Effective Date: 31.12.2024
Last Updated: 31.12.2024

1. Introduction

This Marketing and Communications Policy (“Policy”) describes how Spark Link, s.r.o. (“we,” “us,” or “our”) collects, processes, stores, and uses personal information for marketing, promotional, and communication purposes, in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the California Consumer Privacy Act (“CCPA”) as amended.

By providing your personal information and giving explicit consent, you agree to the practices described in this Policy and in our general Privacy Policy.

2. Scope of Personal Information Collected

We collect the following categories of personal information for marketing and communications purposes:

• Full name

• Email address

• Mobile or telephone number

• Communication preferences

• Other identifiers that you voluntarily provide

Personal information is collected through various channels, including but not limited to: online forms, account registrations, newsletter subscriptions, event participations, direct inquiries, and promotional campaigns.

3. Purpose of Processing
Subject to your explicit, informed consent, your personal information is collected and processed for the following purposes:

To send you promotional communications about our products, services, special offers, and news via email, SMS, or other electronic means. To distribute newsletters, announcements, and educational or informational content. To personalize and tailor marketing communications based on your interactions and preferences. To improve our marketing practices and measure the effectiveness of our campaigns.

We process your personal data based on your affirmative consent under Article 6(1)(a) of the GDPR and, where applicable, as a “business purpose” under the CCPA.

4. Lawful Basis for Processing

We rely on the following lawful bases to process your personal information:

Consent: You have provided clear, explicit consent for us to process your personal data for the specified marketing purposes.
Legitimate Interests (where permitted): In some cases, where allowed by law and without overriding your rights, we may rely on our legitimate interest to promote our services.

5. Consent Mechanisms

Consent must be freely given, specific, informed, and unambiguous. You affirm your consent through clear affirmative action, such as:

Checking an opt-in box on a form.Signing up for newsletters or promotional offers.Providing your email address or phone number with an acknowledgment of this Policy.

You may withdraw your consent at any time without penalty. Withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

6. Right to Opt-Out / Withdraw Consent

You have the right to opt out of receiving marketing communications at any time by:

Clicking the “unsubscribe” link in marketing emails.Replying “STOP” to SMS marketing messages.Contacting us at [email protected].

Upon receipt of an opt-out request, we will promptly update our records and cease further marketing communications within the legally required time frame.

7. No Sale or Disclosure of Personal Information

We do not sell, lease, rent, or share your personal information with third parties for their independent commercial purposes.

We may disclose your information only to authorized service providers who assist in delivering our communications, and such disclosure is subject to strict confidentiality and data processing agreements in compliance with GDPR and/or CCPA requirements.

Under the CCPA, you have the right to request information about the categories and specific pieces of personal information we collect and the purposes for which they are used.

8. Data Storage and Retention

Your personal information is stored securely and is retained only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by applicable law or regulatory requirements.

Upon withdrawal of your consent, or upon exercising your “right to erasure” under GDPR (or equivalent rights under CCPA), we will securely delete or anonymize your personal information.

9. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Right to Access: Obtain confirmation and a copy of the personal information we hold about you.

• Right to Rectification: Request correction of inaccurate or incomplete personal information.

• Right to Erasure (“Right to be Forgotten”): Request deletion of your personal information, subject to legal exceptions.

• Right to Restrict Processing: Request a restriction on further processing of your data.

• Right to Data Portability: Receive a copy of your personal information in a commonly used, machine-readable format.

• Right to Object: Object to the processing of your personal information for marketing purposes.

• Right to Non-Discrimination: You will not be discriminated against for exercising your privacy rights under the CCPA.

To exercise any of these rights, please contact us at [email protected].

10. International Data Transfers
If you are located outside of Slovakia or US, please note that your personal information may be transferred to, stored, and processed in a country that may not have the same level of data protection as your jurisdiction.

Where required, we implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission.

11. Changes to This Policy

We reserve the right to modify or update this Policy at any time to reflect changes in our practices, legal requirements, or for other operational reasons.

We encourage you to review this Policy periodically. Your continued provision of personal information or continued receipt of marketing communications constitutes your agreement to any revised terms.

12. Contact Information

If you have any questions, concerns, or wish to exercise your rights under this Policy, please contact us at:

Email:

[email protected]