Privacy Policy

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.

You can contact us at:

This website does not set or read cookies, and it does not use advertising, marketing or tracking technologies.

It uses a small amount of session-based browser storage, which is technically distinct from cookies and is cleared automatically when the browser tab is closed:

• spark-disclaimer-ack (sessionStorage) — records that you have confirmed the website notice for the current browser tab, so that the notice is not shown again on every page. The stored value is the single character “1” and contains no personal data.
• tsr-scroll-restoration-v1_3 (sessionStorage) — set by the website's routing library to restore the scroll position of pages you have already viewed in the same tab. It contains scroll coordinates only.

The language selector does not store a preference: the selected language is expressed only in the address of the page (English at the site root, French under /fr, German under /de).

You can clear this storage at any time through your browser's privacy or site-data settings, and closing the tab removes it. Further detail is set out on the Cookie Preferences page.

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.

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.

This website does not collect investor onboarding, anti-money-laundering or know-your-customer information. Any such processing arises separately in connection with an investment in the Fund and is governed by the Fund's own documentation, not by your use of this website.

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.

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.

This website does not use website analytics, tag-management, advertising, retargeting, social-media tracking or session-recording services. Google Analytics is not installed.

There are no embedded video players, maps, social feeds, chat tools or third-party form widgets on this website. Links to external material, including news articles and videos hosted on other platforms, are ordinary outbound links: no third-party content is loaded and no data is shared with those platforms unless you choose to follow the link, after which the destination site's own privacy policy applies.

Typefaces are self-hosted and served from this website's own domain. Loading a page therefore contacts no external font service, content-delivery network or other third-party host.

The enquiry form on the Contact page sends your message to us by email. The information you enter — enquiry type, name, organization, email address, country, subject and message — is transmitted to our servers and forwarded to the Spark+ team so that we can respond to you. It is not written to any database and is not stored on this website.

The legal basis for this processing is our legitimate interest in responding to enquiries addressed to us, and, where relevant, taking steps at your request prior to entering into a contract. Providing the information is voluntary, but we cannot reply without at least your email address and message.

Email delivery is carried out on our behalf by a transactional email provider acting as processor. Your enquiry is retained in our email systems only for as long as needed to handle it and to keep a record of our correspondence, after which it is deleted in accordance with our internal retention practice.

To limit automated abuse, the form includes a hidden field that ordinary visitors never see and never complete, and submissions are rate-limited using a short-lived, non-identifying value derived from your IP address. No cookie or browser storage is used for this, and the derived value is not retained after the limiting period expires.

Please do not send confidential, sensitive or special-category information through the form. You may also contact us directly using the email address given in this policy.