Spot.It — Privacy Policy.

Who we are

S2 CONNECT AI LTD, a company incorporated in London under company number 15792062 and located at 39 Atlantis Avenue, London, England, E16 2UD is the controller responsible for your personal data.

Spot.It has designated a Data Protection Officer who can be reached by emailing info@s2connect.ai or by post at the address above.

How is my personal information collected and used by Spot.It?

Spot.It recognizes information from any images and photos: screenshots of social networks, chats, photos of someone else's phone screen, personal photos etc. Advanced algorithms extract critical information from images, making meaningful connections just a tap away. With Spot.It the journey from an intriguing image to a meaningful connection is just a tap away making it an indispensable tool for those seeking efficiency and excitement in their digital life

Image Storage and Sharing

Spot.It securely stores images in our backend systems to provide the core functionality of the app. These images are encrypted and stored in accordance with industry-standard security practices. One of the primary features of our service is the ability to share these images with other Spot.It users. When you use our sharing functionality, you are explicitly consenting to make your uploaded images available to the specific users you choose to share with. You maintain control over which images are shared and with whom. You can revoke sharing access at any time through the app interface.

Location settings

If you have given the App access to your location in your device settings, when you use the App we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device's coordinates to offer certain features to you as part of the Services

If you have given the App access to your location, but wish to stop, you can do so by the following methods:

iPhone app — settings, privacy, location services, Spot.It
Android — settings, security and location, location, Spot.It

How else does the App collect and use my data?

Data collected automatically

When you use the App we automatically collect certain information, including the unique device identifier assigned to your device ("Device ID") and other information regarding your access to or use of the App. We collect information about your browser type, referring domain (this is information about a third party site that you were on before you clicked through to the Spot.It site) and mobile carrier. We use this information to check that it is you using the App, to see how you are using the App service so that we can improve our services, to keep track of your preferences and to create a more tailored user experience.

Data we collect from others

In addition to the data you directly provide us, some data may be received from others, including:

Other users: Users you interact with on the App might provide us with information about you from time to time.
Third party partners: When we publish ads with third party advertising partners, those partners may share information about the performance of those ads, and link the data to the users who consumed them (aka 'tracking'). In some cases, the amount of tracking data our partners share with us will depend on your device settings across the board. In other cases, the amount of data we are able to collect will depend on the information you specifically opt to share with us.

Other data you choose to share with us

Tracking data: By allowing the App to track you, you are consenting to Spot.It obtaining certain more detailed information about you. For more information on the exact information collected when you opt in to track your activity, please consult the 'App Privacy' section of the App's page on the App Store if you are an iPhone user, and the Data safety section on the App's page in the Google Play Store if you are an Android user.
For iOS 14.5 (or later) users: If you opt out of tracking on your device, we will not link identifiable information from third-party companies' apps and websites with identifiable information from the App for advertising purposes. Further information on how to control tracking settings is available below.
Location data: If you are prompted by the Spot.It App to share your location, this is optional. If you decline permission for us to collect location data, we will not collect it, and you can still use the app. However, if you give us permission to collect your location data, we will be able to determine your latitude and longitude with a degree of accuracy that depends on the services and device you are using. Your settings may allow us to collect location information only while you are using the app, or to do so at all times. In all cases, this remains optional.

What is the legal basis that allows Spot.It to use my data?

We are only permitted to use your data when we have a lawful basis to do so or there is an exception under which Spot.It is allowed to use your data. The table below provides an overview of the legal bases that Spot.It relies on to use your data, unless you are in Mexico or the US in which case the "Legal basis" column does not apply to you.

