Privacy Policy

Welcome!

Welcome to Uspot. We take your privacy seriously and know you do too. This Privacy policy (“Policy”) is here to help you understand how we collect, use, disclose, and process your personal data. We also describe your rights and choices with respect to how we process your personal data. Please read this Policy carefully.

Who We Are

This is the Policy of Uspot Tech, S.L. (“Uspot,” “us,” “our,” or “we”), located at Calle Panyo 15 BL. N 2º A, 17800, Olot (Girona), Spain. You can contact us here.

Applicability

This Privacy policy applies to our “Services,” which include our websites that link to or post this Privacy policy, including any subdomains or mobile versions (the “Site(s)”).

Agreement

This Policy is incorporated into the Terms of use governing your use of any of our Services. Any capitalized terms not defined in this Privacy policy will have the definitions provided in our Terms of use. Following notice to you or your acknowledgment of this Privacy policy (including any updates), your continued use of any of our Services indicates your consent to the practices described in this Policy.

Third Parties

Uspot provides services to various clients (“Clients”), enabling them to connect with, support, and offer services to parents, client customers, and their administrators and staff. We offer a platform for these uses, and this Policy covers the data processed and activities conducted through our Services. However, this Policy does not cover the Clients own uses of your data, including any processing they may choose to undertake that is not described in, or different from, this Policy.

This Policy also does not apply to information processed by other third parties, such as when you visit a third-party website or interact with third-party services, unless and until we receive your information from those parties.

Collection and Use of Personal Data

Data We Collect

We collect and process the following types of information, including data that relates to identified or identifiable individuals (“Personal Data”). Specific Personal Data elements listed in each category are examples and may change:

• Identity Data: Includes your name, ID/driver’s license number, gender, marital status, date of birth, social security number, photo/avatar, username, and other biographical information provided on applications, registration forms, or account profiles.
• Transaction Data: Information related to transactions or purchases, such as the item purchased, price, delivery location, and similar details.
• Contact Data: Information used to contact you, such as email addresses, physical addresses, phone numbers, social media or communication platform usernames/handles, and names or salutations.
• Financial Data: Information related to financial accounts or services, such as credit card numbers, bank account numbers, and other relevant data provided during financial transactions.
• Device/Network Data: Information related to your device, browser, or application, including IP addresses, MAC addresses, application IDs, identifiers from cookies, browsing metadata, and other data generated through applications and browsers.
• Location Data: Information related to your precise location, such as data collected from your device’s GPS or other localization services.
• Special Category Data: Information revealing racial, national, or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health information, or data related to sex life or sexual orientation.
• Custom Content: Information provided by a user in a free text or other unstructured format, or through custom fields created by a Client, which may include Personal Data or Special Category Data as provided by the user.

How We Collect Personal Data

We collect Personal Data from various sources based on the context in which it will be processed:

• You: Directly from you, for example, when you input information into an online form, sign up for a waiting list, register, or contact us directly.
• Your Device: Automatically from your devices, such as Device/Network Data collected through cookies and similar technologies when you use our Services, access our Sites, or open our marketing communications.
• Service Providers: From third parties with whom we have a relationship in connection with a relevant transaction, or who collect information on our behalf.
• Data we create or infer: We, or third parties operating on our behalf, create and infer Personal Data (such as Inference Data) based on our observations or analysis of other Personal Data we process, and we may correlate this data with other data we process about you.

Processing of Personal Data

User Account Registration: When you register and create an account on our Services, we process Personal Data such as Identity Data and Contact Data. If you choose to purchase products or services, we also process Financial Data. We use this data to create, maintain, and provide you with important account information. Financial Data is used to process transactions at your request or to store payment information for future purchases.

Client and Family Application/Registration: Clients users may submit applications, registrations, medical forms, and other inquiries through our Services. We process Personal Data, including Identity Data, Contact Data, Financial Data, Custom Content, and Special Category Data on behalf of the Client. This data is used to assess applications, maintain records, facilitate communications, and provide necessary services, including health and treatment records.

Purchases and Donations

On behalf of the Client, we process Transaction Data, Identity Data, Financial Data, and certain Contact Data when you complete a purchase or donate through our Services. All purchases and donations are processed by a third party on our or the Client's behalf. However, we and/or the Client may obtain any Personal Data processed by that third party.

