Privacy Policy

Welcome to Sparring (“we”, “us” and “Sparring”)! Sparring provides legal and strategic support for technology startups and visionaries (“you”). This Privacy Policy (the “Privacy Policy”) is intended to inform you about our practices regarding the collection and use of your data that you may submit to Sparring through our websites including www.sparring.io, https://playbook.sparring.io/ and https://us.sparring.io/ (“Websites”) and when we are providing legal and strategic advice (“Services”). Please read this Privacy Policy carefully!

1. This Privacy Policy was last amended on May 5th 2023. From time to time, we will change the Privacy Policy (particularly with respect to changes in legislation). However, we will keep you informed of any material changes to the Privacy Policy. The updated version can always be found on our Website.
2. We process your personal data in accordance with all applicable laws and regulations, including Regulation (EU) 2016/679 of the European Parliament and of the Council, the General Data Protection Regulation (the “GDPR”) and the California Consumer Privacy Act (the “CCPA”).
3. This Privacy Policy only covers data collection and processing carried out by us. This Privacy Policy does not address, and we are not responsible for, the privacy practices of any other third parties which our Websites or Services may link to.
4. We do not knowingly collect or ask for information from persons under the age of 16. We delete information that we learn is collected from a person under the age of 16 without verified consent of their parent or legal guardian.
5. If you wish to learn more about the processing and protection of your personal data or if you have any further questions, you can contact us at hello@sparring.io.

1. Who processes your personal data?
   1. We provide legal services in the respective jurisdictions by equity partners and/or associated attorneys with requisite qualifications and via the following legal entities:
      1. Sparring, s.r.o., advokátní kancelář, with its registered seat at Perlová 371/5, 11000, Praha 1, Czech Republic, , ID.: 092 83 285, registered with the Czech Bar Association.
      2. Law & Tech s.r.o., advokátska kancelária, with its registered seat at Rooseveltova 809/22, 040 01 Košice – Staré Mesto, Slovak Republic, ID.: 53 004 621, registered with the Slovak Bar Association.
      3. SPARRING LEGAL LLP, with its registered seat at 477 Madison Avenue, 6th Floor, New York, 10022 New York, United States, File Number: 220203000248.
   2. Your personal data is processed by the entity which provides legal services to you.
   3. If we do not provide legal services to you but still collect and process your personal data for the below mentioned purposes, or you receive consultancy services from us, your personal data is processed via the following legal entities:
      1. Sparring s. r. o., with its registered seat at Žižkova 13, 040 01 Košice – Juh, Slovak Republic, ID.: 52 325 369.
2. What personal data is processed?
   We may collect the following types of information about you:
   1. Personal Data
      In particular, we may collect and process your first name, surname, contact information (e.g., your email address), your company details, invoicing and payment details, any message content, and any personal information which you voluntarily provide when using our Websites or Services.
   2. Usage and Analytical Data
      We collect technical information when you visit or interact with our Websites. Technical data may include, in particular, the time and date of user visits, clicks on our Websites, IP address, the browser name, the type of computer or device accessing our service, time spent on the Websites and other similar technical information. We request users to opt in to this tracking through a cookie banner.
   3. Cookies
      1. What are cookies?
         1. To make our Websites work properly, to ensure security, and to optimise them for our users, we sometimes place small data files called cookies and similar technologies on your device.
         2. A cookie is a small text file that the website saves on your device when you visit it. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Permanent cookies last until you or your browser delete them or until they expire.
      2. What cookies do we use?
         1. We use essential functional cookies, specifically WordPress cookies, which are necessary for the functioning of the Website, to help it work better and allow users to have a better experience when using it such as remembering your cookie preferences and prevent bots. These functional cookies expire after 1 year.
         2. We also use analytical cookies to measure the usage of the Websites. The providers of these cookies are:
            • Google LLC. Cookies used by Google for Google Analytics, to prevent fraud, and to prevent malicious attacks expire after 1 year
            • Google LLC. Cookies used for Google Ads optimization expire after 2 months or sooner.
            • Google LLC. Cookies used for spam prevention expire after 6 months.
            • Contentsquare. The Hotjar cookie expires after 1 month.
      3. How to control cookies?
         1. We will inform you about the use of cookies on your device when you visit our website for the first time and, if applicable, we ask for your consent to use the cookies. The cookies will not be used for any purposes other than the ones stated above.
         2. You can deactivate or delete non-essential cookies at any time by withdrawing your consent to their processing by changing the settings on our website. You can also prevent your web browser from accepting cookies by configuring the settings in your web browser.
3. What are the purposes and legal bases for processing of your personal data for European residents?
   1. To fulfill your request
      We will process your personal data to allow us to perform the contract that exists between us, as a result of your decision to use the service we offer through our Websites. This includes, but is not limited to, replying to your message regarding cooperation, processing an application to an open position and providing legal documents.For this purpose, we may process: your name, surname, contact details (e-mail address), content of your message.Legal basis for such processing: performance of a contract in accordance with Art. 6 (1)(b) GDPR.
   2. To provide our Services
      We will process your personal data to allow us to perform the contract that exists between us, as a result of your decision to cooperate with Sparring. This includes, but is not limited to, storing your personal data in our company database, and processing your data upon your instructions.Our processing of personal data when we are providing Services is governed by the agreement made between you and Sparring.For this purpose, we may process: your name, surname, contact details (e-mail address, phone number), your company details, invoicing and payment details, content of our communication via different channels, information related to the provided Services.

