Privacy Policy
Privacy Policy
This privacy policy (the “Policy”) is intended to explain how SPARK VISION IS OOD processes personal data in operating the website https://sparkvision.tech (the “Site”), selling products, responding to enquiries and arranging consultations. Where the seller is SPARK VISION IS ROMANIA SRL, the Policy also describes the processing carried out by that company in connection with the relevant sale.
Here you will find information about what data we use, why we need it, who we share it with and how long we keep it. We also explain what rights you have and how you can manage your choices regarding cookies and advertising tracking. Processing is carried out in accordance with Regulation (EU) 2016/679 (the “GDPR”) and applicable national legislation.
The Policy covers visits to the Site, contacts with us, consultations, orders, payments, deliveries, product returns, complaints and after-sales service. Processing in the course of the actual use of glasses, applications and other products, for example through a camera, microphone or recognition features, is described separately for the relevant product. Data required to handle a complaint or repair remains within the scope of this Policy.
The Policy informs you about the processing and does not require general consent to all of the activities described. You can browse the Site, contact us and make a purchase without allowing optional analytics or advertising tracking.
Who is responsible for your personal data
The controller for the operation of the Site, general enquiries and the arrangement of consultations is SPARK VISION IS OOD, UIC 206677712, address: 1 Krum Popov Str., 1164 Sofia, Bulgaria. The controller is the person that determines why and how personal data is processed.
When you buy a product, the relevant seller is responsible for the processing in connection with the contract, invoicing and the statutory obligations relating to the sale. Under the General Terms and Conditions, the seller is determined by the country of delivery and is indicated in the order confirmation:
| Delivery | Seller and controller for the sale |
|---|---|
| Bulgaria and the other EU countries, except Romania | SPARK VISION IS OOD, UIC 206677712; 1 Krum Popov Str., 1164 Sofia, Bulgaria. |
| Romania | SPARK VISION IS ROMANIA SRL, CUI 54581719, registration No. J2026028294009; Str. Verzisori 6, Bl. D, Ap. B118, 040301, Sector 4, Bucharest, Romania. |
When we use “we” and “us”, we mean the company responsible for the relevant activity. The two companies do not automatically gain access to all of your data. For an order with the Romanian seller, the necessary data is provided to it. To the extent that the Bulgarian company carries out technical and administrative operations solely on its behalf and on its instructions, it acts as a processor for those operations. This does not alter its own responsibilities for the operation of the Site.
You can contact us at customer.support@sparkvision.tech or at the address of the relevant company. If your question concerns a purchase, please state the order number, where you have it, so that we can direct it to the relevant seller.
What personal data is
Personal data is any information relating to an identified natural person or to a natural person who can be identified, directly or indirectly. Different pieces of data which, taken together, make it possible to establish who the person is are also considered personal data. These may include name, email address, telephone number, delivery address, order details, IP address and online identifiers. Data does not cease to be personal merely because a code or other identifier is used instead of a name.
Processing means any operation performed on personal data, including collection, storage, use, disclosure, restriction and erasure. Information about a legal entity is not in itself personal, but the names and contact details of its representatives may be personal data.
What personal data we collect
Information you provide to us
We collect data depending on how you use the Site and what you want from us. Not all of the data listed below is required for every interaction.
| When you provide data | What data we process |
|---|---|
| When making an enquiry | Name, email address and message from our own contact form; telephone number, if you contact us by phone or provide it for us to get back to you; subsequent correspondence. |
| When ordering and for delivery | Name of the buyer and the recipient, email address, telephone number, address or selected delivery office/parcel locker, selected products, quantity, price, order number and status, and the necessary communication. |
| For invoicing and payment | Details of the invoice recipient and the required invoice particulars; selected payment method, amount, status and payment identifier. In the case of a bank transfer or refund, the account holder’s name and bank account may be processed. |
| For withdrawal, returns, complaints and service | Contact, order and product details, serial number where necessary, description of the problem, proof of purchase, relevant photographs, documents, service reports and refund details. |
| When requesting and arranging a consultation | Contact details and other information entered in the consultation form, as well as subsequent correspondence and the arrangements for holding it. |
When you place an order, send an enquiry or request a consultation, we indicate which data you need to provide so that we can fulfil your request. For example, payment and delivery details are needed to process the purchase, and contact details allow us to answer your questions or to clarify and confirm the consultation. If you do not provide the necessary information, we may be unable to fulfil the relevant request. You provide all other data at your discretion. You can make a purchase without creating a customer account.
