top of page

The Spott App Privacy Policy  

​

INTRODUCTION
 

The Spott Fitness Limited (we, us, our) are committed to protecting your personal data and respecting your privacy (you).
 

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes and your rights in relation to your personal data. This information is provided in this policy, and it is important that you read that information. 
 

  • This policy (together with our end-user licence agreement (EULA) and any additional terms of use incorporated by reference into the EULA) applies to your use of:
     

  • The Spott application software (App) once you have downloaded, streamed a copy of the App onto your mobile telephone or handheld device or accessed it via a computer (Device);
     

  • any of the services accessible through the App (Services); and our website at https://www.the-spott.com/ (Website). 
     

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. 
 

This App and Website are not intended for children, and we do not knowingly collect data relating to children. 
 

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
 

IMPORTANT INFORMATION AND WHO WE ARE

​

The Spott Fitness Limited is the controller and is responsible for your personal data.
 

For any enquiries relating to this policy, please contact us at data.protection@the-spott.com.
 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues. Our ICO registration number is ZB204600. 
 

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
 

We keep our privacy policy under regular review.
 

This version was last updated on 14 April 2025. It may change and if it does, the updated version of the policy will be posted and available to read on our Website and, where appropriate, notified to you when you next start the App. The updated policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
 

THIRD PARTY LINKS
 

Our App may, from time to time, contain links to and from the websites of our partner networks and advertisers. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
 

THE DATA WE COLLECT ABOUT YOU
 

We may collect, use, store and transfer different kinds of personal data about you as follows:
 

  • Identity Data: first name, last name, username or similar identifiers, gender and date of birth.
     

  • Contact Data: email address and home address.
     

  • Device Data: includes the type of mobile Device you use, a unique device identifier your mobile operating system, time zone setting. 
     

  • Content Data: includes information stored on your Device, including photos, when you give us access and want to use an existing or new photo as your profile photo. 
     

  • Technical Data: internet protocol (IP) address.  
     

  • Profile Data: includes your username or similar identifiers and password, profile photo, feedback and survey responses.      
     

  • Health Data: includes heart rate data, resting heart rate, maximum heart rate, calorie burn, and body height and weight measurements. 
     

  • Location Data: your geographical location data, as per your Device IP geolocation.  
     

Aside from health data as set out above, we do not collect any other Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions and trade union membership). Nor do we collect any information about criminal convictions and offences.
 

PERMISSIONS WE NEED FOR YOU TO USE OUR APP AND SERVICES
 

Our Services will require permissions to use some of your Device’s functionalities.

The following table sets out what permissions may be required and why we need those in the course of your use of the App and our Services. 

​
 

Screenshot 2025-06-18 at 18.04.16.png
Screenshot 2025-06-18 at 18.04.33.png

HOW IS YOUR PERSONAL DATA COLLECTED?
 

We will collect and process the following data about you:
 

  • Information you give us. This is information (including Identity Contact and Health Data) you consent to giving us about you by filling in forms on the App or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register an App, subscribe to any of our Services, search for an App or Service, and when you report a problem with our App or our Services. If you contact us, we will keep a record of that correspondence. 
     

  • Information we collect about you and your Device. Each time you visit our App, we will automatically collect personal data including Device and Content Data.
     

  • Information we collect through your heart rate monitor including Health Data.
     

  • Location Data. We use your location data only because Google requires this as we utilise Bluetooth Low Energy (BLE) to connect with your heart rate monitor. We do not collect this data. 
     

  • Information we receive from other sources including third parties. We will receive Device Data from analytics providers such as Rook, Mixpanel and Sentry.io.
     

COOKIES
 

We use first-party cookies for tracking purposes via Mixpanel, and Sentry.io and to improve and monitor the performance of the App. 
 

We also use first-party cookies to manage authentication which are technically created using Amazon Web Services (but they are first party as they use our app URL). 
 

HOW WE USE YOUR PERSONAL DATA
 

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances: 
 

  • Where you have consented before the processing.
     

  • Where we need to perform a contract we are about to enter or have entered with you.
     

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
     

  • Where we need to comply with a legal or regulatory obligation. 
     

  • We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us. 
     

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Screenshot 2025-06-18 at 17.59.08.png

DISCLOSURES OF YOUR PERSONAL DATA
 

When you consent to providing us with your personal data, you consent for us to share your personal data with the third parties set out below for the purposes set out in the table above: 
 

  • When you are a club member, with the personal trainers at the clubs you are a member of. You can opt out to share certain personal information with your clubs via the Privacy section of your profile on the App. However, you cannot currently opt out of sharing data generated during sessions, such as your heart rate and calorie burn information, with your trainer. If you wish not to share this information we recommend not connecting a heart-rate device.
     

  • With Stripe, our service provider to process payments and subscriptions on our behalf.  
     

  • With Freshdesk, our service provider to process our customer support requests. 
     

  • With Twilio, our Video conferencing to provide video, audio and live data stream connectivity between club members and trainers during sessions. 
     

  • With Mixpanel and Sentry.io, our service providers to record user app sessions, which enables us to improve and enhance the product. You can opt-out by emailing data.protection@the-spott.com.  
     

  • With Rook, our service provider to enable you to sync Apple Health data and Heart Rate data through the Apple Watch companion app.
     

  • With Be Guided, our service provider for marketing and social media services.
     

  • With The Possibility Partnership, our service providers to manage and maintain our cloud environment.
     

  • With Neoteric, our service providers to produce code and features for the product.
     

  • Google, our advertising partner. Used for advertising tracking purposes through Google Tag Manager.
     

  • Meta, our advertising partner. Used for advertising tracking purposes through Meta Pixel and Meta Ads Manager.
     

  • Usercentrics, our consent tracking tool. Used to manage cookie preferences and consents.
     

INTERNATIONAL TRANSFERS
 

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
     

  • Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
     

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
 

DATA SECURITY
 

All information you provide to us is stored on our secure servers. 
 

Where you use a password to access our App or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
 

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. 
 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
 

DATA RETENTION
 

The period for which we keep personal data is set out in the table below. 
 

By law we have to keep basic information about our customers (including Contact, Identity) for     six years after they cease being customers for tax purposes.
 

In some circumstances you can ask us to delete your data: see below for further information.
 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Screenshot 2025-06-18 at 18.00.38.png

YOUR LEGAL RIGHTS
 

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. 
 

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
     

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
     

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
     

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
     

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    ​(a) if you want us to establish the data's accuracy;

    (b) where our use of the data is unlawful but you do not want us to erase it;

    (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

    (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
     

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
     

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

bottom of page