Privacy Policy

Privacy Policy

Last update: April 2025

 

Spentwell and its affiliated companies are committed to protecting the personal information of its users. Please read this Privacy Policy (this “Policy”) carefully to understand how Spentwell Ltd, 128 City Road., London, EC1V 2NX (“Spentwell”, “we”) processes personal information. This Policy describes how Spentwell processes personal information of its users and other visitors browsing the Site (“users”) in connection with the Site and other services provided by Spentwell as well as privacy practices that apply to third parties..

 

By accessing or using www.thespentwell.com, or any other related sites, applications, services and goods, or any other website operated by Spentwell that links to this policy (each, the “Site”), as well as by registering to a Spentwell account, you acknowledge that you have read and understood this Policy. This Policy may change from time to time; any changes we make to this Policy will be posted on this Site, we will also take any other steps, to the extent required by applicable law, including notifying you about material changes. Changes to this Policy are effective as of the stated “Last Updated” date. We recommend that you check the Policy periodically for any updates or changes.

 

 

1. Overview

 

Information We Collect – You directly provide us with most of the information we collect when you register to the Site, use it, complete forms, or register to any of our programs. We also collect information about your communications with Spentwell as well as any of your posts on our blogs or forums and your communication with other users of Spentwell. In addition, we automatically collect information while you access, browse, view or otherwise use the Site and receive information from third party vendors or other available sources.

 

Our Legal Basis for Using Your Personal Information – Where relevant under applicable laws, all processing of your personal information will be justified by a “lawful ground” for processing as detailed below.

 

How Do We Use the Information Collected? – We use personal information to provide you with quality service and security, to operate the Site, to perform our obligations to you and to develop, improve and personalize our service; to ensure marketplace integrity and security; to prevent fraud; to contact you and send you direct marketing communications; to promote and advertise the Site, our services and the Spentwell marketplace; to comply with lawful requests by public authorities and to comply with applicable laws and regulations.

 

How Long Do We Keep Personal Information – We will keep personal information only for as long as is required to perform the purpose for which it was collected. However, in some cases we will retain personal information for longer periods of time.

 

Children – This Site is offered and available to users who are at least 18 years of age and of legal age to form a binding contract.

 

Sharing Personal Information with Third Parties – We share personal information with third parties in order to operate the Site, provide our services to you, perform obligations imposed on us by applicable laws and regulations, and prevent fraud, infringements and illegal activities.

 

Where We Process Personal Information – Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions.

 

Cookies – We use cookies and similar technologies (such as web beacons, pixels, tags, and scripts) to improve and personalize your experience, provide our services, analyze website performance and for marketing purposes.

 

 

External Links – the Site contains links to third party sites and if you link to a third party site from the Site, any data you provide to that site and any use of that data by the third party are not under the control of Spentwell and are not subject to this Policy.

 

Security – We implement technical and organizational measures to maintain the security of the Site and your personal information and in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures.

 

Specific Provisions for EU, EEA and UK Users – If you are an EU, EEA or UK user, you are entitled to receive further information on our processing and your rights as a data subject, as detailed below.

 

Updating Personal Information – We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately.

 

Contact Us – You can exercise your rights over your personal information, by contacting us at contact@thespentwell.com.

 

The above are just the highlights. We encourage you to read more about the information we collect, how we use it, and more in the detailed version of our Policy below.

 

2. Information We Collect

 

Information You Provide. When you register to the Site or use it, we ask you to provide or otherwise collect personal information provided by you, including a valid email address, login details, name and username, profile details (including picture, education, profession and expertise), physical address or billing information, telephone number or other contact details, date of birth, transactional information), rating and reviews, information included in user generated content and files uploaded by you to the Site. We also collect and process information about or contained in your communications with Spentwell as well as any of your posts on our blogs or forums and your communication with other users of Spentwell.

 

Information We Collect Automatically. We collect information while you access, browse, view or otherwise use the Site including information about transactions and communications with other users, your searches, the pages you visited, browsed and scrolled as well as your clicks and other actions on the Site. We also, collect, use and process the information relating to such usage, including geo-location information, IP address, device and connection information, operating system, session duration, language, currency and keyboard setting, browser information and web-log information, and the URLs of the web pages you’ve viewed or engaged with before or after using the Site. We also collect and process information relating to the use of cookies and similar technologies, as detailed below.

 

Additionally, in order to improve your online experience at Spentwell, we have implemented impression reporting. While you view our ads, we gather user Global Unique Identifier, HTTP request data like, user agent, IP, host, URL, country/continent from which request made, browser info, device/operating system/operating system version.

 

Information We Receive from Third Parties. We receive information from third party vendors and/or other commercially and/or publicly available sources, such as:

 

• If any other third party submits a report and/or complaint about you or your activity on Spentwell, we may receive information relating to the specific report and/or complaint, review and address it.

 

• If you integrate into your account information from third parties or otherwise integrate your account with third party systems, tools or products, we will receive certain information about you according to your permissions at such third parties. 

