Privacy Policy
Sparrks Service GmbH
1. Name and contact details of the controller and the company data privacy officer
This data privacy information applies to data processing by
Data controller: SPARRKS Service GmbH ("sparrks"), Schönhauser Allee 167c, 10435 Berlin,
Local Court Charlottenburg (Berlin),HRB 226047 B, represented by the managing directors Jakob Hansen and Dr. Nicolas Stephan
The external data protection officer of sparrks is Prof. Dr. Reinhold Mauer, who can be contacted at datenschutz@sparrks.de.
2. Collection and storage of personal data and the nature and purpose of their use
a) When visiting the website
When you visit our website www.sparrks.io, the browser used on your 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 without any action on your part and stored until it is automatically deleted
- IP address of the requesting computer,
- Date and time of access,
- Name and URL of the accessed file,
- the website from which access was made (referrer URL)
- browser used and, if applicable, the operating system of your computer and the name of your access provider.
The aforementioned data is processed by us for the following purposes
- Ensuring a smooth connection to the website,
- Ensuring a comfortable use of our website,
- evaluating system security and stability and for other administrative purposes.
- zu weiteren administrativen Zwecken.
The legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest follows from the data collection purposes listed above.
In addition, we use cookies and analysis services when you visit our website. You can find more detailed explanations in sections 4 and 5 of this privacy policy.
b) When using our contact form
For questions of any kind, we offer you the opportunity to contact us via a form provided on the website. It is necessary to provide a valid e-mail address so that we know who sent the request and can answer it. Further information can be provided voluntarily.
Data processing for the purpose of contacting us is carried out in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR on the basis of your voluntarily given consent.
The personal data collected by us for the use of the contact form will be automatically deleted after your request has been processed.
3. transfer of data
Your personal data will not be transferred to third parties for purposes other than those listed below.
We only pass on your personal data to third parties if:
- you have given your express consent to this in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR,
- the disclosure pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR is necessary for the assertion, exercise or defense of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data,
- in the event that there is a legal obligation for the disclosure pursuant to Art. 6 para. 1 sentence 1 lit. c GDPR, and
- his is legally permissible and necessary for the processing of contractual relationships with you in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR.
4. Cookies
We use cookies on our website. These are small files that your browser automatically creates and that are stored on your end device (laptop, tablet, smartphone, etc.) when you visit our website. Cookies do not cause any damage to your end device and do not contain any viruses, Trojans or other malware.
Information is stored in the cookie that results in each case in connection with the specific end device used. However, this does not mean that we obtain direct knowledge of your identity.
On the one hand, the use of cookies serves to make the use of our website more convenient for you. For example, we use so-called session cookies to recognize that you have already visited individual pages of our website. These are automatically deleted after you leave our site.
In addition, we also use temporary cookies to optimize user-friendliness, which are stored on your end device for a specified period of time. If you visit our site again to use our services, it is automatically recognized that you have already visited us and which entries and settings you have made so that you do not have to enter them again.
On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you (see section 5). These cookies enable us to automatically recognize that you have already visited our website when you visit it again. These cookies are automatically deleted after a defined period of time.
The data processed by cookies is required for the purposes mentioned to protect our legitimate interests and those of third parties in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR.
Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a message always appears before a new cookie is created. However, completely deactivating cookies may mean that you cannot use all the functions of our website.
5. Analysis tools
a) Tracking tools
The tracking measures listed below and used by us are carried out on the basis of Art. 6 para. 1 sentence 1 lit. f GDPR. With the tracking measures used, we want to ensure a needs-based design and the continuous optimization of our website. On the other hand, we use the tracking measures to statistically record the use of our website and to evaluate it for the purpose of optimizing our offer for you. These interests are to be regarded as legitimate within the meaning of the aforementioned provision.
The respective data processing purposes and data categories can be found in the corresponding tracking tools.