The contact form and the consultation form are our own development. The information submitted through them is recorded in the Site’s database, which is operated through Supabase. When an enquiry is sent, a notification is sent to customer.support@sparkvision.tech, and when a consultation is requested, a message is sent to an internal Slack channel in order to organise the handling of the request. Our business email is provided through Titan. Access to the information is granted to authorised team members who need it.
If you would like your order to be delivered to another person, we will need their name and contact and delivery details. Please provide only the information necessary to receive the shipment and make the recipient aware of this Policy. For our part, we will also inform them about the processing of their data at the first contact with them and within the applicable statutory time limits. Where the recipient is not a party to the purchase contract, we use their data on the basis of our legitimate interest in organising and carrying out the requested delivery. In the same way, we process the business contact details of representatives of our customers that are legal entities in order to carry out the necessary communication in connection with their orders and service.
Information relating to payment and purchase on instalments
Orders are paid for by bank transfer. To establish payment and fulfil the order, we process the necessary data from the bank transaction, including the name of the payer, bank account, amount, date, payment reference and transfer identifier. In the case of a refund, we process the necessary details of the recipient and their bank account. We do not request bank card details, security codes or online banking passwords.
Purchase on instalments through First Investment Bank AD (Fibank) is offered for Bulgaria only. When you choose this option, before you apply we inform you what data is required and whether you provide it directly to the bank or whether certain data is transmitted through us. The bank processes the application and financing data as an independent controller in accordance with its own privacy information.
The relevant lender reviews your application, assesses your creditworthiness and decides whether and on what terms to provide financing. It is independently responsible for these activities and provides its own information about the processing of your personal data. We do not assess your creditworthiness; we receive the necessary information about the approval, refusal or status of the financing so that we can process your order.
Information we receive from others
In order to fulfil your order and provide the related service, we sometimes receive information from the partners involved in these activities. For example, the bank or payment service provider may confirm to us that a payment or refund has been made, and the courier may confirm whether the shipment has been delivered or returned. We use this information to track the fulfilment of the specific order, to notify you of its status and to take the necessary steps in servicing it.
If another person places an order and names you as the recipient, we will receive from them your name and the contact and delivery details provided. We will use this data to arrange the delivery and, where necessary, to contact you in connection with receiving the shipment.
Affiliate discount codes
In the online shop we use Coupon Affiliates for WooCommerce to manage affiliate discount codes. When you use such a code, it is recorded against your order so that we can apply the discount and record the use of the relevant affiliate code. For participating affiliates, we process the necessary identification and contact details, the codes provided to them and information about their use. Where the affiliate relationship involves remuneration, we also process the data necessary for calculating, recording and paying it.
Information collected when browsing the Site
When you visit the Site, your browser and the systems that enable it to operate automatically provide certain technical information. This may include your IP address, the date and time of the visit, the address of the page opened and the type of browser and device used. Technical errors or requests that indicate a possible attempt at abuse may also be logged. We use this information to load the pages you request, to maintain the normal operation of the Site and to detect and resolve technical problems and security threats.
If you consent to the relevant category of cookies and similar technologies, additional information is collected through Google Analytics and Meta Pixel only for visits to predefined permitted pages, subject to the limitations described below. The use of these tools, the purposes of the processing and the ways in which you can change your choice are described below. The information collected may constitute personal data even where it does not include your name — for example, if it includes an online identifier by which your browser or device can be recognised and your separate visits can be linked to one another.
