Privacy Policy

Effective Date: 27 March 2024

Last Updated: 22 March 2024

This Privacy Policy details the measures that we take to preserve and safeguard your privacy when you visit Spoil Me or use our Service. It also demonstrates how we may process data in accordance with the EU General Data Protection Regulation ("GDPR"). For the purpose of the GDPR, the data controller is Spoildotme Ltd, HE 446803, Nikolaou Lazarou 13, 3020 Limassol, Cyprus (“Spoil Me”, “we” or “us”) is committed to protecting the privacy of all individuals in respect of whom we hold personal information.

PLEASE READ THIS PRIVACY POLICY CAREFULLY

By using the Spoil Me mobile application (the "App") or the website located at https://spoil.me, including any products and services related to it (the "Website") or any (App and Website individually referred to as a "Spoil Me Service" or collectively as the "Spoil Me Services") or otherwise indicating your acceptance (e.g. by clicking tick-box or bottom "agree" or "continue"), you agree to the following terms of our Privacy Policy, which will bind you at all times and in whatever manner you use the Spoil Me Services.

Please note:

1. PERSONAL DATA WE COLLECT.

Generally, “personal information”, “personal data” or similar terms refer to any information that identifies you or relates to you. However, the exact meaning of personal information may be determined by the law of the country of your residence.

We will process the following information which may be considered personal information:

Information You Provide To Us Directly

  • Account details of Creator. Your user details when you sign up as a Creator, such as your name/ user name and email address. Your connected Stripe account.
  • Profile Data as Creator
    • Information, such as your username, name, surname, your profile image.
    • Social media profile usernames/links. If you choose to link your social media account to your Spoil Me account.
    • Your content. You may also post the content, like your wishlist, photos or video. To add certain content, like photos, you may allow us to access your camera or photo album.
      You can choose what information to share on your profile. You don't have to provide additional information on your profile; however, profile information helps you to get more from our Spoil Me Services. Be cautious when sharing information, as it may become visible to other users.
  • Information of Fan. Information you provide in connection with completing a transaction or make a payment of Gift Fund, using the Spoil Me Services as a Fan, including your name, e-mail, and any other information you decide to provide. Your provided email will be used solely for the purpose of completing transactions and send Services related communications.
  • Details of your request. When you contact or visit us, we may process the details of your request, communications, complaints, or other interaction.
  • Activity Data. Information you provide to us when you participate in any interactive features of Spoil Me Services, including surveys, contests, promotions.

Information We Collect Automatically

Such automatically collected data helps us operate Spoil Me and improve it to deliver better service, including but not limited to enabling us to estimate our audience size, and understand how you use Spoil Me and what you like and dislike the most.

  • Transaction information. Transaction information such as your payment in our Spoil Me Services as Fan, including date of purchase, currency, amount, payment type and the last four digits of your card number.
  • App and country information: Information regarding the version of the app that you are using and the country version of the app store from which you downloaded Spoil Me.
  • Technical information. When accessing Spoil Me Services, your device and browser will automatically provide unique information such as account ID, mobile device ID, internet protocol (IP) address, cookie ID or online identifiers, language preferences, operating system, browser type, time zone setting, approximate location and date and time of access. (If you have provided your consent) IDFA, whichever is applicable to your device. If you want to disable the collection of IDFA by Spoil Me Services, please follow in-app instructions.

If you use an iOS device:

Go to Privacy settings to see a list of apps that request to track your activity. On iPhone or iPad, go to Settings > Privacy > Tracking.

Tap to turn off or turn on permission to track for Spoil Me.

We, along with third parties, may employ cookies, Software Development Kits (SDKs), and other technologies that track and automatically gather the mentioned Personal Data. For additional details about how we use these technologies, refer to the section titled "Cookies, Software Development Kits, and Other Tracking Technologies".

  • Usage data. Details of your use of Spoil Me, including frequency of use, areas and features of the application that you access and information regarding engagement with particular features of the app.
  • Interaction information. When we send you emails or other communications, we may collect technical interaction information, such as opens and clicks.