Google Tag Manager
- What personal data is collected and to what extent is it processed? On our website, we use the service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google Tag Manager). Google Tag Manager provides a technical platform for executing and controlling other web services and web tracking programs in a bundled manner by means of so-called "tags". In this context, Google Tag Manager stores cookies on your computer and, if web tracking tools are executed using Google Tag Manager, analyzes your surfing behavior (so-called "tracking"). This data sent by individual tags integrated into Google Tag Manager is merged, stored and processed by Google Tag Manager under a uniform user interface. All integrated "tags" are listed separately in this privacy policy. You can find more information on data protection for the tools integrated in Google Tag Manager in the relevant section of this privacy policy. When using our website with activated integration of Google Tag Manager tags, data such as your IP address and your user activities are transmitted to servers of Google Ireland Limited. With regard to the web services integrated via Google Tag Manager, the regulations in the respective section of this privacy policy apply. The tracking tools used in Google Tag Manager ensure that the IP address of Google Tag Manager is anonymized before transmission by means of IP anonymization of the source code. Google Tag Manager only enables the anonymized collection of IP addresses (so-called IP masking).
- Legal basis for the processing of personal data The legal basis for data processing is your consent in our information banner regarding the use of cookies and web tracking (consent through clear confirmatory action or behavior) in accordance with Art. 6 para. 1 lit. a GDPR.
- Purpose of data processing On our behalf, Google will use the information obtained via Google Tag Manager to evaluate your visit to this website, to compile reports on website activity and to provide us with other services relating to website activity and internet usage.
- Duration of storage Google will store the data relevant for the function of Google Tag Manager for as long as it is necessary to fulfill the booked web service. Data collection and storage is anonymized. If there is any personal reference, the data will be deleted immediately, provided that it is not subject to any statutory retention obligations. In any case, the deletion takes place after expiry of the retention obligation.
- Objection and deletion option You can prevent the collection and forwarding of personal data to Google (in particular your IP address) and the processing of this data by Google by deactivating the execution of script code in your browser, installing a script blocker in your browser or activating the "Do Not Track" setting in your browser. You can also prevent Google from collecting the data generated by the Google cookie and relating to your use of the website (including your IP address) and from processing this data by Google by clicking on the following link http://tools.google.com/dlpage/gaoptout?hl=de download and install the available browser plug-in. You can find Google's security and data protection principles at https://policies.google.com/privacy .
Google Analytics
- Scope of the processing of personal data On our website, we use the web tracking service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter: Google Analytics). As part of web tracking, Google Analytics uses cookies that are stored on your computer and enable an analysis of the use of our website and your surfing behavior (so-called tracking). We carry out this analysis on the basis of the Google Analytics tracking service in order to constantly optimize our website and make it more accessible. When you use our website, data, in particular your IP address and your user activities, are transmitted to servers of Google Ireland Limited. We carry out this analysis on the basis of Google's tracking service in order to constantly optimize our website and make it more accessible. We also require web tracking for security reasons. Web tracking enables us to track whether third parties are attacking our website. The information from the web tracker enables us to take effective countermeasures and protect the personal data processed by us from these cyber attacks. By activating IP anonymization within the Google Analytics tracking code of this website, your IP address will be anonymized by Google Analytics before transmission. This website uses a Google Analytics tracking code that has been extended by the operator gat._anonymizeIp(); to enable only anonymized collection of IP addresses (so-called IP masking).
- Legal basis for the processing of personal data The legal basis for data processing is your consent in our information banner regarding the use of cookies and web tracking (consent through clear confirmatory action or behavior) in accordance with Art. 6 para. 1 lit. a GDPR.
- Purpose of data processing Google will use this information on our behalf to evaluate your visit to this website, to compile reports on website activity and to provide us with other services relating to website activity and internet usage. We also require web tracking for security reasons. Web tracking allows us to track whether third parties are attacking our website. The information from the web tracker enables us to take effective countermeasures and protect the personal data processed by us from these cyber attacks.
