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Sparxity

Privacy Policy

Last updated: 23 October 2026

We operate our websites in accordance with the principles set out below:

We undertake to comply with the statutory provisions on data protection and endeavour to observe at all times the principles of data avoidance and data minimisation.

1. Name and Address of the Controller and of the Data Protection Officer

a) The Controller

The controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States of the European Union, as well as other provisions of data protection law, is:

SpiNNcloud Systems GmbH
Freiberger Str. 37
01067 Dresden
Telefon: +49 351 21 776-006
E-Mail: info@sparxity.ai
Website: sparxity.ai

b) The Data Protection Officer

You may contact the controller’s data protection officer as follows:

SiDIT GmbH, www.sidit.de, email: info@sidit.de

2. Explanation of Terms

We have designed our privacy policy in accordance with the principles of clarity and transparency. Should any ambiguities nevertheless arise regarding the use of various terms, the relevant definitions may be consulted here.

3. Legal Basis for the Processing of Data

a) Processing of Personal Data under the GDPR

We process your personal data such as your first name and surname, your email address, your IP address, etc. only where there is a legal basis for doing so. Under the General Data Protection Regulation, the following provisions in particular may apply:

  • Article 6(1)(1)(a) GDPR: The data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • Article 6(1)(1)(b) GDPR: Processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract.
  • Article 6(1)(1)(c) GDPR: Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Article 6(1)(1)(d) GDPR: Processing is necessary in order to protect the vital interests of the data subject or of another natural person.
  • Article 6(1)(1)(e) GDPR: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
  • Article 6(1)(1)(f) GDPR: Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child.

However, at the relevant points in this privacy policy we will always indicate the legal basis on which your personal data is processed.

b) Consent of a Person with Parental Responsibility under Article 8(1)(2), second alternative, GDPR

A person with parental responsibility must consent to all data processing operations carried out within the context of this website for which the consent of a minor who has not yet reached the age of 16 is required.

Information on the individual data processing operations, their purposes and the categories of data concerned for which the data subject’s consent is required can be found in this privacy policy.

You may withdraw your consent at any time by sending a declaration of withdrawal in text form to the contact details of the controller. Processing carried out up to the point of withdrawal remains lawful.

c) Processing of Information under Section 25(1) TDDDG

We also process information pursuant to Section 25(1) TDDDG (German Telecommunications Digital Services Data Protection Act) by storing information on your terminal equipment or accessing information already stored on your terminal equipment. This may concern both personal and non-personal data, such as cookies, browser fingerprints, advertising IDs, MAC addresses and IMEI numbers. Terminal equipment is any equipment connected directly or indirectly to the interface of a public telecommunications network for the purpose of sending, processing or receiving messages, Section 2(2) no. 6 TDDDG.

As a rule, we process this information based on your consent, Section 25(1) TDDDG.

Where an exception under Section 25(2) no. 1 and no. 2 TDDDG applies, we do not require consent. Such an exception applies where we access or store information solely for the purpose of transmitting a message over a public telecommunications network, or where this is strictly necessary in order for us to provide a telemedia service that you have expressly requested. You may withdraw your consent at any time.

We inform you that the withdrawal of consent does not affect the lawfulness of processing carried out on the basis of the consent up to the point of withdrawal.

4. Disclosure of Personal Data

The disclosure of personal data likewise constitutes processing within the meaning of section 3 above. At this point, however, we wish to inform you separately about the topic of disclosure to third parties. The protection of your personal data is a matter of great importance to us. For this reason, we exercise particular caution when it comes to disclosing your data to third parties.

Disclosure to third parties therefore takes place only where there is a legal basis for the processing. For example, we disclose personal data to persons or companies that act for us as processors pursuant to Article 28 GDPR. A processor is any party that processes personal data on our behalf — in particular, in a relationship in which it is subject to our instructions and control.

In accordance with the requirements of the GDPR, we conclude a contract with each of our processors in order to bind them to compliance with data protection law and thereby afford your data comprehensive protection.

