particular by organizing and
systematizing the data packages. Data processing by Google Tag Manager may take place
outside the EU or the EEA (in particular in the USA). An adequate level of data protection
is guaranteed for this data transfer on the basis of the adequacy decision (EU-U.S. Data
Privacy Framework). The legal basis for this processing is Art. 6(1)(a) GDPR. Google
Tag Manager does not initiate any data storage. Further information on data protection at
Google can be found at:
https://www.google.de/intl/en/policies/privacy.
Secondly, Google Tag Manager integrates third-party tags, such as tracking codes or
tracking pixels, on our website. The tool triggers other tags, which in turn collect your
data; this is explained separately in our privacy policy.
Google Tag Manager itself does not evaluate the device information and personal data of
users collected by the tags. Rather, your data is forwarded to the respective third-party
service for the purposes specified in our consent management tool. We have configured
Google Tag Manager to work with our consent management tool so that the triggering of
certain third-party services in Google Tag Manager depends on the selections you have
made in our consent management tool, so that only those third-party tags trigger data
processing for which you have given your consent. The use of Google Tag Manager is subject
to your consent for the respective third-party service.
The legal basis for this processing is your consent in accordance with Art. 6(1)(a) GDPR. Data processing by Google Tag Manager may take place outside the EU or the EEA (in
particular in the USA). An adequate level of data protection is guaranteed for this data
transfer on the basis of the adequacy decision (EU-U.S. Data Privacy Framework). Please
refer to the following descriptions of the individual third-party services to find out how long
your data will be stored in each case. Further information on data protection at “Google”
can be found at: https://policies.google.com/privacy.
You can revoke your consent to processing and transfer to third countries at any time by
using the slider for the respective third-party provider in the cookie tool settings. This does
not affect the lawfulness of processing based on consent before revocation.

You have the following rights with regard to your data processed by us:
• the right to information about your personal data stored by us in accordance with
Art. 15 GDPR;
• if necessary, the right to rectify inaccurate or incomplete personal data
stored by us in accordance with Art. 16 GDPR;
• the right to erasure and to be forgotten of your personal data stored by us in
accordance with Art. 17 GDPR;
• the right to restrict or block the processing of your personal data in accordance with
Art. 18 GDPR;
• where applicable, the right to data portability pursuant to Art. 20 GDPR;
• the right to object to the processing of your personal data in accordance with
Art. 21 GDPR;
• the right to withdraw any consent given in accordance with Art. 7 (3) GDPR;
• the right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR
If you have any further questions about the processing of your personal data or wish to
exercise any of your rights, please send us an email atinfo@sparque.ai .
SPARǪUE B.V. would also like to point out that you have the option of submitting a
complaint to the national supervisory authority, the Autoriteit Persoonsgegevens.
You can do this via the following link: https://autoriteitpersoonsgegevens.nl/eentip-of-klacht-indienen-bij-de-ap.

SPARǪUE B.V. takes the protection of your personal data seriously and takes appropriate
measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and
unauthorized modification. If you believe that your personal data is not secure or there are
signs of misuse, please contact our customer service department or send an email to info@sparque.ai .

To make it easier for us to ask for your consent to use cookies or other tracking technologies
so that we can process device information and personal data when you visit our website, we
use the consent management tool “CookieYes.” CookieYes allows you to consent to or
refuse the processing of your device information and personal data using cookies or similar
technologies for the purposes listed in the cookie banner or cookie settings menu. Such
processing purposes may include the integration of external elements, the integration of
streamed content, statistical evaluations, reach measurement, and personalized advertising.
With CookieYes, you can give or refuse your consent for all processing purposes as a whole,
or give or refuse your consent for individual purposes or individual services/providers. In
addition, you have the option of changing your selection at any time and revoking any
consent you have already given with effect for the future. You can change your settings
again later. The purpose of integrating “CookieYes” is to enable users of our website to
decide on the permissibility of cookies and similar technologies and to give them the
opportunity to change settings they have already made when continuing to use our website.
When using
“CookieYes,” we process personal data and information about the devices used. No data is
transmitted to a third-party provider. The information about the settings you have made is
stored locally on your device. The legal basis for processing is Art. 6(1) sentence 1(c) GDPR
in conjunction with Art. 7(1) GDPR, insofar as the processing serves to fulfill the legally
standardized obligations to provide evidence for the granting of consent. Otherwise, Article
6(1)(a) GDPR is the relevant legal basis. Your consent will be requested again twelve
months after you have saved your user settings. Your user settings will then be saved again
for this period, unless you delete the information about your user settings yourself in your
device settings beforehand.
You may object to the processing if it is based on Article 6(1)(a) of the GDPR. You have the
right to object if you have reasons arising from your particular situation. You can send us
your objection using the contact details listed in the “Controller” section.

Our website may contain links to third-party websites from time to time. If you follow a
link to any of these websites, please note that these websites have their own privacy
policies and that we do not accept any responsibility or liability for these policies. Please
read the policies published on these websites before submitting any personal data.