Privacy Policy

SpAItial Ltd Privacy Notice

Updated: 24 September 2026

This Privacy Notice ("Privacy Notice") sets out how SpAItial Ltd processes your personal data in connection with our websites at https://www.spaitial.ai/, https://app.spaitial.ai/, https://developers.spaitial.ai/ and https://docs.spaitial.ai/ (together, the "Site"), and the services we offer to our customers, including through our Site and the native iOS application SpAItial Capture (i.e. the SpAItial Platform, an AI-powered platform that enables users to capture or generate 3D worlds and assets) (together our "Services"). We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data. If we update this Privacy Notice, we will update the effective date at the top of the page. Your access to and use of our Site and Services, including your account page and any secure area, is subject at all times to our Terms of Service. This Privacy Notice specifically applies to the processing of personal data of individuals we interact with during the day-to-day provision of our Services. This Privacy Notice applies to the processing of personal data carried out by any company within the SpAItial Ltd to the extent such processing is caught by the requirements of the UK Data Protection Act 2018 and/or the General Data Protection Regulation ("UK GDPR") and/or the EU General Data Protection Regulation ("EU GDPR").

PURPOSE OF THIS PRIVACY NOTICE

This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party, and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data. When we talk about "personal data", we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. This Privacy Notice is intended to assist you in making informed decisions when using our Site and our Services. Please take a moment to read and understand it. It should be read in conjunction with our Website Terms of Service, and our Cookie Policy. This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).

ABOUT US

SpAItial Ltd (company no: 15994344) is a company established under the laws of England and Wales. Registered office: 1-2 Paris Garden, London SE1 8ND SpAItial Ltd is the main operating entity within the group and is responsible for the provision of the Site as well as the development of AI systems with a spatial understanding of the world, as well as recruitment activities via its embedded careers platform. SpAItial is based in Europe and provides Services globally, including to users in the United States. For the purpose of the UK GDPR SpAItial Ltd will be considered an independent controller of your personal data. SpAItial Ltd shall be your primary point of contact for any questions about the processing of your personal data.

HOW TO CONTACT US

If you have any questions about this Privacy Notice or want to exercise your rights as a data subject set out in this Privacy Notice, you can contact us as follows:

Email

Send us an email at: [email protected]

Post

Write to us at: SpAItial Ltd, 1-2 Paris Garden, London SE1 8ND

GOOGLE SIGN-IN AND GOOGLE USER DATA

SpAItial lets you create and sign in to an account using Sign in with Google. Sign in with Google is provided through our authentication partner, Supabase. When you choose Sign in with Google, we access and receive the following Google user data from your Google account: your Google account email address; your name; and your Google profile picture, if you have one.

How we use Google user data

We use this Google user data only to create, authenticate and administer your SpAItial account, and to display your name and profile picture in the product. We do not use Google user data for advertising, advertising measurement or credit scoring. We do not sell Google user data.

How we store Google user data

We store this Google user data with your SpAItial account, hosted by our authentication and database provider (Supabase), until you delete your account or disconnect Google sign-in.

How we share Google user data

We do not share Google user data with third parties except as needed to operate authentication and account services (currently Supabase) and as otherwise described in the "SHARING PERSONAL DATA" section of this Privacy Notice.

How to delete Google user data

You can delete your SpAItial account and the Google user data associated with it through Settings in SpAItial Capture, or by emailing [email protected]. Disconnecting Google sign-in or deleting your account stops further access to your Google account. You can also revoke SpAItial's access to your Google account from your Google Account permissions page. We do not request access to your Gmail, Drive, Calendar, Contacts or any other Google product data. We only use Sign in with Google for account authentication.

SPAITIAL CAPTURE

SpAItial Capture is our native iOS application for scanning a physical space, preparing a capture on your iPhone and, when you choose to upload and process it, creating a 3D world through the Services.