Purposes and legal bases for using your data
We use your personal data for specific purposes, relying for each of them on the applicable legal basis set out in the table below. For the use of optional analytics and advertising technologies, we ask for your prior consent. Your choice whether to give it does not affect your ability to place an order or its fulfilment.
| Purpose | Legal basis |
|---|---|
| Answering a question about a purchase and arranging a requested consultation. | Taking steps at your request prior to entering into a contract — Art. 6(1)(b) GDPR, where you will be a party to it. |
| Accepting and fulfilling an order, payment, delivery and contractual service. | Entering into and performing a contract with you — Art. 6(1)(b) GDPR. |
| Invoicing, accounting, tax obligations and the exercise of statutory consumer rights, including withdrawal and complaints. | Compliance with legal obligations — Art. 6(1)(c) GDPR; contractual basis for actions to perform the agreed service. |
| General enquiries, contacts with representatives of organisations and recipients of shipments who are not buyers. | Legitimate interest — Art. 6(1)(f) GDPR: responding to correspondence, business relationships and carrying out the requested delivery. |
| Reliable operation of the Site, detection of technical problems, fraud and abuse. | Legitimate interest in security — Art. 6(1)(f) GDPR; legal obligation to apply appropriate measures to protect personal data. |
| Analysis of use through Google Analytics; measuring and personalising advertising through Meta Pixel. | Prior consent given to analytics and marketing technologies — Art. 6(1)(a) GDPR. |
| Handling rights requests and responding to mandatory requests from authorities. | Legal obligation — Art. 6(1)(c) GDPR. |
| Establishment, exercise and defence of legal claims. | Legitimate interest in protecting rights — Art. 6(1)(f) GDPR, and legal obligation where applicable. |
| Applying an entered discount code to the order. | Performance of the contract with the buyer — Art. 6(1)(b) GDPR. |
| Managing relationships with affiliates and recording the affiliate codes used. | Performance of a contract, where the affiliate is a natural person; legitimate interest in managing affiliate relationships and recording codes, including when dealing with representatives of legal entities; legal obligation for the applicable accounting and tax reporting. |
Where we process your personal data on the basis of legitimate interest, we assess in advance whether this is necessary for the relevant purpose and whether our interest is not overridden by your rights and freedoms. In this assessment we also take into account what you can reasonably expect from us in view of our relationship and the way in which you provided your data. You have the right to object to such processing on grounds relating to your particular situation. More information about this right and how to exercise it can be found in the section “Your rights”.
When you make a purchase or send us an enquiry, we do not automatically subscribe you to a newsletter and we do not use the data from the order or the form to create and upload contact lists to advertising platforms. If we offer the option to receive marketing communications, we will ask for your separate consent, which you will be able to withdraw at any time. Regardless of your choice regarding marketing communications, we may send you necessary information about your order, delivery or requested consultation, such as confirmations, clarifications and notifications of changes.
Sensitive information
In order to respond to your enquiry, arrange a consultation or fulfil an order, we do not usually need to receive diagnoses, medical documents or detailed information about your health or disabilities. We therefore ask you not to include such information, your personal identification number (EGN) or unnecessary personal data about other people in free-text fields. If you submit a complaint, describe the problem with the product and attach only the documents and photographs necessary to examine it. When making an enquiry on behalf of another person, use your own contact details and share only the information necessary for the question concerned.
We recognise that information about interest in or the purchase of an assistive device, especially when combined with other data, may make it possible to draw conclusions about a person’s health. For this reason, we do not use data from orders, consultations and complaints, or information about interest in products that may reveal a health condition, to create advertising audiences, and we do not provide it to Meta or Google Analytics. This also applies to technical information, such as addresses and titles of visited pages or actions taken, where it may reveal such circumstances.
If we nevertheless receive sensitive information that is not necessary for your request, we restrict access to it and delete it once we have identified its presence. The mere provision of such information does not mean that you have given explicit consent for us to use it.
