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Contents

Introduction 1. Who We Are 2. Data We Collect 3. How We Use Your Data 4. Legal Basis for Processing 5. Sharing Within the Spotbookr Group 6. Sharing with Third Parties 7. International Transfers 8. Data Retention 9. Data Security 10. Your Rights 11. Children’s Privacy 12. Research & Technical Use 13. Changes to This Policy 14. Contact & Complaints

Data Policy

Last updated: March 31, 2026 · Version 1.2

Issued by Spotbookr Inc on behalf of Spotsavr

We take your data seriously and we want to be completely transparent. This Data Policy tells you exactly what data we collect about you, why we collect it, who we share it with, how long we keep it, and what rights you have. By creating an account or continuing to use Spotsavr, you acknowledge and agree to the practices described in this Policy.

Introduction

When you use Spotsavr, you share information with us. This Policy explains how Spotbookr Inc, as the operator of Spotsavr, acts as the data controller for that information, meaning we determine why and how your data is processed.

This Policy applies to data collected through spotsavr.com, app.spotsavr.com, related emails, and any other Spotsavr-branded services operated by Spotbookr Inc. It should be read alongside our Cookie Policy and Terms & Conditions.

1. Who We Are

Spotbookr Inc is the data controller for personal data collected through Spotsavr. Spotbookr Inc is the parent company of a group of technology platforms including:

  • spotsavr.com, influencer promo code platform (this Service)
  • spotbookr.com, the Spotbookr parent platform
  • sbkrindex.com, a Spotbookr data and index platform
  • Other current and future subsidiaries, affiliated platforms, and products of Spotbookr Inc (the “Spotbookr Group”)

References to “we”, “us”, or “our” in this Policy refer to Spotbookr Inc as data controller. Where data is processed across the Spotbookr Group, relevant group entities may act as joint controllers or processors, as described in Section 5.

2. Data We Collect

We collect data about you in several ways: data you give us directly, data generated by your use of the Service, and data we receive from third parties.

2.1 Data You Provide Directly

DataWhen collectedWhy
Email addressRegistrationAccount creation, login, communications
Username / display nameRegistration or profile setupIdentify you on the platform
Password (hashed & salted)RegistrationSecure authentication
Profile pictureOptional, profile setupPersonalise your profile
Bio / interestsOptional, profile setupFeed personalisation
Reports / feedbackWhen you report a code or contact usService improvement, support

2.2 Data Generated by Your Use of the Service

DataDescription
Usage dataPages visited, features used, time spent on each section, scroll depth, click patterns
Interaction dataCodes you copy, save, like, or report; brands and creators you follow or unfollow
Search & filter dataSearch terms entered, filters applied, categories browsed
Session dataLogin times, session duration, logout events, 2FA activity
Device & technical dataIP address, browser type and version, operating system, device type, screen resolution, language settings
Referral dataThe URL or source that referred you to Spotsavr
Error & performance dataErrors encountered, page load times, API response times
Deal sighting dataPromotional banner text from retailer pages (domain, banner snippet up to 1,000 chars, source) — captured when no specific promo code is identified
Code discovery dataWhen the Hermes browser extension detects a potential promo code on a web page, the following is sent to our servers: the domain, the code text, the detection method (banner, URL, input field, or meta tag), and a short context snippet (up to 500 characters). The full page content is never transmitted.
Email engagement dataWhether you opened an email we sent (via a tracking pixel), whether you clicked a link in the email (via a redirect), your IP address and user agent at the time of the interaction

2.3 Data from Third Parties

We may receive data about you from:

  • Other Spotbookr Group platforms, if you use SSO (single sign-on) to access Spotsavr from another Spotbookr platform, we receive basic account data from that platform.
  • Social media platforms, if you connect a social account (where this feature is offered), we receive the data you authorise.
  • Email service providers, whether you have opened or interacted with emails we send you.
  • First-party email tracking: emails sent by Spotsavr may contain a tracking pixel (1×1 transparent image) and tracked links. When you open an email or click a link, we record the event type, timestamp, your IP address, and user agent. This data is used to measure engagement and improve email quality.