We use the Transaction Data, Identity Data, and Contact Data as necessary to complete your transaction and provide you with relevant information. Financial Data is used only as necessary to process your transaction, and we may store your Financial Data for future purchases if you request.

Client Comments, Messaging, and Custom Content

On behalf of the Client, we process Identity Data, Contact Data, and Custom Content when you use our Services to fill out forms, message the Client, or send messages to a camper. We use this data to carry out the processes and transactions you request. Additionally, we may use Identity Data to improve our Services. Custom Content and Identity Data may be made available on our Site for viewing by parents, event organizers, and Client Administrators.

We do not screen messages, comments, or other postings for personal or inappropriate content.

Events, Planning, and Client Activities

On behalf of the Client, we may process Identity Data, Contact Data, Custom Content, and Special Category Data in connection with the management of events, trips, and other activities, as well as Client administration.

We use this data to help Clients manage these activities. Subject to your rights and choices, we may also use Identity Data, Contact Data, and Custom Content on behalf of Clients for maintaining event-related records scheduling, attendance, transportation, counselor assignments, and providing health services or meal adjustments based on your consent provided to the Client.

Staffing Data

We may process Identity Data, Financial Data, Contact Data, and certain Special Category Data on behalf of our Clients in connection with applications for roles such as administrator, counselor, volunteer, or other support positions. This may include criminal, professional, credit, or other background checks as requested by the Client.

Staffing data is used as requested by the Client, necessary for these activities, or as required by law. Financial Data may be collected and stored for payroll or reimbursement purposes. Subject to your rights and choices, we process this Personal Data to assist Clients in the assessment, creation, maintenance, and termination of the staffing relationship or for background checks.

Uspot may maintain relationships with background check providers and assist Clients in the request, fulfillment, and storage of background check information. However, Clients are the controllers of such information and are responsible for obtaining applicants consent, ensuring the legal rights of applicants, and for their use of background check data.

Administration Data

On behalf of the Client, we may process Identity Data, Financial Data, and Contact Data as well as certain Special Category Data in connection with administrative information collected by Clients, such as invoicing, expense reporting, financials, or other internal processes. This information may include medical information of certain staffers, campers, or event attendees, or other similar Special Category data, to the extent provided by the staffer, camper, parent, or attendee.

On behalf of the Client, we process Identity Data, Financial Data, and Contact Data primarily in connection with Clients’ internal business activities in relation to the analysis and internal reporting of Client financials, performance, or other activities. All administrative data will be used as is required by the Client as necessary in connection with these activities, or as required by law. Financial Data is collected and may be stored for payroll or reimbursement purposes, or as otherwise necessary in the context of the staffing relationship. Subject to your rights and choices, we may process the Special Category Data in connection with the individual’s consent, or as otherwise permitted by law.

Cookies and Similar Technologies

We, and certain third parties, may process Device/Network Data when you interact with cookies and similar technologies. We may receive this data from third parties to the extent allowed by the applicable partner. Please note that the privacy policies of third parties may apply to these technologies and information collected.

In connection with our legitimate interests in providing and improving the user experience and efficiency of our Services, and understanding information about the devices and demographics of visitors to our Services, we use this information (i) for “essential” or “functional” purposes, such as to enable various features of the Services such as your browser remembering your username or password, maintaining a session, or staying logged in after a session has ended; (ii) for analytics and site performance purposes, such as tracking how the Services are used or perform, how users engage with and navigate through the Services, what sites users visit before visiting our Services, how often they visit our Services, and other similar information; and (iii) for the purpose of displaying advertisements via retargeting to those users who visited our Site or who may be interested in our Service.

Some of these technologies can be used by third parties to identify you across platforms, devices, sites, and services. Clients may also have access to information, such as reports and analytics, generated through these services.

Business Purposes of Processing

In addition to the processing described above, we generally process Personal Data for several common purposes in connection with our business. For example:

Operate our Services and Fulfill Obligations: We process any Personal Data as is necessary to provide the Services, and as otherwise necessary to fulfill our obligations to you, e.g., to provide you with the information, features, and services you request.

