Privacy policy
Last updated 9 October 2026 · Version 1.0 · Effective 9 October 2026
This policy explains how Sparkline Markets (“we”, “us”) handles personal data when you visit https://sparkline.markets (the “Site”) or write to us.
In short: we collect only what you send us through the contact form or by email, and the technical data every web server records. We use no cookies, no analytics, no advertising and no third-party content. We do not sell your data.
1. Who is responsible
The controller is the publisher of Sparkline Markets, a project in formation that has not yet been incorporated. Its full legal identification will be added here as soon as the company is established.
Privacy contact: legal@sparkline.markets, or the Site’s contact form (topic “Other”).
We have not appointed a Data Protection Officer.
2. What we collect, why, and on what basis
- Data: the topic you choose (Investors, Partnerships, Press or Other), your name, email address and message, the date and time we received it (UTC) and a random reference number we assign. We also receive anything else you choose to include in your message, such as your firm or role.
- Source: you.
- Purpose: to read and answer your enquiry and follow up on it, including any discussion you ask for about a possible investment, partnership or other agreement.
- Legal basis: our legitimate interest in answering messages sent to us (Art. 6(1)(f) GDPR) and, where your enquiry concerns a possible agreement with you, steps taken at your request before entering into it (Art. 6(1)(b) GDPR).
- Is it required? Contacting us is optional. If you use the form, all four fields are needed so that we can reply.
- By email: if you write to legal@sparkline.markets, we receive your email address, name and message, and the usual email data (date, subject). The same purposes, legal bases, retention and recipients apply.
- Anti-spam: the contact service uses your IP address only in its working memory, to limit how many messages can be sent per hour (our legitimate interest in protecting the form from abuse, Art. 6(1)(f) GDPR). It never stores your IP address with your message and erases it from memory one hour after the last message sent from that address. Like every request to the Site, your form submission is also recorded in our server logs, with your IP address, for no more than 15 days (see below). The form also contains a hidden field that only automated bots fill in.
Please do not send sensitive information (such as health data or political opinions), passwords or financial account details. If you send such information anyway, we use it only to reply and delete it with your message.
When you exercise your rights
We keep your request and our reply to show that we handled it (legal obligation, Art. 6(1)(c) GDPR), for up to 5 years after we close it. We delete any proof of identity once checked.
When you visit the Site (server logs)
- Data: IP address, date and time, the page or file requested, HTTP status code, browser user agent and referring page (referrer). If a request fails or is blocked, an error entry with similar data.
- Source: your browser sends this automatically with every request, including when you submit the form.
- Purpose: to deliver the Site, keep it secure (detect and block abuse and attacks) and fix technical problems.
- Legal basis: our legitimate interest in operating and securing the Site (Art. 6(1)(f) GDPR).
We do not use logs to profile visitors or combine them with other data, except to investigate a specific security incident or where the law requires it.
We have weighed these legitimate interests against your rights: the data is minimal, expected for any website and kept briefly.
Your right to object. You may object at any time, on grounds relating to your particular situation, to our use of your data based on legitimate interests (contact messages and server logs). Write to legal@sparkline.markets. We will stop unless we have compelling legitimate grounds or need the data for legal claims.
3. How long we keep it
- Contact messages and our replies (form or email): kept for 24 months after receipt, then deleted, automatically on our server and through a monthly clean-up of our mailbox. If an ongoing relationship requires it, such as an active discussion or an agreement, we keep them for as long as that relationship lasts, then only as long as needed to meet legal obligations or to establish, exercise or defend legal claims.
- Rights requests: your request and our reply, for up to 5 years after we close it. Proof of identity is deleted once checked.
- Server logs: no more than 15 days, then deleted automatically.
- Anti-spam counters: held in working memory only, never saved, and erased one hour after the last message sent from the same IP address.
4. Who receives it
- Our team: only the people who handle your enquiry.
- OVH SAS (Roubaix, France): our hosting provider, which runs our server, and routes email sent to our domain, on our behalf in the European Union.
- Yahoo: the email service on which we receive and answer your messages, whether sent through the form or to legal@sparkline.markets. Yahoo processes mailbox content under its own terms and privacy policy (legal.yahoo.com).
- Professional advisers bound by confidentiality, such as lawyers or auditors, where needed.
- Authorities or courts, where the law requires it or to establish, exercise or defend legal claims.
We do not sell, rent or trade personal data, and we do not share it for advertising.
5. Transfers outside Europe
Our server is in the European Union. Our email service provider (Yahoo) may transfer data outside the European Economic Area, including to the United States. Such transfers rely on a European Commission adequacy decision (such as the EU-US Data Privacy Framework, where the recipient is certified) or, otherwise, on Standard Contractual Clauses (Art. 46 GDPR). To obtain a copy of, or more information about, these safeguards, write to legal@sparkline.markets.
6. Your rights
Under the GDPR, and equivalent laws such as the UK GDPR and the Data Protection (Jersey) Law 2018, you can:
- access your data and get a copy;
- have inaccurate or incomplete data corrected;
- have your data erased;
- restrict how we use it;
- object at any time, on grounds relating to your situation, to processing based on our legitimate interests; we will then stop unless we have compelling legitimate grounds or need the data for legal claims;
- receive the data you gave us in a structured, machine-readable format and have it sent to someone else (portability), where we process it for steps before an agreement;
- withdraw your consent at any time where we rely on it (we currently do not);
- give instructions on what happens to your data after your death.
