PRIVACY POLICY

About Spark Vision AB and this privacy policy

Spark Vision AB, Reg. No. 556656-7029, Johannefredsgatan 1, 431 53 Mölndal, Sweden (“Spark Vision” or “we”) develops and sells products within the field of 3D visualisation and digital interaction. We produce photorealistic CG visuals and have invented software products.

As part of our business, Spark Vision processes personal data for which Spark Vision is the data controller. This means that Spark Vision is responsible for ensuring that the processing of personal data is carried out in accordance with applicable law and this privacy policy. We take necessary measures to ensure that your personal data is processed in a lawful, fair and transparent manner.

It is important to us that you feel comfortable with how we process your personal data. This privacy policy contains information about how we process personal data and it is important that you read and understand it before using any of our services. If you do not approve of this privacy policy, you should not use our services.

If you have any questions regarding our processing of your personal data, please contact us using the contact details provided below.

Please note that our website may contain links to third-party websites. These websites have their own privacy policies and Spark Vision is not responsible for their business or information policies. We recommend reviewing those privacy policies before submitting any personal data.

What personal data do we collect and where from?

Depending on the context, the personal data we collect may include:

• Name and contact information including address, mobile number and email address
• Job applications including cover letters, résumé and photos (when applicable)
• Username and password for our online services and desktop software
• Delivery and billing information, payment information and other information provided in connection with purchasing or delivering a product or service
• Other information relevant for customer surveys, marketing or offers

We may collect personal data from the following sources:

• When you contact us by email or phone
• Through Spark Vision’s website (for example when subscribing to a newsletter, requesting information or submitting a job application)
• Through agreements, invoices or business contact when you are a customer or a contact person for a business partner
• From third parties such as public records or business partners

What personal data are processed, for which purpose, legal basis and retention period?

1. Purchase of our services

Access to our software services

Purpose
We collect personal data to provide users with access to our software services.

Personal data processed
Email address, company/employer, license information and possibly name.

Legal basis
Legitimate interest in fulfilling obligations towards customers by giving users access to software services, including user account administration and monitoring usage.

Retention period
For as long as the agreement regarding the software is ongoing.

Software usage and support

Purpose
To analyse how the software is used and provide support and guidance based on user statistics.

Personal data processed
User statistics from a specific user within the software.

Legal basis
Legitimate interest in ensuring customers can fully use the software and its features.

Retention period
For as long as the software agreement is ongoing.

Accounting and invoicing

Purpose
To store invoice documentation in accordance with accounting laws.

Personal data processed
Information on invoices such as name and contact details provided by your company.

Legal basis
Compliance with legal obligations.

Retention period
During the agreement and for seven years after the fiscal year in which the invoice was issued.

2. Customer service or other communication

Customer support

Purpose
To provide customer service and respond to inquiries.

Personal data processed
Name, contact details, address and other information provided during phone or email communication.

Legal basis
Legitimate interest in providing customer service.

Retention period
For as long as necessary to answer and follow up on your inquiry.

Business communication

Purpose
To communicate with contact persons at customer companies and manage business transactions.

Personal data processed
Name, organisation, position, phone number and email.

Legal basis
Legitimate interest in communicating with customer contacts.

Retention period
As long as you are a contact person for a company doing business with Spark Vision. If the data is included in an agreement it may be stored for ten years after termination due to Swedish limitation law.

3. Newsletter and marketing

Email marketing and newsletters

Purpose
To send marketing emails, newsletters and customer surveys.

Personal data processed
Name and contact details submitted on our website.

Legal basis
Consent.

Retention period
Until consent is withdrawn.

Customer relationship marketing

Purpose
To market services and maintain relationships with customers.

Personal data processed
Name, contact details and details regarding purchased products.

Legal basis
Legitimate interest.

Retention period
Up to five years after the business relationship ends, unless you object to marketing.

4. Recruitment

Purpose
To manage recruitment processes.

Personal data processed
Application documentation including name, contact details, CV, cover letter and photo.

Legal basis
To fulfil obligations related to potential employment agreements.

Retention period
During the recruitment process and for two years afterwards to defend potential legal claims.

5. Product development

Purpose
To improve and develop products.

Personal data processed
Software usage data including statistics on end-user behaviour.

Legal basis
Legitimate interest in improving products.

Retention period
During the agreement period. After termination the data will be aggregated and anonymised.

Transfer of personal data

Spark Vision only transfers personal data as described below and does not sell personal data to third parties.

Transfers to data processors may include:

• Business partners who require access to fulfil obligations relating to your purchase
• Third-party service providers such as IT services, cloud hosting, payment services, CRM systems, delivery services and recruitment services

These providers may only use the data for the services they provide on our behalf.

Transfers to independent data controllers may include:

• Compliance with legal obligations (for example disclosure to authorities)
• Business transactions such as mergers or acquisitions where personal data may be transferred to new owners

Transfer of personal data outside the EU/EEA

Personal data may in certain cases be transferred outside the EU/EEA.

When this happens, Spark Vision ensures appropriate safeguards such as:

• Transfers to countries approved by the European Commission as providing adequate protection
• Standard contractual clauses approved by the European Commission
• Binding corporate rules approved by supervisory authorities

You may request a copy of these safeguards by contacting Spark Vision.

Withdrawal of consent

If we process your personal data based on consent, you may withdraw your consent at any time. You can do so by contacting us using the contact details below or by using the unsubscribe link in marketing emails.

Your rights

Under applicable law you have several rights regarding your personal data.

These include:

Right to information and access

You may request confirmation of whether we process your personal data and request a copy of the data we hold.

Right to rectification

You may request correction of incorrect or incomplete personal data.

Right to erasure (right to be forgotten)

You may request deletion of personal data when certain conditions apply.

Right to object

You may object to processing based on legitimate interest or direct marketing.

Right to restriction of processing

You may request that the processing of your personal data be restricted in certain circumstances.

Right to data portability

You may request that personal data you have provided be transferred in a structured digital format.

Right to withdraw consent

You may withdraw consent at any time.

Right to complain

You may file a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten).

Changes to this privacy policy

This privacy policy may be updated when necessary. Updated versions will be published on Spark Vision’s website.

Contact

If you have any questions regarding this privacy policy, please contact:

Spark Vision AB
Johannefredsgatan 1
431 53 Mölndal
Sweden

Email: gdpr@spark-vision.com