Privacy Policy of Spottem

Spottem collects some Personal Data from its Users.

Policy summary

Personal Data collected for the following purposes and using the following services:

    • Analytics
      • Google Analytics

Personal Data: Cookies; Usage Data

  • Google Analytics for Firebase

Personal Data: Application opens; Application updates; Cookies; device information; first launches; geography/region; In-app purchases; number of sessions; number of Users ; operating systems; session duration; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

  • Beta Testing
    • Google Play Beta Testing

Personal Data: Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data as specified in the privacy policy of the service

  • Beta by Crashlytics

Personal Data: app information; Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data as specified in the privacy policy of the service

  • TestFlight

Personal Data: app information; Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name

  • Contacting the User
    • Contact form and Mailing list or newsletter

Personal Data: email address; first name; last name; phone number

  • Phone contact

Personal Data: phone number

  • Content commenting
    • Comment system managed directly

Personal Data: email address; first name; last name; phone number; Usage Data; username

  • Content performance and features testing (A/B testing)
    • Firebase Remote Config

Personal Data: various types of Data as specified in the privacy policy of the service

  • Device permissions for Personal Data access
    • Device permissions for Personal Data access

Personal Data: Camera permission; Contacts permission; Photo Library permission; Precise location permission (continuous); Precise location permission (non-continuous); Social media accounts permission; Storage permission

  • Displaying content from external platforms
    • Font Awesome

Personal Data: Usage Data

  • Google Fonts

Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

  • Google Maps widget

Personal Data: Cookies; Usage Data

  • Hosting and backend infrastructure
    • Algolia and Firebase Hosting

Personal Data: various types of Data as specified in the privacy policy of the service

  • Firebase Cloud Firestore, Firebase Cloud Functions, Firebase Cloud Storage and Firebase Realtime Database

Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service

  • Infrastructure monitoring
    • Crashlytics

Personal Data: Crash information; device information; Universally unique identifier (UUID)

  • Firebase Performance Monitoring

Personal Data: various types of Data as specified in the privacy policy of the service

  • Interaction with external social networks and platforms
    • Facebook Like button and social widgets

Personal Data: Cookies; Usage Data

  • YouTube button and social widgets

Personal Data: Usage Data

  • Interaction with live chat platforms
    • Facebook Messenger Customer Chat

Personal Data: Cookies; Data communicated while using the service; Usage Data

  • Location-based interactions
    • Geolocation and Non-continuous geolocation

Personal Data: geographic position

  • Managing contacts and sending messages
    • Firebase Cloud Messaging and Firebase Notifications

Personal Data: various types of Data as specified in the privacy policy of the service

  • Managing data collection and online surveys
    • SurveyMonkey

Personal Data: address; company name; Cookies; country; Data communicated while using the service; date of birth; email address; first name; gender; geographic position; last name; number of employees; password; phone number; profession; state; Usage Data; username; website

  • Managing support and contact requests
    • ZOHO CRM Email

Personal Data: various types of Data as specified in the privacy policy of the service

  • Platform services and hosting
    • Apple App Store and Google Play Store

Personal Data: Usage Data

  • Registration and authentication
    • Facebook Authentication and Google OAuth

Personal Data: various types of Data as specified in the privacy policy of the service

  • Firebase Authentication

Personal Data: email address; first name; last name; password; phone number; profile picture; social media accounts ; username

  • Remarketing and behavioral targeting
    • Facebook Custom Audience

Personal Data: Cookies; email address

  • Facebook Remarketing, Google Ad Manager Audience Extension, Google Ads Remarketing and Remarketing with Google Analytics

Personal Data: Cookies; Usage Data

  • Social features
    • Firebase Dynamic Links and Firebase Invites

Personal Data: various types of Data as specified in the privacy policy of the service

  • Inviting and suggesting friends

Personal Data: various types of Data

  • Public profile

Personal Data: geographic position; picture; username

  • SPAM protection
    • Akismet

Personal Data: various types of Data as specified in the privacy policy of the service

  • Google reCAPTCHA

Personal Data: Cookies; Usage Data

  • Tag Management
    • Google Tag Manager

Personal Data: Cookies; Usage Data

Further information about Personal Data

    • Access the address book

Spottem may request access to your address book.

  • Analysis and predictions based on the User’s Data (“profiling”)

The Owner may use the Personal and Usage Data collected through Spottem to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User’s rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

  • Personal Data collected through sources other than the User

The Owner of Spottem may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

  • Push notifications

Spottem may send push notifications to the User to achieve the purposes outlined in this privacy policy.

Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for Spottem, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Spottem.

  • Push notifications based on the User’s geographic location

Spottem may use the User’s geographic location to send push notifications for the purposes outlined in this privacy policy.

Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.

