PROCESSING OF PERSONAL INFORMATION BY SPOND
Last updated: 18 October, 2023
Here is a summary of how we process your personal information. You are encouraged to read the full privacy statement.
- The Spond Team app and website together with Spond Club Solution website (”Spond” or the “service”) is provided by Spond AS. Our service also includes additional features which are made available depending on your location.
- We process your personal information in accordance with applicable data protection laws (including if applicable the GDPR, the Personal Data Act in Norway, the Data Protection Act 2018 in the UK and the California Consumer Privacy Act as well as other applicable national laws which relate to the processing of personal data in our service.
- Our commitment to process personal data in accordance with applicable data protection laws is described in our Privacy Statement below. We want full transparency about what we do with your personal information. If you have questions, please contact us.
- Most of the information we have about you is information you provide us when you register a profile or which is created when you use or otherwise engage with Spond. This includes where you participate in a fundraiser or if you use Spond Cashback, in the locations where those features are available.
- In some cases we first receive basic profile information from group or club administrators in accordance with their privacy practices, (for example, so that you can create a Spond profile and be added to a group or a club).
- We constantly want to make our services better. Therefore, we also collect information about how you and others use Spond so that we can analyse usage patterns and the needs of our users. Typically, we de-identify and aggregate such information so that individual users are not identified.
- We customise Spond and our communication with you based on how you use the service so that the service is as relevant as possible for you.
- Your personal information is not shared with anyone unless we have to share to provide the service or you have consented to such sharing, except where we are permitted to process such data on legitimate interest grounds.
- You can update your registered profile information at any time, and we will not store the information any longer than is necessary for the purpose and statutory duties.
- Children aged 13 years and over may use the service without their guardian’s approval. Children below 13 of age must have their guardian`s approval. An adult nominated as a child’s guardian and who has registered in the service will be able to see the child’s activity (for example, events they participate in or comments they provide). The minimum age for creating groups in the service is 15 years.
- Where you enter a Spond competition in the UK, this is operated by Spond Limited, which will be the controller of personal data for the competition.
- Other Spond users may access your information, for instance administrators of groups that you are a member of or if you choose to share or merge your account with other members.
It is important for Spond that your privacy is safeguarded when using the service and that you understand how we use your personal information. In this privacy statement, we explain, among other things, which information we collect, why, and how we use the information.
The privacy statement applies to users of Spond, including group administrators in Spond Team and administrators in Spond Club.
- Information we collect
Information you provide us (profile information)
In connection with your profile, you can register, among other things, name, email, phone number, address, date of birth and payment card number. You can also choose to upload a profile picture. When you create a user account, we also create a user ID associated with your profile.
In addition, if you enter one of our competitions, you provide us with certain personal information such as name, email, telephone number, and address for delivery of any prizes. The information may be collected directly or through the provider of the payment service, depending on which payment method you choose.
Interests and activities you add to your profile (account information)
In connection with your profile, you can add other information, such as groups you create or become part of and the activities associated with the groups you are part of (football, skiing, handball etc).
Payment and transaction information (financial information)
If you make any purchases we may collect financial information, such as the product that is purchased and details (time, date and product information and payment method (e.g. payment card information). We also facilitate fundraising campaigns and allow users to administer Spond Cashback for their club and/or group in which we also store your bank account number.
Posts, comments, messages and emojis (user generated content)
You can use Spond to communicate with a specific recipient or others in the team. Spond offers a variety of features for this purpose, such as by allowing you to participate in polls, create and post in events, react with emojis and send individual messages. You should not share sensitive information or other information that you do not want others to know.
Information Spond collects when you use the service (behavioural and technical data)
We collect personal information when you use the service, including (i) which groups you participate in and your activity, (ii) the domain from which the service is visited, (iii) which browser is used, (iv) the duration of the visit, (v) the IP address, (vi) device information, (vii) cookie identifiers, (viii) anonymous identifiers, (ix) time of visit, (x) how you use the service (including which features you use and content you click), (xi) how many groups you create, (xii) location and (xiii) how long it takes for you to complete tasks in the service.
We collect data about your general location, determined from your IP address when you connect to our service, your membership in clubs or groups with linked places, or any location details related to events you create etc.