Information We Obtain From Third Parties

In addition to the information you may provide us directly, we receive information about you from others, including:

  • Social media. You may decide to share information with us through your social media account, such as your interaction with our posts and content, social media profile by sharing your "stories" and 'likes' on social media platforms, such as Twitter and Instagram, TikTok.
  • Our suppliers. We may receive information about you from our partners where our ads are published on a partner's service (in which case they may pass along details on a campaign's success). We may receive information about you from our analytics service providers to help us measure traffic and usage trends with data they collect through Spoil Me Services in accordance with their own privacy policies.

2. DATA ACCURACY

We will rely on the information provided by you as accurate, complete, and up to date, and we would be grateful if you could inform us of any changes.

3. HOW WE USE YOUR INFORMATION

If you are an individual in the EEA or the UK, we have to inform you about the "legal ground" for us to use your "personal data". This will typically be the performance of our contract with you (based on our Spoil Me Terms of Use) or our legitimate interest to use your personal data to ensure that Spoil Me Services are provided properly, efficiently and securely, as is further explained below. We may be obligated to process some of your personal data to comply with applicable laws and regulations.

Where the legal basis is consent, you can withdraw consent at any time. You may withdraw your consent by adapting your settings or by deleting your content (for instance where you entered information in your profile that may be considered 'special' or 'sensitive'). In any case, you may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

Where we rely on legitimate interests as the legal basis for processing personal data, we have considered whether or not those interests are overridden by the interests or fundamental rights or freedoms of the individuals whose data are being processed and concluded that the processing is, on balance, fair. Where the legal basis is legitimate interests, you have a right to object to our use of your data.

We use your information for the following purposes:

  • To register you as a service user when you sign up for Spoil Me Services and to enable you to use Spoil Me Services and its functionalities.
  • To enable you to make payments through our Spoil Me Service.
  • To assist and contact you in relation to your enquiry or to send you information which you have requested about Spoil Me Services.
  • To fulfill your requests and send you service communications and notifications about matters relevant to your use of Spoil Me Services and your engagement with us, such as information about offers you might be interested in, targeted content, confirmations of purchases, details of events, surveys, changes in our terms, etc.
  • To send you promotional information through various marketing channels including post, email, social media and etc. about Spoil Me Services and our organization, reviewing and optimizing campaign performance and profiling information about your interests known, observed or inferred for direct marketing purposes.
  • To improve and develop Spoil Me Services, including to: obtain feedback; record preferences; conduct statistical analysis; make services and features more relevant; improve user experience; and work with third parties and evaluate data to improve and develop Spoil Me Services.
  • To ensure proper administration of our business, including to: keep appropriate records about how Spoil Me Services are used; resolve complaints; conduct troubleshooting; manage our business relationships and identify opportunities; register interactions with our communications, such as emails; enforce our terms; and debt collection.
  • To engage our third party service providers who may process your information on our behalf to facilitate the provision of Spoil Me Services and the fulfillment of essential service functions, such as web hosting, cloud storage, analytics, payments, plugins, communications, accounting, security and others. It is our legitimate interest in delivering our Spoil Me Services properly, efficiently and understanding our users’ needs and to make analytics of our audience as it helps us understand our product and business metrics.
  • To monitor our networks, Spoil Me Services and systems for suspicious activities, test and audit our systems and deploy appropriate security measures.
  • To monitor operations, user activity and networks for fraud prevention, including information from third parties who may alert us about suspicious activities.
  • To share information with our group companies.
  • To share data with another organization for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization or similar event relating to our business.
  • To process information as is required for our compliance with the law or to establish, exercise or defend legal claims.
  • To process and share information with other third parties where required by law, such as regulators, law enforcement agencies or where mandatory under a court order.

4. PAYMENT DETAILS.

Spoil Me does not process payments from Users. When making a payment, you enter your credit card details into a form supplied by the third-party payment provider that will be processing the payment, and this information goes directly to the payment provider‘s server. We do not receive any of your actual payment details or personal data related to the payment, we only keep the data about transaction dates, currencies, value, and transaction subjects.

