Privacy Policy

This policy allows us to establish and ensure compliance with applicable rules regarding the processing of Personal Data and to provide the necessary information about the rights of Data Subjects in this context.

SPARK CAPITAL, LDA, a legal entity with registration number 514 202 238, headquartered at Avenida da Liberdade, 108 – 5º 1250-146 Lisbon, is the entity that, under a transparent Privacy Policy, has implemented efficient and effective measures that ensure the protection and confidentiality of Personal Data, limited to authorized purposes, collected, and processed under the General Data Protection Regulation (EU) 1016/679) and other applicable national legislation, strictly adhering to the rights of the User / Data Subject.

SPARK CAPITAL, LDA reserves the right to change the Privacy Policy at any time, updating it on the website, providing the User / Data Subject with direct access to this information.

For any clarification regarding the Privacy Policy and the exercise of Data Subject rights, please contact us via email:

Data Controller:

SPARK CAPITAL, LDA Avenida da Liberdade, 108 – 5º 1250-146 Lisbon Phone: 21 346 16 96 Email: info@sparkcapital.pt

Data Protection Officer

SPARK CAPITAL, LDA Avenida da Liberdade, 108 – 5º 1250-146 Lisbon Phone: 21 346 16 96 Email: info@sparkcapital.pt

Collection and Processing of Personal Data

Generally, the personal data collected and processed includes the full name, photograph, place of birth, nationality, date of birth, identification document number and validity, marital status, tax identification number, address, email, and phone/mobile number. Additionally, other data may be requested, namely: educational qualifications, professional status, employer name, financial information, investor profile, money laundering, and terrorism financing risk.

Personal Data is collected directly from the respective subject, via email, phone contact, and/or contract between both parties, and indirectly through partners or third parties. Once collected, Personal Data is always processed rigorously, complying with the rules and principles of the General Data Protection Regulation and other applicable legislation.

Only the necessary data for each specific purpose is processed, which is not available or unlawfully disclosed to third parties.

Personal Data will be retained for the period and according to the purpose for which it was obtained. To this end, we organize ourselves in a manner and with technical means that prevent possible intrusions, dissemination, alteration, unauthorized treatment, and access, as well as any unlawful treatment. Thus, we retain Personal Data for as long as necessary to fulfill contractual and legal obligations, ensuring compliance with duties imposed, namely, but not limited to, within the scope of commercial and tax law, banking law, the Money Laundering Act, and the Securities Code, and as evidence within the applicable legal prescription periods. For the purposes described in our Privacy Policy, Personal Data will be retained and kept for the maximum period provided by law and, when the retention limit is reached, if nothing prevents it, Personal Data will be securely destroyed.

Rights of Data Subjects

According to the principle of transparency, which defines our Privacy Policy, we must ensure that the information and/or communications related to the Processing of Personal Data are easily accessible, understandable, and formulated in clear and simple language. Therefore, we propose to act efficiently in clarifying the Processing of Personal Data, which will be transmitted in the same way they were requested unless otherwise requested by the respective Data Subject.

Under the General Data Protection Regulation (GDPR), which grants individuals several rights, we must ensure that these rights, listed below, are duly safeguarded.

The Data Subject, hereinafter referred to as the Subject, has the Right to Access their Personal Data and confirm whether it is being processed, in which case they may obtain the following information: Purpose of data processing, categories of personal data, recipients or categories of recipients to whom the personal data has been or will be disclosed, intended retention period or criteria used to define this period.

Under these terms, the Subject may, under the Right to Rectification, request the correction of their data that is inaccurate or outdated and may also request that they be completed.

Additionally, the Subject has the Right to Erasure or Forgetting when Personal Data is no longer necessary for the purpose that justified its collection, withdraws consent on which the legitimacy of the Processing is based, expresses opposition to the respective Processing without justifiable reasons; Personal Data has been unlawfully processed, or when they must be erased by legal obligation.

Under the new Right to Restriction of Processing, the Subject may determine that, for a certain period, the Processing of Data is limited in its use, i.e., “frozen”, with the data, namely, not being communicated to third parties, transferred internationally, or erased.

Notwithstanding SPARK CAPITAL, LDA’s obligation to communicate to the Subject any rectification, erasure, or limitation of the processing performed under the Right to Notification.

The Subject is also guaranteed the Right to Data Portability, which consists of the right to receive from the Data Controller their data in a structured, commonly used, and machine-readable format, and the right to transmit it to another Controller, if the Data Processing in question is based on consent or a contract and is carried out by automated means.

The Subject has the right to object – Right to Object – at any time to the Processing of their Personal Data, for reasons related to their particular situation, whenever the processing is necessary for the exercise of functions of public interest or the exercise of public authority; the pursuit of the legitimate interests of the controller or a third party; or the reuse of data for a purpose different from that which motivated their initial collection. In this case, we will immediately cease Processing unless there are compelling and legitimate reasons that prevail over the interests, rights, and freedoms of the Subject, or for the purposes of exercising a right in a judicial process.

Lastly, but not least, the Subject is guaranteed the Right not to be subjected to any decision made solely based on automated processing, including profiling, which produces legal effects or significantly affects them.