Privacy Policy

Dotspot Limited (“Dotspot”, the “Company” or “We”) respect your privacy and we are committed to protecting it through our compliance with this policy.
This privacy policy (the “Policy”) describes the types of information, including Personal Data that we may collect from you or that you may provide when you visit our website www.dotspot.tech (our “Site”), and/or our mobile application (our “App”) (our Site and App together our “Platform”), establish an Account, and our practices for collecting, using, maintaining, protecting and disclosing that information. As used in this Privacy Policy, “Personal Data” means any information that can be used to individually identify a person, and may include, but is not limited to, name, email address, postal or other physical address, title, and other personally identifiable information as fully defined below.
If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.
For the purpose of the GDPR, the Data Controller is Dotspot Limited.
This policy applies to information we collect:
• On our Site and our App.
• On phone calls, in e-mail, text and other electronic messages between you and Dotspot.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to our Site and/or App.
• When you voluntarily share information from your Social Media Provider account with Dotspot via our Site and/or our App.
• In the case of Influencers, when you publicly share information on social media on your public profile and in posts relating to places of interest, things for people to go and see, things to do such as activities, food, experiences etc. which you go to or recommend.
• In the case of Influencers, when you participate in an Influencer marketing job listed by a business on the Platform (a “Gig”).

It does not apply to information collected by:
• us through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• any third party, including through any application or content (including advertising) that may link to or be accessible from our Site and/or App.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using our Site and/or our App, Platform, or Services you agree to this Policy.
You should check this Policy frequently for any changes. We reserve the right to modify or amend the terms of our Policy from time to time and you will be notified of such changes by notifications on our Site, and/or App, or by sending you emails informing you of such changes, or by any other reasonable means. Your continued use of our Platform following the posting of changes to these terms will mean you accept those changes. If we intend to apply the modifications or amendments to this Policy pertaining to Personal Data already in our possession, we will provide you with notice of the modifications or amendments 15 days prior to such modifications or amendments taking effect.
BY ACCESSING OUR PLATFORM, AND/OR BY USING OUR SERVICES OR PARTICIPATING IN A GIG, YOU ARE AGREEING TO AND ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OUR SITE, APP, OUR PLATFORM, AND/OR SERVICES.


Children Under the Age of 16

Our Site and/or our App, Platform, or Services is not intended for persons under 16 years of age. No one under age 16 may provide any information to our Site, App, Platform, or Services. Specifically, we do not knowingly collect Personal Data from children under 16. If you are under 16, do not use or provide any information on our Site and/ or App or on or through any of its features/register on the Site, download our App, access our Platform, establish an Account, use our Services, and/or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at info@dotspot.tech.


Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Site and/ or App, including the following information:
1. Account Information. This information is collected when you establish your Account and/or apply to participate in a Gig. Dotspot collects information by which you may be personally identified, such as name, postal address, e-mail address, your Social Media Provider identifiers, including Instagram handle, from which we will also get your basic information from your profile like your name, gender, profile photo, followers, geolocations, information pertaining to a Gig, and any other identifier by which you may be contacted online or offline (“Personal Data”).
2. Activities on your Account. When you create an account on our Site and/or App, we will collect details of transactions you carry out through our Site and/or App and of the fulfilment of your Gigs.
3. Payment Method. At the appropriate time, we will require you to furnish us information for facilitating Payment. Such information will include your account information including routing number, bank information, PayPal information for facilitating Payment, and/or other necessary information. Our payment processing partners facilitate the payment and they may require some tax related information to facilitate such payment. We do not keep your tax information.
4. Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, phone numbers, the contents of the message. This also includes information collected from you when you participate in a Gig.
5. Information that we collect when you use our Site and/or App
• Location Information. We collect this information automatically as you navigate through our Site and/or App, through your Internet provider or wireless service provider, whichever applicable.
• Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Site and/or App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Site and/or App, including traffic data, location data, logs and other communication data and the resources that you access and use on the Site and/or App.
- Information about your computer, mobile device, including the current version of the operating system on your phone, and/or internet connection, including your IP address, operating system and browser type.
- We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and does not include Personal Data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties. It helps us to improve our Site and/or App and to deliver a better and more personalized service, including by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Site and/or App according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Site and/or App.
The technologies we use for this automatic data collection may include:
• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site and/or App. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site and/or App.
We do not collect Personal Data automatically, but we may tie this information to Personal Data about you that we collect from other sources or you provide to us.
We collect and process Influencers’ personal data which is publicly available on social media, in order to provide our App. We initially collect such personal data to determine whether to include an Influencer’s recommendations on the App, and if so we embed that Influencer’s Instagram posts recommending places of interest etc. This includes the following information, either collected directly from the Influencers’ social media profile or by cross-referring using the Facebook Places API:
• Instagram handle
• Instagram username
• Information included in Instagram bio section (this may include name and email address)
• Posts (images and text) posted publicly on Instagram
• Geolocation – using location tagged in Instagram post, cross-referenced with Facebook Places to give location map coordinates
If you are an Influencer whose Instagram posts are embedded in our App, and you do not wish this to continue, please let us know and we would be happy to delete the link. We will need to retain a copy of your Instagram handle as a record that you do not wish your posts to be used.


