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: 

​

• 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 webRTC video service provider to provide video, audio and live data stream connectivity during training sessions. 
   

• 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.
   

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

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

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

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 platform, 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 table above sets out the retention periods that apply to each type of data we collect from you and process. 
 

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.
 

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 to 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.