5. COOKIES, SOFTWARE DEVELOPMENT KITS, AND OTHER TRACKING TECHNOLOGIES

When you use Spoil Me Services, we, along with our service providers, vendors, and third-party partners, may use cookies and similar technologies to gather certain data about you and your usage of the Spoil Me Services.

We also utilize third-party analytics tools to assist us in monitoring traffic and usage patterns for Spoil Me. These tools gather data through third-party SDKs integrated into Spoil Me, including data about which features of Spoil Me you access or use, your actions within the app. This data may be used to provide content, advertising, or functionality, or to measure and analyze ad performance on Spoil Me or other websites or platforms. Third parties may also use this information for their own purposes.

We may collaborate with ad networks and other ad-serving providers that display ads for us and others on non-affiliated platforms. Some of these ads may be personalized, meaning they are intended to be relevant to you based on information ad networks and ad-serving providers gather about your use of the app over time, including information about relationships among different browsers and devices. This is known as interest-based advertising.

Your choices. Most browsers and devices are set to accept cookies and similar tracking technologies by default. However, you may have the option to set your browser and device settings to limit these technologies. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

For users in the European Economic Area, United Kingdom, and United States, you can opt out from the processing of Personal Data via cookies, SDKs, and other tracking technologies by sending a request to [email protected].

Further, you can prevent our Spoil Me Services from setting cookies by using a browser with privacy features or installing browser plugins and configuring them to block cookies/trackers.

Be aware that these opt-out mechanisms apply specifically to the device or browser in which they are activated. Therefore, you'll need to opt out on every browser and device that you use. Also, note that some parts of the Spoil Me Services may not work as intended if you refuse cookies or similar tracking technologies, and disabling these technologies may restrict your access to some of our content. Your choices are typically specific to the device and browser you use.

6. HOW WE MAY DISCLOSE YOUR INFORMATION TO THIRD PARTIES

We do not rent or sell your Personal Data to any third parties outside the Spoil Me or its affiliates (as defined below).

We do not share your personal information except as approved by you or as described below:

  • We may engage other companies and individuals to perform services on our behalf. An example of these services may include analyzing data and providing customer support. These agents and service providers may have access to your personal information in connection with the performance of services for us, and they are bound by appropriate contractual safeguards in place.
  • We may release your information as permitted by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, or safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection. In certain situations, Spoil Me may be required to disclose personal information in response to lawful requests by public authorities or for local law enforcement requirements.
  • We may share your Personal Data if our company or any of our affiliates, subsidiaries or business units is involved in a business change such as a merger, divestiture, restructuring, reorganization, acquisition, bankruptcy, dissolution, or liquidation. In these situations, your Personal Data and other collected data may be among the assets transferred or disclosed as part of the business transaction or proceeding.
  • Spoil Me may contain third party tracking and data collection and analytics tools from our service providers. Such third parties may use cookies, APIs, and SDKs in Spoil Me to enable them to collect and analyze user and device related data and information on our behalf. We collect and use this analytics information in an aggregated manner with analytics information so that it cannot reasonably be used to identify any particular user. The privacy policies of our service providers may include additional terms and disclosures regarding their data collection and use practices and tracking technologies, and we encourage you to check those privacy policies to learn more about their data collection and use practices, use of cookies and other similar tracking technologies.
  • We may share aggregate or anonymized information about you with advertisers, publishers, business partners, sponsors, and other third parties.
  • Sharing with other users. You share information with other Users when you voluntarily disclose information on Spoil Me Service (including your public Profile data).

7. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers, mobile operating systems, and apps have a Do-Not-Track ("DNT") feature or setting that can be turned on to indicate your preference not to have your online browsing activities monitored and collected. However, there isn't a uniform standard tech solution for recognizing and implementing DNT signals yet. As a result, we currently do not respond to DNT browser signals or any other automatic method that indicates your decision not to be tracked online. If a standard for online tracking is created that we are required to adhere to in the future, we will update you on this practice in an updated version of this privacy notice. We do acknowledge the global privacy control signal if your browser or device is using such a signal. For more information, please refer to Section “Your Choices” above.