If it is genuinely necessary for us to process data about your health in order to provide specific assistance, before requesting it we will explain to you what information is needed, why it is necessary, how long we will keep it and on what basis under Art. 9 GDPR we will process it. Where that basis is your explicit consent, we will request it separately. Consent to the use of cookies does not constitute consent to the processing of health data.
Cookies and your choices
When you visit the Site, small text files called “cookies” may be stored in your browser. They make it possible, for example, to remember the products you have selected in your basket or your preferences and, where you have given consent, to analyse the use of the Site and measure the effectiveness of advertising.
In addition to cookies, pixels and similar technologies may also be used, which send information about your visits and actions on the Site without necessarily storing a file in your browser. Therefore, the choice you make through the banner and “Cookie settings” also applies to these technologies, not only to cookies.
| Category | What it is used for |
|---|---|
| Strictly necessary | For expressly requested functions, for example saving the basket and session when ordering, security and remembering your cookie choice. They are not used for advertising. They do not require consent only to the extent that they fall within the statutory exemption. |
| Analytics | Google Analytics for analysing permitted visits and improving the Site. Disabled until you give your consent. |
| Marketing | Meta Pixel for measuring and personalising advertising through permitted interactions. Disabled until you give your consent. |
Through the cookie banner you can decide whether to allow the use of optional cookies and similar technologies. You can accept all, reject them or select individually the categories you wish to allow. Analytics and marketing technologies remain disabled until you consent to them. If you close the banner, scroll the page or continue browsing the Site, we will not treat this as consent.
You can change your preferences or withdraw the consent given at any time through the “Cookie settings” link at the bottom of the Site. After withdrawal, we stop collecting data through the relevant technologies for the purposes you no longer allow. This does not affect the lawfulness of processing carried out on the basis of your consent before its withdrawal. If you wish personal data already collected to be erased, you can submit a request in the manner described in the section “Your rights”, subject to the conditions laid down in the GDPR.
So that you do not have to set your preferences on every visit, we store your choice in the relevant browser for up to 6 months. You can change it before that period expires. If you delete cookies or use another browser or device, you may need to make your choice again. We will also ask for a new choice in the event of a material change in the purposes of use or the providers of the relevant technologies.
In “Cookie settings” you will find detailed information about the cookies and similar technologies actually used, including their names, providers, purpose and duration. The period for which a cookie remains in your browser is not necessarily the same as the period for which the data collected through it is stored. Information about the storage of this data is provided in the relevant sections of the Policy.
Limits on analytics and advertising tracking
Google Analytics and Meta Pixel are used only after consent to the relevant category and only on predefined pages whose content and transmitted data have been reviewed for the risk of revealing sensitive information. All other pages are excluded from tracking through these tools.
We do not send to Google Analytics or Meta Pixel data from product pages, contact forms, consultation forms, the basket, order checkout and confirmation, payments, returns and complaints, including the related confirmation pages.
Automatic tracking of page changes and clicks, automatic collection of form data and automatic matching of contact details are disabled. Only expressly configured data about permitted visits is transmitted. We do not send events for a requested consultation, order or complaint.
The limitations also cover page addresses and titles, the address of the previous page and the parameters of the events sent, so that no personal or sensitive information from excluded pages is transmitted through them. In the absence, refusal or withdrawal of consent, we do not send data through the relevant tool.
Google Analytics
If you allow analytics cookies and similar technologies, we use Google Analytics 4 for statistical analysis of visits to the predefined permitted pages. Data about the permitted visit, date and time, general information about the browser and device, and online identifiers that can link separate visits are processed. Page addresses and information about the source of the visit are limited in accordance with the measures described above. We do not use the service to track consultations, orders or complaints.
The provider of the service for the European Economic Area is Google Ireland Limited, and other companies in the Google group may also be involved in providing it. According to Google’s documentation, for visits from the European Union the IP address is used to determine approximate location and is then discarded before the data is recorded. However, this does not mean that the rest of the information collected is anonymous, as online identifiers may allow a browser or device to be recognised.
We do not send to Google Analytics the content of completed forms, your name, email address, telephone number or health information. We do not use the service to create advertising audiences or to link your visits to the contact details you have provided to us.
