Privacy Policy

Last updated: September 16, 2025

Sparkeys Gestion Ltd (hereinafter “we”, “our”, “Sparkeys”) attaches great importance to the protection of the personal data of its clients and visitors. This policy describes what data we collect, how we use it, how we protect it, and the rights of the data subjects.

1. Definitions

“Personal data”: any information relating to an identified or identifiable natural person.  
“Processing”: any operation or set of operations performed on personal data (collection, recording, organization, structuring, storage, adaptation, consultation, use, transmission, etc.).  
“Controller”: Sparkeys Gestion, which determines the purposes and means of data processing.  
“Processor”: a third party acting on behalf of Sparkeys to process data according to our instructions.  
“WhatsApp Business”: the messaging service used by Sparkeys to communicate with its clients and prospects.

2. Data Collected

  • Contact details: name, surname, email address, phone number, postal address, etc.
  • Communication data: messages exchanged via WhatsApp Business, timestamps, content of conversations if provided by the user.
  • Concierge service data: details of requested services, preferences, location if necessary for service delivery.
  • Technical / browsing data (if website): IP address, browser type, visited pages, session duration, etc.

3. Purposes of Processing

  • respond to your service requests and carry out concierge services;
  • communicate via WhatsApp Business or other channels for information, confirmations, modifications, customer support;
  • improve our services and personalize your experience;
  • comply with our legal, administrative, and accounting obligations;
  • direct marketing (if you have consented), newsletters, promotional offers.

4. Legal Basis of Processing

  • performance of a contract or service delivery;
  • explicit consent of the data subject (e.g., for marketing);
  • legal obligation;
  • legitimate interest of Sparkeys to ensure management, security, and customer relations, provided that these interests do not override the rights and freedoms of the data subjects.

5. Data Processing via WhatsApp Business

In accordance with the WhatsApp Business Data Processing Terms:

  • WhatsApp acts as a processor of your personal data on our behalf (see terms).
  • WhatsApp will only process your data according to our instructions, for the purposes outlined in this policy.
  • WhatsApp implements appropriate technical and organizational measures to ensure confidentiality and data security.
  • WhatsApp will notify Sparkeys without undue delay in the event of a personal data breach.
  • Sparkeys remains responsible (as Controller) for overall compliance (collection, transparency, users’ rights).

6. Data Recipients

  • our internal staff;
  • our subcontractors (WhatsApp, hosting providers, IT providers, payment services, etc.);
  • legal authorities if required by law;
  • business partners, only with your explicit consent.

7. International Transfers

If some data is transferred outside Mauritius or the European Union, this will be done in compliance with applicable laws, with adequate safeguards (standard contractual clauses, approved mechanisms, etc.).

8. Retention Period

  • Data will be kept as long as necessary to achieve the purposes for which it was collected or to comply with legal obligations.
  • Communication data (WhatsApp, emails, etc.) is generally retained for up to 3 years after the last interaction, unless a longer legal retention period applies.

9. Rights of Data Subjects

Depending on applicable law, you have the following rights:

  • right of access, rectification, and erasure (“right to be forgotten”);
  • right to restrict processing;
  • right to data portability;
  • right to object, particularly to direct marketing;
  • right to withdraw your consent at any time;
  • right to lodge a complaint with a data protection authority.

10. Security

We have implemented technical and organizational security measures to protect your data:

  • encryption of communications (where possible);
  • restricted access to data;
  • regular backups;
  • internal security controls.

11. Cookies (if applicable)

Our website may use cookies to:

  • ensure proper functionality;
  • measure audience and performance;
  • personalize the user experience.

You can manage your preferences in your browser settings.

12. Changes

We may update this policy. Any update will be published on our website with a new revision date.

13. Contact

Sparkeys Gestion Ltd
Registered office: Stephen Lane Road, 65288 Pereybere, Rivière du Rempart District, Mauritius
ERN: 03762199
Business Registration No. (BRN): C23202023
VAT: 28195766

📞 +230 55 17 07 33
✉️ contact@sparkeys-gestion.com
🌍 https://www.sparkeys-gestion.com