Privacy Policy

Last updated: 20 October 2026

This Privacy Policy explains how we process personal data when you use the sparkshare.eu website, the SparkShare webshop (webshop.sparkshare.eu), the SparkShare web portal (portal.sparkshare.eu), the SparkShare mobile app and the SparkShare chargers and network. We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR) and Croatian law.

1. Who we are

The controller of your personal data is SparkShare d.o.o. za informatičke usluge, Stjepana Radića 19a, 31000 Osijek, Croatia, OIB: 36562127189, registered at the Commercial Court in Osijek under MBS 030265519 (“SparkShare”, “we”).

The SparkShare mobile app is published on Google Play and the App Store by VACO d.o.o., Šandora Petefija 64, 31328 Lug, Croatia, a company of the same group. VACO d.o.o. develops the app and provides the cloud service the app runs on, and processes personal data only on SparkShare’s instructions.

For all questions and requests about personal data, contact us at info@sparkshare.eu or by post at the address above.

2. What data we collect and why

Website sparkshare.eu

• Contact form and e-mail: first and last name, company, e-mail address, phone number and your message, so that we can answer your enquiry or prepare an offer you asked for (legal basis: steps prior to entering into a contract and our legitimate interest in answering enquiries).
• Spam protection: the contact form uses Google reCAPTCHA, which analyses device and usage data to distinguish people from bots (legitimate interest in the security of the website).
• Statistics, images and fonts: we use Jetpack (Automattic) for aggregated visit statistics and fast image delivery, and Google Fonts for fonts. These services receive your IP address and technical browser data (legitimate interest in a secure, fast and well-maintained website).

Webshop

• Customer account and orders: name, company details (for business customers), delivery and billing address, e-mail address, phone number, ordered products and order and payment status, so that we can conclude and perform the purchase contract, deliver the goods and handle returns, complaints and warranty claims. You can pay by bank transfer or online by card (legal basis: contract; legal obligation for invoicing and accounting).

SparkShare app, web portal, chargers and network

• User account: e-mail address and/or phone number, name if you provide it, login data and device identifier, to create and protect your account and to let you log in to the web portal with the app (legal basis: contract).
• Charging and wallet: charging sessions (charger, time, energy in kWh and price), WTC token balance and transactions and COMC coupons, so that we can provide charging, payment and the exchange of WTC tokens between members, and issue invoices. You buy WTC by card; when you sell WTC, we pay the amount to your bank account, so we also process your IBAN (legal basis: contract; legal obligation).
• Charger owners: charger location and settings, consumption and charging data, the price you set and the WTC you earn, so that your charger can work in the network, appear on the network map and earn WTC for you (legal basis: contract).
• Location: only if you allow it in the app, your device location is used to show chargers near you on the map. You can turn location access off at any time in your phone settings (legal basis: consent).
• Contacts: the app accesses your phone contacts only if you allow it, and only to send a COMC coupon to a contact you choose (legal basis: consent).
• Support: messages you send us by e-mail, phone or in our community channels, so that we can help you (legal basis: contract and legitimate interest).
• Technical and security data: IP address, device and app version, error logs, charger diagnostic data and the status of over-the-air (OTA) updates, so that chargers and the platform stay safe and working (legal basis: contract and legitimate interest).

News and offers

We do not send newsletters yet. If we start, we will send news and offers only to those who have agreed to receive them, or to existing customers about similar products, and every message will include an easy way to unsubscribe (legal basis: consent or legitimate interest).

3. Who receives your data

We do not sell personal data. We share it only when necessary, with:

• VACO d.o.o. (app development and the app’s cloud service), Sedmi Odjel d.o.o. (hosting) and our other IT service providers;
• delivery services (e.g. DPD) for webshop orders;
• banks and card payment providers – card payments are processed by the card payment provider, and we do not receive your full card number;
• accountants, auditors and legal advisers;
• Google (reCAPTCHA, Google Fonts, Google Play), Apple (App Store) and Automattic (Jetpack), as described above;
• other members of the SparkShare network, only to the extent needed for the service – for example, a charger owner sees the charging sessions on their own charger;
• public authorities, when required by law.

4. Where we store data

The SparkShare platform (app, web portal and charger cloud) runs in data centres in the European Union, provided by Sedmi Odjel d.o.o. and VACO d.o.o. Some of the providers listed above (such as Google, Automattic and our website hosting provider) may process data outside the European Economic Area. In that case the transfer is protected by appropriate safeguards, such as the EU Standard Contractual Clauses or the EU–US Data Privacy Framework.

5. How long we keep data

• Account, app and charger data: as long as your account is active. When the account is closed, we delete or anonymise the data, except what we must keep by law.
• Invoices and accounting records: 11 years, as required by Croatian accounting law.
• Contact form and e-mail enquiries: up to 2 years after the last contact, unless they lead to a contract.
• Technical logs: only as long as needed for security and troubleshooting.

6. Your rights

Under the GDPR you have the right to:

• access your personal data and receive a copy;
• have inaccurate data corrected or incomplete data completed;
• have your data erased (“right to be forgotten”);
• restrict processing;
• data portability;
• object to processing based on legitimate interest, and to direct marketing at any time;
• withdraw your consent at any time, without affecting processing carried out before the withdrawal;
• lodge a complaint with the Croatian Personal Data Protection Agency (AZOP), Selska cesta 136, 10000 Zagreb, azop.hr.

Send your requests to info@sparkshare.eu. We will reply within one month and may ask you to confirm your identity first.

7. Deleting your SparkShare account

You can delete your SparkShare account at any time directly in the SparkShare app. If you cannot use the app, send an e-mail to info@sparkshare.eu with the subject “Delete account” from the e-mail address linked to your account, or state the phone number you use in the app. Before deleting, we recommend that you use or sell any remaining WTC tokens and coupons. We delete all personal data except what we must keep by law, such as invoices.

8. Cookies

The sparkshare.eu website uses only cookies that are needed for it to work (for example for logged-in site administrators) and cookies set by Google reCAPTCHA and Jetpack for security and statistics. We do not use advertising or social-media tracking cookies. You can delete or block cookies in your browser settings.

9. Security

We protect data with technical and organisational measures, including encrypted connections (HTTPS/TLS), access control and regular software updates. We require the same from our service providers.

10. Children

Our services are not intended for children under 16, and we do not knowingly collect their personal data.

11. Changes to this policy

We may update this Privacy Policy. The current version is always published on this page, and we will inform you about significant changes in the app or by e-mail.