Information we collect from others (third party information)
Administrators of Spond groups in Spond Team and Spond Club may upload basic profile information to the service (for example, for the purpose of inviting individuals to join a group managed in Spond). When Spond Team or Spond Club administrators provide this information they do so in accordance with their own privacy practices and policies.
For further information about the data controllership arrangements in this regard, please see below in section 4.
If you are a child, your personal information may also be provided to us by your parent or guardian.
If you use Spond Cashback, we receive information about time of purchase, place of purchase, and the amount paid. We receive this information from an external financial service provider (e.g. Nets). .
If you use Spond Cashback for online purchases, we will also receive information regarding which products or services you purchased from our payment service provider.
- How we use your personal information (and our legal basis for doing so)
The legal bases we use for processing your personal information are (i) where necessary to perform or enter into a contract with you (“contract”), (ii) where necessary to fulfil the legitimate interests of us or a third party (“legitimate interests”), (iii) your opt-in consent (“consent”), or (iv) where necessary for us to comply with our legal obligations (“legal obligations”). We have set out below our purposes for processing your personal information and the legal basis that applies to each one.
To provide our service (contract)
When you use the service to send messages with other users or create groups etc., we also process user generated content. As part of our service, we also use profile information and behavioural and technical information to provide customer service and support to help you in the best possible way.
The legal basis for processing activities that are necessary to provide our service, is contract. For more specific details of processing in respect of Spond Cashback and Fundraising Campaigns, please see relevant sections below.
Personalisation of the user experience and communication (legitimate interests)
It is in our interest to provide a user-friendly service that is as relevant as possible to you. In this regard we use your profile information, account information and behavioural and technical data to suggest and communicate content and features tailored for you. We also customise the service based on your inputs and preferences such as through automatic login, restoring your shopping basket, and customisation of service for your device.
The legal basis for these processing activities is legitimate interest, where our legitimate interest is to provide a user-friendly and relevant service to our users.
Development, improvement, statistics and measurement (legitimate interests)
We use profile information, account information, (limited) financial information and behavioural and technical information to better respond to users’ preferences and wishes and to improve the service as a whole. This includes analysing and identifying user trends among large and small user groups, compiling statistics and insights about how our service is used, collecting user information from surveys, and testing new features. In most instances, we take measures to ensure that we do not identify individual users. The legal basis for these processing activities is legitimate interest, where our legitimate interest is to improve and further develop the service..
It is also in our interests to use surveys to collect feed-back from users so we can improve our service and develop them. For anyone that has made a purchase through our competitions, we send out an invitation to participate in a survey. The invitation including a link to the survey is sent to the email address or telephone number you registered upon entry. If you do not wish to participate and/or not receive further invitations to participate in surveys, you can unsubscribe by using applicable functionality in the invitation.
To deliver and measure the effectiveness of ads on Spond
We may show you personalised ads based on your profile and account information. We may also use location data to show ads based on your approximate location, like the city you are in. Furthermore, ads can be shown based on where you are in the app (contextual ads), which also ensures the ads are relevant to you and other users, depending on how you use the service.
The legal basis for this processing of personal information is legitimate interest, where our legitimate interest is to provide a personalised service with ads that are relevant for you. This helps us ensure that Spond remains a free service for as many people as possible. However, you can control how we use your personal information in the privacy settings of your Spond account. If you prefer not to see personalised ads, we will only show you contextual ads.
Concerning children’s privacy, we have established guidelines and technical measures to ensure that the personal information of users under 18 is not processed for delivering personalised ads. Instead, we may show contextual ads or ads based on location data. When you turn 18, like other users over 18, you will have the option to choose whether you want to see personalised ads or not.
To measure the effectiveness of the ads, we create and share insight and measurement reports with our advertisers. This processing of personal information is based on behavioural and technical data, including ad views and user interactions with the ads. These reports do not contain information that can be linked to you as an individual. We also use such data to enhance our ad products. The legal basis for this processing is our legitimate interest in ensuring reliable reporting to our advertisers and contributing to the continuous improvement of our ad products.
Direct marketing – marketing via email, sms etc. (legitimate interests or consent)
We send marketing for our own services via email, SMS, and similar channels if you are already a user of our services and have not objected to receiving such marketing. We will always ask for your consent to send such marketing if you are not a user of our services, or if we intend to send you information about products or services from others.When we send you direct marketing communications as described above, we use your profile information. We may also personalise our marketing using other information such as your account information, financial information and behavioural and technical information. The legal basis for this processing of personal information is our legitimate interest in keeping you informed about our offers and promotions.