How We Use Your Information

Lawful basis for processing
Most commonly we will use your personal data where we need to perform a contract we are about to enter or have entered with you, or where you have consented before the processing.
We will collect and process Influencers’ personal data which they publicly post on social media where it is necessary for our legitimate interests, and the Influencers’ interests and fundamental rights do not override those interests. Our legitimate interests are to help our users save, organise and display on maps the geotagged locations that their favourite Influencers have made public on Instagram.

Purposes of processing

To install the App and register you as a new App user
• Type of data: Account information
• Lawful basis for processing: Your consent

To process in-App purchases and deliver services including managing payments and collecting money owed to us
• Type of data: account information, payment method, activities on your account
• Lawful basis for processing: your consent, performance of a contract with you, necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you, including notifying you of changes to the App or any services
• Type of data: account information, payment method, activities on your account, communications
• Lawful basis for processing: your consent, performance of a contract with you, necessary for our legitimate interests (to keep records updated and to analyse how customers use our products and services), necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey
• Type of data: account information, information We Collect Through Automatic Data Collection Technologies, activities on your account, communications
• Lawful basis for processing: your consent, performance of a contract with you, necessary for our legitimate interests (to analyse how customers use our products and services, and to develop them and grow our business)

To administer and protect our business and the App including troubleshooting, data analysis and system testing
• Type of data: account information, information We Collect Through Automatic Data Collection Technologies, activities on your account
• Lawful basis for processing: necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve the App
• Type of data: account information, information We Collect Through Automatic Data Collection Technologies, activities on your account, communications, location information
• Lawful basis for processing: your consent, necessary for our legitimate interests (to develop our products and services, and grow our business)

In relation to Influencers: to determine which Influencers and which posts to embed in our App
• Type of data: name, username(s), photographs, geolocation
• Lawful basis for processing: necessary for our legitimate interests (to help our users save, organise and display on maps the geotagged locations that their favourite Influencers have made public on Instagram)

In relation to Influencers: to embed Instagram posts in our App (i.e.
• Type of data: name, username(s), photographs, geolocation
• Lawful basis for processing: necessary for our legitimate interests (to help our users save, organise and display on maps the geotagged locations that their favourite Influencers have made public on Instagram)

In addition, we may use information that we collect about you or that you provide to us, including any Personal Data for any other purpose with your consent, or to comply with the law (e.g. disclosure to HMRC for tax purposes).


Disclosure of Your Information

We may disclose aggregated information about our users and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:
• To our subsidiaries and affiliates.
• To contractors, service providers and other third parties, such as our payment processing partners, we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Dotspot’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by Dotspot about our Site and/or App users is among the assets transferred.
• For any other purpose disclosed by us when you provide the information.
•  With your consent.

We may also disclose your Personal Data:
• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use, and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Dotspot, our • customers or others.


Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. We do not sell, trade, or otherwise transfer your Personal Data unless we provide you with advance notice. However, this does not include website hosting partners and other third parties who assist us in operating our Site and/ or App, conducting our business, or servicing, so long as those parties agree to keep your information confidential.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an e-mail stating your request to
info@dotspot.tech.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.


Where We Store Your Personal Data

All information we hold about you is stored on our secure servers [in the UK / within the EEA].
The data that we collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.
Such countries may not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission may not have given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to a United Kingdom and/or European Commission approved contract designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
If you would like further information please contact us (see ‘Contact Information’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.


Accessing and Correcting Your Information

If you are a User, you can review and change your Personal Data by logging into the Site and/or App and visiting your Account page.
You may also send us an e-mail at
info@dotspot.tech to request access to, correct or delete any Personal Data that you have provided to us. We cannot delete your Personal Data except by also deleting your Account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your Account from our Site, App, or Platform, copies of your Content may remain viewable in cached and archived pages or might have been copied or stored by other Site or App users.
If you are an Influencer whose Instagram posts are embedded in our App, and you do not wish this to continue, please let us know and we would be happy to delete the link. We will need to retain a copy of your Instagram handle as a record that you do not wish your posts to be used.


Data Subject Rights

You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Information” section of this policy.

• Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
• Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services or Platform and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services and Platform.
• Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

If you have any concerns or questions or if you have any complaints about how we handle Personal Data collected from EU and EEA residents (not applicable to Switzerland), please email them to
info@dotspot.tech. We strive to address those requests or complaints expeditiously.


Data Retention

How long we retain your Personal Data depends on the type of data and the purpose for which we process the data.
We will hold User Data for 6 years following the User’s deletion of the App.
We will hold Influencer data while the App is available to the public, and for 6 years following this period.


Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site and/or App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Site and/or App. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site and/or App.


Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Site home page and comparable place on the App. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Site and/or App and this privacy policy to check for any changes.


Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:
info@dotspot.tech

Last updated: 25 March 2019


Privacy Policy

Dotspot Limited (“Dotspot”, the “Company” or “We”) respect your privacy and we are committed to protecting it through our compliance with this policy.
This privacy policy (the “Policy”) describes the types of information, including Personal Data that we may collect from you or that you may provide when you visit our website www.dotspot.tech (our “Site”), and/or our mobile application (our “App”) (our Site and App together our “Platform”), establish an Account, and our practices for collecting, using, maintaining, protecting and disclosing that information. As used in this Privacy Policy, “Personal Data” means any information that can be used to individually identify a person, and may include, but is not limited to, name, email address, postal or other physical address, title, and other personally identifiable information as fully defined below.
If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.
For the purpose of the GDPR, the Data Controller is Dotspot Limited.
This policy applies to information we collect:
• On our Site and our App.
• On phone calls, in e-mail, text and other electronic messages between you and Dotspot.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to our Site and/or App.
• When you voluntarily share information from your Social Media Provider account with Dotspot via our Site and/or our App.
• In the case of Influencers, when you publicly share information on social media on your public profile and in posts relating to places of interest, things for people to go and see, things to do such as activities, food, experiences etc. which you go to or recommend.
• In the case of Influencers, when you participate in an Influencer marketing job listed by a business on the Platform (a “Gig”).

It does not apply to information collected by:
• us through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• any third party, including through any application or content (including advertising) that may link to or be accessible from our Site and/or App.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using our Site and/or our App, Platform, or Services you agree to this Policy.
You should check this Policy frequently for any changes. We reserve the right to modify or amend the terms of our Policy from time to time and you will be notified of such changes by notifications on our Site, and/or App, or by sending you emails informing you of such changes, or by any other reasonable means. Your continued use of our Platform following the posting of changes to these terms will mean you accept those changes. If we intend to apply the modifications or amendments to this Policy pertaining to Personal Data already in our possession, we will provide you with notice of the modifications or amendments 15 days prior to such modifications or amendments taking effect.
BY ACCESSING OUR PLATFORM, AND/OR BY USING OUR SERVICES OR PARTICIPATING IN A GIG, YOU ARE AGREEING TO AND ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OUR SITE, APP, OUR PLATFORM, AND/OR SERVICES.