Users must be aware that disabling push notifications may negatively affect the utility of Spottem.

  • Push notifications for direct marketing

Spottem may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by Spottem).

Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for Spottem or all of the apps on the particular device.

Users must be aware that disabling push notifications may negatively affect the utility of Spottem.

Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.

  • Unique device identification

Spottem may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

  • User identification via a universally unique identifier (UUID)

Spottem may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users’ preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

Contact information

    • Owner and Data Controller

G67 Pty Ltd
748 Richards Drive
Elite Park
Midrand
1685
Gauteng
South Africa

Owner contact email: info@spottem.co.za

Full policy

Owner and Data Controller

G67 Pty Ltd
748 Richards Drive
Elite Park
Midrand
1685
Gauteng
South Africa

Owner contact email: info@spottem.co.za

Types of Data collected

Among the types of Personal Data that Spottem collects, by itself or through third parties, there are: first name; last name; phone number; email address; username; password; profile picture; social media accounts ; Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; geography/region; number of Users ; number of sessions; session duration; In-app purchases; Application opens; Application updates; first launches; operating systems; gender; date of birth; country; Data communicated while using the service; device logs; app information; Contacts permission; Camera permission; Precise location permission (continuous); Precise location permission (non-continuous); Storage permission; Social media accounts permission; Photo Library permission; Universally unique identifier (UUID); Crash information; geographic position; address; company name; profession; state; number of employees; website; various types of Data; picture.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Spottem.
Unless specified otherwise, all Data requested by Spottem is mandatory and failure to provide this Data may make it impossible for Spottem to provide its services. In cases where Spottem specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Spottem or by the owners of third-party services used by Spottem serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Spottem and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Spottem (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Registration and authentication, Analytics, Beta Testing, Contacting the User, Content commenting, Content performance and features testing (A/B testing), Device permissions for Personal Data access, Displaying content from external platforms, Hosting and backend infrastructure, Infrastructure monitoring, Interaction with external social networks and platforms, Interaction with live chat platforms, Location-based interactions, Managing contacts and sending messages, Managing data collection and online surveys, Managing support and contact requests, Platform services and hosting, Remarketing and behavioral targeting, Social features, SPAM protection and Tag Management.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Device permissions for Personal Data access

Depending on the User’s specific device, Spottem may request certain permissions that allow it to access the User’s device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.

Please note that the revoking of such permissions might impact the proper functioning of Spottem.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Spottem.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Contacts permission

Used for accessing contacts and profiles on the User’s device, including the changing of entries.

Photo Library permission

Allows access to the User’s Photo Library.

Precise location permission (continuous)

Used for accessing the User’s precise device location. Spottem may collect, use, and share User location Data in order to provide location-based services.

Precise location permission (non-continuous)

Used for accessing the User’s precise device location. Spottem may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for Spottem to derive the exact position of the User on a continuous basis.

Social media accounts permission

Used for accessing the User’s social media account profiles, such as Facebook and Twitter.

Storage permission

Used for accessing shared external storage, including the reading and adding of any items.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Analytics
  • Beta Testing
  • Contacting the User
  • Content commenting
  • Content performance and features testing (A/B testing)
  • Device permissions for Personal Data access
  • Displaying content from external platforms
  • Hosting and backend infrastructure
  • Infrastructure monitoring
  • Interaction with external social networks and platforms
  • Interaction with live chat platforms
  • Location-based interactions
  • Managing contacts and sending messages
  • Managing data collection and online surveys
  • Managing support and contact requests
  • Platform services and hosting
  • Registration and authentication
  • Remarketing and behavioral targeting
  • Social features
  • SPAM protection
  • Tag Management

Further information about Personal Data

  • Access the address book
  • Analysis and predictions based on the User’s Data (“profiling”)
  • Personal Data collected through sources other than the User
  • Push notifications
  • Push notifications based on the User’s geographic location
  • Push notifications for direct marketing
  • Unique device identification
  • User identification via a universally unique identifier (UUID)

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time.Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data.Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data.Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification.Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data.Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed.Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller.Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint.Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Spottem or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, Spottem may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Spottem and any third-party services may collect files that record interaction with Spottem (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Spottem does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Spottem and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

You agree to be bound by any changes made in the terms of this Privacy Policy. Continuing to use the service will indicate your acceptance of the amended terms. If you do not agree with any of the amended terms, you must avoid any further use of the service.

 

 

Severability

Should any provision of this privacy policy be deemed or become invalid or unenforceable under applicable law, the invalidity or unenforceability of such provision shall not affect the validity of the remaining provisions, which shall remain in full force and effect.

Definitions and legal references

Latest update: September 25, 2019

Spottem hosts this content and only collects the Personal Data strictly necessary for it to be provided.