- Duration of storage Google will store the data relevant for the provision of web tracking for as long as it is necessary to fulfill the booked web service. Data collection and storage is anonymized. If there is any personal reference, the data will be deleted immediately, provided that it is not subject to any statutory retention obligations. In any case, the deletion takes place after expiry of the retention obligation.
- Objection and deletion options You can prevent the collection and forwarding of personal data to Google (in particular your IP address) and the processing of this data by Google by deactivating the execution of script code in your browser or activating the "Do Not Track" setting in your browser. You can also prevent Google from collecting the data generated by the Google cookie and relating to your use of the website (including your IP address) and from processing this data by Google by clicking on the following link ( http://tools.google.com/dlpage/gaoptout?hl=de ) and install the available browser plug-in. You can find Google's security and data protection principles at https://policies.google.com/privacy?hl=de .
HubSpot CRM
- Wir nutzen das CRM-Tool von Hubspot Inc. 2 Canal Park, Cambridge, MA 02141, Vereinigte Staaten.
- HubSpot is an integrated software solution that can be used to cover various online marketing activities. This includes, for example, our website content management, email marketing, social media publishing & reporting, contact management, as well as the provision of any landing pages and contact forms.
- Our registration service allows our website visitors to find out more about our company. You can also download content and provide your contact information and other demographic information. This information and the content of our website is stored on the servers of our software partner HubSpot and can be used by us to contact our website visitors. We also use the information to determine which of our company's services are of interest to you.
We use HubSpot on the basis of your consent in accordance with Art. 6 para. 1 lit. a) GDPR. We use HubSpot Forms on the basis of our legitimate interest in accordance with Art. 6 para. 1 lit. f) GDPR, whereby our legitimate interest lies in the provision of any contact forms and simplified communication with interested parties. We would like to point out that when using HubSpot Forms, there is no personal tracking as with HubSpot itself. - HubSpot is a software company from the USA. HubSpot Inc. relies on EU standard contractual clauses to legitimize the transfer of data to the USA: https://legal.hubspot.com/dpa
- Further information on data protection can be found in HubSpot's privacy policy: HubSpot privacy policy, HubSpot information on the EU GDPR, information on the Cookies used by HubSpot.
6. Rights of data subjects
You have the right:
- to request information about your personal data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right to lodge a complaint, the origin of your data if it was not collected by us, and the existence of automated decision-making including profiling and, if applicable, meaningful information about its details;
- in accordance with Art. 16 GDPR, to immediately request the correction of incorrect or incomplete personal data stored by us;
- in accordance with Art. 17 GDPR, to demand the deletion of your personal data stored by us, unless the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest or to assert, exercise or defend legal claims;
- in accordance with Art. 18 GDPR, to demand the restriction of the processing of your personal data if the accuracy of the data is disputed by you, the processing is unlawful but you refuse to delete it and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have lodged an objection to the processing in accordance with Art. 21 GDPR;
- in accordance with Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transmitted to another controller
- in accordance with Art. 7 para. 3 GDPR, to withdraw your consent once given to us at any time. As a result, we may no longer continue the data processing that was based on this consent in the future and
- to lodge a complaint with a supervisory authority in accordance with Art. 77 GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters.
7. Right of objection
If your personal data is processed on the basis of legitimate interests in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR, you have the right to object to the processing of your personal data in accordance with Art. 21 GDPR, provided that there are reasons for this arising from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right to object, which will be implemented by us without specifying a particular situation.
If you would like to exercise your right of revocation or objection, simply send an e-mail to datenschutz@sparrks.de.
8. Data security
We use the widespread SSL (Secure Socket Layer) method in conjunction with the highest level of encryption supported by your browser when you visit our website. As a rule, this is 256-bit encryption. If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead. You can tell whether an individual page of our website is transmitted in encrypted form by the closed display of the key or lock symbol in the lower status bar of your browser.
We also use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.
9. Up-to-dateness and amendment of this privacy policy
This privacy policy is currently valid and was last updated in March 2024.
