Alphaspark Lab · Experimental

Legal

Privacy Policy

Effective 22 October 2026 · Version 1.1 · Terms of Service

In short

AlphaSpark is an experimental lab. We collect only what we need to run your account and the tools you use (your login details, the investment profiles you build, and any pitch decks you upload), plus product analytics if you allow them. We use a small number of named service providers to do this, and we never sell your data. The service is offered as-is, so please do not upload anything you cannot afford to lose or that you are not allowed to share.

1. Who we are (Scope and Controller)

This Privacy Policy explains how Martino Bagini, an individual resident in Italy who operates AlphaSpark ("AlphaSpark", "we", "us"), processes personal data when you visit alphaspark.it, use the application at app.alphaspark.it, or otherwise interact with us (together, the "Service").

Data controller: Martino Bagini, Via Arcivescovo Calabiana 6, 20139 Milano (MI), Italy.
Privacy contact: data@alphaspark.it
Data Protection Officer: none appointed, as one is not required for this Service. Please send all privacy questions and requests to the privacy contact above.

This policy covers personal data about you as a user. It also covers personal data about third parties (for example, founders named in a pitch deck) that you upload to the Service; see section 3.4.

Experimental service. AlphaSpark is an experimental, pre-release service. Features, data flows and the providers listed below may change while we iterate. We will update this policy when they do (section 12).

2. Information we collect

2.1 Information you give us

2.2 Information collected automatically

We configure PostHog to mask everything you type and the content shown on profile, simulation and deck pages (including deck text and extracted data). Recordings therefore show the interface, not your investment data or the contents of decks. We do not record network request or response contents.

We do not use advertising or marketing cookies.

2.3 Information from third parties

Purpose Data used Legal basis (GDPR Art. 6)
Create and manage your account, authenticate you Account data, auth cookies Performance of a contract (6(1)(b))
Provide the tools: store profiles, run simulations, extract data from decks, generate fit analyses Profile data, simulation inputs, uploaded documents Performance of a contract (6(1)(b))
Keep the Service secure, prevent abuse, debug errors Technical and log data Legitimate interests (6(1)(f)): running a secure, working service
Improve and develop the experimental Service, using aggregated or de-identified usage information Technical data; de-identified content statistics Legitimate interests (6(1)(f)): improving the product
Respond to your messages and send essential service notices (for example, changes to these terms, or a shutdown) Account data, communications Performance of a contract; legitimate interests
Newsletters and product updates (only if you sign up for them) Email address, name Consent (6(1)(a)), which you can withdraw at any time via the unsubscribe link in every email or by writing to data@alphaspark.it
Product analytics and session recordings (PostHog): understand which features are used, where users get stuck, and how well the tools work (for example, how complete extractions are) Usage events with the counts and categories described in section 2.2, masked session recordings, cookie and device identifiers, pseudonymous user ID Consent (6(1)(a)), given through the cookie banner and withdrawable in Cookie settings
Comply with legal obligations, respond to lawful requests, establish or defend legal claims Any relevant data Legal obligation (6(1)(c)); legitimate interests

You are not legally required to give us any personal data. Account data is needed to create an account; without it, we cannot provide the Service. Uploading decks and other content is optional. Refusing analytics has no effect on what you can do in the Service.

3.1 AI processing

Some features send the content you provide (for example, the text of an uploaded deck or your profile parameters) to OpenAI through its API, to extract or classify information and generate analyses. Under OpenAI's API terms, content sent through the API is not used to train OpenAI's models. OpenAI may keep API inputs and outputs for up to 30 days to monitor for abuse, and then deletes them. Outputs are generated automatically, may be inaccurate, and are not investment advice.

The Service produces scores and classifications to support your judgement. We do not make decisions about you that produce legal or similarly significant effects based solely on automated processing.

3.3 No sale of data

We do not sell or rent personal data, and we do not share it for cross-context behavioural advertising.

3.4 Third-party personal data in uploaded content

Pitch decks often contain personal data about other people (founders' names, photos, bios, contact details, shareholdings). By uploading such content you confirm that you have the right to share it with us for this purpose, and that doing so is consistent with any confidentiality obligations you have. We process this data only to provide the feature you requested and do not use it to contact the individuals concerned. Individuals who believe their data has been uploaded can contact us at data@alphaspark.it.

4. Sharing and third-party services

We share personal data only with:

Provider Role Data involved Location
Clerk, Inc. Authentication and user management, including sign-up and verification emails Account data, auth cookies, IP and device data USA
Railway Corporation Application and API hosting, database, and storage of uploaded files All data stored in the Service EU (Railway EU West region)
Cloudflare, Inc. DNS, hosting of our static website (Workers), proxying of our API, and security and bot protection IP address and request metadata of website visitors; API requests and responses in transit, including content you upload Global edge network (USA-headquartered)
OpenAI, L.L.C. AI extraction, classification and analysis through the API Uploaded document text, profile and simulation inputs USA
PostHog, Inc. Product analytics and session recordings (consent only) Usage events, masked session recordings, device data, pseudonymous ID EU (PostHog EU Cloud, Frankfurt)