For individual user and event data, we have selected a retention period of 2 months. This setting does not determine the retention period of all aggregated statistical reports provided by the service. You can read more about how Google processes data in the information on how Google uses data from sites or apps that use its services and in the Google Privacy Policy.
Meta Pixel
If you allow marketing cookies and similar technologies, we use Meta Pixel on the predefined permitted pages to measure the effectiveness of our advertising on Facebook and Instagram and to show advertisements to relevant audiences. Only data about permitted visits, subject to the limitations described above, is used for these purposes.
When the Pixel is active, online identifiers, IP address, browser information, the address of the page visited and the time of the visit may be sent to Meta Platforms Ireland Limited. If Meta recognises you, it may link the information received to your Facebook or Instagram profile. The tool may also transmit information about visitors who do not have a profile on these platforms.
We do not provide Meta with the content of forms, names, email addresses, telephone numbers or information that reveals a health condition or disability. We do not use the Pixel in consultation forms and their confirmation pages, in the basket, at order checkout and confirmation, payment, returns or complaints. We also exclude from advertising tracking other pages or actions where information about them may reveal sensitive circumstances about the visitor.
For the collection and transmission of data through the Pixel, the purposes and means of which we determine jointly with Meta, SPARK VISION IS OOD and Meta act as joint controllers. Our responsibilities include selecting and configuring the tool on the Site, providing prior information and obtaining the necessary consent. The allocation of obligations is set out in the joint controller addendum with Meta. Notwithstanding this allocation, you can exercise your rights against each of the joint controllers.
For subsequent processing in which Meta independently determines the purposes and means, its privacy policy applies. There you will also find information about the data retention periods and criteria and the ways to exercise your rights. Further details about the cookies used by Meta are available in its cookie policy.
You can withdraw your consent to marketing technologies at any time through “Cookie settings” on our Site. Thereafter, Meta Pixel will not be used for further tracking through the Site in the relevant browser.
Who we share personal data with
Only those members of our team who need the information to perform their specific duties — for example, to respond to an enquiry, process an order or assist with a complaint — have access to your personal data.
For some of these activities we work with external providers and partners, to whom we provide only the data necessary for the relevant service. Who your data will be provided to depends on the specific order or request, including the chosen payment and delivery method and the after-sales service required. The table below describes the categories of recipients and the purposes for which they need access.
| Recipient | Why access is needed |
|---|---|
| The relevant seller | For processing and fulfilling the order, invoicing, consumer rights and service. The allocation between the two companies is described above. |
| Couriers and logistics partners - Speedy for Bulgaria and DPD for Romania | For delivery and return of shipments. The necessary recipient, contact and delivery details and information about the shipment are provided. For Romania, delivery is made to a selected pick-up point. |
| Banks, payment providers, First Investment Bank AD or another chosen lender | For payment, refunds and a requested purchase on instalments through Fibank for Bulgaria only. For their own banking activities and statutory obligations, banks act as independent controllers. |
| Automattic / WordPress.com | For providing the online shop platform and infrastructure. |
| Railway | For hosting and the technical operation of the Site; the region used is Amsterdam, the Netherlands. |
| Supabase | For operating the Site’s database, including data from the contact form and the consultation form; the region used is Ireland. |
| Titan — Flock FZ-LLC | For providing business email and the related correspondence. |
| Accounting and other technical providers | For the necessary accounting services, security and technical support, with access only to the data necessary for the relevant service. |
| Google and Meta | Where consent has been given and subject to the limitations described in the cookies section. |
| Legal advisers and competent authorities | Where there is a specific obligation, proceedings or a need to protect rights. |
Servicing is carried out by our team in accordance with the allocation of responsibilities between the companies described in this Policy. For this purpose we use the necessary data about the order, the product, the reported problem and the service actions carried out.
