Spott — Privacy Policy

Effective: 2026-06-10

This Privacy Policy describes how Spott ("we", "us", "the app") collects, uses, shares, and protects your information. It also explains the rights you have over your data and how to exercise them.

Spott is operated by a solo developer ("the operator"). For all privacy inquiries, contact: spottnowapp@gmail.com.

Quick summary (this is for orientation only — the full policy below is what governs): We collect the minimum needed to run a dating app. We never sell your data. We never use it for advertising. We never train AI models on it. Your location is rounded to ~500m before it leaves your phone. You can export everything or delete it all in two taps.

1. Information we collect

Account info

Email address — for sign-in, password reset, and transactional emails.
Date of birth — verified at sign-up to enforce our 18+ minimum age policy. We store age only; the raw DOB is retained for audit + dispute purposes.
Display name and pronouns — these are visible to other users.

Profile content

Photos you upload (up to 6 profile photos, plus private-album photos).
Profile fields — short bio, interests, position, body type, tribe, ethnicity, relationship status, looking-for.
Voice intros — recorded audio up to 30 seconds, attached to your profile.
Intent mode (Casual, Dating, or Both) — visible on your profile.

Sensitive personal information (handled with heightened protections)

Some optional profile fields are categorized as Sensitive Personal Information under the California Privacy Rights Act (CPRA) and Special Categories of Personal Data under GDPR Article 9. We process these only with your explicit consent, given when you choose to fill in the field:

Sexual orientation and gender identity (implicit in your intent-mode selection and pronoun fields).
Health information (HIV status, last-tested date — both optional).
Biometric data (your verification selfie — see below).

You may decline any of these fields and still fully use the app, with the exception of the verification selfie, which is required to unlock direct messaging. You may withdraw consent at any time by clearing the field, ending verification, or deleting your account.

Health information is used for exactly one purpose: displaying it on your profile to other signed-in members, because you chose to add it. It is never used for matching algorithms, analytics, or advertising, and never disclosed or sold to any third party.

Washington residents: this section, together with the Information, Use, Retention, and Rights sections of this policy, serves as our Consumer Health Data disclosure under the Washington My Health My Data Act. You may access, withdraw consent for, and delete consumer health data at any time — directly in the app (Edit Profile, Export my data, Delete account) or by emailing spottnowapp@gmail.com. We do not sell consumer health data.

Verification

A selfie you upload at sign-up for human review.
- Stored encrypted at rest in Google Cloud Storage.
- Viewable only by you and a small number of admins under a custom Firebase Auth claim.
- Never shown to other users.
- Deleted 90 days after verification approval, or immediately on rejection.
- This is biometric data; processing is limited to identity confirmation only.

Location

Your approximate device location, rounded to a ~500-meter grid before it leaves your phone. Spott's servers never receive your exact GPS coordinates.
We use the rounded value to compute an approximate distance (e.g., "0.4 mi", "12 mi") for other users to see. Because both users' coordinates are grid-rounded before the math happens, this number is only ever accurate to roughly a quarter mile — it can never reveal your exact position, and other users never see your coordinates.
If you enable Travel mode (Spott+ feature), the city you pin is used in place of your real location until you disable it.

Device + push

Expo push tokens — used to send DM, match, and admin-action notifications via Apple Push Notification Service.
Crash logs — anonymous, no personal information, retained for stability monitoring.

Activity

Swipes, matches, blocks, reports, profile views (visible only to you).
Direct messages and reactions, stored encrypted in transit and at rest.

What we DO NOT collect

Your real name (unless you put it in your display name).
Your contact list.
Your camera roll outside the photo(s) you explicitly select.
Browsing history outside Spott.
Behavioral advertising signals.
Tracking cookies, third-party analytics SDKs, or fingerprinting.
Data via Apple App Tracking Transparency — we do not track you across other apps or websites.

2. How we use your information (and our lawful basis under GDPR)

Purpose	Data used	GDPR lawful basis
Match you with nearby people based on your filters and intent mode	Profile fields, rounded location	Contract (Art. 6(1)(b)) — necessary to provide the service
Verification + DM gating	Selfie (biometric data)	Explicit consent (Art. 6(1)(a) + Art. 9(2)(a))
Display sensitive profile fields you opted into (HIV status, etc.)	Health, sexual orientation	Explicit consent (Art. 9(2)(a))
Operate safety features (block, report, photo moderation, rate limits)	Activity logs, reports	Legitimate interest (Art. 6(1)(f)) — preventing harm
Send push notifications for DMs, matches, admin actions	Push token, message preview	Contract (Art. 6(1)(b))
Send marketing emails about Spott (waitlist updates, launch)	Email	Consent (Art. 6(1)(a)) — opt-out in every email
Respond to support tickets	Tickets, account info	Contract + Legitimate interest
Detect/respond to ToS violations	Activity, reports	Legitimate interest + Legal obligation
Comply with subpoenas, court orders, regulator demands	Any	Legal obligation (Art. 6(1)(c))

We do not use your data to train AI/ML models. We do not sell or share your data with advertisers. We do not use your data for any purpose not listed above.