Personalization/Customization: We process Personal Data (excluding Facial Recognition Data or Special Category Data) as necessary in connection with our legitimate business interest in personalizing our Services. For example, aspects of the Services may be customized to you so that it displays your or a Clients name, to reflect appearance or display preferences, display recent or commonly used features or data, or other similar functionality.

Internal Processes and Service Improvement: We process Personal Data (excluding Facial Recognition Data or Special Category Data) as necessary in connection with our improvement of the design of our Services, understanding how our Services are used or function, for customer service purposes, in connection with the creation and analysis of logs and metadata relating to service use, and for ensuring the security and stability of the Services. Additionally, we may use Personal Data to understand what parts of our Service are most relevant to users, how users interact with various aspects of our Services, how our Services perform or fail to perform, etc., or we may analyze use of the Services to determine if there are specific activities that might indicate an information security risk to the Services or our Users.

Marketing Communications

Data: We may process Identity Data and Contact Data in connection with email marketing communications, including (i) on behalf of Clients, when you register for an account, and choose to enroll, or are enrolled by the Client, to receive marketing communications; (ii) on behalf of Clients, when you open or interact with, a Client’s electronic marketing communications; (iii) on our own behalf when you contact us directly, or express an interest in our products and services; and (iv) on our own behalf when you open or interact with our marketing communications.

Uses: We use Identity Data and Contact Data as necessary to provide marketing communications, and consistent with our legitimate business interests, we may send you marketing and promotional communications if you sign up for such communications or purchase services from us.

Aggregate Analytics

We process Personal Data (excluding Special Category Data) to create aggregate analytics on how our Services are used. This includes analyzing company and investment trends, service performance, and generating reports on the use of our Services, user demographics, and other similar information. The resulting aggregate data will not contain information that can readily identify an individual. This processing is subject to users rights and choices.

Compliance, Health, Safety & Public Interest

We may process any Personal Data subject to this Policy for purposes determined to be in the public interest or as required by law, without your consent or further notice. This includes fulfilling legal obligations, protecting the vital interests of individuals, or addressing requirements from public authorities. For more details on how we disclose Personal Data in extraordinary circumstances, please refer to the data sharing section.

Other Processing of Personal Data

If we process Personal Data in connection with our Services in a way not described in this Policy, this Policy will still apply generally (e.g., with respect to users rights and choices) unless otherwise stated when you provide it.

Data Sharing

Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer Personal Data to the following categories of recipients:

• Clients: We process data on behalf of Clients and may share your Personal Data with Clients to the extent such information was provided to us for processing on their behalf. For example, any forms, applications, messages, or other material may be processed by us for Clients, and all Personal Data processed on behalf of the Client may be available to the Client and its users. These parties may engage in direct marketing, or other activities that are outside our control.
• Service Providers: In connection with our legitimate business interests or other business purposes, we may share your Personal Data with service providers or sub processors who provide certain services or process data on our behalf. For example, we may use cloud-based hosting providers to host our Sites or disclose information as part of our own internal operations, such as security operations, internal research, etc. We disclose Special Category Data to service providers only with your consent where required by law.
• Affiliates: In order to streamline certain business operations, develop products and services that better meet the interests and needs of our customers, and inform our customers about relevant products and services, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies.
• Corporate Events: Your Personal Data may be processed in the event that we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
• Legal Disclosures: In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, or in the vital interests of us or any person. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.

Your Rights and Choices

Your Rights

Depending on your location and applicable law, you may have the following rights regarding your Personal Data:

• Access: You may have the right to know what information we collect, use, disclose, or sell, and to receive a copy of your Personal Data and information about how it is shared.
• Rectification: You can request the correction of inaccurate or incomplete Personal Data.
• Delete: You may request that we delete your Personal Data, subject to certain conditions and exceptions as required by law. We may delete your data entirely, or we may anonymize or aggregate your information such that it no longer identifies you.
• Data Export: You may request a copy of your Personal Data in a structured, commonly used, and machine-readable format and transfer it to another controller.
• Right to Object: You can object to our processing of your Personal Data based on our legitimate interests. We will limit processing where our interests do not override your rights and freedoms or where processing is not necessary for legal claims.
• Right to Restrict: You can request the restriction of processing your Personal Data under certain circumstances, such as when the accuracy of the data is contested or processing is unlawful but you object to deletion.
• Automated Processing: You may opt-out of or request limitations on automated decision-making, including profiling, where it produces legal effects or similarly significantly affects you.
• Consent Withdrawal: If you have given consent for the processing of your Personal Data, you can withdraw it at any time, which will not affect the lawfulness of processing based on consent before its withdrawal.
• Regulator Contact: You have the right to file a complaint with your local data protection authority if you believe your rights are being violated.