 

 

We combine your personal information with information we collect automatically or obtain from other companies and use it for the purposes detailed in this Policy.

 

3. Our Legal Basis for Using Your Personal Information

 

Where relevant under applicable laws, all processing of your personal information will be justified by a “lawful ground” for processing. In the majority of cases, processing will be justified on the legal basis that:

 

• you have provided your consent for us to use your personal information for a specific purpose;

 

• our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with services which you have purchased);

 

• the processing is necessary to comply with a relevant legal obligation or regulatory obligation that we have (e.g. fraud prevention); or

 

• the processing is necessary to support our legitimate interests as a business (e.g. to improve our services to you), subject to your overriding interests and fundamental rights and provided it is conducted at all times in a way that is proportionate.

 

4. How Do We Use The Information Collected?

 

We will use your personal information for the following purposes:

 

• to provide you with quality service and security, to operate the Site, to fulfil our obligations to you and to develop, improve and personalise our service. For example, we use personal information to verify your identity. We also use this information to establish and set up your account, verify or re-issue a password, log your activity, enable your communications with other members, provide customer support and contact you from time to time. The information helps us to develop and improve our services, to understand and analyse our performance as well as your preferences and performance and to customise and personalise our service and enhance your experience.

 

• to ensure marketplace integrity, prevent fraud and maintain a safe and secure marketplace and services. For example, we use personal information to monitor, track and prevent illegal, fraudulent and inappropriate activities, monitor content integrity, conduct security investigations and risk assessments, verify or authenticate information provided by you, investigate reports and complaints about users, enforce our Terms of Service and comply with applicable laws. We also use automated processing to achieve the above objectives. In certain cases, if we detect activity that we think poses a risk to the Spentwell marketplace, other users, our community, or third parties we may restrict or limit your ability to use Spentwell. If you would like to challenge any such decision, please contact us at contact@thespentwell.com

 

• to contact you, as requested by you or as otherwise approved by you or permitted according to this Policy.

 

• to promote and advertise the Site, our services and the Spentwell marketplace. For example, we use the information collected from you for the purpose of sending direct marketing messages (as detailed below), to show you information that may be of interest to you or other promotional activities or events.

 

• to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations.

 

We will ask for your consent before using information for a purpose other than those set out in this Policy.

 

Direct marketing:

 

• We use your personal information to send you direct marketing communications about our products, services or promotions from Spentwell that may be of interest to you or our related services. This may be via email, post, SMS, telephone or targeted online advertisements.

 

• Our processing of your personal information for marketing purposes is based on our legitimate interest, on your consent, or on other legal basis permitted by applicable laws.
• We take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.

 

This Site is also protected by reCAPTCHA. Google Privacy Policy and Terms of Service apply with respect to data collected by reCAPTCHA. The use of Google reCAPTCHA is required in order to prevent fraud and misuse of the Site by use of automated machines. To learn more, please see Google’s privacy policy.

 

5. How Long Do We Keep Personal Information?

 

We apply a general rule of keeping personal information only for as long as is required to perform the purpose for which it was collected. However, in some circumstances, we will retain your personal information for longer periods of time. We will retain personal information for the following purposes:

 

• as long as it is necessary and relevant for our operations, e.g. so that we have an accurate record of your dealings with us in the event of any complaints or challenges;

 

• in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Site terms and take other actions as permitted by law;

 

• to comply with statutory or other obligations to which Spentwell is subject to; and

 

• if and to the extent necessary, we need it to preserve evidence within the statutes of limitation.

 

6. Children

 

This Site is offered and available to users who are at least 18 years of age or older and of legal age to form a binding contract.

 

7. Sharing Personal Information with Third Parties

 

We share your personal information with third parties as detailed below:

 

• With other users and Site visitors. Once you register, your username, and additional information regarding your activity is made public and is visible to all users of the Site. This information includes photos you upload, your published portfolio, ratings and reviews, and additional information you may choose to add to your profile. Your information will also be shared with other users when you message or otherwise communicate with them. When you publish your information and/or share your data with other Spentwell users, you do so at your own risk. If you choose to share personal information with other users, including Sellers providing you a service via Spentwell, such personal information is shared with other users as separate controllers. While our Terms of Service require Sellers to keep the information shared with them confidential, Spentwell cannot ensure that all users will do so and it is your responsibility to ensure that other users will comply with your standards;

 

• With users with whom you interact. We share personal information to help facilitate interactions between users.

 

• With Service Providers. We share personal information for business purposes with service providers that provide us with services for the purpose of operating the Site, opening and operating your account. organisational measures to allow third parties to adequately safeguard personal information and only process it in accordance with our instructions;

 

• When you submit a report or complaint about a user. We may share personal information about you when you submit reports or complaints about other users to allow them to protect their rights or as required by applicable laws.