3. Third-party processors

The app runs on the following infrastructure. Each provider is contractually obligated under a Data Processing Addendum to protect your data:

Provider	Purpose	Data location	Privacy policy
Google Firebase — Authentication, Firestore, Cloud Storage, Cloud Functions, Cloud Vision SafeSearch	Backend, photo moderation	`us-central1` (United States)	policies.google.com/privacy
Apple Push Notification Service	Push delivery	United States	apple.com/legal/privacy
Expo Push	Push relay	United States	expo.dev/privacy
Apple App Store (subscription billing)	IAP processing	United States	apple.com/legal/privacy

We do not use Facebook SDK, AdMob, Google Analytics, Mixpanel, Amplitude, Segment, Branch, AppsFlyer, or any other analytics/ad-tech provider.

4. International data transfers

The app is operated from the United States. By creating an account from outside the US, you consent to the transfer of your data to the US for processing.

For users in the European Economic Area, United Kingdom, and Switzerland, we rely on the European Commission's Standard Contractual Clauses (SCCs) for the transfer of personal data to the United States, combined with the supplementary measures required under Schrems II. Google Firebase has signed the EU-approved SCCs and the UK International Data Transfer Addendum.

5. Sharing with other users

What other users CAN see

Display name, pronouns, age (unless hidden), photos, bio, interests, position, body type, tribe, intent mode, voice intro, distance bucket, verification badge.
Optional fields you chose to fill: HIV status, last-tested date, looking-for, relationship status.
Whether you have an active Looking Now post.

What other users CANNOT see

Your email or date of birth.
Your exact location.
Your verification selfie.
Who else you've swiped on, matched with, or messaged.
Your block list, report history, or support ticket history.
Whether you're in Incognito mode (Spott+ feature — hides your profile views entirely).

You can hide your distance and online status from other users in Settings → Privacy. Age is always shown — for full discretion, Spott+ Incognito mode hides your profile from Browse entirely and stops your views from being tracked.

6. Your rights

All users

Access + export. Settings → Account → Export my data triggers a JSON download of everything we have about you.
Correction. Settings → Edit Profile lets you change any field at any time.
Deletion. Settings → Account → Delete account permanently removes your profile, photos, messages, swipes, matches, support tickets, and verification selfie within 30 days. This action is irreversible.
Withdraw consent. Clear an optional field, exit Verification, or delete your account at any time.

EU / UK / Switzerland (GDPR, UK GDPR, FADP)

In addition to the above, you have the right to:

Object to processing based on legitimate interest (Art. 21).
Restrict processing while a dispute is open (Art. 18).
Data portability in a machine-readable format (Art. 20) — our Export endpoint satisfies this.
Lodge a complaint with your local Data Protection Authority. Find yours at edpb.europa.eu/about-edpb/about-edpb/members_en.

The operator (a solo developer) acts as the data controller for your information. We do not currently have a Data Protection Officer because our processing volume falls below the GDPR Art. 37 threshold. If you are an EU resident and our processing changes such that an EU representative is required, we will appoint one and update this page.

California (CCPA / CPRA)

You have the right to:

Know what personal information we have collected, used, disclosed, and shared.
Delete your personal information.
Correct inaccurate personal information.
Opt out of the "sale" or "sharing" of personal information — we do neither, so there is nothing to opt out of.
Limit the use of Sensitive Personal Information — we already restrict it to operating the service.
Non-discrimination — we will never deny service or charge a different price for exercising these rights.

We do not sell personal information and have not done so in the prior 12 months.

Quebec (Law 25)

We act as the person in charge of the protection of personal information for your data (the operator listed above). The same access, correction, deletion, and portability rights described above apply, alongside Quebec-specific consent rules. Contact spottnowapp@gmail.com to exercise any right.

Canada (PIPEDA), Brazil (LGPD), Australia (Privacy Act)

Similar rights apply under your local law. Contact us at spottnowapp@gmail.com — we honor all valid requests regardless of jurisdiction.