Purpose for which data isused	Data	Legal basis
To provide you with the App and the Spot.It services.	Device ID, location (if provided), images uploaded to the app	Contract performance with the data subject/conclusion of contract with data subject
To connect you with other users near you and allow you to listen to, and engage with, conversations with other users based on your and their respective locations	WiFi access points and location data when you use the App (if you give us permission)	Legitimate interests – it is in our legitimate interests to provide this functionality as part of the Services
To enable image sharing functionality between users	Images uploaded to the app, sharing preferences	Consent – you explicitly agree to share specific images with selected users
To send you other marketing information about our offers and services	Device ID	Legitimate interests – it is in our legitimate interests to promote our products and services
To measure the performance of the advertising initiatives for our products and services and to optimise the delivery of ads, including by serving follow-up ads to you.	Optional tracking information you choose to share through your mobile device's privacy settings. The data we collect from third party partners is set out in Spot.It's page on the Apple App Store and Google Play Store, as applicable.	Consent
To show city location information to you and other users	Location data when you use the Services	Consent
To carry out research and analysis to help us improve the Services	Log and usage data, including IP address, traffic statistics, clickstream data, mobile carrier and search terms	If you are in Chile or Russia, consent. Otherwise, legitimate interests – it is in our legitimate interests to analyse the way in which users are accessing and using our services so that we can further develop and improve the Services
To respond to correspondence and queries that you submit to us	IP address and any information you provide in your correspondence and queries	If you are in Chile, consent. Otherwise, legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to users and troubleshoot problems
To block accounts as part of our anti-spam procedures	IP address and IP session information, user agent string	If you are in Chile, consent. Otherwise, legitimate interests – it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and security of our services
To block payment transactions as part of our anti-fraud procedures	IP address, country	Legitimate interests – it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and security of our services

How long will Spot.It keep my data?

We keep your personal information only as long as we need it for legitimate business purposes (as set out above) and as permitted by applicable law.

In practice, we delete or anonymise (if permitted by applicable law) your information when you stop using the app, unless:

we must keep it to comply with applicable law;
we must keep it to evidence our compliance with applicable law;
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
to the extent permitted by law, the information may be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security.

Where Spot.It uses machine learning, for example, to help us detect and prevent fraudulent transactions, and to detect and prevent spam communications on the app (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly, and if it is permitted by applicable laws. Where this is the case, we always seek to minimise the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other user personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.

Who does Spot.It share information with?

We may share aggregated information that includes your personal data (but which doesn't identify you directly), together with other information including log data with third parties for industry analysis and demographic profiling.

In addition, we share your data with the following categories of third-parties:

Information technology companies (hardware and software) which provide services to support our products
Fraud prevention and anti-spam providers to protect the service from criminal activity
Moderators to monitor activity on the site/apps and approve content
Law enforcement agencies, where we are required to by law, where there is an investigation into alleged criminal behaviour, or to protect the vital interests of a person

We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is nonattributable to the greatest extent possible.

In the event that Spot.It or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.

Your data may be shared with other Spot.It group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.

Your rights

UK/EU

Under UK and European law, you have the right to lodge a complaint with data protection regulators. If you are based or the issue you would like to complain about took place in the UK, you can complain to the Information Commissioner's Office (ICO). You can find out how to raise a concern with the ICO by visiting their website at www.ico.org.uk. If you're based or the issue you would like to complain about took place within the European Economic Area, you can complain to your local data protection regulator and a list of their contact details can be found here.

You have a number of rights under UK/European data protection law:

Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this notice).
Right of access: you can request a copy of your data.
Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
Right to erasure: you have the right to have your data deleted in certain circumstances.
Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.
Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

If you want to exercise any of your rights listed above please visit our Feedback Page or email us at info@s2connect.ai. You can also contact us by post at 39 Atlantis Avenue, London, England, E16 2UD.

California

If you are a California resident, please note the following about how we collect, use and disclose your personal information, including additional rights you may have to your personal information:

CA Personal Information. Consistent with the “What is the legal basis that allows Spot.It to use my data” section above, we may collect certain categories of information about California residents, such as:
- Identifiers: device ID, IP address, device information;
- Internet or Other Electronic Network Activity: traffic statistics, clickstream data, mobile carrier, and search terms;
- Geolocation Data: physical location of a California resident's mobile device;
- Visual Information: images uploaded to our app for processing and sharing functionality;
- The above categories of personal information correspond with the categories of personal information listed under Cal. Civ. Code § 1798.140(o)(1)(A), (F), and (G).
Sources of CA Personal Information. We may collect personal information automatically when California residents use Spot.It.
Use of CA Personal Information. We process California residents' personal information for the purposes outlined in the "What is the legal basis that allows Spot.It to use my data" section above.
CA Personal Information Sold or Disclosed for Business Purposes.
- Sharing Personal Information for Business Purposes: We disclose the following categories of personal information for business purposes: Identifiers, Internet or Other Electronic Network Activity, and Geolocation Data to information technology, fraud prevention and anti-spam services providers.
- No Sale of Personal Information: We do not sell California residents' personal information.
CA Privacy Rights. If you are a California resident and subject to certain exceptions, you may have the following rights:
- Right to Know and Delete: you may have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically ("right to know") and/or to delete the personal information we hold about you. To submit a request to exercise these rights, please submit an email request to info@s2connect.ai and include "CCPA Request" in the subject line. To protect your and others' privacy and security, we will verify your identity before responding to any request. You will not be penalized or discriminated against for exercising your rights to your personal information.
- Right to Opt-Out (“Do Not Sell My Personal Information”). You have the right to opt-out of the sale of your personal information by a business. We do not sell your personal information.
- Shine the Light: California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you can write to us at info@s2connect.ai.
- “Do Not Track”: Under California law, operators of online services are required to disclose how they respond to "do not track" signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our users' personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users' online activities over time and across different online services when the users use the operator's service. We do not knowingly permit third parties to collect personal information about an individual user's online activities over time and across different online services when using the app.

