Privacy Policy

The data controller responsible for your personal data is:

• SPS Digital Tech
• CVR (Danish business registration no.): 42962554
• Country: Denmark
• Email: stephan@spsdigitaltech.com
• Responsible contact: Stephan Smuts, Founder

We keep data collection to a minimum. Depending on how you interact with us, we may process:

• Contact data you provide voluntarily - your name, email address and the content of your message - when you email us or connect via LinkedIn. This website does not store contact-form submissions on our servers; enquiries reach us directly by email.
• Server access logs kept by our hosting provider - including your IP address, browser type (user-agent) and the pages you request - which are processed to deliver the website securely and reliably and are retained only for a limited period (around 30 days).
• Anonymous usage statistics collected via Plausible Analytics, a privacy-friendly, cookie-less analytics tool. It does not use cookies, does not collect personal data and does not track you across websites. All data is aggregated and cannot be used to identify you.
• With your prior consent only: experience analytics via Hotjar (Contentsquare), which may process interaction data such as pages visited, clicks, scrolls, mouse movements and session recordings, and may set cookies or similar technologies for that purpose.
• With your prior consent only: Meta Pixel (Meta Platforms Ireland Limited), which may process pages visited, device/browser data and conversion events (for example completing our CRA assessment) so we can measure and improve Facebook/Instagram advertising. Meta may also use this information for its own purposes as described in Meta's Data Policy.
• A functional 'locale' cookie that remembers your language preference (English or Danish), and a functional cookie that stores your cookie-consent choice. These are strictly necessary for the site to work as requested and are not used for marketing.

Under the EU ePrivacy rules (implemented in Denmark) and the GDPR, non-essential cookies and similar technologies require your prior consent. We distinguish between:

• Necessary cookies: the 'locale' cookie (language preference) and the 'sps_cookie_consent' cookie (your Accept/Reject choice for optional analytics). These are set without a separate opt-in because they are required to provide a service you request or to remember a choice you already made.
• Optional experience analytics: Hotjar / Contentsquare. The tracking script is loaded only after you click Accept in our cookie banner. If you Reject, the script is not loaded and Hotjar cookies are not set by us for that purpose.
• Optional advertising measurement: Meta Pixel. The Pixel is loaded only after you click Accept in our cookie banner. If you Reject, the Pixel is not loaded and Meta advertising cookies are not set by us for that purpose.

Hotjar (Contentsquare) may use cookies and similar technologies to produce heatmaps and session recordings so we can understand how the website is used and improve usability. Recordings can include mouse movements, clicks, scrolls and pages visited. We configure this tool for website improvement. You can change or withdraw consent at any time via Cookie settings in the website footer. Withdrawing consent does not affect the lawfulness of processing before withdrawal.

Meta Pixel may set cookies or similar technologies to measure ad performance and conversion events on our website (including CRA assessment completion and lead capture). This helps us understand which ads are effective. Meta may also receive and process this data under its own terms. You can change or withdraw consent at any time via Cookie settings in the website footer.

Plausible Analytics does not use cookies and is not gated by the cookie banner.

We rely on the following legal bases under Article 6(1) of the GDPR:

• Responding to your enquiry and taking steps at your request prior to entering into an agreement - Article 6(1)(b) and our legitimate interest under Article 6(1)(f).
• Operating and protecting the website securely and reliably, including server access logs - legitimate interest under Article 6(1)(f).
• Maintaining anonymous, aggregated website statistics via Plausible - legitimate interest under Article 6(1)(f).
• Hotjar / Contentsquare experience analytics (heatmaps and session recordings), including related cookies - your consent under Article 6(1)(a) and applicable ePrivacy consent rules.
• Meta Pixel advertising measurement and conversion tracking, including related cookies - your consent under Article 6(1)(a) and applicable ePrivacy consent rules.
• Remembering your language preference and cookie-consent choice - legitimate interest in providing the service you requested under Article 6(1)(f).

We do not sell your personal data. We may share it with service providers who act as data processors on our behalf under a data processing agreement pursuant to Article 28 of the GDPR - including our website hosting and content-delivery provider (Netlify, Inc.), our email provider (Google Workspace, provided by Google Ireland Limited), our privacy-friendly analytics provider (Plausible), and - where you have consented - Contentsquare / Hotjar for experience analytics. Where you consent to the Meta Pixel, event data is also shared with Meta Platforms Ireland Limited for advertising measurement; Meta may act as an independent controller for some of that processing under its Data Policy. Processors may only process personal data on our documented instructions where they act as processors.

Our website is hosted by Netlify, Inc. in the United States, which means some personal data (such as server access logs) is transferred to the US. When you contact us by email, your message is processed through Google Workspace, whose infrastructure may also involve processing in the US. Where you consent to Hotjar / Contentsquare, interaction data may be processed by Contentsquare outside the EU/EEA depending on their infrastructure. Where you consent to the Meta Pixel, Meta may process data outside the EU/EEA. We rely on appropriate safeguards such as an EU adequacy decision, the EU-U.S. Data Privacy Framework where applicable, and/or the European Commission's Standard Contractual Clauses (Article 46 of the GDPR).

We keep correspondence only for as long as necessary to handle your enquiry and any resulting business relationship, and to comply with statutory obligations under Danish law (for example bookkeeping requirements where relevant). Cookie-consent choices are stored for up to six months (or until you change them). Hotjar / Contentsquare and Meta Pixel retention follow their product settings and (where applicable) our instructions as controller. When data is no longer needed, it is deleted or anonymised.

Under the GDPR (Articles 15–22) you have the following rights regarding your personal data:

• The right of access to your personal data.
• The right to rectification of inaccurate data.
• The right to erasure ('right to be forgotten').
• The right to restriction of processing.
• The right to data portability.
• The right to object to processing based on legitimate interests.
• The right to withdraw consent at any time, where processing is based on consent (including via Cookie settings in the footer).

To exercise any of these rights, contact us at stephan@spsdigitaltech.com. We will respond within the time limits set out in the GDPR.

If you are dissatisfied with how we process your personal data, you have the right to lodge a complaint with the Danish Data Protection Agency (Datatilsynet):

• Datatilsynet, Carl Jacobsens Vej 35, 2500 Valby, Denmark
• Email: dt@datatilsynet.dk
• Phone: +45 33 19 32 00
• Website: www.datatilsynet.dk

We may update this Privacy Policy to reflect changes in our processing activities or in applicable law. The 'last updated' date below indicates when it was last revised.