Privacy Notice

Last updated: [DATE]. This is a founder-reviewable draft — replace the bracketed placeholders and have it checked by a lawyer qualified in your jurisdiction (including for GDPR/EU compliance) before relying on it.

1. Who we are

[COMPANY] ("Sparehawk", "we", "us"), of [ADDRESS], is the controller responsible for the personal data described in this notice. Contact us at [EMAIL] for any privacy question, or to exercise the rights in Section 6.

2. What we collect

• Search activity: the part numbers, keywords, and filters you search for, and which results you view. We use this to run and improve the search itself, and to understand which parts buyers need that we do not yet have supplier coverage for.
• RFQ / contact details: when you request a quote, the contact information you provide (typically name, company, email, and the part(s) you need), plus anything you write in a free-text message.
• Supplier account data: if you register as a supplier, your company details, contact person, and the inventory data you submit (see the Supplier Terms for how that data is used).
• Technical data: IP address, browser/device information, and basic usage logs, collected automatically for security, rate-limiting, and diagnosing issues.

We do not knowingly collect any special category of personal data, and the Service is not directed at children.

3. Why we process it (purposes and legal basis)

| Purpose | Legal basis | | ------------------------------------------------------------------------------ | ------------------------------------------ | | Operating and improving search and the catalog | Legitimate interest in running the Service | | Forwarding your RFQ contact details to a supplier you are matched with | Performance of your request (contract) | | Fraud prevention, rate-limiting, abuse detection | Legitimate interest | | Sending you a reply about an RFQ or support request | Performance of your request (contract) | | Aggregated, de-identified demand analytics (e.g. "no supplier coverage for X") | Legitimate interest |

4. Forwarding your data to suppliers

When you submit an RFQ, we share the details you provided (and the part you asked about) with the supplier(s) we match you to, so that supplier can contact you directly with a quote. Each supplier that receives your enquiry becomes an independent controller of the data we forward to them, governed by their own privacy practices for anything they do with it afterwards (see our Supplier Terms for the obligations we place on suppliers regarding this data, including a restriction on using it for unrelated marketing without your consent).

We do not sell your personal data, and we do not share it with suppliers other than the one(s) relevant to your specific request.

5. Retention

We retain RFQ and contact data for as long as reasonably necessary to fulfil the request and resolve any related support issue, and in any case no longer than [RETENTION PERIOD, e.g. 24 months] after your last interaction, unless a longer period is required by law. Aggregated search/demand analytics that no longer identify you may be retained indefinitely.

6. Your rights

Subject to applicable law (including the GDPR, if you are in the EU/EEA/UK), you may have the right to: access the personal data we hold about you; correct it; request its deletion; restrict or object to certain processing; and receive a copy in a portable format. To exercise any of these, contact [EMAIL]. If you are in the EU/EEA/UK, you also have the right to lodge a complaint with your local data protection authority.

7. Sub-processors

We use the following third-party processors to run the Service:

• Resend (transactional and RFQ-notification email delivery).
• [HOSTING/INFRASTRUCTURE PROVIDER] (application hosting and database infrastructure).

We only share the minimum data necessary with each processor for the purpose above, under a data processing agreement.

8. Cookies

The Service uses only the cookies/local storage strictly necessary to run search and remember your language preference. We do not currently use advertising or third-party tracking cookies. If this changes, this notice will be updated and, where required, we will ask for your consent first.

9. Changes to this notice

We may update this notice from time to time; the "Last updated" date above will change accordingly. Material changes will be highlighted on this page.