It may become necessary to amend this privacy policy as a result of the further development of our website and services or due to changes in legal or official requirements. The current privacy policy can be viewed at any time on the website at https://www.sparrks.io/datenschutzerklaerung can be retrieved and printed out by you.
1. Data protection officer
The person responsible within the meaning of data protection laws, particular the EU General Data Protection Regulation (DSGVO), is:
Dr. Nicolas Stephan Co-Founder & Managing Director SPARRKS Service GmbH, Schönhauser Allee 167c, 10435 Berlin, Germany
You can reach him at +49 (0)30 52014961 or by email at nicolas.stephan@sparrks.de.
2. Your data subject rights
You can exercise the following rights at any time using the contact details provided by our data protection officer:
- Information about your data stored by us and its processing (Art. 15 DSGVO)
- Correction of inaccurate personal data (Art. 16 DSGVO)
- Deletion of your data stored by us (Art. 17 DSGVO)
- Restriction of data processing if we are not yet allowed to delete your data due to legal obligations (Art. 18 DSGVO)
- Objection to the processing of your data by us (Art. 21 DSGVO)
- Data portability, provided you have consented to the data processing or have concluded a contract with us (Art. 20 DSGVO)
If you have given us consent, you can revoke it at any time with effect for the future.
You may at any time lodge a complaint with a supervisory authority, e.g. the competent supervisory authority in the federal state of your residence or the authority responsible for us as the responsible body. A list of supervisory authorities (for the non-public sector) with address can be found at: > https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html
For reasons of better readability, the masculin form is used in the following for personal names and personal nouns. Corresponding terms apply in principle to all genders for the purposes of equal treatment.
3. Addition Privacy Policy for Coaches
3.1 Disclosure of certain data to the user
Users are the employees of our clients who have booked our coaching. We call the employees of our clients who have booked our coaching "users". When we suggest you as a coach for a user, we share the following information about you with the user: practice experience, education, and personal information. You provide this information to us yourself.
3.2 Disclosure of certain data to the coaches
When a user chooses you for coaching, we share the following information about the user with you: First name, last name, language, employer, position, work experience, leadership experience, concerns.
You may not use the user's data for any purpose other than to fulfill the specific coaching assignment; any processing beyond this is prohibited. After the coaching has ended, it is contractually stipulated that you delete all personal data related to the user.
We process all of the above data in order to properly fulfill our contracts concluded with you and with our clients regarding the coaching of the user (Article 6(1)(b) DSGVO).
3.3 Disclosure of certain data to our customers
During the contractual relationship, we will provide our respective client with the first and last name of all coaches who have conducted a coaching session.
4. Additional privacy policy for users
4.1 Disclosure of certain data to coaches
In order to provide appropriate coaching, we will disclose the following data to one or more appropriate coaches from our selective coach pool:
First name, last name, language, employer, position, work experience, concern information, suggested dates. We do not ask for special personal data, especially health data, and do not protect them separately if they become known.
The coaches do not process this data for any other purpose than the fulfillment of the specific coaching assignment; any processing beyond this is prohibited. It is contractually stipulated that the coaches delete all personal data relating to a particular user after the coaching has been completed.
4.2 Deletion of personal data
We collect all of the above mentioned personal data in order to be able to fulfill our user support contracts concluded with customers as agreed (Article 6(1)(b) DSGVO). We delete this data immediately upon corresponding requests from the users as soon as we receive them at info@sparrks.de.
Insofar as we have included names or pseudonyms in invoices for billing purposes at the instruction of the customers, these invoice components cannot be deleted before the expiry of the tax retention period.
5. Contacting by e-mail
If you contact us by email, we will process your message together with your contact details (name, email address and any other information added by your email client and the servers that transmit your email).
This data processing is based on our legitimate interest to respond to your request and to process any follow-up messages (Article 6(1)(f) DSGVO). We will delete this data immediately in response to corresponding requests as soon as we receive them at info@sparrks.de.
Our mail servers work with TLS and SSL, which means that the data transfer between your mail servers and ours is encrypted as long as your email provider supports at least one of these features.