Children Under the Age of 16

Our Site and/or our App, Platform, or Services is not intended for persons under 16 years of age. No one under age 16 may provide any information to our Site, App, Platform, or Services. Specifically, we do not knowingly collect Personal Data from children under 16. If you are under 16, do not use or provide any information on our Site and/ or App or on or through any of its features/register on the Site, download our App, access our Platform, establish an Account, use our Services, and/or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at info@dotspot.tech.


Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Site and/ or App, including the following information:
1. Account Information. This information is collected when you establish your Account and/or apply to participate in a Gig. Dotspot collects information by which you may be personally identified, such as name, postal address, e-mail address, your Social Media Provider identifiers, including Instagram handle, from which we will also get your basic information from your profile like your name, gender, profile photo, followers, geolocations, information pertaining to a Gig, and any other identifier by which you may be contacted online or offline (“Personal Data”).
2. Activities on your Account. When you create an account on our Site and/or App, we will collect details of transactions you carry out through our Site and/or App and of the fulfilment of your Gigs.
3. Payment Method. At the appropriate time, we will require you to furnish us information for facilitating Payment. Such information will include your account information including routing number, bank information, PayPal information for facilitating Payment, and/or other necessary information. Our payment processing partners facilitate the payment and they may require some tax related information to facilitate such payment. We do not keep your tax information.
4. Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, phone numbers, the contents of the message. This also includes information collected from you when you participate in a Gig.
5. Information that we collect when you use our Site and/or App
• Location Information. We collect this information automatically as you navigate through our Site and/or App, through your Internet provider or wireless service provider, whichever applicable.
• Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Site and/or App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Site and/or App, including traffic data, location data, logs and other communication data and the resources that you access and use on the Site and/or App.
- Information about your computer, mobile device, including the current version of the operating system on your phone, and/or internet connection, including your IP address, operating system and browser type.
- We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and does not include Personal Data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties. It helps us to improve our Site and/or App and to deliver a better and more personalized service, including by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Site and/or App according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Site and/or App.
The technologies we use for this automatic data collection may include:
• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site and/or App. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site and/or App.
We do not collect Personal Data automatically, but we may tie this information to Personal Data about you that we collect from other sources or you provide to us.
We collect and process Influencers’ personal data which is publicly available on social media, in order to provide our App. We initially collect such personal data to determine whether to include an Influencer’s recommendations on the App, and if so we embed that Influencer’s Instagram posts recommending places of interest etc. This includes the following information, either collected directly from the Influencers’ social media profile or by cross-referring using the Facebook Places API:
• Instagram handle
• Instagram username
• Information included in Instagram bio section (this may include name and email address)
• Posts (images and text) posted publicly on Instagram
• Geolocation – using location tagged in Instagram post, cross-referenced with Facebook Places to give location map coordinates
If you are an Influencer whose Instagram posts are embedded in our App, and you do not wish this to continue, please let us know and we would be happy to delete the link. We will need to retain a copy of your Instagram handle as a record that you do not wish your posts to be used.


How We Use Your Information

Lawful basis for processing
Most commonly we will use your personal data where we need to perform a contract we are about to enter or have entered with you, or where you have consented before the processing.
We will collect and process Influencers’ personal data which they publicly post on social media where it is necessary for our legitimate interests, and the Influencers’ interests and fundamental rights do not override those interests. Our legitimate interests are to help our users save, organise and display on maps the geotagged locations that their favourite Influencers have made public on Instagram.

Purposes of processing

To install the App and register you as a new App user
• Type of data: Account information
• Lawful basis for processing: Your consent

To process in-App purchases and deliver services including managing payments and collecting money owed to us
• Type of data: account information, payment method, activities on your account
• Lawful basis for processing: your consent, performance of a contract with you, necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you, including notifying you of changes to the App or any services
• Type of data: account information, payment method, activities on your account, communications
• Lawful basis for processing: your consent, performance of a contract with you, necessary for our legitimate interests (to keep records updated and to analyse how customers use our products and services), necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey
• Type of data: account information, information We Collect Through Automatic Data Collection Technologies, activities on your account, communications
• Lawful basis for processing: your consent, performance of a contract with you, necessary for our legitimate interests (to analyse how customers use our products and services, and to develop them and grow our business)

