Privacy Policy

Data controller

Ceero ApS (CVR 45 44 13 93), Njalsgade 21F, 2. sal, Copenhagen, is the data controller for personal data processed in connection with sparro.dk and the Sparro platform. You can contact us at nicklas@ceero.eu or on WhatsApp +45 31 33 25 99.

What we collect

Waitlist: your email address and the timestamp of your consent. Account: name, email, your company's CVR number and address, and a MitID-based identifier if you log in with MitID. Bookkeeping: invoices, receipts, and the documents you upload or send by email. Bank: transaction and account data from your bank via a PSD2-approved connection, when you connect your bank account yourself. Payroll: payroll-run data via Intect. Employees' CPR numbers are stored encrypted in Sparro so they can be registered with the payroll system; tax cards sit with our payroll provider. Communication: if you enable AI triage of your inbox, relevant emails are read to categorize them and suggest replies; CPR numbers in that text are automatically filtered out before it's sent to an AI model.

Purpose and legal basis

Waitlist sign-up relies on your consent (GDPR Article 6(1)(a)), given by actively checking the consent checkbox — not merely by submitting the form. As a customer, we process your data to perform the contract for the bookkeeping service (Article 6(1)(b)) and to comply with the Danish Bookkeeping Act's retention requirements (Article 6(1)(c)). Optional features such as AI categorization and the accountant marketplace rely on your active choice to use them. You can withdraw consent at any time by contacting us.

Who we share it with

We use the following processors to deliver the service. Resend (Resend, Inc., USA) sends waitlist and system emails. Anthropic (USA), Google (USA), and Voyage AI (USA) process document text, receipts, and content from your inbox to suggest booking, categorization, replies, and search — CPR numbers are filtered out before any text from your inbox is sent to them. Enable Banking brokers your PSD2 bank connection; Mastercard processes payment initiation if you use that feature. Intect (Denmark) runs the actual payroll and the eIndkomst reporting. Stripe and MobilePay (Vipps MobilePay) process payment for your subscription. WorkOS handles login, and Criipto brokers MitID verification. Vercel hosts the application (EU region), Neon hosts the database, and Bunny.net stores uploaded files. We also run our own infrastructure at Hetzner (Nuremberg, EU) for traffic statistics, rate limiting, and the NemHandel connection. E-invoices are sent and received via NemHandel/Peppol through e-invoice.be. Traffic statistics on sparro.dk are collected cookie-free and self-hosted via Plausible (at Hetzner) — no third party receives this data. We never sell your data to third parties. Transfers to processors outside the EU/EEA (including Resend, Anthropic, Google, Voyage AI, Stripe) rely on the European Commission's Standard Contractual Clauses.

Staff and internal access

Sparro employees may, in limited circumstances, access your account and business data through our internal administration tool — for customer support, updating business details, opening/closing accounts, billing and subscription administration, and approving accountant partners on the marketplace. Access is restricted to employees who need it, and views of sensitive customer data are logged. We're building a feature that would let an employee get temporary, read-only access to view your account the way you see it, for troubleshooting a specific support case — never access to change or create anything on your behalf. This feature hasn't been taken into use yet; once it is, you'll always be able to tell: a visible notice will appear in your account while access is active, and the event will be recorded in your account's own activity log with the time and which employee had access. We're continuing to expand how detailed this logging is.

Retention

Waitlist emails are kept until the product launches or you ask us to delete them. Bookkeeping records (receipts, invoices, account statements) are kept for at least 5 years under the Danish Bookkeeping Act, counted from the end of the financial year the material relates to — we can't delete this earlier, even on request, while that period runs. Once the retention period expires, material is reviewed for deletion; automatic deletion isn't yet fully in place for all bookkeeping data, so the period may in practice run longer than 5 years until that manual review has happened. When you dismiss or reply to an email in the AI triage feature, the personal data in it is deleted 30 days later — unless the email has been booked as a receipt or invoice, in which case the sender and subject are instead kept as part of the ordinary 5-year retention. Emails you haven't yet acted on aren't covered by this 30-day deletion. Closing your account freezes it (read-only, and closing can be reversed) — it doesn't delete your data. If you want your data deleted, you need to separately request account deletion, which immediately removes non-statutory data (e.g. push notifications and sessions), while your bookkeeping itself continues to be retained until the statutory deadline has passed.

Cookies

Sparro sets, among others, the following cookies and similar local storage. Functional cookies (exempt from consent): a language cookie and a cookie that remembers which company you're logged in as, both for up to 365 days, and a cookie named theme that remembers your choice of light or dark appearance. It is set only when you press the appearance control, holds only the value light or dark, lasts for the browser session (or 365 days if you chose "Accept all" in the cookie notice) and is never shared with third parties. Strictly necessary cookies (exempt from consent): login and session cookies, and a short-lived security cookie (typically 10 minutes) each time you connect an external service (e.g. your bank, Gmail, or payroll) — deleted once the connection is established. Referral cookie: if you arrive via a referral link, we set a cookie for 30 days used to credit the referral — it isn't used for advertising or cross-site tracking, but it doesn't fall under the strictly-necessary exemption; you can always delete it in your browser. Our traffic measurement (Plausible) is cookie-free and sets no cookies at all. We don't use any third-party advertising or tracking cookies.

Your rights

Under the GDPR you have the right to access, rectify, and erase your data, as well as the right to restrict or object to our processing and the right to data portability. Note that the right to erasure is limited for bookkeeping material while the statutory retention period runs. Contact us at nicklas@ceero.eu to exercise your rights. You can also file a complaint with the Danish Data Protection Agency (datatilsynet.dk).

Security

All traffic to sparro.dk and the platform itself is encrypted (HTTPS). Data is stored encrypted at our database provider, and each company's data is logically separated from every other company's. Access to systems that process your data is limited to employees who need it, and certain sensitive views are logged (see "Staff and internal access" above).

Instagram (@sparroapp)

This section applies when you comment on a post on Sparro's Instagram account @sparroapp, send the account a message or mention it. It comes on top of the rest of this policy. It does not change how Instagram itself processes your data: that is Meta's responsibility.

How to have your Instagram data deleted: see the Data deletion page.

Changes to this policy

We'll update this page whenever how we process personal data changes — for instance when we adopt a new processor or feature. Material changes are announced on the page or by email.