3. How We Use Your Data

We use your data only for legitimate purposes. Here is a full breakdown:

PurposeData UsedDetails
Providing the ServiceAccount, usage, interaction dataTo operate Spotsavr, authenticate you, deliver your personalized feed, and process your code saves and likes
PersonalisationInterests, interaction data, followsTo rank and surface codes most relevant to you based on the brands and creators you follow
CommunicationsEmail addressTo send account confirmation, security alerts, password resets, and service notifications. You may opt out of non-essential communications.
Security & fraud preventionIP address, device data, session dataTo detect unauthorized access, prevent account takeovers, and protect the integrity of the platform
Service improvementUsage, error, performance dataTo identify bugs, improve features, and measure the impact of changes
AnalyticsAggregated usage dataTo understand how the Service is used at scale, including which features are popular and how users navigate the platform
Research & technical developmentInteraction, usage, and preference dataSee Section 12 for full details. Data is used across the Spotbookr Group for product development, algorithm training, and platform research.
Code database expansionCode discovery dataTo discover new promo codes across retailer websites, improve code freshness, and grow the Spotsavr database
Email engagement analysisEmail tracking dataTo measure open and click rates, optimise email content and frequency, and ensure deliverability
Legal complianceAll categories as requiredTo comply with applicable laws, respond to legal requests, and enforce our Terms & Conditions

4. Legal Basis for Processing

Where applicable data protection law requires us to identify a legal basis for processing your personal data, we rely on the following:

  • Contract performance: Processing necessary to provide the Service you have signed up for (e.g. authentication, feed delivery).
  • Consent: Where you have given specific consent, such as for research and development data use, cross-platform sharing within the Spotbookr Group, and certain cookies. You may withdraw consent at any time, though this will not affect the lawfulness of processing before withdrawal.
  • Legitimate interests: Where processing is necessary for our legitimate business interests (e.g. fraud prevention, analytics, service improvement), provided those interests are not overridden by your rights.
  • Legal obligation: Where processing is required to comply with applicable law.

5. Data Sharing Within the Spotbookr Group

By creating an account or using Spotsavr, you expressly acknowledge and consent to your personal data and usage data being shared with and processed by other entities within the Spotbookr Group, including:

  • Spotbookr.com, the Spotbookr parent platform
  • SBKRIndex.com, the Spotbookr data index platform
  • Any other current or future subsidiaries, affiliates, and platforms operated by Spotbookr Inc

Data shared within the Spotbookr Group is used for the following purposes:

  • Providing seamless authentication and SSO across Spotbookr Group platforms;
  • Internal analytics and business reporting across the Group;
  • Technical research and product development (see Section 12);
  • Training and improving algorithms used across Spotbookr Group platforms, including recommendation systems, quality scoring models, and content ranking;
  • Fraud prevention and security coordination across platforms;
  • Operational and administrative purposes.

All entities within the Spotbookr Group are bound by data protection obligations consistent with this Policy. Data shared within the Group is not used for purposes beyond those described above without additional consent.

6. Sharing with Third Parties Outside the Spotbookr Group

We do not sell your personal data to third parties outside the Spotbookr Group. However, we may share data with the following categories of trusted service providers:

CategoryPurposeExamples
Cloud hosting & infrastructureStoring and serving data and the applicationVPS providers, CDN services
Email deliverySending transactional and notification emailsSMTP / email API providers
AnalyticsWeb analytics and performance monitoringGoogle Analytics 4 (Google LLC) — collects anonymised usage data including pages visited, session duration, device type, and approximate location. Google's privacy policy: policies.google.com/privacy. By creating an account and accepting these Terms, you consent to analytics tracking while using the Spotsavr service.
SecurityDDoS protection, bot detection, fraud preventionSecurity service providers

All third-party service providers are contractually required to:

  • Only process data on our documented instructions;
  • Implement appropriate technical and organizational security measures;
  • Not use your data for their own independent purposes;
  • Delete or return data when their services are no longer required.

We may also disclose data where required to do so by law, court order, or government authority, or where we reasonably believe disclosure is necessary to protect the rights, property, or safety of Spotbookr Inc, its users, or the public.

7. International Data Transfers

Spotbookr Inc is a technology company and your data may be processed in countries outside your own, including countries that may not have equivalent data protection laws to those in your jurisdiction. Where we transfer personal data internationally, we take appropriate steps to ensure that it receives an adequate level of protection, including through contractual arrangements with data processors.