To administer and protect our business and the App including troubleshooting, data analysis and system testing
• Type of data: account information, information We Collect Through Automatic Data Collection Technologies, activities on your account
• Lawful basis for processing: necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve the App
• Type of data: account information, information We Collect Through Automatic Data Collection Technologies, activities on your account, communications, location information
• Lawful basis for processing: your consent, necessary for our legitimate interests (to develop our products and services, and grow our business)

In relation to Influencers: to determine which Influencers and which posts to embed in our App
• Type of data: name, username(s), photographs, geolocation
• Lawful basis for processing: necessary for our legitimate interests (to help our users save, organise and display on maps the geotagged locations that their favourite Influencers have made public on Instagram)

In relation to Influencers: to embed Instagram posts in our App (i.e.
• Type of data: name, username(s), photographs, geolocation
• Lawful basis for processing: necessary for our legitimate interests (to help our users save, organise and display on maps the geotagged locations that their favourite Influencers have made public on Instagram)

In addition, we may use information that we collect about you or that you provide to us, including any Personal Data for any other purpose with your consent, or to comply with the law (e.g. disclosure to HMRC for tax purposes).


Disclosure of Your Information

We may disclose aggregated information about our users and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:
• To our subsidiaries and affiliates.
• To contractors, service providers and other third parties, such as our payment processing partners, we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Dotspot’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by Dotspot about our Site and/or App users is among the assets transferred.
• For any other purpose disclosed by us when you provide the information.
•  With your consent.

We may also disclose your Personal Data:
• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use, and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Dotspot, our • customers or others.


Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Disclosure of Your Information for Third-Party Advertising. We do not sell, trade, or otherwise transfer your Personal Data unless we provide you with advance notice. However, this does not include website hosting partners and other third parties who assist us in operating our Site and/ or App, conducting our business, or servicing, so long as those parties agree to keep your information confidential.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending us an e-mail stating your request to
info@dotspot.tech.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.


Where We Store Your Personal Data

All information we hold about you is stored on our secure servers [in the UK / within the EEA].
The data that we collect from you may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services.
Such countries may not have the same data protection laws as the United Kingdom and EEA. Whilst the European Commission may not have given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the United Kingdom and EEA, any transfer of your personal data will be subject to a United Kingdom and/or European Commission approved contract designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
If you would like further information please contact us (see ‘Contact Information’ below). We will not otherwise transfer your personal data outside of the United Kingdom or EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.


Accessing and Correcting Your Information

If you are a User, you can review and change your Personal Data by logging into the Site and/or App and visiting your Account page.
You may also send us an e-mail at
info@dotspot.tech to request access to, correct or delete any Personal Data that you have provided to us. We cannot delete your Personal Data except by also deleting your Account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your Account from our Site, App, or Platform, copies of your Content may remain viewable in cached and archived pages or might have been copied or stored by other Site or App users.
If you are an Influencer whose Instagram posts are embedded in our App, and you do not wish this to continue, please let us know and we would be happy to delete the link. We will need to retain a copy of your Instagram handle as a record that you do not wish your posts to be used.


Data Subject Rights

You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.
To make any of the following requests, contact us using the contact details referred to in the “Contact Information” section of this policy.

• Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging into your service account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
• Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all of our Services or Platform and you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services and Platform.
• Right to File Complaint: You have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

If you have any concerns or questions or if you have any complaints about how we handle Personal Data collected from EU and EEA residents (not applicable to Switzerland), please email them to
info@dotspot.tech. We strive to address those requests or complaints expeditiously.


Data Retention

How long we retain your Personal Data depends on the type of data and the purpose for which we process the data.
We will hold User Data for 6 years following the User’s deletion of the App.
We will hold Influencer data while the App is available to the public, and for 6 years following this period.


Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site and/or App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Site and/or App. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site and/or App.


Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ Personal Data, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Site home page and comparable place on the App. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Site and/or App and this privacy policy to check for any changes.


Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:
info@dotspot.tech