8. LINKS TO OTHER SITES

For the convenience of our visitors and clients, Spoil Me Services may contain links to other sites, such as those of our partners or vendors, which are subject to different privacy policies. The Policy will not apply to your use of other websites. While we generally try to link only to sites that share similar high standards and respect for privacy, we have no responsibility or liability for the content, products or services offered, independent actions, or the privacy and security practices employed by these other independent sites. We encourage you to ask questions and review the applicable privacy policies found on such other websites, services and applications to understand how your information may be collected and used on these independent sites before disclosing information to third parties.

9. HOW LONG IS YOUR INFORMATION KEPT

We retain your Personal Data for as long as your account is active or as needed for the purposes of processing. At any time, you can delete your account, as well as the Personal Data associated with it by sending a request to [email protected] or proceed with App Settings.

Please note that we still may retain certain data about you if so needed due to applicable legislation requirements, any potential or ongoing dispute resolution, or in order to enforce our rights. Even if we delete some or all of your Personal Data, we may continue to retain and use anonymized data previously collected that can no longer be used for personal identification.

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

Please, note that deletion of App does not imply the deletion of your account and your data.

10. HOW DO WE SECURE YOUR INFORMATION

We employ organizational and technical measures to protect against unauthorized access, accidental loss, alteration, or destruction of the personal data we hold. We also ensure our third-party service providers uphold similar standards.

We strive to use the minimum amount of personal data necessary for each purpose.

Our staff is granted access to your personal data strictly on a "need-to-know" basis.

Regrettably, the transfer of personal data over the internet isn't entirely secure. Despite our best efforts to safeguard your personal data, we can't fully guarantee the security of your data transmitted to or stored in our IT systems, and any transmission is at your own risk. Upon receiving your personal data, we will do our utmost to protect it.ill use strict procedures and security features to try to prevent unauthorized access.

11. WHERE IS YOUR INFORMATION PROCESSED

We may transfer your personal information to our group companies, suppliers and other third parties in countries different to your country of residence.

In addition, data may be transferred to our subsidiaries or processors in third countries or subcontractors of our processors in third countries.

Some of our service providers are based in the United States, which means your personal data may be transferred to and stored in the United States. We may disclose your personal data to some US companies, in particular to Stripe Inc., for the purpose of providing the Service to you.

Where required under the EEA GDPR, in case of transfers of personal data from the EEA to countries outside the EEA, where we cannot rely on adequacy decisions adopted by the European Commission (for more information, please see here) we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the Standard Contractual Clauses of the European Commission (article 46(2)(c) GDPR). For more information on these Standard Contractual Clauses, please see here.

Where required under the UK GDPR, in case of transfers of personal data to countries outside the United Kingdom, we ensure appropriate safeguards are in place to guarantee the continued protection of your personal data, particularly by signing the UK Addendum to the EU Standard Contractual Clauses or the UK International Data Transfer Agreement, whichever is more appropriate in the given situation. For more information on UK Addendum and the UK International Data Transfer Agreement please see here. We may also guarantee the protection of your personal data by relying on adequacy decisions adopted or approved by the authorities in the United Kingdom.

12. YOUR RIGHTS.

Depending on where you reside you may have the right to have access to your personal information and ask us to rectify, erase and restrict the use of your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us, and to withdraw consent to the use of your personal information. You can exercise these rights directly with us by submitting a request at [email protected]. Subject to applicable law, you also have the right to restrict our use of information that constitutes your personal data for marketing purposes and lodge a complaint or direct questions to the data protection authority. If you believe that Spoil Me has not processed your personal data in accordance with the applicable legislation, you may submit a complaint to the data protection authority through the website www.dataprotection.gov.cy.