Data processed by SpAItial Capture

Account and notification data. The app uses your name, email address and SpAItial account identifier for authentication and to associate captures, worlds, credits and settings with your account. If you enable push notifications, it sends an Apple Push Notification service ("APNs") device token linked to your account so we can deliver capture-completion and failure notices. The app requests removal of the registered token when you disable push delivery, and account deletion removes notification registrations during cleanup. Capture images. The app records image frames from the iPhone camera while you scan. These are live camera frames, not photographs selected from your photo library. The frames are stored in the local capture bundle and are uploaded when you ask the app to upload or process that capture. ARKit environment-scanning data. An uploaded capture includes ARKit-derived camera trajectory and poses, camera calibration and orientation, and capture-relative frame timing. Per-frame camera metadata is included while its upload setting is enabled (it is on by default), and LiDAR depth maps are included only after you enable that off-by-default setting for a new scan. The app uses ARKit room mesh, point-cloud preview and world-map files locally for capture guidance, preview and continuation; those local preview and continuation files are not included in the current capture upload. Raw motion data. Raw Core Motion accelerometer, gyroscope and device-motion streams are optional and off by default. The app records and uploads these streams for a new scan only after you enable Raw motion data in Advanced Settings. Capture-relative frame timing is still included when raw motion is off. Capture diagnostics. Each uploaded capture includes a capture event log recording events such as pauses, app or camera interruptions, ARKit tracking state, thermal state and camera-pressure state. We use this to explain gaps and diagnose capture or processing problems. App Store purchase data. If you buy consumable credits in the app, Apple provides a signed transaction and later transaction or refund updates. We process data such as your account token, product and transaction identifiers, purchase and revocation information, App Store environment, price and currency to verify the purchase, grant credits once, reconcile refunds, prevent abuse, maintain billing records, provide support and measure first-party purchase revenue. Apple processes the payment; SpAItial does not receive your full payment-card details.

How we use Capture data

We use capture images and environment-scanning data to upload, align, reconstruct and deliver the 3D world you request. We use optional raw motion and depth or per-frame camera data to support capture processing and diagnosis, not to assess your health or fitness. We use capture diagnostics to maintain, troubleshoot and support the capture workflow; account and push-token data to authenticate you and deliver requested service notifications; and App Store transaction data to operate the credit purchase and refund lifecycle and for linked first-party revenue analytics. None of these data types is used to track you across other companies' apps or websites. Our legal bases are performance of our contract where the processing is needed to provide the capture, world-generation, account or purchased-credit functionality you request; our legitimate interests in securing, diagnosing and supporting the Services; compliance with legal obligations where applicable; and your consent where we ask for an optional permission or opt-in. Optional marketing consent is separate from capture processing.

Capture service providers

Apple provides StoreKit and App Store payment and refund services, Sign in with Apple where selected, and APNs delivery. Apple processes data under its own terms and privacy policy. Our cloud, storage, authentication, email and other service providers process Capture data only as needed to operate the Services, as described in "SHARING PERSONAL DATA" and on our Subprocessors page.

Capture retention and deletion

Local capture bundles stay on your iPhone until you delete the scan in SpAItial Capture or remove the app. SpAItial cannot remotely delete files that remain only on your device. Data uploaded from Capture and related account, world, notification and billing records are retained under the rules in "HOW LONG WE KEEP YOUR PERSONAL DATA". You can request account deletion in SpAItial Capture under Settings > Delete account, or by emailing [email protected]. The in-app request requires recent authentication and, for an account linked to Sign in with Apple, a fresh Apple authorization so we can revoke that authorization. Once the request is accepted, the app signs you out, access is disabled, we attempt to revoke current sessions and cloud cleanup continues asynchronously. The cleanup cancels active generations and deletes the account profile, personal workspace, associated cloud captures, uploads and worlds, notification registrations and billing customer profile. Local capture bundles on the iPhone are not deleted by the cloud process. Verified deletion requests are completed within the period stated on our Security page, subject to the retention exceptions and legal obligations described in this Privacy Notice.

WHAT PERSONAL DATA WE COLLECT

In providing our Site and Services, we may collect and process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you use our Site and Services and includes the following:

Identity Data

First name; last name.

Contact Data

Delivery address; billing address; email address; telephone number.

Registration Data

First name; last name; email address; date of birth; country; company name; job title; password; contact preferences; any other personal data that you may provide when you register an account with us.

Financial Data

Bank account details; payment card details.

Transaction Data

Details about payments made between you and us; details of Services purchased from us; details of returns and complaints.

Profile Data

Account username; password; profile picture or avatar; purchase/order details; interests and preferences; contact preferences; whether you have participated in any promotions or competitions; feedback and survey responses; the content of any messaging you send using contact channels made available on the Site (for example, support email or in-product messaging).

Behavioural Data

Data relating to your browsing and in-product activity, obtained through cookies, analytics scripts and similar technologies (including, where you have consented, PostHog); information about when your current or previous sessions started; details about any Services you viewed or purchased through the Site.