5. Storage Period and Erasure

We erase your personal data where it is no longer necessary for the purposes for which it was collected or otherwise processed, and where the processing is not necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, or for the establishment, exercise or defence of legal claims.

6. SSL / TLS Encryption

For security reasons and in order to protect the transmission of confidential content, such as the enquiries you send to us as the website operator, this website uses SSL / TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the padlock symbol in your browser line.

When SSL / TLS encryption is activated, the data you transmit to us cannot be read by third parties.

7. Cookies

On our website we use cookies. Cookies are small data packets that your browser automatically creates and that are stored on your end device when you visit our website. These cookies serve to store information in connection with the particular end device used.

In the use of cookies, a distinction is drawn between technically necessary cookies and “other” cookies. Technically necessary cookies are those that are strictly necessary in order to provide an information society service that you have expressly requested.

a) Technically Necessary Cookies

In order to make the use of our offering more convenient for you, we use technically necessary cookies; these may be so-called session cookies (e.g. language and font selection, shopping basket, etc.), consent cookies, cookies to ensure server stability and security, or similar. The legal basis for these cookies is Article 6(1)(1)(f) GDPR, our legitimate interest in the error-free operation of the website and our interest in providing our services to you in an optimised manner.

8. Collection and Storage of Personal Data and the Nature and Purpose of Its Use

a) External Hosting

Our website is hosted with Vercel Inc., 440 N Barranca Ave #4133, Covina, CA 91723, United States (USA). For this reason, all personal data collected on our website is stored on the servers of our host, unless an external third-party service is integrated. This may concern the IP address, your email address, communication data or similar. The specific personal data concerned is set out below in connection with the individual functions and services we explain.

Should we use an external third-party service, this is made clear in the description of the respective service or tool. The host processes your data only on our instructions and only insofar as this is necessary to perform the services on the website. The host does not process the data for its own purposes. We have concluded a data processing agreement with it.

b) When Visiting the Website

When our website is accessed, the browser used on your end device automatically sends information to the server of our website. This information is temporarily stored in a so-called log file. The following information is collected in this process without any action on your part and stored until it is automatically erased:

  • IP address of the requesting computer
  • date and time of access
  • name and URL of the file retrieved
  • website from which access is made (referrer URL)
  • browser used and, where applicable, the operating system of your computer, as well as the name of your access provider

We process the aforementioned data for the following purposes:

  • ensuring a smooth connection to the website
  • ensuring convenient use of our website
  • evaluating system security and stability
  • error analysis
  • for further administrative purposes.

Data that permits conclusions to be drawn about your person, such as the IP address, is erased after 7 days at the latest. Should we store the data beyond this period, the data is pseudonymised so that it can no longer be attributed to you. The legal basis for the data processing is Article 6(1)(1)(f) GDPR. Our legitimate interest follows from the purposes of data collection listed above. We do not under any circumstances use the data collected for the purpose of drawing conclusions about your person.

c) External Content Hosting by Sanity

We use the Sanity service to store and deliver the content of our website, such as text and images. Each time you access a page that loads such content, a direct connection to Sanity’s servers is established in order to display it.

The provider of this service is Sanity AS, Trondheimsveien 2K, 0560 Oslo, Norway.

When the connection to these servers is established, technically necessary data such as your IP address and information about your browser are transmitted to the provider. As Sanity’s corporate group also includes a company based in the United States, the processing of data in the United States cannot be ruled out.

The legal basis for this data processing is our legitimate interest in providing our online content in a professional and secure manner pursuant to Article 6(1)(f) GDPR.