5. Cookies and similar technologies

We use two kinds of cookies and similar technologies:

Name Set by Category Purpose Duration
__session, __client, __client_uat (and suffixed variants) Clerk Strictly necessary Keep you signed in; secure your session Session to ~1 year (provider-defined)
__clerk_environment (local storage) Clerk Strictly necessary Authentication configuration Until cleared
__cf_bm, _cfuvid, cf_clearance (when set) Cloudflare Strictly necessary Bot protection, rate limiting, security challenges 30 minutes to session (cf_clearance per configuration)
as_consent AlphaSpark Strictly necessary Remember your cookie choices 6 months
ph_<project key>_posthog (cookie and local storage), plus PostHog session-storage keys PostHog Analytics (consent) Pseudonymous identifier and session ID, for usage analytics and session recordings Cookie up to 1 year; session storage until the tab closes

We do not use advertising or marketing cookies. You can also block or delete cookies in your browser settings, but the Service will not work without the strictly necessary ones.

6. International transfers

Our application, database and uploaded files are hosted by Railway in the EU, and PostHog stores analytics data in the EU (Frankfurt). Some processing still takes place outside the EEA: Clerk (authentication), OpenAI (AI processing of the content you submit) and Google (sign-in) process data in the United States, and Cloudflare operates a global network. Railway and PostHog are US companies and may access EU-stored data from outside the EEA for support and maintenance. Where personal data is transferred outside the EEA/UK, we rely on an adequacy decision (including the EU–US Data Privacy Framework, where the recipient is certified) or on the European Commission's Standard Contractual Clauses, together with supplementary measures where appropriate. You can request a copy of the relevant safeguards at data@alphaspark.it.

7. Data retention

We keep personal data only as long as needed for the purposes above:

Data type Suggested retention
Account data While your account is active; deleted within 30 days of account deletion
Investment profiles and simulations While your account is active, or until you delete them; deleted within 30 days of account deletion
Uploaded decks (original files) Until you ask us to delete your account, or until you delete the deck yourself where the app allows it; deleted within 30 days of the request
Extracted structured data from decks Same as uploaded decks
Inactive accounts If an account has had no sign-in for 24 months, we email you, then delete the account and its content 30 days later unless you sign in
Server and security logs (Railway) Up to 7 days (longer only if needed to investigate an incident)
Backups Overwritten on a rolling cycle of up to 30 days
Support communications Up to 24 months after the last contact
Records needed for legal claims or obligations For the applicable limitation period
Product analytics events (PostHog) Up to 12 months, then deleted; deleted on account deletion
Session recordings (PostHog) Up to 30 days
Edge and security logs (Cloudflare) Per Cloudflare's standard retention (short-lived; we do not export them to long-term storage)
Data sent to OpenAI Up to 30 days for OpenAI abuse monitoring, then deleted (zero retention, if enabled)

Because the Service is experimental, data may also be lost earlier than these periods (see the Terms of Service). Do not rely on the Service as your only copy of anything.

8. Security

We use reasonable technical and organisational measures appropriate to an early-stage service, including encryption in transit (HTTPS/TLS), Cloudflare's edge protection against attacks and bots, delegated authentication through Clerk with hashed passwords, access controls limiting who can reach production data, and provider-level encryption at rest where available. No system is completely secure, and as an experimental service we cannot guarantee the security of your data. If a personal data breach is likely to put you at risk, we will notify you and the competent authority as the law requires.

9. Your rights

If you are in the EEA, the UK or Switzerland, you have the right to:
- Access your personal data and receive a copy;
- Rectify inaccurate or incomplete data;
- Erase your data ("right to be forgotten");
- Restrict processing in certain circumstances;
- Data portability: receive data you provided in a structured, machine-readable format (you can also use the export feature);
- Object to processing based on legitimate interests;
- Withdraw consent at any time, where processing is based on consent, without affecting earlier processing;
- Lodge a complaint with a supervisory authority, in particular in your country of residence, place of work, or where an alleged infringement occurred. In Italy, this is the Garante per la protezione dei dati personali (www.garanteprivacy.it).

To exercise your rights, email data@alphaspark.it from the address linked to your account. We will respond within one month (extendable by two months for complex requests) and may need to verify your identity. To delete your account and everything in it, email data@alphaspark.it from your registered address or use Account settings → Delete account, once available. We will confirm, and complete the deletion within 30 days.

10. Children's privacy

The Service is a professional tool for investors and is not directed at anyone under 18. We do not knowingly collect personal data from children. If you believe a child has given us personal data, contact data@alphaspark.it and we will delete it.

The Service may link to third-party websites or services. Their own privacy policies apply, not this one.

12. Changes to this policy

Because AlphaSpark is experimental, we may update this policy as the Service changes. We will post the new version with a new effective date and, for material changes, notify you by email or in the app before they take effect. Earlier versions are available on request.

13. Contact

Martino Bagini (AlphaSpark)
Via Arcivescovo Calabiana 6
20139 Milano (MI), Italy
Email: data@alphaspark.it