Version: September 2025

1. Controller

This Privacy Policy applies to the processing of personal data by:

Brightness Subscriptions BV
Graftermeerstraat 22C
2131AC Hoofddorp
The Netherlands
CoC: 81921985
VAT: NL862270480B01
E-mail: privacy@sparklecloud.ai

2. Personal Data We Process

We process the following categories of personal data:
- First and last name
- Company name and contact details
- Email address and telephone number
- Billing and payment details
- Login details (username and password – encrypted)
- Platform usage data (IP address, logins, module usage)

3. Purposes of Processing

We process personal data for the following purposes:
- To provide and deliver the SparkleCloud.AI service
- To manage customer accounts and billing
- To provide customer support
- To improve our services
- To comply with legal obligations

4. Legal Basis

We process personal data based on:
- Performance of a contract
- Consent (e.g., for marketing newsletters)
- Legal obligations (e.g., accounting and tax compliance)
- Legitimate interests (e.g., usage statistics to improve services)

5. Data Retention

- Personal data is retained for as long as the customer relationship continues.
- After termination of the Agreement, administrative data will be retained for a maximum of 7 years in accordance with statutory requirements.

6. Sharing with Third Parties

We only share personal data with third parties when necessary for our services or when legally required. This includes:
- Hosting and cloud providers (e.g., AWS/Google Cloud)
- Payment providers (e.g., Mollie/Stripe)
- Analytics tools (e.g., Google Analytics – if applicable)

We have data processing agreements in place with these parties to ensure proper protection of personal data.

7. Security

We take appropriate technical and organizational measures to protect personal data against loss, misuse, or unauthorized access. These include:
- Data encryption
- Access control and password protection
- Regular backups

8. Rights of Data Subjects

You have the right to:
- Access your personal data
- Request correction or deletion of your data
- Request restriction of processing
- Object to processing
- Request data portability

Requests may be sent to privacy@sparklecloud.ai.

9. Complaints

If you have a complaint about the processing of your personal data, you may contact us at privacy@sparklecloud.ai.
You also have the right to file a complaint with the Dutch Data Protection Authority via www.autoriteitpersoonsgegevens.nl.