Our providers and partners may have different responsibilities for your personal data depending on the service they provide. Where they process data on our behalf and on our instructions, our relationship is governed by a contract that sets out the conditions of processing and their obligations to protect the information. Where they independently determine the purposes and means of processing, for example to comply with their own statutory obligations, they act as separate controllers and provide their own information about the use of the data. In both cases, we retain our responsibility for the lawful collection and disclosure of data on our part.
Transfers of data outside the EEA
We use the services of international providers, including Automattic/WordPress.com, Railway, Supabase, Titan, Slack, Google and Meta. In the provision of these services, personal data may be processed or accessed outside the European Economic Area, including through participating companies and subcontractors. The regions selected for hosting the Site with Railway and for the database with Supabase are Amsterdam, the Netherlands, and Ireland respectively. Locating the core infrastructure in the EU does not in itself rule out access or other processing outside the EEA.
When we transfer personal data outside the EEA, we comply with the requirements of Chapter V GDPR. Depending on the country and the recipient, the transfer may be based on a decision of the European Commission recognising the relevant level of protection as adequate, or on other appropriate safeguards. Such safeguards may be the standard contractual clauses approved by the European Commission, together with supplementary protection measures where necessary.
For transfers to the USA, we may rely on the EU–US Data Privacy Framework only to the extent that the relevant adequacy decision is in force and the recipient holds a valid certification covering the specific transfer. If you would like more information about the recipients, countries or applicable safeguards, you can write to us at customer.support@sparkvision.tech. You can also request a copy of the relevant safeguards at the same address.
The provision of data between the Bulgarian and the Romanian seller takes place within the European Union and does not constitute a transfer outside the EEA.
How long we keep your personal data
We keep your personal data for the period necessary for the purpose for which it was collected, also taking into account applicable statutory obligations. Therefore, different data and documents relating to a single purchase may have different retention periods. For example, the invoice must be kept for the period prescribed by law even after the delivery has been completed, whereas working copies and other information that is no longer needed are deleted earlier. The table below sets out the periods for the individual categories of data or the criteria by which we determine them.
| Data | Period or criterion |
|---|---|
| Enquiries and consultations without a subsequent purchase | Up to 12 months after the last substantive contact or the consultation held, whichever is later. An automatic reminder does not restart the period. |
| Orders and contractual service | For the fulfilment of the purchase and the applicable after-sales service. Thereafter, only the documents necessary for a statutory obligation or the protection of specific rights are set aside, in accordance with the following rows. |
| Returns, complaints and warranty service | Until the case is closed and the resulting obligations are fulfilled. Evidence that remains necessary for legal claims is kept for the applicable limitation period, including where a longer warranty is in effect. |
| Necessary evidence relating to the contract and claims | In accordance with the applicable limitation period; the general period is 5 years under Bulgarian law and 3 years under Romanian law, unless another period applies. The starting point depends on the specific claim. In the event of suspension, interruption or a pending dispute, only the relevant data is kept until the need ceases, including for the enforcement of the judgment given. |
| Accounting and tax documents of the Bulgarian seller | Accounting registers, financial statements and documents for tax control — 10 years, counted from 1 January of the following reporting period; for other accounting records — 3 years under Art. 12 of the Accountancy Act, unless another applicable rule requires longer retention. Invoices necessary for tax control fall within the first category. |
| Accounting registers and supporting documents of the Romanian seller | Under the general rule of Art. 25 of Romanian Accounting Law No. 82/1991 — 5 years, counted from 1 July of the year following the financial year in which they were drawn up, unless a specific applicable obligation exists. |
| Technical records for operation and security | Up to 90 days. Relevant records concerning a specific incident or dispute may be kept until the investigation and the necessary actions are completed. |
| Cookie choice and proof of consent | The choice in the browser — up to 6 months or until changed/deleted. The minimum proof of the choice, the date and the version — up to 12 months after the consent expires or is withdrawn. |
| Individual data in Google Analytics | 2 months according to the user and event setting. Irreversibly anonymised aggregates may be used thereafter. |
| Requests to exercise rights | Until the request is closed and up to 12 months after the final response or the last actions, whichever is later; in the event of a dispute — only the evidence necessary for its resolution. |
| Data about affiliates and affiliate codes used | Data about affiliate relationships is kept for the duration of the relationship and thereafter only to the extent necessary for applicable statutory obligations or legal claims. The code recorded against the order is kept in accordance with the period for the relevant order data. |
Where Meta processes data for purposes it determines independently, the retention periods are determined in accordance with its Privacy Policy, to which we have provided a link above. For our part, we do not create or maintain contact lists from forms and orders for building advertising audiences.