Technical Data

IP address; browser type and operating system; geolocation, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.

Marketing and Communications Data

Marketing preferences; service communication preferences.

User Content Data

Content that you upload, submit or otherwise make available through our Services, including images, text prompts, instructions and other inputs provided to our AI-powered features ("Input Data"); and any 3D worlds, assets or other content generated by our Services in response to your Input Data ("Output Data").

Capture Data

The SpAItial Capture account, notification, camera-frame, ARKit environment-scanning, optional raw motion, diagnostic and App Store transaction data described in "SPAITIAL CAPTURE".

HOW WE COLLECT AND RECEIVE PERSONAL DATA

We collect and receive personal data using different methods:

Personal data you provide to us

You may give us your personal data directly, for example, when you use purchase Services on our Site, contact us with enquiries, complete forms on our Site, subscribe to receive our marketing communications or provide feedback to us.

Personal data we collect using cookies and other similar technologies

When you access and use our Site, we will collect certain Behavioural Data and Technical Data. We collect this personal data by using cookies, analytics scripts and local storage (see the "Insight and analysis through Cookies" section below and our Cookie Policy).

Personal data received from third parties

We may receive personal data about you from third parties. Such third parties may include Google (when you use Sign in with Google, as described in "GOOGLE SIGN-IN AND GOOGLE USER DATA"), Apple (when you use Sign in with Apple or make an App Store purchase or refund), analytics providers and third parties that provide technical services to us so that we can provide our Site and our Services (for example authentication, hosting, payments and security providers). Browser analytics and session replay through PostHog run only where you have consented to non-essential cookies; limited server-side operational, error and purchase-revenue events do not use browser cookies.

Publicly available personal data

From time to time, we may collect personal data about you (Identity Data, Contact Data or Profile Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).

WHO WE COLLECT PERSONAL DATA ABOUT

We collect and process personal data from the following people:

Site visitors

If you browse our Site or register an account on our Site, we will collect and process your personal data in connection with your interaction with us and our Site.

Customers

If you buy our Services, we may collect and process your personal data in connection with the supply of services to you.

People who contact us with enquiries

If you contact us with an enquiry through our Site, submit a complaint through our Site or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal data in connection with your interaction with us and our Site.

Beta participants

If you have been invited to participate in, or have registered for, a private beta or early access programme for our Services, we will collect and process your personal data in connection with your participation in such programme, including your use of the Services and any feedback you provide.

HOW WE USE YOUR PERSONAL DATA

We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.

Use of our Site.

If you browse our Site

When you browse our Site, we collect and process Behavioural Data and Technical Data to help us understand how you are using and navigating our Site. We do this so that we can better understand which parts of our Site are more or less popular and improve the structure and navigation of our Site. Our legal basis for processing It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to our Site in a secure and effective way and so that we can make improvements to our Site.

If you register and access an account on our Site

You may be required to register an account with us in order to gain access to certain features and functionality of our Site and/or to receive certain offers and benefits. Account applicants will need to complete the registration form, providing all required Registration Data. If you register using Sign in with Google, we receive your Google account email address, name and profile picture as described in "GOOGLE SIGN-IN AND GOOGLE USER DATA". We will use this data in order to process your registration. Once the account is registered, we will process your Registration Data to identify you when you log in to your account and access secure areas of our Site. We will also process certain Technical Data and Marketing and Communications Data so that we can administer your account and contact you about your account. We will also collect and process Behavioural Data and Technical Data when you use certain features and functionality on our Site. This data helps us understand how you use our Site so that we can improve it. Our legal basis for processing It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide access to the Site and our Services in a secure and effective way and so that we can make improvements to our Site.

If you purchase Services through our Site

We collect and maintain personal data that you submit to us for the purpose of supplying our Services that you have requested from us via our Site. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent. The personal data we process may include your Identity Data, Contact Data, Registration Data, Profile Data, Financial Data and Transaction Data (where applicable). We process this information so that we can fulfil the supply Services, maintain our user databases and to keep a record of how our Services are being used. Our legal basis for processing It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide our Services in an effective, safe and efficient way.

If you use the interactive features on our Site

We will collect and use personal data about you when you use certain features on our Site. For example, depending on the nature of your enquiry, we may process your Identity Data, Contact Data, Registration Data, Profile Data and certain Behavioural Data and Technical Data when you use contact channels available on the Site to get in touch with us. Our legal basis for processing It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest to use personal data in such a way to ensure that we can respond to your enquiries, provide access to our Site in a secure and effective way and make improvements to our Site.