We have concluded a data processing agreement with Sanity in accordance with Article 28 GDPR. This agreement ensures that the provider processes the data only in accordance with our instructions. Further information can be found in Sanity’s privacy policy at: https://www.sanity.io/legal/privacy

9. Rights of the Data Subject

You have the following rights:

a) Access

Pursuant to Article 15 GDPR, you have the right to request access to the personal data concerning you that we process. This right of access includes information about:

  • the purposes of the processing
  • the categories of personal data
  • the recipients or categories of recipients to whom your data has been or will be disclosed
  • the planned storage period or at least the criteria used to determine that period
  • the existence of a right to rectification, erasure, restriction of processing or objection
  • the existence of a right to lodge a complaint with a supervisory authority
  • the origin of your personal data, where it was not collected from us
  • the existence of automated decision-making, including profiling, and, where applicable, meaningful information about the details thereof

b) Rectification

Pursuant to Article 16 GDPR, you have the right to obtain the rectification without undue delay of inaccurate or incomplete personal data stored by us.

c) Erasure

Pursuant to Article 17 GDPR, you have the right to request the erasure without undue delay of your personal data held by us, insofar as further processing is not necessary for one of the following reasons:

  • the personal data is still necessary for the purposes for which it was collected or otherwise processed
  • for exercising the right of freedom of expression and information
  • for compliance with a legal obligation which requires processing under the law of the European Union or of the Member States to which the controller is subject, or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
  • for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) and Article 9(3) GDPR
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, insofar as the right referred to under section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing
  • for the establishment, exercise or defence of legal claims

d) Restriction of Processing

Pursuant to Article 18 GDPR, you may request the restriction of the processing of your personal data for one of the following reasons:

  • You contest the accuracy of your personal data.
  • The processing is unlawful and you oppose the erasure of the personal data.
  • We no longer need the personal data for the purposes of the processing, but you require it for the establishment, exercise or defence of legal claims.
  • You have objected to the processing pursuant to Article 21(1) GDPR.

e) Notification

Where you have requested the rectification or erasure of your personal data, or a restriction of processing, pursuant to Article 16, Article 17 or Article 18 GDPR, we will notify all recipients to whom your personal data has been disclosed, unless this proves impossible or involves disproportionate effort. You may request that we inform you of these recipients.

f) Portability

You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format. You also have the right to request that this data be transmitted to a third party, provided that the processing was carried out by automated means and is based on consent pursuant to Article 6(1)(1)(a) or Article 9(2)(a), or on a contract pursuant to Article 6(1)(1)(b) GDPR.

g) Withdrawal

Pursuant to Article 7(3) GDPR, you have the right to withdraw at any time any consent you have given to us. The withdrawal of consent does not affect the lawfulness of processing carried out on the basis of the consent up to the point of withdrawal. Going forward, we may no longer continue the data processing that was based on your withdrawn consent.

h) Complaint

Pursuant to Article 77 GDPR, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes the GDPR.

i) Objection

Where your personal data is processed on the basis of legitimate interests pursuant to Article 6(1)(1)(f) GDPR, you have the right, pursuant to Article 21 GDPR, to object to the processing of your personal data, insofar as there are grounds for doing so arising from your particular situation, or where the objection is directed against direct marketing. In the latter case, you have a general right to object, which we will implement without the need to state any particular situation. If you wish to exercise your right of withdrawal or objection, an email to info@sparxity.ai is sufficient.

j) Automated Individual Decision-Making, Including Profiling

You have the right not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning you or similarly significantly affects you. This does not apply where the decision:

  • is necessary for entering into, or the performance of a contract between you and us
  • is authorized by law of the European Union or of the Member States to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and your legitimate interests
  • is based on your explicit consent

However, such decisions may not be based on special categories of personal data under Article 9(1) GDPR, unless Article 9(2)(a) or (g) GDPR applies and suitable measures to safeguard your rights and freedoms and your legitimate interests have been taken.

With regard to the cases referred to in (i) and (iii), we take suitable measures to safeguard your rights and freedoms and your legitimate interests, which include at least the right to obtain human intervention on our part, to express your point of view and to contest the decision.

10. Amendment of the Privacy Policy

Should we amend this privacy policy, this will be indicated on the website.