Spraffl Privacy


Spraffl limited (“Spraffl”, “we”, “us”) owns and operates the website at www.spraffl.com and applications downloaded from our website or from the Apple App Store, or from any other application market directly under our name. The term “services” throughout this document collectively refers to goods or services provided by each of these entities, accessed through any of the above mentioned media.

Any information uploaded, downloaded or appearing on our services, including data, text, graphics, video, messages or other materials is collectively defined as “content”.

We are committed to protecting and respecting your privacy.

This policy (together with our Spraffl Terms of Use & Service and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the Act), or any equivalent locals laws or regulations, the data controller is Spraffl limited of 111 George street, Edinburgh, EH2 4JN.

By using the Services, you consent to the use of your Personal Information as described in, and for the purposes set out in this Privacy Policy. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. We will not actively collect Personal Information for the purpose of sale or marketing in a way that specifically identifies you. In other words, we don’t sell customer lists. You may withdraw your consent to our processing of your Personal Information at any time.  However, withdrawing consent may result in your inability to continue using some or all of the Spraffl services.


We require some personal details from you during signup.  We need these to ensure you get the most out of Spraffl, to protect you and to comply with our legal obligations. These details are for security and admin purposes only.

None of the personal details we collect and link to your account will be shown to other Spraffl users. Spraffl lets post anonymously from a specific location.  So unless you Spraff personal details, or others Spraff about you, then none of your personal details will show on your post (except the location of your Spraff)

You are completely responsible for the content you post on Spraffl.  By using the services, you agree not to post any content which is illegal, defamatory, in breach of any law or regulation, or infringes a third parties rights.  We are giving you a voice at Spraffl; so if you abuse it and cause us to get into trouble, you agree to indemnify us for any losses, fines other claims we suffer as a result of your breach.

It would go against the ethos of Spraffl, but we reserve the right to(and by using te services you consent to) us disclosing any personal information we have gathered about you and your use of the services to any police or regulatory authority to which we are obliged to comply.

In more detail…


We collect and use Personal data (defined below) to communicate with you as part of the Spraffl experience, to personalise your experience, and to allow you to use the Services as a whole. More specifically, we aim to collect, use and disclose only such information as is required to enable us to manage your account, to provide the Services, to maintain our customer/visitor lists, to respond to your enquiries or provide feedback, for identification and authentication purposes, for service improvement, to target advertisements, and to address issues like malicious use of the Services. We will maintain the confidentiality of any contact information you provide to us on registering with the Website or the Spraffl App and will use it only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed below), unless you agree that we may disclose it to other third parties.

Two types of information may be collected through the Services: Personal Information and Non-Personal Information. This Privacy Policy does not extend to the collection, use or disclosure of the following information which is currently not limited by applicable privacy laws: (a) information that is publicly available or (b) Non-Personal Information (as defined further below).

Personal Information…

Personal data is information by which an individual can be indemnified.  This could include your name, email address, phone number date of birth location (from time to time) and gender.  At the time we collect this information, we will clearly identify the purposes for which we are collecting it, and the purposes for which it will be used.  You have the choice wether or not to give us the information we ask for but please be aware that certain information is required to setup an account and access our services. Unless you disclose it, you won’t be able to use our services.  And they are pretty good.

We may collect personal information when you sign up for our services or when you enter certain information into your account settings.  Furthermore, we may also collect information from third party services you specifically grant us access to as part of your Spraffl experience.  These services may include but are not limited to social services like Facebook, Foursquare, twitter and Pinterest.  Information collected from these third party services may include your name, email address and phone number but may also include your friends names, email addresses and phone numbers. Our access to third party services mentioned above can be revoked by you at any time.

When you register with us, we may have access to listings of your friends, including their names, email addresses, locations and phone numbers either through your address book or from the third party services you have signed up through. We may use that information to allow you to invite your friends to Spraffl and we may choose to highlight to you content posted by your friends (though no personal details will be exposed). For example friend’s Spraff content may be highlighted in a different colour to those of non-connected Spraffl users.

We will not market to or contact your friends without your consent unless they are also users of the Spraffl Service in which case they will have agreed to our privacy policy and user terms.

If you contact us, we may keep a record of that correspondence.

If enabled, we may use SMS to verify your phone number.

In order to give you the best user experience, and to comply with our legal and regulatory obligations, we may also collect information about your computer, including where available your IP address, operating system and browser type. This also helps us with system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and is anonymised so does not on its own identify any individual.


Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By using our services, you allow us to download cookies onto your device.


The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We would only do so for the purposes of giving you a great Spraffl service, or to comply with our legal obligations. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We will always process, store and transfer your personal data in accordance with UK data laws.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.


We use information held about you in the following ways:

  • To set you up as Spraffl user, and to verify your identity
  • To ensure that content from our services is presented in the most effective manner for you and for your computer device.
  • To provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes.
  • To allow you to participate in interactive features of our service, when you choose to do so.
  • To notify you about changes to our service.
  • To comply with our legal and regulatory obligations.

We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, people who frequent bars in Edinburgh). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.


We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Spraffl ltd. or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use (refer to our Terms of Use page) and other agreements; or to protect the rights, property, or safety of Spraffl ltd. our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.


Our site may, from time to time, contain links to and from the websites of other networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.


Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.


Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@spraffl.com.