After the relevant period expires, we delete the personal data or anonymise it irreversibly so that it can no longer be linked to you. This procedure also covers copies stored in our business email or with providers that process data on our behalf.
For enquiries and consultations without a subsequent purchase, we apply automatic deletion in the database and deletion rules for the related correspondence in our business email. Internal notifications are deleted automatically no later than 12 months after they are sent. Only specific data for which there is a separate applicable statutory obligation or a need for the establishment, exercise or defence of legal claims is kept longer, in accordance with the periods and criteria in the table.
Deleted data may remain in backups for a limited period until it is removed according to the established schedule. These copies are not used for ongoing communication or service. If the system needs to be restored from a backup, we take the necessary steps to ensure that data whose retention period has already expired, or which was deleted for another reason, is deleted again.
Your rights
In connection with the processing of your personal data, you have the rights described below. You can exercise them regardless of whether you have made a purchase, sent an enquiry or only visited the Site. You do not need a customer account to do so. Each right applies subject to the conditions laid down in the GDPR, with the purpose, the legal basis and the circumstances of the specific processing being relevant.
Access to and rectification of data
You have the right to obtain confirmation as to whether we process your personal data and, if so, to request access to it and a copy. You can also obtain information about the purposes of the processing, the recipients of the data, the retention periods and the other circumstances provided for in the GDPR.
If you find that the data we hold is inaccurate or incomplete, you can ask us to correct or complete it.
Erasure of data
You can ask us to erase your personal data where there are grounds for doing so — for example, if it is no longer necessary for the purposes for which it was collected, if it has been processed unlawfully, or if you have withdrawn your consent and there is no other legal basis for us to continue the processing.
The right to erasure does not apply unconditionally. In certain cases we need to retain some of the data in order to comply with a legal obligation or to establish, exercise or defend legal claims. For example, a request for erasure does not override our obligation to keep accounting documents for the period prescribed by law. If we cannot comply with your request in whole or in part, we will explain the reasons to you.
Restriction of processing
In certain cases you can ask us to temporarily restrict the use of your data. This is possible where you contest its accuracy and time is needed for us to verify it, or where the processing is unlawful but you prefer the data to be kept with restricted use instead of being erased.
You can also request restriction where we no longer need the data but you need it for the establishment, exercise or defence of legal claims. You have the same right where you have objected to the processing, pending verification of whether our legitimate grounds override yours.
Where processing is restricted, we continue to store the data but use it for other operations only in the cases permitted by the GDPR. We will inform you before the restriction is lifted.
Data portability
Where we process data by automated means on the basis of your consent or a contract with you, you can request to receive the personal data you have provided in a structured, commonly used and machine-readable format. This allows you to provide it to another controller. Where technically feasible, you can ask us to transmit it directly to the controller you designate.
Objection to processing
Where processing is based on our legitimate interest, you have the right to object on grounds relating to your particular situation. Upon receipt of the objection, we will stop the relevant processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or that the data is necessary for the establishment, exercise or defence of legal claims.
If you object to the use of your data for direct marketing, we will stop processing for that purpose, including related profiling, without you needing to give reasons.
Withdrawal of consent
Where processing is based on your consent, you can withdraw it at any time. For analytics and marketing cookies and similar technologies, you can do this through “Cookie settings” on the Site. You can also contact us at the email address given below.
Withdrawal does not affect the lawfulness of processing carried out on the basis of your consent before its withdrawal.