Russia

Under Russian law you have the right to obtain information relating to your personal data. You have the right to obtain from us rectification of your personal data, its blocking or erasure where personal data is incomplete, irrelevant, inaccurate or unlawfully processed, or is no longer necessary in relation to the purpose for which it was processed, as well to take any other measures to protect your rights in accordance with the law.

Argentina

Under Argentine law, you have the right to lodge a complaint with the data protection regulator.

If you live in Argentina, you have a number of rights under Argentine Data Protection law, for instance:

Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this notice).
Right of access: you can request a copy of your data.
Right of update/rectification: if the data held is inaccurate, you have the right to have it updated/rectified.
Right to erasure: you have the right to have your data deleted in certain circumstances.
Rights related to automated decision-making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to request an understandable explanation of the logic applied in the automated decision-making process.

In Argentina the data owner is entitled to exercise the right of access to his/her/its personal data free of charge at intervals of not less than six months, unless a legitimate interest to that effect is established in accordance with article 14, paragraph 3 of Law No. 25,326. THE PUBLIC INFORMATION ACCESS AGENCY, in its capacity as the Control Entity of Law No. 25,326, has the power to attend complaints and claims filed by those whose rights are affected due to breaches of applicable regulations on personal data protection. The data owner may at any time request the removal or blocking of his/her/its name from the databases referred to in this article. Every communication for advertising purposes that is carried out by mail, telephone, email, Internet or any other future remote means, shall state expressly and prominently the possibility of the data owner to request the withdrawal or blockage, in whole or in part, of his/her/its name from the database. At the request of the interested party, the name of the person responsible or user of the database that provided the information must be reported.

Mexico

If you are in Mexico you have at all times the right to access and view the information we have about you: likewise, you have the right to require such information to be corrected or cancelled; you may oppose our use of your personal data for specific purposes and/or revoke at any time the consent you granted us for the processing of your personal data to the extent permitted by the law. In order to exercise such rights or to ask any questions or complain in relation to the processing of your personal data please address your request to the following email: info@s2connect.ai.

Your requests will be evaluated in the terms set out in the applicable laws. Our specialist will communicate to you (i) the information required for your identification as well as the documents needed to be sent alongside your request; (ii) the time periods in which you will receive an answer to your request; (iii) how you should file your request, including the forms that you may use to file your request, if any, and; (iv) the form or means in which we will deliver you the information.

In addition, you may limit the use or disclosure of your personal data by sending your request at info@s2connect.ai.

If your request is appropriate, our specialist will register you on the exclusion list for the purpose for which the exclusion is applicable.

How does Spot.It protect my personal data?

Spot.It has implemented security measures intended to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal data. Our technical experts at Spot.It work hard to ensure your secure use of our application.

While we take reasonable precautions against possible security breaches of our application and records, no application or internet transmission is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe and to log out of your account after use.

Where is my personal data kept?

We want you to be able to access Spot.It wherever you happen to be in the world. To enable us to provide that service, we operate a global network of servers including in сentral Europe. The hardware is located in third-party data centres but is owned by Amazon. If your personal information is transferred from the UK or the European Union to other countries outside the UK or European Union respectively, we ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place, such as approved model clauses (which can be found here), and implementing robust contractual standards. If you want more information relating to the nature of the safeguards we have in place please email info@s2connect.ai.

Why did I receive an Apple Tracking Transparency prompt?

If you are an iOS 14.5 (or later) user: Apple's App Tracking Transparency (ATT) framework requires Spot.It (like all app developers) to ask iOS users for permission before collecting data about them from other companies' apps and websites for advertising targeting or measurement purposes.

Spot.It will display the ATT prompt prior to connecting identifiable data collected from Spot.It with identifiable data from other companies' apps and websites for advertising purposes.

