Privacy Policy

Effective Date: April 16, 2026 · Version 1.1
Spontlr Inc. · 131 Continental Drive, Suite 305, Newark, Delaware 19713, USA

1. Who We Are

Spontlr is a verified lifestyle community app. We connect real, ID-verified people with each other and with local businesses so you can explore your city, earn real rewards, and be part of something genuine.

We are not a social media app. We don't sell advertising. We don't profile you. We exist to help you do life — not to monetise your attention.

Spontlr Inc. is the data controller for all personal data described in this policy. This means we are responsible for how your data is used and protected.

2. What Data We Collect

We collect the minimum we need to make Spontlr work safely. Here is everything, explained plainly.

Data you give us directly

Full name and date of birth — required to verify your identity and confirm you are 16 or older
Email address and password — to create and access your account
Profile photo, bio, location (city), job title, and any other profile fields you choose to fill in
Posts, photos, and content you share on Spontlr — visible to other verified members
Messages you send to other members — private and encrypted in transit
Government-issued ID — submitted once for identity verification. Not stored by Spontlr after verification is complete.
Business information — business name, address, category, contact details, and any promotional content you create
Payment information — processed securely via our payment provider. We do not store card details.

Data we collect automatically

Device type and operating system — for technical compatibility and security
IP address — for security, fraud prevention, and detecting suspicious activity
Location — only when you open the app and only if you grant permission (explained in Section 5)
App usage data — which features you use, to improve the product

What we deliberately do NOT collect

Browsing history or activity outside Spontlr
Contacts, call logs, or SMS data
Behavioural profiles for advertising purposes
Sensitive personal data (race, religion, political views, health) — we never ask for this
Permanent location tracking — we do not track you in the background

3. Why We Use Your Data

Every piece of data we collect has a specific reason. Here they are:

To run Spontlr for Business

Create and manage your business account
Verify your business identity so the platform stays real, safe, and fraud-free
Show your business to verified members near your location
Enable you to post offers, events, and content visible to verified members
Process subscriptions, payments, and manage your points/rewards balance

To keep Spontlr safe

Detect and prevent fake accounts, bots, and abuse
Enforce our Community Standards and respond to reports
Protect against account takeovers and unauthorised access
Ensure users who misrepresent their identity are removed

To communicate with you

Send important security and account notifications (you cannot opt out of these as they are necessary)
Send activity updates and relevant offers — you can opt out any time in Settings
Occasional product updates and non-essential messages — opt out any time in Settings

4. Our Legal Basis for Using Your Data (EU / GDPR)

If you are in the European Union or EEA, data law requires us to have a documented legal reason for each use of your data. Here they are:

Contract performance — because you signed up and agreed to our Terms of Service. We need your data to deliver the service.
Legitimate interests — for security, fraud prevention, and improving the product, where this does not override your rights.
Legal obligation — for tax purposes and regulatory compliance.
Consent — for optional features such as location-based discovery and non-essential communications. You can withdraw consent at any time.

5. Location Data

Location is core to how Spontlr works — it helps members discover local businesses and experiences near them.

How it really works

We request your location only when you open the app and only if you grant permission
We do not track your location in the background
We do not store a log of where you have been
We only show you what is near you right now — we do not share your precise location with anyone, ever
If you deny location permission the app still works — you just won't see distance-based results
You can revoke location permission at any time in your device Settings

On iOS, location permission is requested via the Apple App Store standard prompt. On Android, via the Google Play standard prompt. We comply with both platform privacy requirements and incorporate their privacy frameworks.

6. Data Sharing

We do not sell your data. We do not share your data with advertisers. The only parties who may access your data are:

Identity verification provider — to verify your ID (data is not retained after verification)
Payment processor — to handle subscriptions and transactions securely
Cloud infrastructure providers — to host the app and store data securely (currently Google Firebase / Google Cloud)
Regulators or law enforcement — only if required by law, and only to the minimum extent required

All third-party providers are bound by data processing agreements and must comply with applicable privacy law.

7. How Long We Keep Your Data

Account data — kept while your account is active. Deleted within 30 days of account closure.
Government ID — deleted immediately after verification is complete. We do not retain it.
Messages — kept while the conversation exists. Deleted when either party deletes the conversation.
Financial records — kept for 7 years as required by tax law.
Security logs (IP addresses etc.) — kept for up to 12 months, then deleted.

8. Your Rights

You have the following rights over your personal data:

Access — request a copy of the data we hold about you
Correction — ask us to correct inaccurate data
Deletion — ask us to delete your data (subject to legal retention requirements)
Portability — request your data in a machine-readable format
Objection — object to certain uses of your data
Withdraw consent — for any processing based on consent, withdraw it at any time

To exercise any right, email us at privacy@spontlr.com. We will respond within 30 days.

9. EU / EEA Representative (Article 27)

Spontlr Inc. is incorporated in the United States. For EU/EEA users, we have appointed a representative in accordance with Article 27 of the GDPR. Contact details are available on request at privacy@spontlr.com.

10. Supervisory Authorities

If you believe we have mishandled your data, you have the right to lodge a complaint with your national data protection authority:

Poland: UODO — uodo.gov.pl
Germany: BfDI — bfdi.bund.de
Ireland: DPC — dataprotection.ie
Other EU countries: Contact your local DPA. A full list is available at edpb.europa.eu.

11. Children

Spontlr is not intended for anyone under 16. We verify age as part of identity verification. If we discover a user is under 16, their account is immediately removed and their data deleted.

12. California Residents (CCPA / CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act:

The right to know what personal information we collect, use, and disclose
The right to delete your personal information
The right to opt out of the sale or sharing of your personal information — we do not sell or share your data
The right to non-discrimination for exercising your privacy rights

To exercise these rights, email privacy@spontlr.com.

13. Changes to This Policy

If we make significant changes to this policy, we will notify you via the app and update the effective date above. Continued use of Spontlr after changes take effect constitutes acceptance of the updated policy.

14. Contact Us

Spontlr Inc.
131 Continental Drive, Suite 305
Newark, Delaware 19713, USA
privacy@spontlr.com

Spontlr Inc. · Privacy Policy v1.1 · Effective April 16, 2026