How to exercise your rights
You can submit a request to customer.support@sparkvision.tech or to the address of the relevant controller given in this Policy. Describe what you would like us to do and provide sufficient information for us to establish which data your request relates to.
We will respond without undue delay and at the latest within one month of receiving the request. If its complexity or the number of requests received requires more time, the period may be extended by up to two further months. In that case, we will inform you within the first month and explain the reasons for the extension.
If we have reasonable doubts about the identity of the requester, we may request additional information necessary to confirm it. We do not automatically require a copy of an identity document for every request.
Exercising your rights is, as a rule, free of charge. If a request is manifestly unfounded or excessive, the GDPR allows us to charge a reasonable fee taking into account the administrative costs, or to refuse to act. In such a case, we will give reasons for our decision and inform you of the available remedies.
Complaint to a supervisory authority
If you believe that we are processing your personal data in breach of the applicable rules, you have the right to lodge a complaint with a competent supervisory authority. You do not need to contact us first in order to exercise this right.
In Bulgaria, you can contact the Commission for Personal Data Protection, address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, website: https://cpdp.bg, email: kzld@cpdp.bg.
In connection with processing by the Romanian seller, you can also contact the Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal (ANSPDCP), website: https://www.dataprotection.ro, email: anspdcp@dataprotection.ro.
You can also lodge a complaint with the competent supervisory authority in the EU country in which you habitually reside or work or in which the alleged infringement took place. Regardless of the right to lodge a complaint with a supervisory authority, you also have the right to a judicial remedy.
Automated decisions and profiling
We do not take decisions based solely on automated processing of your personal data which produce legal effects concerning you or similarly significantly affect you.
If you allow marketing cookies and similar technologies, the Meta advertising tracking described in the relevant section may involve profiling. This means that information about visits to the predefined permitted pages may be used to assess your presumed interests and to show you more relevant advertisements. You can withdraw your consent at any time through “Cookie settings”.
If you apply for a purchase on instalments, the assessment of your creditworthiness and the decision whether you receive financing are made by the relevant lender. We do not carry out this assessment and do not determine the conditions for approval. The lender provides separate information about how it processes your data, including whether it uses automated decisions or profiling, what the consequences are for you and how you can exercise your rights in relation to them.
How we protect your data
We apply technical and organisational measures to protect your personal data against loss, misuse, alteration and unauthorised access or disclosure. We tailor these measures to the nature of the data, the purposes of the processing and the possible risks to your rights and freedoms. They include limiting access to persons who need the information to perform their duties, managing granted access rights, protecting data in transit and incident response procedures.
As a rule, you do not need to send a copy of an identity document in order to contact us or exercise your rights. If there is reasonable doubt about your identity, we will request only the additional information necessary to confirm it.
When you send a device for repair, please do not provide passwords or personal files that are not necessary to identify and resolve the problem. If the diagnostics require access to specific data on the device, we will agree with you in advance what information is needed, what it will be used for and how access will be provided. Submitting a complaint or handing over the device for repair does not in itself constitute permission for unrestricted access to its contents.
Links to other services
The Site may contain links to services provided by other organisations, for example banks, payment service providers or manufacturers. When you move to such a service, the relevant organisation may collect and use personal data in accordance with its own purposes and obligations. We therefore recommend that you read its privacy policy before providing information or using the service.
References to the policies of other organisations help you understand how they process your data. They do not relieve us of responsibility for the personal data we collect, use or disclose, nor for the processing for which we act as joint controllers under the conditions described in this Policy.
Changes to the Policy
We may update this Policy when there are changes to the functionality of the Site, the way in which we process personal data or the applicable legal requirements. The current version will be available on this page, and we will indicate the date of its last update.
If the changes materially affect the way in which we use your personal data, we will notify you in an appropriate manner before they take effect, for example by means of a visible notice on the Site. Where new consent is required for the intended processing, we will request it separately. The mere publication of the updated Policy or continued use of the Site does not constitute such consent. Changes do not apply retroactively and cannot render lawful any processing that lacked the necessary legal basis at the time it was carried out.
Last updated: 12 October 2026