6. Processors and other recipients of personal data
- Google Cloud Platform: Frankfurt datacenter (europe-west3)
- INWX GmbH, Prinzessinnenstr. 30, 10969 Berlin, Germany
7. Cookies
7.1 General
Like many other websites, we also use so-called cookies. Cookies are small text files that are stored on your laptop, tablet, smartphone or similar when they visit our website.
You can delete individual cookies or the entire cookie inventory. In addition, you will receive information and instructions on how to delete cookies or block their storage in advance. Depending on the browser provider, you can find the necessary information under the following links:
- Mozilla Firefox: https://support.mozilla.org/de/kb/cookies-loeschen-daten-von-websites-entfernen
- Internet Explorer: https://support.microsoft.com/de-de/help/17442/windows-internet-explorer-delete-manage-cookies
- Google Chrome: https://support.google.com/accounts/answer/32050?hl=de&co=GENIE.Platform%3DDesktop
- Opera: http://www.opera.com/de/help
- Safari: https://support.apple.com/kb/PH17191?locale=de_DE&viewlocale=de_DE
7.2 Use of cookies
We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.
The following data is stored and transmitted in the cookies:
- Language settings
- Frequency of page views
- Use of website functions
The data collected in this way is pseudonymized by technical precautions. Therefore, an assignment of the data to the calling user is no longer possible. The data will not be stored together with other personal data of you.
When you access our website, you will be informed about the use of cookies for analysis purposes and your consent to the processing of personal data used in this context will be obtained. In this context, a reference to this privacy policy is also made.
7.3 Technically necessary cookies -type and purpose of processing
8. Legal basis and legitimate interest
8.1 Provision mandatory or required
The provision of the aforementioned personal data is not required by law or contract. However, without this data, the service and functionality of our website cannot be guaranteed. In addition, individual services and services may not be available or may be limited.
In this regard, we refer to our information about your right to object according to Art. 21 DSGVO below.
8.2 Data processing
The processing is carried out in accordance with Art. 6 para. 1 letter f DSGVO on the basis of our legitimate interest in a user-friendly design of our website.
Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website.
9. Contact Formular
9.1 Nature and purpose of processing
9.2 Legal basis
The processing of the data entered in the contract form is based on a legitimate interest (Art. 6 para. 1 letter f DSGVO).
By providing the contact form, we would like to enable you to contact us in an uncomplicated manner. The information you provide will be stored for the purpose of processing the request and for possible follow-up questions.
If you contact us to request a quote, the data entered in the contact form will be processed for the implementation of pre-contractual measures (Art. 6 para. 1 letter b DSGVO).
9.3 Recipient
9.4 Duration of storage
If there is a contractual relationship, we are subject to the statutory retention periods under the German Commercial Code (HGB) and delete your data after these periods have expired.
9.5 Provision mandatory or required
10. Use of Google Analytics
10.1 General
Insofar as you have given your consent, this website uses Google Analytics, a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (hereinafter: Google). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, due to the activation of IP anonymization on these web pages, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.
You can find more information on terms of use and data protection at https://www.google.com/analytics/terms/de.html und unter https://policies.google.com/?hl=de.
On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.
The data send by us and linked to cookies, user IDs (e.g. user ID) or advertising IDs are automatically deleted after 14 months. The deletion of data whose retention period has been reached takes place automatically once a month.
10.2 Withdrawal of consent
You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link:
Browser Add On to disable Google Analytics.
11. SSL-encryption
12. Information about your right of objection after Art. 21 DSGVO
Right to object on a case-by-case basis
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(f) DSGVO (data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Art. 4 No. 4 DSGVO.
If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.
13. Change of our privacy policy
We reserve the right to adapt this data protection declaration on an ongoing basis so that it always complies with the current legal requirements or in order to implement changes to our services in the data protection declaration, e.g. when introducing new services. The adapted data protection declaration will then apply to your renewed contact.