 

• For legal reasons. We share personal information with law enforcement agencies, public authorities or other parties in order to respond to a court order, judicial process or to regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe it necessary or appropriate to disclose personal information to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to claims against us; and to protect the rights, property, or personal safety of Spentwell, our customers, or the public;

 

• For payments and fraud detection. We share personal information with payment processors, fraud detection agencies and similar third parties for the purpose of facilitating payments done via the Site, securing the Site and protecting it against fraud, unauthorized transactions (such as money laundering), claims or other liabilities;
•  

With social media partners. We share limited personal information with social media platforms and marketing partners, to promote our services or the Spentwell marketplace. Such features and third party services collect certain information about you and may set a cookie to enable their functionality. Such third parties’ features are governed by their policies;

 

• With our corporate affiliates. We share personal information with Spentwell’s corporate affiliates for business and operational purposes, including for the purpose of operating our and our affiliates’ business, providing supplemental services to you, preventing fraud and maintaining safe and secure services, promoting our and our affiliates’ services and for other purposes listed herein; and

 

 

8. Where We Process Your Personal Information

 

Some of the personal information you provide to us will be stored or processed on our behalf by third party suppliers and data processors and may be located in other jurisdictions, whose laws may differ from the jurisdiction in which you live. Whether to third parties or internally, there are also transfers of personal information from the European Economic Area (“EEA”) to countries outside of the EEA not deemed to provide an adequate level of data protection from a European data protection perspective. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.

 

 

 

 

9. Cookies

 

We use cookies and similar technologies (such as web beacons, pixels, tags, and scripts) to improve and personalize your experience, provide our services, analyse website performance and for marketing purposes. Where the use of cookies on our Site involves the processing of your personal information, this Policy applies. The types of cookies used by us and our partners in connection with the Site and our service can be classified into the categories “essential cookies”, “analytics cookies” and “marketing cookies”.

 

 

10. External Links

 

Please note that the Site contains links to third party sites and if you navigate to a third party site from the Site, any data you provide to that site and any use of that data by the third party are not under the control of Spentwell and are not subject to this Policy. You should consult the privacy policies of each site you visit. This Policy applies solely to personal information collected by our Site. If you upload content, including personal information, to a social network and then tag the Site, your submission will be subject to that social network’s terms of use and privacy policy, even where you post on an official Spentwell page on the social network. We do not have control over these terms of use and privacy policies and have not reviewed their adequacy. You should therefore review these before submitting any personal information.

 

12. Security

 

We implement technical and organisational measures in order to maintain the security of the Site, our services and personal information and in preventing unauthorised access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. However, the transmission of data via the internet is not completely secure, and although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the Site. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.

 

Users who have registered to the Site agree to keep their password in strict confidence and not disclose such password to any third party.

 

Further information about our data security practices can be provided on request.

 

13. Specific Provisions for EU, EEA and UK Users

 

This section of the Policy applies to you if you are in the EU, the European Economic Area (EEA) or UK.

 

The Controller (within the meaning of the EU and UK General Data Protection Regulation (“GDPR”)) for the processing of personal data as described in this Privacy policy is: Spentwell  Ltd., 128 City Road., London, EC1V 2NX.

 

Under applicable EU regulation, you have the following rights in respect of your personal information:

 

• to obtain information about how and on what basis your personal information is processed and to obtain a copy;

 

• to rectify inaccurate personal information;

 

• to erase your personal information in limited circumstances where (a) you believe that it is no longer necessary for us to hold your personal information; (b) we are processing your personal information on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal information to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal information; and (d) where you believe the personal information we hold about you is being unlawfully processed by us;

 

• to restrict processing of your personal information where: (a) the accuracy of the personal information is contested; (b) the processing is unlawful but you object to the erasure of the personal information; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defence of a legal claim or (d) you have objected to us processing your personal information based on our legitimate interests and we are considering your objection;

 

• to object to decisions which are based solely on automated processing or profiling;

 

• where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or

 

• to obtain a copy of or access to safeguards under which your personal information is transferred outside of the EEA.

 

Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal data by us and we may be required to no longer process your personal data. Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.

 

To exercise your rights please contact us as stated in the “Contact Us” section.

 

In addition to the above, you have the right to lodge a complaint with a supervisory authority for data protection. Please note that the right of access and the right to erasure do not constitute absolute rights and the interests of other individuals may restrict your right of access or erase in accordance with local laws.

 

We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardise the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.

 

14. Deleting or Updating Personal Information

 

According to applicable privacy laws, you may have the right and choices with respect to your personal information, including the right to request the deletion of your personal information in certain circumstances (as detailed in section 13 and above). If you are a Spentwell user and you wish to delete your account information, please contact us at contact@thespentwell.com.

 

We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your account profile settings. In the event that you believe your information is in any way incorrect or inaccurate, please let us know immediately. We will make sure we investigate the matter and correct any inaccuracies as quickly as possible where necessary or give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes.

 

When updating your personal information or deleting it, we will ask you to verify your identity before we can act on your request.

 

If you delete your User Generated Content (“UGC”), as defined in the Spentwell Terms of Service, from the Site, copies of your UGC may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including UGC, is governed by our Terms of Service.

 

16. Contact Us

 

To exercise any of your rights in connection with your personal information, we kindly ask that you contact us at contact@thespentwell.com.