You can also complain to a supervisory authority:
- the authority of the country where you live or work, or where you believe the infringement took place: for example the CNIL in France (www.cnil.fr), the ICO in the United Kingdom (ico.org.uk) or the Jersey Office of the Information Commissioner (jerseyoic.org); the list of EU and EEA authorities is at edpb.europa.eu.
7. How to exercise your rights
Write to legal@sparkline.markets, or use the contact form (topic “Other”), and tell us what you would like us to do.
To protect your data, we check that the request comes from you, usually by replying to the email address you used to contact us. We ask for more only if we have reasonable doubts, and we delete any proof of identity once checked.
We answer within one month. For complex or numerous requests we may extend this by two further months; if so, we will tell you why within the first month. Requests are free unless they are manifestly unfounded or excessive.
8. No automated decisions
We make no decisions about you based solely on automated processing, and we do not profile visitors.
9. Children
The Site is not directed to anyone under 18, and we do not knowingly collect data from them. If you believe a minor has sent us personal data, contact us and we will delete it.
10. Security
The Site is served only over HTTPS (with HSTS) using TLS 1.2 or higher, under a strict Content Security Policy, on a hardened server. The contact service runs in isolation with restricted permissions; its message file can be read only by that service and our administrators, and its system log records reference numbers and delivery status, never message content. No system is perfectly secure. If a breach affecting your data occurs, we will notify the CNIL and you where the law requires.
11. Cookies and similar technologies
The Site sets no cookies and uses no similar technologies: no local or session storage, no tracking pixels, no fingerprinting, no analytics, no advertising and no social media widgets. Every file, fonts included, is served from our own server, so your browser contacts no third party when you visit.
Because we store nothing on, and read nothing from, your device beyond what is strictly needed to display the Site, no consent is required and we show no cookie banner.
We respect Global Privacy Control and Do Not Track signals; as we track nothing, there is nothing further to switch off. If this ever changes, we will update this policy first and ask for your consent before using any non-essential cookie or tracker.
No third party collects personal information about your online activities over time or across other websites through our Site.
12. United Kingdom and Switzerland
If you are in the United Kingdom, we give you the rights in section 6 as they apply under the UK GDPR and the Data Protection Act 2018, and you may complain to the Information Commissioner’s Office (ico.org.uk).
If you are in Switzerland, the Federal Act on Data Protection (FADP) gives you similar rights, and you may complain to the Federal Data Protection and Information Commissioner (edoeb.admin.ch).
Both countries recognise the EU as providing adequate protection. Any onward transfer to the United States follows section 5, using the UK and Swiss equivalents of those safeguards where applicable.
13. United States residents
California
The California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA), applies only to businesses above certain size thresholds. To the extent it applies to us, and in any event as a matter of policy, this section is our notice at collection and privacy policy for California residents.
Collected in the last 12 months:
- Identifiers: name, email address, IP address.
- Internet or network activity: pages and files requested, date and time, browser user agent, referrer.
- Professional information, only if you include it in your message, and anything else you choose to write.
We do not intentionally collect sensitive personal information and do not use any to infer characteristics about you.
Sources: you, and your browser.
Business purposes: answering your enquiries; security and integrity; debugging; operating the Site.
Disclosed for a business purpose: identifiers, internet activity and any professional information in your message, to our hosting provider, our email service provider and professional advisers bound by confidentiality, and to authorities or courts where the law requires.
No sale or sharing: we do not sell personal information or share it for cross-context behavioral advertising, have not done so in the last 12 months, and have no actual knowledge of selling or sharing data of anyone under 16. We do not disclose personal information to third parties for their direct marketing.
Retention: see section 3.
Your rights: to know and access the categories and specific pieces of personal information we hold; to delete it; to correct it; to opt out of sale and sharing (there is none; we honour Global Privacy Control); to limit the use of sensitive personal information (we use none); and not to be discriminated or retaliated against for exercising any of these rights.
How: write to legal@sparkline.markets or use the contact form. We confirm receipt within 10 business days and respond within 45 days, which we may extend once by 45 days with notice. We verify requests by matching the email address you used to contact us. An authorized agent may act for you with your signed permission; we may confirm directly with you.
Nevada
We do not sell covered information. You may still send a request not to sell to legal@sparkline.markets.
Other US states
Whether or not your state’s privacy law applies to us, wherever you live in the United States you can ask us to confirm whether we hold your personal data and to access, correct or delete it, or to receive a portable copy. We do not sell personal data, use it for targeted advertising, or profile you. Use the contact details above. If we decline your request, you can appeal by replying to our decision with “Appeal”; we will answer within 45 days. If we deny your appeal, you may contact your state Attorney General.
14. Other countries
We apply this policy to everyone, wherever they are. If you live elsewhere, for example in Canada, Brazil or Australia, you may have rights under your local law; we will respond to requests in line with that law, and you may complain to your local authority (for example the Office of the Privacy Commissioner of Canada or Brazil’s ANPD). Data is processed as described in section 5.
15. Changes to this policy
We may update this policy. The version and effective date at the top show the latest change. Before a material change, such as a new purpose or the use of cookies or trackers, takes effect, we will make it clear on the Site.
16. Contact
Sparkline Markets · legal@sparkline.markets