You may at any time opt out of such marketing. By opting out of receiving marketing messages or by withdrawing any consent you may have given to receive marketing, you also object to further use of your personal data for marketing purposes, including by means of profiling.
When using Spond Cashback for online purchases, we also access transaction information and through the use of analysis tools, we analyse this information in combination with other information we have about you so we can adapt our communications, including if we send you any marketing. You can opt-out of such communication at any time by changing the settings in the Cashback section in the app.
From time to time, we conduct referral campaigns based on our legitimate interest, where Spond users can refer others to become Spond users.
Use of third-party marketing services
We utilize services from third parties such as Google and Meta/Facebook to market our service. In this context, we share your profile information and/or behavioural and technical data. The legal basis for this processing is consent and/or our legitimate interest in promoting our services through relevant channels and receiving other marketing-related services, such as analysis and performance measurement.
Investigation and preventing security issues and abuse
We may process profile information and behavioural and technical information to ensure the security of the service and individual users, as well as to avoid and reduce the risk of security incidents. The legal basis for this is our legitimate interest in detecting and preventing misuse of the service.
Cookies, device identifiers or similar technology (“cookies”) may be stored or given access to on your device for the purposes described above. The legal basis for using cookies is consent in accordance with the national implementation of the ePrivacy directive or other local laws in the country you use the service.
For purposes required by law (legal obligation)
We process your personal information where we are required to hold or collect personal data to meet legal requirements on us, such as details of purchases for bookkeeping purposes or where we need consent from a parent or guardian to provide online services to children under 13. We will also share your personal information where required to do so in response to requests by government or law enforcement authorities conducting an investigation.
- How we share your personal information
We use third party service providers (for example our technology providers or third parties who distribute our competition prizes) who are our processors to process personal information on our behalf (subject to a data processing agreement that ensures an appropriate level of data protection).
International data transfers
Some of our processors are located outside the UK/EEA including in the US. The processing of personal data by such processors is safeguarded by entry into the UK or EU’s (as applicable) standard contractual clauses for transfer of personal data to third countries.
Sharing and processing your information as part of Spond Cashback
If you use Spond Cashback, we share your bank account number with our payment service provider(s), and pursuant to executed data processor agreement(s). The purpose of the sharing is to enable us to track and allocate transactions related to Spond Cashback. We don’t share other information with payment service providers for this purpose. If you register multiple bank account numbers, they will know that it is the same person that has registered the bank account numbers, but they will not receive information about your identity.
The administrator of each of the groups you are associated with will know how much Cashback the group has earned, but will not be able to see each member’s contribution.
The Spond Cashback partners regularly receive lists of transactions done by Spond-users so that they can compare this information with information in their own systems (store, amount and time of purchase). They will not receive any other information about you.
When you use Spond Cashback for online purchases, we also share a unique code with a partner or with a partner network that acts as an intermediary between us and our partners. This code acts as an identifier that lets us know that you have made a specific purchase. Neither the partner nor the partner network can connect the identifier to you.
Spond Fundraising Campaigns
Where available, the Spond Fundraising Campaign is a service that allows members, friends, family, and others invited to the fundraising campaign to contribute to your team’s or group’s finances. In order to carry out the Spond Fundraising Campaign, it is necessary to process personal data about the members and those who are invited to participate in and those who contribute to the fundraising campaign. In the following we describe how personal data is processed together with the group administrator.
The group administrator chooses group members to participate in a Spond Fundraising Campaign. It is therefore the administrator who is responsible for informing the individual member before the administrator registers the member. Once the administrator has included a member, we will use the member’s personal information (name and photo) to create a sales page for the fundraising campaign that the member/guardian may use if they wish to participate in the fundraising campaign. The member can then send invitations to others to purchase entries or products from the member’s sales page. We do not register who the member invites to a fundraising campaign, but we can see if a member uses the sharing functionality offered in the service. The administrator of each group will know how much each member has raised via sales. This is so that the administrator can follow the development and results of the fundraising campaign. However, the administrator can’t see any details with regards to who made purchases.
