Privacy Policy

When you contact us: we process the information you choose to provide, such as your name, business contact details, organisation, message and any files you send.

When you use the website: hosting and security systems may process technical data needed to deliver and protect the site, such as IP address, browser or device information, requested page, date and time, and security or diagnostic events.

The website has no contact form, user account, advertising technology or analytics service.

• To answer enquiries and take requested steps before entering a contract: performance of a contract or pre-contractual steps (GDPR Article 6(1)(b)).
• To manage business correspondence, relationships and service delivery: our legitimate interests in operating and developing our advisory business (Article 6(1)(f)).
• To operate, diagnose and secure the website and prevent misuse: our legitimate interests in reliable and secure systems (Article 6(1)(f)).
• To meet accounting, tax, regulatory or other legal duties: compliance with a legal obligation (Article 6(1)(c)).

We do not use website visitor data for automated decision-making or profiling.

We may share personal data only where necessary with website hosting, network security, email and IT providers; professional advisers supporting our work; a client or project counterparty where you ask us to coordinate; or a public authority where disclosure is legally required.

The website is hosted using OpenAI Sites, with network and security infrastructure that may be provided by Cloudflare. Some service providers may process data outside the European Economic Area. Where required, such transfers rely on an adequacy decision, Standard Contractual Clauses or another lawful safeguard.

We do not sell personal data.

SparkleLeaf does not use analytics, advertising or marketing cookies. The hosting or security network may set strictly necessary cookies or use similar technical measures to protect the site, manage traffic and prevent abuse. These functions are necessary for secure website delivery.

We keep enquiry and business correspondence only for as long as needed for the relevant relationship, requested service, dispute handling and applicable legal or accounting obligations. Technical logs are kept for the period reasonably necessary for security, diagnostics and service operation. We delete or anonymise data when it is no longer required.

Depending on the circumstances, you may request access, correction, deletion, restriction, portability, or object to processing based on legitimate interests. You may contact us at daniel.tong@sparkleleaf.com. We may need to verify your identity before acting on a request.

You also have the right to lodge a complaint with the Information Commissioner of the Republic of Slovenia or another competent supervisory authority.

We may update this policy when our website, services or legal obligations change. The date at the top identifies the current version.

If SparkleLeaf later adds forms, analytics, newsletters or other data-handling features, this policy will be updated before those features are used.