Privacy Policy

1. Basics

Your privacy is important to us. It is policy of clickSPA GmbH (in establishing) to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website clickspa.app, and other sites and mobile or web apps we own and operate (in following text, Services).

This policy is effective as of May 17, 2023 and was last updated on March 17, 2024.

2. Consent

By accessing our Services, you accept our Privacy Policy and Terms of Use and consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy. In addition, by using our Services, you accept the policies and practices described in this Privacy Policy. Each time you visit our Services and voluntarily provide us with information, you agree that we may collect, use and share the information you provide and that you consent to receive emails or other information to receive contact as described in this Privacy Policy. Regardless of whether you register with us or create an account, this Privacy Policy applies to all users of the Site and Services.

3. Information We Collect

Information we collect includes both information you knowingly and actively provide us when using or participating in any of our services and promotions, and any information automatically sent by your devices in the course of accessing our products and services.

3.1. Log Data

When you visit our Services, our servers may automatically log the standard data provided by your web browser. It may include your device's Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, other details about your visit, and technical details that occur in conjunction with any errors you may encounter.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

3.2. Personal Information

We may ask for personal information which may include one or more of the following:

Name
Email
Phone number
Postal code
Country
Date of birth
Gender

3.3. Information collected while using the application

While using our Application, we may, with your prior consent, collect the following to provide features of our Application:

Images and other information from your device's camera and photo library
Your location

We use this information to provide features of our Services, to improve and customize our Services. The information may be uploaded to the Company's servers and/or a service provider's server, or simply stored on your device. You can enable or disable access to this information at any time through your device settings.

4. Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

5. Collection and Use of Information

We may collect personal information from you when you do any of the following on our Services:

Use a mobile device or web browser to access our content
Contact us via email, social media, or on any similar technologies
When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

to contact and communicate with you
to enable you to access and use our Services, associated applications, and associated social media platforms
for internal record keeping and administrative purposes
for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use

Please be aware that we may combine information we collect about you with general information or research data we receive from other trusted sources.

6. Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. We will comply with laws applicable to us in respect of any data breach.

You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services.

7. How Long We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. If your personal information is no longer required, we will delete it or make it anonymous by removing all details that identify you.

If you choose to delete your account or specifically request us to do so via email, we will delete all of your personal information from our servers 30 days after that request. This applies to both our private and commercial users.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

8. Children's Privacy

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.

9. Third-party Companies

We use third-party services that may collect information used to identify you.

Third-party privacy policy links used by our Services:

10. Disclosure of Personal Information to Third Parties

We may disclose personal information to:

a parent, subsidiary, or affiliate of our company
third party service providers for the purpose of enabling them to provide their services, for example, IT service providers, data storage, hosting and server providers, advertisers, or analytics platforms
our employees, contractors, and/or related entities
our existing or potential agents or business partners
sponsors or promoters of any competition, sweepstakes, or promotion we run
courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you third parties to collect and process data

11. International Transfers of Personal Information

The personal information we collect is stored and/or processed where we or our partners, affiliates, and third-party providers maintain facilities. Please be aware that the locations to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.

12. Your Rights and Controlling Your Personal Information

You always retain the right to withhold personal information from us, with the understanding that your experience of our Services may be affected. We will not discriminate against you for exercising any of your rights over your personal information. If you do provide us with personal information you understand that we will collect, hold, use and disclose it in accordance with this privacy policy. You retain the right to request details of any personal information we hold about you.

If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person's consent to provide the personal information to us.

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time. We will provide you with the ability to unsubscribe from our email-database or opt out of communications. Please be aware we may need to request specific information from you to help us confirm your identity.

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

13. Use of Cookies

A cookie is a small file that most websites store on your device and is accessed with each visit.

We use cookies to ensure our services run smoothly, to detect fraud and prevent violations of our Terms and Conditions, to understand how you use and interact with our website, to promote and evaluate our products and services, to the extent permitted by law and evaluate and improve our services and your user experience.

There are two types of cookies that can be set:

First-party cookies: These cookies are placed and read by clickSPA itself when you use our services.
Third-party cookies: These cookies are not set by clickSPA, but by other providers, such as Google, for website analysis.

13.1. Can I deactivate cookies?

Yes. You can switch off the setting of cookies via the cookie settings (to open, click on the cookie symbol at the bottom left). This excludes cookies that are necessary to provide our services.

You can also manage your cookie settings in your browser and deactivate clickSPA cookies. However, if you disable cookies in your browser, some features of our website or services may not behave as intended. Check your internet browser's help pages or follow the links below to find out more:

14. Limits of Our Policy

Our Services may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

15. Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

16. Contact Us

For any questions or concerns regarding your privacy, you may contact us here.