      Legal basis for such processing: performance of a contract in accordance with Art. 6 (1)(b) GDPR.

   3. To improve our Websites
      If consented to, we will process your usage and analytical data outlined under 2.2 to allow us to track your usage and use analytics to improve our Websites. You can opt out at any time through your browser settings. More information can be found in Section 2.3.Legal basis for such processing: consent to processing of personal data in accordance with Art. 6 (1)(a) GDPR.
   4. To keep you informed
      If consented to, we will process your contact information to allow us to send you updates and our newsletters. You can change your preferences and opt out at any time.For this purpose, we may process: your name, surname, contact details (e-mail address).Legal basis for such processing: consent to processing of personal data in accordance with Art. 6 (1)(a) GDPR.
   5. To develop our Services and extend our know-how
      We want to grow and learn and provide you with the best possible Services and customer experience. Thus we process your data for knowledge sharing among our entities specified in Section 1 above  and for development of our business activities.For this purpose, we process mostly the following categories of your personal data: your name, surname, contact details (e-mail address, phone number), your company details, content of our communication via different channels, information related to the provided Services.Legal basis for such processing: legitimate interest to develop our business and our know-how in accordance with Art. 6 (1)(f) GDPR.
   6. Fulfill legal obligations
      We will process your personal data to fulfill legal requirements imposed on us by applicable laws (e.g. tax laws, AML laws, fraud prevention laws, data protection laws).The scope of personal data we process for this purpose depends on the requirements imposed on us by the public authorities and by applicable law.Legal basis for such processing: compliance with a legal obligation to which we are subject in accordance with Art. 6 (1)(c) GDPR.
4. Who are recipients of your personal data?
   1. We do not share your personal data with any recipient outside the group of Sparring entities mentioned in Section 1 above, except in the following circumstances:
      1. Sharing is necessary for legal reasons. We may share your personal data with other recipients if we have a bona fide belief that access to and use of your personal data is reasonably necessary to: (i) comply with any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, property or safety of Sparring, our users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
      2. Sharing is necessary for provision of legal services. We may share your personal data with our partnering law firms in other jurisdictions, if it is necessary for the purpose of provision of legal services to you. These law firms process your data as independent controllers and are bound by the duty of confidentiality imposed on them by the locally applicable laws. We will inform you about such processing and will provide you with the details of the respective partner law firm in advance. We may also share your data with our suppliers providing us with supporting services necessary for our operation (e.g., accounting and finance related services, IT services, HR and people management services, etc.).
      3. Sharing is necessary for operational purposes. We may share your personal data with our external suppliers, who provide us with various services, which are crucial for our operation and delivery of our services. These include mainly providers of IT services, cloud and email solutions and AI-related services, providers of communication tools, providers of tax, accounting and financial reporting services, providers of crypto payment-related services, providers of marketing-related and event organizing services and providers of time management and operational services. As these external suppliers process your data as our processors, we share your data with them upon checking their data protection standards and concluding data processing agreements. When required, we also ensure that EU Standard Contractual Clauses are in place.
5. Do we transfer your data to countries outside the EU/EEA?
   1. For European residents, personal data is collected and processed by Sparring, s.r.o., advokátní kancelář, Law & Tech s.r.o., advokátska kancelária, and  Sparring s.r.o. depending on the services you receive.