13. ELECTRONIC COMMUNICATIONS.

As a user of our service, your agreement includes receiving electronic communications from us, which could be via email or push notifications. All interactions between us will occur electronically, whether you are using our Spoil Me Services, sending us emails, or we are posting notices on our service or sending you emails. These communications may involve service-related notices as part of your relationship with us. It's important to note that you agree to receive communications from us electronically for contractual purposes, and you accept that all terms and conditions, agreements, notices, disclosures, and any other communications we provide to you electronically meet any legal requirement as though they were in writing. This does not affect your statutory rights. Communications from us and our affiliated companies may encompass operational communications about your account or the use of our Spoil Me Services,, for example, technical and security notices, updates to this Privacy Policy and Terms and Conditions, and updates about new and existing features such as changes/updates to features of our Spoil Me Services, and their scope, prices of in-app subscriptions.

If legally required, we'll seek your consent to send promotional materials about new products, features, or offers from Spoil Me and its affiliates.

You have the option to unsubscribe from receiving promotional emails from us at any time by:

  • Following the unsubscribe links in any promotional email sent to you.
  • Reaching out to us anytime at [email protected].

You may opt-out of push notifications by changing the settings on your mobile device.

14. AGE RESTRICTION.

You may use the Service only if you are over the age of eighteen (18). We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. If you believe that we may have collected personal data from a child, please contact us directly at [email protected] in order to remove it.

15. UPDATES.

This Privacy Policy may change from time to time, and we encourage you to review it periodically. The last revision date this Privacy Policy is indicated at the top of the page. We may modify or update this Privacy Policy from time to time. We may make revisions or updates to this Privacy Policy from time to time. However, if we determine that the changes may have risk to your rights and freedoms, we will ask for your consent to those changes.

16. CONTACT INFORMATION

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us [email protected].

SPOILDOTME LTD, Nikolaou Lazarou 13, 3020 Limassol, Cyprus; registration number HE 446803.

17. YOUR EEA & UK DATA PRIVACY RIGHTS

This section provides further disclosures and describes the rights in relation to your personal data that you may have under GDPR if you are an individual in the EEA or UK GDPR if you are an individual in the UK.

Personal data

“Personal data” means any information relating to an identified or identifiable natural person; such person is known as a ‘data subject’. In practice, almost all information relating to you will be your personal data.

How do we process your information and why?

We will process your personal data as “controller” for the purposes and on the legal grounds for processing set out above. We will update you about any new purposes of processing your personal data from time to time, and we will obtain your prior consent for such new purposes where we are required to do so at law.

Data subject rights

Subject to certain exemptions, limitations and appropriate proof of identity, as a data subject, you will generally have numerous rights in relation to your personal data that you may exercise with the controller, including the following:
  1. Right to request the categories of Personal Information collected about you. You may also contact us for further details about our retention policy and international data transfers.
  2. Right to make an access request to receive copies of personal data, as well as to share your personal data with other parties.
  3. Right to rectification of any inaccurate or incomplete personal data.
  4. Right to withdraw consent previously provided, without affecting the lawfulness of our processing based on consent before its withdrawal.
  5. Right to object to our processing of personal data for direct marketing purposes, or that is based on our legitimate interests, and any automated decision-making and profiling.
  6. Right to erasure of personal data, in certain circumstances.
  7. Restriction on the processing of personal data in certain circumstances.
  8. Right to data portability from one service provider to another, where applicable.
  9. Right to lodge a complaint with your country’s supervisory authority. Subject to the GDPR, you have the right to lodge a complaint with a local data protection authority in the country of your residence, where you work or where an alleged infringement of the applicable data protection law took place. Please see a list of EU member states’ supervisory authority here, and the UK’s supervisory authority (ICO) here.

All requests will be processed in a timely manner, generally within one month. If we cannot process your request within this period we shall explain why and process it as soon as possible thereafter. You can exercise these rights directly with us by submitting a request at [email protected]. Please note that these rights are not absolute and we may be entitled (or required) to refuse requests where exceptions apply.

18. YOUR CALIFORNIA PRIVACY RIGHTS

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

19. YOUR NEVADA DATA PRIVACY RIGHTS

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to [email protected]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.