If you contribute to our Site or post content on our Site.

If you write an article or blog for us or contribute in any other way to publications we send to our account holders and/or publish on our Site or in print, we may use your personal data (such as your Identity Data and/or Contact Details) to credit you for your contribution. If you provide photographs or other images in support of your article or blog, we may publish one or more of those images alongside your article or blog. If you submit any other content to us, including via our Site, such as photographs, quotes or testimonials, we may process any personal data comprised within that content for the purposes of making available particular Services via our Site and promoting our Site and our Services. We may also allow third parties to use the articles or blogs that you contribute, or the content that you provide (please see the "If you request content from our Site" section below). If the use of such content would involve the use of your personal data, we may use your Contact Details to ask your permission to use the relevant content, unless we are satisfied that we have a lawful right to use the content without your permission. Our legal basis for processing Where we use your content in connection with Services that we provide via our Site, it is in our legitimate interest to use any personal data that you provide to us to ensure that we provide the relevant Services in an effective way. Where we permit a third party to use your personal data contained within content that you submit, we will do so without your permission if we are satisfied that it is within our or the third party’s legitimate interest to use your personal data, including to promote our Services or services offered by the third party. If it is not within our legitimate interest, we will contact you to ask your permission, in which case our processing of such personal data will be based on your consent.

If you request content from our Site

Certain parts of our Site may allow account holders and third parties to request access to and/or use of specific published content, including photographs, quotes and testimonials. If you request content from us, we will ask you to provide your Identity Data, Contact Data, and any other information relevant to your request. We will process this information in order to process and respond to your request. Our legal basis for processing If you have requested content from us, it is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we process your request in an effective way.

Customer service.

If you have a general question or need help with any issue concerning our Site or our Services There are various ways in which you are able to contact us (see the "How to contact us" section above), including by email and through any contact channels made available on our Site. From time to time, you may also be able to submit specific enquiries on other pages of our Site, including in secure account areas. When you make an enquiry, we will collect and process your Identity Data, Contact Data and, if applicable, certain Profile Data and Transaction Data, as well as any other personal data you volunteer that is relevant to your enquiry. If you have a technical issue concerning our Site, we may also collect and process Behavioural Data and Technical Data to help us diagnose the technical issues you are experiencing and to help us resolve them in an efficient way. We use this information to manage and respond to your enquiry. We also record (including voice recordings of telephone conversations) and use the information referred to above to train our personnel so that they can effectively deal with enquiries. Our legal basis for processing It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services.

Surveys and feedback.

If you complete our surveys or provide feedback on your experience of our Site and/or our Services From time to time, we will invite you to provide feedback about us, our Site and Services, in the form of online surveys. We will collect and process your Identity Data, Contact Data and, if applicable, certain Profile Data and Transaction Data, as well as any other personal data you choose to volunteer in your survey response or other feedback. We use this information to help us to monitor and improve our Site and our Services, to assist with the selection of future product features and service improvements, and to train our personnel. You can also voluntarily provide feedback by email or via our available contact channels. Please see the section above for more information. Our legal basis for processing It is in our legitimate interest to use the personal data provided by you so that we can improve our Site and Services and provide them in an effective way.

Insight and analysis through Cookies.

If we use cookies to help us understand more about you and your use of our Site and our Services We use cookies, analytics scripts and local storage (all of which we generically refer to as "Cookies") to collect Behavioural Data and Technical Data from the devices that you use to access our Site and Services. We do not use advertising pixels, retargeting tags or social-media tracking pixels, and we do not share Cookie data with advertising networks. Please see our Cookie Policy for the cookies we use, who sets them, how long they last, and how to change your preferences. We use this data to analyse how you use our Site and Services, including:

• to understand which pages and features are used, and to improve navigation, design and performance;
• to diagnose errors and (on the SpAItial Platform, and only if you accept non-essential cookies) to review session replay so we can debug and improve the product;
• to help us with the selection of future product features and service improvements; and
• to remember essential preferences such as your cookie choice and display theme. Our legal basis for processing Where your data is collected through the use of non-essential cookies (currently PostHog analytics and session replay), we rely on consent. You can withdraw that consent at any time via Cookie Settings, as described in our Cookie Policy. Where we use essential cookies that are required for the Site to function (for example to keep you signed in), it is in our legitimate interest, or necessary to perform our contract with you, to use that personal data so that we can provide the Site securely and effectively.