   2. We transfer your personal data to countries outside the European Union and the European Economic Area where we engage with external service providers. In such a case, we transfer your personal data only to a country that is considered to have an adequate level of protection in accordance with the EU Commission’s decision or there are appropriate safeguards in place to protect your personal data, such as standard contractual clauses or binding internal company rules. Regardless of the country in which your personal data is processed, we take reasonable technical, legal and organisational measures to ensure that the level of protection is the same as in the European Union and the European Economic Area. If you wish to know more about international transfers of your personal data and the appropriate safeguards that we have in place to govern the transfer of your personal data, you may contact us through email at hello@sparring.io.
   3. If we are involved in a merger, acquisition or other restructuring, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your options.
6. For how long do we store your personal data?
   1. We only store your personal data if it is legally permitted and necessary for the purposes for which they were collected. Unless the deletion of your data is against the law or we need it in accordance with our legitimate business interests (e.g. to prevent fraud, to fulfill anti-money laundering requirements, to defend our claims), your data will be deleted from our repositories and systems within three years of their acquisition.
7. What are your rights?
   1. Right of access – We offer you access to your personal data we process. This means you can contact us and request from us a confirmation whether or not your personal data is being processed and if so, you have the right to request access to your data, which we will provide to you in the form of a so-called “registry” (stating, in particular, purposes, categories of personal data, categories of recipients of personal data, storage periods or criteria for determining storage periods).
   2. Right to rectification – You have the right to have inaccurate personal data we have stored about you rectified.
   3. Right to erasure – You may also ask us to erase your personal data from our systems. We will comply with such requests unless we have legitimate grounds to not delete your personal data.
   4. Right to restriction of processing – You may request us to restrict certain processing of your personal data. If you restrict certain processing of your personal data, this may lead to decreased functionality of using our Website.
   5. Right to data portability – You have the right to receive your personal data from us in a structured, commonly used and machine-readable format in order to transmit the personal data to another controller.
   6. Right to object processing – When we process your personal data based on our legitimate interest or for direct marketing purposes, you may object to such processing.  We can process your personal data further if we can demonstrate the compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.
   7. Right to withdraw your consent – When we process your personal data based on your consent, you have the right to withdraw such consent at any time. Please note that the withdrawal of your consent does not affect legality of the processing previously performed based on the originally granted valid consent.
   8. Rights related to automated decision making and profiling – We do not use automated decision-making or profiling for the outlined purposes of data processing. However, if you have been subject to an automated decision and do not agree with the outcome, you can contact us using the details below and ask us to review the decision in a non-automated manner.
   9. Californian residents also have the following rights when their personal data is processed by us:
      1. Right to equal services without discrimination – You have the right to recieve equal services and not be discriminated against if you withhold your personal data.
   10. How to use your rights – You may exercise your aforementioned rights, free of charge, by sending an email to hello@sparring.io. We may require confirmation of your identity depending on your request.
8. Can I complain?
   1. If you believe that the processing of your personal data is not in accordance with the relevant legal regulations concerning the protection of personal data, you can file a complaint with the relevant data protection supervisory authority.
9. Is my data safe?
   1. We take all reasonable and appropriate security measures to protect us and you from unauthorized access or unauthorized alteration, disclosure or destruction of the personal data we process. Measures include possible encryption, firewalls, secure devices and access rights systems. Should security breaches that are likely to adversely affect your privacy occur despite security measures, we will notify you as soon as possible. If you have any questions, do not hesitate to contact us at hello@sparring.io.