Interactions with other Spond users
The profile information you provide us (name, e-mail, telephone number, picture (if submitted) and any user generated content is visible for other members of the individual Spond group where you are a member or other participants to events where you participate. You can choose that only the group administrators should have access to your email address and phone number.
The profile information you choose to share and your contact preferences can be seen by other team members when you use the service to communicate with them. If you do not want other Spond users to have access to your information as described above, you should limit the information you submit and use the service the way you find appropriate.
In addition, if you enter any of our competitions or otherwise contribute to a fundraising campaign, the individual who asked you to participate will be shown your name and the time and amount of your contribution. You will not be able to anonymise this information. If you do not want this information to be shared with the individual who asked you to participate, you should not enter the competition or otherwise contribute to the fundraising campaign.
We have a Facebook and Instagram page. Facebook stores cookies on your device when you use their service. We recommend that you read Facebook’s information about how they process personal data. In relation to personal data that we control and have access to through your use of our Facebook and Instagram page, we are joint controllers with them. We may use insights from social media platforms for statistical and analytical purposes and only at an aggregated level.
- Responsibilities in Spond Club and groups in Spond Team
Spond Team enables group administrators to organise sport activities, including through integrations with Spond Club. When the group administrator adds new members to a group and those individuals do not have existing Spond accounts, we act as a joint controller with the group administrator. We process basic profile information for the purpose of directing those individual members to complete the registration of their individual profile in Spond in order to obtain the full benefit of the service and to provide basic functionality. This includes sending messages, participating in polls or receiving information about events generated by the group admin before the Spond account is activated. For individuals processed in such groups who already have a Spond account, we may process personal data as described in this privacy statement as a joint controller together with the respective group administrators.
Spond Club is a web based membership administration system for both large and small sports clubs and organisations that integrates with Spond Team.
Spond Club receives personal data (a) directly from members who join clubs, (b) from club administrators who input member details and (c) from groups within Spond Team that move into Spond Club.
Spond Club helps clubs streamline membership fee processes and organisational administration. In Norway, Spond Club is also integrated with the The Norwegian Olympic and Paralympic Committee and Confederation of Sports (NIF) for the limited sharing of member information. When we assist clubs and associations with carrying out such tasks, we do so as their data processor and the club or organisation is the data controller.
- Your rights as a Spond user
You have certain rights in respect of the personal data we process about you. Those rights include the right to access, rectify, erase, obtain and reuse across different services (“data portability”), restrict or object to certain processing (or withdraw your consent to processing if the legal basis for the processing is consent).
You can request to exercise these rights by contacting us at [email protected]. These rights may be limited, for example if fulfilling your request would reveal personal information about another person, where it would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in applicable data protection law. We will inform you of relevant exemptions we rely upon when responding to any request you make.
The profile information you have provided us with is always visible to you in the service. If any of the information we have registered about you is incorrect, we encourage you to make changes to your profile.
We will not process your personal information beyond what is necessary to fulfil the purpose of the processing and our statutory duties.
Note that your activity in Spond (for example registrations, de-registrations, posts, notifications, and other communication) will remain visible for relevant persons (including Spond group members and event participant etc.) after you have de-registered from one or more of your groups or you delete your Spond profile. When you delete your Spond-profile, your name and contact information associated to your activities will be anonymised and or removed.
- Children’s privacy
Children aged 13 years and over may use the service without their guardian’s approval. Children below 13 of age must have their guardian`s approval. An adult nominated as a child’s guardian and who has registered in the service will be able to see the child’s activity (for example, events they participate in or comments they provide). The minimum age for creating groups in the service is 15 years.
- Information Security
We have implemented organisational and technical procedures and measures that will ensure that your personal information is not compromised, not unintentionally changed, and available when required.
- Changes to the Privacy Statement
We will occasionally update this privacy statement to reflect any changes to the way we process your personal information in connection with the service. In such cases, a changed privacy statement will be published on spond.com. In case of major changes, we will notify you directly in the appropriate manner, either via the service or by email.
- Controller and contact information
Spond AS, organisation number 998 209 218, Myntgata 2, 0151, Oslo.
Where you enter a competition in the UK, the controller of your information is Spond Ltd, company number 13705044, at Profile West Suite 2, First Floor, 950 Great West Road, Brentford, Middlesex, TW8 9ES.
We can be contacted by email: [email protected]. See also https://get.spond.help/l/en, where you can read help articles and chat with our support team.