Advertising and marketing activities.

If we send you marketing communications by email We use your Identity Data, Contact Data and Marketing and Communications Data to send you (or the organisation you represent) marketing communications by email where you have opted in (for example the product-updates checkbox at sign-up) or where we otherwise have a lawful right to do so. The product-marketing checkbox is optional and unchecked by default, and agreeing to marketing is not a condition of creating or using a SpAItial account. Account, security, purchase and service-status messages are not product marketing. Our marketing will include information about us, our Site, and our Services, any events we may hold and the offers and promotions we offer from time to time. We do not use cookies or advertising networks to show you personalised ads on third-party websites or social media, and we do not share Cookie data with advertising partners. Our legal basis for processing We will only send marketing communications to you by email where you have consented to receive such content by email, or where we have another lawful right to send marketing to you using email. For example, in certain circumstances we may rely on our legitimate interest to send marketing by email to certain business users of our Site and our Services. You can unsubscribe from marketing emails at any time using the link in the email or by contacting us.

Business administration and legal compliance.

If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets. Our legal basis for processing Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order. We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

AI model training and service improvement.

If we use your personal data to train, develop and improve our AI models and Services We may use your User Content Data (including your Input Data and Output Data), together with associated Behavioural Data and Technical Data, for the purposes of monitoring, analysing, developing, testing and improving our Services and the underlying AI models and systems that power them. This includes using such data to train and fine-tune our proprietary AI models. This processing is carried out internally and we do not share your User Content Data with third-party AI model providers for their own model training purposes. It is in our legitimate interest to use your personal data in the ways described above to ensure that we can develop, improve and maintain the quality, safety and performance of our Services and our underlying AI models and systems.

IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Services you have requested from us or to process an application to register an account. In these circumstances, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

HOW WE OBTAIN YOUR CONSENT

Where our use of your personal data requires consent, you can provide such consent at the time we collect your personal data following the instructions provided, or by informing us using the contact details set out in the "How to Contact Us" section above.

THIRD-PARTY LINKS

This Privacy Notice only applies to personal data processed by us through your use of our Site and/or in connection with our business operations. However, from time to time, our Site may contain links to third-party websites and services. We have no control over these websites and services and this Privacy Notice does not apply to your interaction with the relevant third parties. When you use a link to go from our Site to another website (even if you don’t leave our Site) or you request a service from a third party, your browsing and interactions on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. For example, our Site invites you to connect with us on social media platforms such as X (Twitter) and LinkedIn. When you click on the links we provide to such third-party platforms, you will be transferred from our Site to the relevant third-party platform and the privacy notice (and other terms and conditions) of that platform will apply to you. We do not monitor, control or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.

SHARING PERSONAL DATA

We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations. When processing your personal data, we may need to share it with third parties (including other entities within our group of companies), as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.

Third-party suppliers who provide applications/functionality, data processing or IT services

We share personal data with third parties who support us in providing our Site and help provide, run and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share limited personal data with PostHog for browser analytics and session replay where you have accepted non-essential cookies, and for server-side operational, error and purchase-revenue events that do not use browser cookies. Browser cookie processing is described in our Cookie Policy, and our current providers are listed on our Subprocessors page. For the avoidance of doubt, we do not share your User Content Data (including Input Data or Output Data) with third-party AI model providers for the purpose of training their own models.

Payment providers and banks

We share personal data with third parties who assist us with the processing of payments and refunds. For an in-app credit purchase, Apple processes the payment and refund request and sends us verified transaction and refund information; we do not receive your full payment-card details.

Third-party post/email marketing and CRM specialists

We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our post and email marketing communications and account-related communications.

Auditors, lawyers, accountants and other professional advisers

We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.

Law enforcement or other government and regulatory agencies and bodies

We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

Another corporate entity in connection with a business transition

If we are involved in a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets, we may share or transfer personal data to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Notice.

Other third parties

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

TRANSFERS OUTSIDE THE UK AND THE EUROPEAN ECONOMIC AREA ("EEA")

SpAItial is based in Europe. To provide our Site and Services to users globally (including users in the United States), we may use third party suppliers (for example, cloud-based data storage providers) located outside the UK and the EEA. Therefore, when you submit personal data to us, you acknowledge that your personal data may be transferred outside the UK and the EEA to countries such as the United States and other countries where our suppliers operate, where it will be stored and processed by us for the purposes set out in this Privacy Notice. Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws. When transferring your personal data outside the UK or the EEA, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.