You can opt in or out of tracking at any time as follows:

Privacy & Security > Tracking, where you can see a list of all the apps that have requested to track your activity.

Tap to turn Spot.It's permission to track on or off.

Does Spot.It collect any other personal data about me?

When you submit an enquiry to our Customer Support team through our Contact page, your IP address may be monitored. Additionally, any information you provide will be used to assist in addressing your questions or concerns.

Does Spot.It use my personal data for any other purpose?

We may use your personal data to resolve disputes, troubleshoot problems and enforce our Terms of Service.

From time to time we may run surveys for research purposes and we may contact you to find out if you would like to take part. Such surveys are optional and more information will be provided at the point of contact. We may also contact you for feedback purposes.

What are ‘cookies’ and what ‘cookies’ does Spot.It use?

We collect information by placing cookies on your computer or mobile. A cookie is a piece of text stored on your computer or mobile by your web browser. They are basically a tool that stores information about website visits, recognises you and your preferences each time you visit Spot.It, and ensures site functionality and enables us to provide the services our users request.

When you visit the publicly available sections of Spot.It, a session ID cookie is placed on your computer that only lasts while you're visiting. We also place persistent cookies (also known as local storage devices) on your device, so that Spot.It remembers you and makes your experience faster and easier. We may use persistent tracking cookies on your mobile device, mainly for security protection purposes, such as to prevent phishers, scammers, and unauthorised access attempts.

You may set your browser and your mobile settings to block cookies and local storage devices, but if you do so, you may not be able to access the features that Spot.It offers.

Spot.It's use of cookies and local storage devices basically falls into the following categories:

cookies related to the performance of Spot.It's site, such as analytics that help us determine how our site is performing and ensuring a smooth and trouble-free experience for our users and visitors;
cookies related to the functionality of Spot.It's site, such as remembering your preferences or your preferred language;
and third party cookies which link to other social networks and which you request via social plugins.

Spot.It uses cookies and local storage devices so that we know who you are, what interests you have and so that you can do the things online that you want to do, like chat with new people and share your content knowing that your data will be secure. Below is a table to explain Spot.It’s cookie functions and why they’re used.

Cookie Functions	Cookie Purposes
Analytics and research	Spot.It uses Google Analytics to collect information about how visitors use the Spot.It site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. For more information about Google’s privacy policy, please visit http://www.google.com/intl/en/policies/
Authentication	These cookies help us to identify our members so that when you’re logged in, you can enjoy Spot.It’s offerings, experiences and various features, such as uploading photographs or when you’ve asked Spot.It to ‘remember me’. These cookies also help to remember who invited you to join Spot.It.
Security and site integrity	We use cookies and other devices, such as CAPTCHAs, to help keep Spot.It and our members safe and secure. These cookies do things like protect Spot.It users from spam and fraud. We may use persistent cookies, which will help us to ensure we have identified the same device is logging into the correct account. These types of cookies also help with our anti-spam measures and may help us to prevent phishers, scammers, unauthorised log-in attempts to your account and accessing any hacked accounts.
Site features and services	These cookies and local storage devices provide the functionality that our Spot.It users enjoy, such as uploading of photographs, chats and your account settings. In some cases, the site feature you choose may allow a third party to place cookies or local storage devices on your computer. The third party who places cookies on your device is responsible for how they process their data and Spot.It recommends that you read their privacy policies. Third parties who place cookies on your device when you use Spot.It include the following, and we have included a link to their privacy policies: Twitter, https://twitter.com/privacy Facebook, https://en-gb.facebook.com/policy.php YouTube, http://www.google.co.uk/intl/en/policies/privacy/
Performance	We need to use certain cookies and local storage devices to ensure our members have the best possible experience, such as assisting with your navigation of our site, ensuring pages load up quickly and respond faster to your requests for Spot.It services.

Our use of cookies and local share devices, including the specific cookie names, may change over time, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices. If you would like to know more about cookies, including flash cookies/local storage devices, and/or how to disable them. the following websites provide useful information:

Changes to the Privacy Policy

Any changes to this Privacy Policy or to the purposes for processing your data will be communicated to you by means that are reasonable, such as by email or a notification on our app. To the extent permitted by law, changes will be effective from the day after publication, unless we let you know otherwise. To the extent permitted by law, your use of our site/app after the Privacy Policy has been updated means you consent to the changes, where applicable.

This Privacy Policy was last updated on April 22, 2025.