Privacy notice
Last updated 24 October 2026
This notice explains how the details you send through the offer form on drillkit.ai, springcedar.com, euryko.com, kimiware.com, anglikos.com, fluentjam.com, sparksesl.com, jamveo.com are used. It follows the EU General Data Protection Regulation (GDPR).
Who is responsible
The data controller is Matthew James Soldato, based in Italy. You can write to offers@sparksesl.com about anything in this notice.
What we collect
- Your name and email address and, if you give them, your company and your message.
- The amount you offer and the domain it is for.
- A pseudonymised (hashed) form of your IP address and the time of your request, used to limit repeated attempts.
- The result of the Cloudflare Turnstile check that the form was sent by a person.
Why we use it
- To answer your offer and negotiate a possible sale. Legal basis: steps taken at your request before a contract (Art. 6(1)(b) GDPR).
- To protect the form from spam, fraud and abuse. Legal basis: our legitimate interest in keeping the service safe (Art. 6(1)(f) GDPR).
When you tick the box on the form, you confirm you have read this notice and agree to your details being used for these purposes. We don’t use them for marketing, we don’t sell them and we don’t share them with other buyers.
Who processes it for us
- Cloudflare, Inc. hosts the site, stores the offers and sends the emails. Cloudflare may process data outside the EU; these transfers are covered by the EU–US Data Privacy Framework and the European Commission’s Standard Contractual Clauses.
- Google Ireland Limited provides the seller’s Gmail mailbox, where offers are forwarded. Google may process data in the United States; these transfers are covered by the EU–US Data Privacy Framework and the European Commission’s Standard Contractual Clauses.
- Escrow.com, only if we agree on a sale. You open the transaction directly with Escrow.com, under its own privacy policy.
How long we keep it
- Offers that don’t lead to a sale are deleted 12 months after they are sent.
- If a sale goes ahead, the records needed for accounting and tax are kept for 10 years, as Italian law requires.
- Hashed IP addresses are deleted after 30 days.
Cookies and tracking
This site sets no cookies and uses no analytics or advertising trackers. Fonts are served from this site, not from Google. Cloudflare Turnstile runs only on the offer form, to tell people from bots.
Your rights
You can ask to see, correct or delete your data, to restrict or object to its use, and to receive it in a portable format. Write to offers@sparksesl.com; we reply within one month. You can also complain to the Italian data protection authority, the Garante per la protezione dei dati personali, at garanteprivacy.it.