Adequacy decisions

We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or by the UK government. For further details, see: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en https://www.gov.uk/government/publications/uk-approach-to-international-data-transfers/international-data-transfers-building-trust-delivering-growth-and-firing-up-innovation

Standard contractual clauses

Where we use certain service providers, we may use specific contracts approved by the European Commission and/or the ICO which give personal data similar protection to the protection it has in the UK and EEA. For further details, see: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en#eu-standard-contractual-clauses https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/international-data-transfer-agreement-and-guidance/

HOW LONG WE KEEP YOUR PERSONAL DATA

In respect of personal data that we process in connection with the supply of our Services, we may retain your personal data as required from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability. Where we process personal data in connection with the registration and use of an account on our Site, we may retain your personal data as required from the date that the relevant account is terminated (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability. For SpAItial Capture, local scan files remain on your iPhone until you delete them in the app or remove the app. Account deletion initiated in the app is processed asynchronously as described in "SPAITIAL CAPTURE"; uploaded Capture data follows the account and Services retention rules in this section. App Store transaction, refund, security and audit records may be retained where needed to administer credits and refunds, resolve disputes, prevent fraud or comply with legal, tax and accounting obligations. Where we process any other personal data, we will retain relevant personal data for up to three years from the date of our last interaction with you (and in compliance with our data protect obligations). We may then destroy such files without further notice or liability. If any personal data is only useful for a short period (e.g. for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us. If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.

CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA

We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. Those measures are described on our Security page. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Site and those who purchase our Services. Our current subprocessors are listed publicly.

PERSONAL DATA OF MINORS

Our Site and Services are not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. We may implement age-related verification or safeguards as part of the registration process for our Services. However, this does not prevent minors from providing personal data to us. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors. If you are under the age of 18, you must not use our Site or purchase Services from us and you must not provide us with any personal information. If we discover that we are holding the personal data of a minor, we will delete that information as soon as possible. Please contact us if you have reason to believe that a minor may have submitted personal data to us (see the "How to contact us" section above).

AUTOMATED DECISION-MAKING

We do not make decisions about you based solely on automated processing that produce legal effects or similarly significant effects on you. Our Services use AI and automated systems to generate 3D content based on your inputs, but this does not constitute automated decision-making of the kind described above. If this changes in future, we will update this Privacy Notice accordingly.

YOUR RIGHTS AS A DATA SUBJECT

You have certain rights in relation to the personal data we hold about you. These rights include the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority. If you would like to exercise any of these rights, please contact us using the details set out in the "How to Contact Us" section above.

Your right of access

If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

Your right to rectification

If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.

Your right to erasure

You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). You can initiate deletion of your SpAItial account in SpAItial Capture under Settings > Delete account, or contact [email protected]. In-app account deletion starts asynchronous cloud cleanup and does not delete scan files that remain only on your iPhone. If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

Your right to restrict processing

You can ask us to "block" or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

Your right to object

You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.

Your right to data portability

You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.

Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the "How to Contact Us" section above, by using any other opt-out mechanism we may provide (such as an unsubscribe link in an email), or, for non-essential cookies, via Cookie Settings as described in our Cookie Policy.

Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the "How to Contact Us" section above. As we are incorporated in the United Kingdom, our main regulatory authority is the Information Commissioner’s Office ("ICO") and so you can report any issues or concerns to the ICO in respect of compliance with the UK GDPR. Contact details for the ICO can be found on its website at https://ico.org.uk You can also report any issues or concerns to a national supervisory authority in the EU country of your residence or the place of the alleged infringement in respect of compliance with the EU GDPR. You can find a list of contact details for all EU supervisory authorities at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en

Your rights in relation to automated decision-making and profiling

You have the right in some case not to be subject to a decision when it is based solely on automated processing, including profiling, if it produces a legal effect on or similarly significantly affects you, (unless such processing is necessary for the entering into, or the performance of, a contract between you and us, is required or authorized by law, or you have explicitly consented). If an automated decision based solely on automated processing, including profiling has a legal or similarly significant impact on you, you are in some cases entitled to certain rights such as an explanation of the logic behind the decisions and the significance and the envisaged consequences of it for you, and also the right to request human intervention, express your views, and challenge the decision.