Privacy Policy

Last updated: 19 August 2026

This Privacy Policy explains how Spoty ("Spoty", "we", "us", "our") collects, uses, shares and protects information when you use the spoty.app website and the Spoty mobile applications for Android and iOS (together, the "Service"). It should be read together with our Terms of Use.

By using the Service, you agree to the collection and use of information as described in this Policy.

1. Who We Are

The Service is currently operated on an unincorporated basis under the name "Spoty" / "spoty.app". For the purposes of this Policy, "we", "us" and "our" refer to the Spoty operator. Once Spoty is operated through a registered legal entity, this section will be updated to include that entity's full name, registration number and legal address.

Contact: [email protected]

2. Scope

This Policy applies to:

  • the spoty.app website;
  • the Spoty mobile app on Android (Google Play);
  • the Spoty mobile app on iOS (App Store).

The mobile apps display the same content as the website and share the same data practices described below.

3. Information We Collect

3.1 Location data

If you allow it, we access your device's location (precise or approximate) to show you lunch and happy-hour offers near you on the map. On mobile, this uses the "when in use" location permission; on web, it uses your browser's geolocation feature. Location is used to display nearby offers and is not stored on our servers beyond what is necessary for that session.

3.2 Usage and analytics data

We currently use Google Analytics to understand how the Service is used. This may collect information such as pages/screens viewed, approximate location derived from your IP address, device and browser type, and session data, using cookies or similar technologies (see Section 5).

3.3 Content you provide to us

  • Contact/support requests: if you email us (e.g. [email protected]), we receive your email address, name (if given) and the content of your message.
  • Comments and reviews: if the Service allows you to leave comments or reviews about restaurants or offers, we collect the content you submit and any name/handle you provide with it.

3.4 Planned features (not yet active)

We plan to introduce user accounts (email/password or sign-in via Google, Apple or Facebook) and may introduce push notifications in the future. If and when these features launch, this Policy will be updated in advance to describe what data they involve (e.g. account credentials or profile data, push notification tokens) and the purposes for using it.

3.5 What we do not collect

Spoty does not process orders or payments — it is a discovery and comparison service, not a checkout system — so we do not collect payment card or financial data through the Service. Information about restaurants and their offers is business information about merchants, not personal data about you.

4. How We Use Your Information

We use the information described above to:

  • show you relevant lunch/happy-hour offers near your location;
  • operate, maintain and improve the Service;
  • understand usage patterns through analytics;
  • respond to your support and contact requests;
  • display comments/reviews you choose to submit;
  • comply with legal obligations and protect against misuse of the Service (see also our Terms of Use).

5. Legal Basis for Processing (EU/EEA users)

Where the GDPR applies, we rely on the following legal bases:

  • Consent — for location access and non-essential cookies/analytics; you may withdraw consent at any time (e.g. via device/browser settings).
  • Legitimate interests — for basic analytics and keeping the Service secure and working correctly.
  • Contract — where processing is necessary to provide a feature you requested (e.g. responding to your message, or, once available, running your account).
  • Legal obligation — where we must retain or disclose information to comply with the law.

6. Cookies and Similar Technologies

The website uses cookies (and mobile apps may use comparable identifiers) mainly for analytics via Google Analytics. You can control cookies through your browser settings, and on mobile devices you can control tracking-related permissions through your device settings. Blocking cookies may affect some features of the Service.

7. How We Share Information

We do not sell your personal data. We may share information with:

  • Service providers who help us run the Service, such as Google (Analytics and Maps) and our hosting/infrastructure providers, acting on our instructions;
  • Legal and safety recipients, where required by law, to protect our rights, or to prevent fraud or abuse;
  • Successors, if Spoty is transferred, restructured, or its assets acquired, subject to this Policy continuing to apply to your data.

8. International Data Transfers

Some of our service providers (e.g. Google) may process data outside the European Economic Area, including in the United States. Where this happens, we rely on appropriate safeguards such as Standard Contractual Clauses or equivalent mechanisms recognized under EU data protection law.

9. Data Retention

We keep personal data only for as long as necessary for the purposes described in this Policy, for example: analytics data is retained according to our Google Analytics configuration; support emails are kept as long as needed to resolve and document your request; comments/reviews remain visible until removed by you or us. We delete or anonymize data when it is no longer needed, unless a longer period is required by law.

10. Your Rights

If the GDPR applies to you, you have the right to:

  • access the personal data we hold about you;
  • request correction of inaccurate data;
  • request deletion of your data;
  • restrict or object to certain processing;
  • request a portable copy of data you provided to us;
  • withdraw consent at any time, without affecting processing carried out before withdrawal;
  • lodge a complaint with a supervisory authority, such as Latvia's Data State Inspectorate (Datu valsts inspekcija, www.dvi.gov.lv), or your local authority.

To exercise these rights, contact us at [email protected].

11. Children's Privacy

The Service is not directed at children under 16, and we do not knowingly collect personal data from children under that age. If you believe a child has provided us with personal data, please contact us at [email protected] and we will delete it.

12. Security

We use reasonable technical and organizational measures to protect information from unauthorized access, loss, or misuse. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

13. Mobile App Permissions

  • Location (Android: ACCESS_FINE_LOCATION, ACCESS_COARSE_LOCATION; iOS: "when in use" location) — used to show offers near you on the map. You can deny or revoke this at any time in your device settings; the map will then default to a general area or require manual search.
  • Internet access (Android: INTERNET) — required for the app to load offers and map content.

14. Changes to This Policy

We may update this Policy from time to time, for example when we launch new features such as accounts or push notifications. We will post the updated version on this page with a new "Last updated" date, and, for material changes, we will provide additional notice where appropriate.

15. Contact Us

If you have questions about this Policy or how we handle your data, contact us at:[email protected]