8. Data Retention

We retain your data for as long as necessary to provide the Service and for the purposes described in this Policy. The following retention periods apply:

Data TypeRetention Period
Account data (email, username, password hash)For the life of your account, plus up to 90 days after deletion for administrative purposes
Interaction data (saves, likes, follows, copies)For the life of your account; may be retained in anonymized form after deletion
Usage & session logsUp to 12 months in identifiable form; may be retained in aggregated/anonymized form indefinitely for research
Device & IP dataUp to 6 months, or longer where required for security or legal purposes
Email communicationsUp to 24 months
Code discovery dataIndefinitely, or until the discovered code is confirmed expired and removed from the database
Email engagement data (opens, clicks)Up to 12 months in identifiable form; retained in aggregated form indefinitely
Research & analytics data (anonymized)Indefinitely, in anonymized or aggregated form

When you request deletion of your account, we will delete or anonymise your personal data within a reasonable period, subject to any legal obligations that require us to retain certain data for longer (e.g. fraud investigation, legal proceedings).

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

  • Password hashing using industry-standard algorithms (bcrypt);
  • HTTPS encryption for all data in transit;
  • Two-factor authentication (2FA) available for all accounts;
  • Access controls limiting who within Spotbookr Inc can access personal data;
  • Regular security reviews of our infrastructure;
  • Session expiry and token rotation.

Despite these measures, no system is 100% secure. We cannot guarantee the absolute security of your data and are not responsible for security breaches that are outside our reasonable control. In the event of a data breach affecting your rights, we will notify you and relevant authorities as required by applicable law.

10. Your Rights

Depending on your jurisdiction, you may have some or all of the following rights with respect to your personal data:

RightWhat it means
Right of accessYou can request a copy of the personal data we hold about you
Right to rectificationYou can ask us to correct inaccurate or incomplete data
Right to erasureYou can ask us to delete your personal data (subject to legal retention obligations)
Right to restrictionYou can ask us to restrict how we use your data in certain circumstances
Right to data portabilityYou can ask for your data in a machine-readable format to transfer to another provider
Right to objectYou can object to processing based on legitimate interests, including for research purposes
Right to withdraw consentWhere processing is based on consent, you can withdraw it at any time

To exercise any of these rights, please contact us via spotbookr.com. We will respond within a reasonable timeframe and no later than required by applicable law. We may need to verify your identity before processing your request.

If you are unhappy with how we have handled your data, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

11. Children’s Privacy

The Service is not directed at children under the age of 18. We do not knowingly collect personal data from persons under 18. If you are under 18, please do not use the Service or provide any personal data. If we become aware that we have collected data from a person under 18 without appropriate consent, we will delete that data as promptly as possible. If you believe a child has provided us with their personal data, please contact us immediately.

12. Research & Technical Use of Your Data

One of the core purposes for which we collect and process data is research and technical development across the Spotbookr Group. We want to be fully transparent about what this means:

What “research and technical purposes” means in practice

Your interaction data, including which codes you view, copy, save, like, and skip; which brands and creators you follow; how you navigate the feed; and how your preferences change over time, is used to:

  • Train and improve the quality scoring algorithms that rank codes across Spotsavr and other Spotbookr Group platforms;
  • Develop and refine personalisation and recommendation models;
  • Understand user behavior patterns to improve product design and feature development across the Spotbookr Group;
  • Conduct A/B testing and experimentation to evaluate new features;
  • Build and maintain data infrastructure shared across the Spotbookr Group, including spotbookr.com and sbkrindex.com.

Where possible, data used for research purposes is anonymized or aggregated so it cannot be linked back to you individually. Where identifiable data is used, it is accessed only by authorized personnel within the Spotbookr Group and handled in accordance with this Policy.

You have the right to object to your data being used for research purposes. To do so, contact us via spotbookr.com. Note that objecting to this use may limit our ability to personalise the Service for you.

13. Changes to This Policy

We may update this Data Policy from time to time. When we make changes, we will update the “Last updated” date at the top. For material changes, we will endeavor to notify you via email or through a prominent notice in the Service. Continued use of the Service after changes are posted constitutes acceptance of the revised Policy.

14. Contact & Complaints

For any questions, requests, or concerns about how we handle your data, or to exercise your rights under Section 10, please contact us:

Spotbookr Inc, Data & Privacy

Website: spotbookr.com
See also: Terms & Conditions · Cookie Policy

If you are located in the European Economic Area or United Kingdom and believe we have not handled your data in accordance with applicable law, you have the right to lodge a complaint with your local data protection supervisory authority.

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