Your Choices

You may have the following choices regarding the Personal Data we process, to the extent required under applicable law:

• Consent: If you consent to processing, you may withdraw your consent at any time, to the extent required by law.
• Direct Marketing: You can opt-out or withdraw consent for direct marketing communications via links in our communications or by contacting us.
• Location Data: Control or limit Location Data collection through your device’s location services preferences menu or network interface settings.
• Online Advertising: Opt-out of behavioral advertising via third-party services directly. For example, opt-out of Google’s use of cookies through Google’s Ads Settings.
• Other Processing: You may object to our processing of your Personal Data for certain purposes by contacting us regarding data rights requests. Note that we may not be required to cease processing based solely on an objection.

Exercising Your Rights

To exercise any of these rights, please contact us at:

• Uspot Tech, S.L.
• Calle Panyo 15 BL. N 2º A
• 17800, Olot (Girona), Spain
• E-mail: admin@uspot.io

All rights requests must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data. We may require that you provide the email address we have on file for you (and verify that you can access that email account) as well as an address, phone number, or other information we have on file, in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agents authority to act on your behalf.

Note Regarding Clients Data

In many cases, Uspot acts as a processor of Clients’ Personal Data. We may notify Clients of your data rights requests; however, we may be unable to directly fulfill these requests unless we control or have access to the data. Uspot may not have access to all Personal Data controlled by Clients. Please contact the Client directly for data rights requests regarding Client-controlled information. We will assist the Client as appropriate in fulfilling your request. Interfaces we provide for you to control your data apply only to data we control.

Data Retention

We retain Personal Data for the periods stated above, or as long as relevant to its purpose or required by law. As we process data on behalf of Clients, we may retain or delete information at the Client’s request. Retention periods are periodically reviewed, and data may be pseudonymized or anonymized for longer-term retention.

Minors

Our Services are intended for Clients, event organizers, attendees, and campers’ parents, and are not directed at individuals under 16. We do not knowingly collect Personal Data directly from such individuals. If we inadvertently collect such data, we will promptly delete it. Do not use the Services if you are under the age of majority in your jurisdiction without parental consent.

International Transfers

We operate and use service providers located both within and outside the European Union. When transferring Personal Data internationally, we ensure compliance with the General Data Protection Regulation (GDPR). If you are located outside the EU, your Personal Data may be transferred to the EU.

The EU provides specific legal protections for Personal Data, and we ensure that any transfers of Personal Data outside the EU are safeguarded by using appropriate transfer mechanisms. These mechanisms include the use of Standard Contractual Clauses (SCCs) approved by the European Commission, binding corporate rules, or other adequacy mechanisms permitted under EU law.

We are committed to ensuring that your Personal Data remains protected according to the highest standards, regardless of where it is processed.

Supplemental Data Processing Disclosures

Categories of Personal Data Disclosed for Business Purposes

For purposes of compliance with global privacy standards, including the GDPR, we may disclose the following categories of Personal Data to service providers for business purposes:

• Identity Data
• Transaction Data
• Contact Data
• Financial Data
• Device/Network Data
• Location Data
• Special Category Data
• Face Recognition Data
• Custom Content

Data Sale

We do not sell your Personal Data to third parties. Any transfer of your data is done in compliance with applicable laws and based on your consent or other legal bases.

Categories of Data, Sources, and Purposes

Changes to Our Privacy Policy

We may change this Privacy Policy from time to time. Changes will be posted on this page with the effective date. Please visit this page regularly so that you are aware of our latest updates. Your acknowledgment of these changes or use of the Services following notice of any changes (as applicable) indicates your acceptance of any changes.

Contact Us

Feel free to contact us with questions or concerns using the appropriate address below.

General inquiries: admin@uspot.io

Physical address:

• Uspot Tech, S.L.
• Calle Panyo 15 BL. N 2º A
• 17800, Olot (Girona), Spain