How to exercise any right

Email spottnowapp@gmail.com from the address attached to your account. We will respond within 30 days (45 days for CCPA/CPRA requests).

7. Marketing communications

If you join the waitlist at spottnow.com, you have consented to receive email updates about Spott's launch. We use a transactional email service (TBD before launch) and you can unsubscribe via the link at the bottom of every email at any time.

We never send marketing push notifications. Push is reserved for DMs, matches, and admin actions (e.g., your verification was approved).

8. Retention

Data	Retention
Active accounts	As long as you keep the account
Deleted accounts	Account + profile + photos + messages: removed within 30 days. Audit logs (blocks, reports, ban records): up to 12 months for safety compliance.
Verification selfies	Deleted 90 days after approval, or immediately on rejection
Looking Now posts	Automatically deleted 24 hours after expiry
Messages	Retained while the chat exists; deleted with the account
Waitlist emails	Retained until you unsubscribe or we launch (whichever comes first); transferred to your user record if you create an account
Crash logs	30 days

9. Security

All network traffic over HTTPS / TLS 1.2+.
Server-side Firestore Security Rules enforce per-user data isolation with a default-deny posture; your email, date of birth, phone number, and push tokens are stored in a private record readable only by you and our systems.
Device attestation (Apple App Attest) helps ensure backend requests come from the genuine Spott app.
All purchases are cryptographically verified server-side against Apple before benefits activate.
Cloud Storage uses signed-URL access with short expirations; chat media is restricted to chat participants.
Rate-limited APIs prevent abuse. Public-facing photos (profile, casual, and Looking Now images) pass automated content moderation before they become visible to others. Private photos — private albums and photos sent in chat — are not scanned; they stay between the participants and are reviewed only if someone reports them.
Verification selfies accessible only to admins under a custom Firebase Auth claim.
Encrypted database backups are retained for 14 days, then destroyed.
All third-party processors are SOC 2 compliant.

Despite reasonable security measures, no system is impenetrable. If you suspect your account has been compromised, contact us at spottnowapp@gmail.com immediately. In the event of a personal-data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authorities without undue delay (within 72 hours where required by GDPR Art. 33–34).

10. Children's privacy (COPPA + GDPR-K)

Spott is 18+ only. We do not knowingly collect data from anyone under 18, and our service is not directed to children under 13 under the U.S. Children's Online Privacy Protection Act (COPPA) or anyone under 16 (or the applicable digital-consent age in your country) under GDPR.

Sign-up enforces a date-of-birth gate. If we learn we have collected data from a minor, we will delete the account and all associated data, including immediate deletion of any uploaded selfie.

If you are a parent or guardian who believes your child has created a Spott account, contact spottnowapp@gmail.com and we will delete it immediately.

We have zero tolerance for child sexual abuse material (CSAM). Where required by law, apparent CSAM and related account information are reported to the National Center for Missing & Exploited Children (NCMEC) and/or law enforcement. "Underage" is a dedicated in-app report category reviewed with priority.

11. Cookies and similar technologies

The Spott app does not use cookies, web beacons, pixels, SDK trackers, or device fingerprinting. The marketing website (spottnow.com) uses only the strictly necessary functional cookies required to maintain a logged-in session (none currently in use) — no advertising, analytics, or tracking cookies. We respect the Global Privacy Control (GPC) signal where applicable.

12. Do Not Track

The Spott app and website do not track users across third-party services, so there is no Do-Not-Track signal we need to honor. The browser DNT header is currently not standardized in a way we can act on; we instead respect the legally-binding Global Privacy Control signal.

13. Changes to this policy

If we make material changes to this policy, we will:

Notify you in-app and via email (if you have an account or are on the waitlist).
Update the Effective date at the top of this page.
Where required by law, request your renewed consent before applying the change to your account.

For non-material changes (clarifications, typo fixes, new third-party processors operating under the same purposes), we'll update the page without notice but log the change in our internal changelog.

14. Contact and complaints

For any privacy question, request, or complaint:

Email: spottnowapp@gmail.com
Mail (US users only): the Spott operator, [address available on request]

We aim to respond within 7 business days for general questions and within the statutory deadline (30 days GDPR / 45 days CCPA-CPRA) for formal rights requests.

If you are unsatisfied with our response, you have the right to lodge a complaint with your local Data Protection Authority (EU/UK), the California Privacy Protection Agency (California), or your country's equivalent body.