Privacy Policy

How Spotka collects, uses, and protects your personal data.

Revision published: October 29, 2026  ·  Existing accounts: not before November 12, 2026

29 October 2026 revision. This notice applies to accounts created on or after 29 October 2026. It explains processing; it is not a request for consent to unrelated processing. For existing accounts, it takes effect no earlier than 12 November 2026 and only after the required 14-day notice period has been provided. The previous version continues to apply to those accounts until that notice period ends. Required notice, consent and mandatory legal rights are preserved; the revision does not retroactively extend retention of data collected under an earlier notice.

This policy covers the Spotka app and web app: onboarding, your profile, Agentic Gatherings, messaging, and the AI features that support them. It does not cover the separate Sponic Gardens physical venue; see sponicgardens.com/docs/privacy for that.

1. Who we are (data controller)

Spotka is operated by Sponic Gardens sp. z o.o., a company registered in Poland. Registered office: al. „Solidarności" 68/121, 00-240 Warsaw, KRS 0001248017, NIP 5253094235, REGON 545044515. We are the data controller for the personal data described in this policy.

Questions about this policy, or to exercise your rights: [email protected].

2. Data we collect

Information you provide directly

Data collected through your use of the app

Data from third parties

Finding friends via your contacts

Spotka members can optionally use their phone's contacts to find friends who are already members, or invite the ones who aren't. This is always something the member chooses to do. We never read anyone's contacts automatically.

3. How we use your data

PurposeData usedLegal basis
Providing and operating the appAccount, profile, gathering dataContract
Onboarding and AI features you requestProfile answers and inputs you submit to the selected featureContract: processing needed to provide the onboarding or AI feature you request
Background personalisation of suggestionsProfile, preferences and relevant app activityLegitimate interests: making suggestions relevant to members; you may object under section 7
Suggesting nearby gatherings and membersLocation (only if enabled)Consent
Processing gathering paymentsBilling data (via payment processor)Contract
Sending service and gathering notificationsEmail, push tokenContract
Helping members find friends who are already membersContact email hashes used for matchingLegitimate interest
Safety and abuse preventionAccount, message metadata, device dataLegitimate interest
Evaluating and improving service qualityAI interaction and usage dataLegitimate interest
Legal complianceAs requiredLegal obligation

Personal data is processed for the purposes and on the legal bases described above. Using an AI feature involves sending relevant inputs to service providers; it does not itself constitute consent to unrelated processing.

4. AI and automated decision-making

AI features use information you provide and relevant activity to generate responses and personalised suggestions. Recommendations may be inaccurate. Where the GDPR gives you rights concerning a solely automated decision with legal or similarly significant effects, you can exercise those rights, including requesting human intervention, through the contact address in this policy.

Ask Fern on spotka.co

Ask Fern on spotka.co. When you send a question, we send its text and the conversation context to OpenRouter and one of Together AI, Fireworks AI, DeepInfra or Baseten running the GLM model made by Z.ai, so it can write an answer. If that service cannot answer, we send the request to Google, which runs Gemini. The GLM route is restricted to providers offering zero data retention and refusing data collection. We keep the question and answer to help our team improve the answers, without linking them to a Spotka account. They expire after 90 days and are deleted by the next daily cleanup. These services may process the request outside the European Economic Area, including in the United States. Please do not share personal details in this chat.

5. How we share your data

We share personal data only in the following circumstances:

6. Data retention

We retain personal data only for as long as necessary for its purpose, taking account of the service you use, legal obligations and relevant claims. The following criteria determine the period:

You may request erasure or further information using the contact address in this policy. Erasure is subject to the exceptions in applicable data protection law; it does not necessarily remove legally required records or information held by independent controllers.

7. Your rights

Depending on your location, you may have the right to: access the data we hold about you, correct it, request deletion (subject to our retention obligations), receive it in a portable format, object to processing based on legitimate interests, restrict processing, withdraw consent at any time, and exercise applicable rights concerning solely automated decisions with legal or similarly significant effects.

To exercise any of these rights, email [email protected]. We respond without undue delay and within one month of receiving a request, as required by the GDPR. For complex or numerous requests, the GDPR permits an extension of up to two further months; we will explain any extension within the first month. We may ask for information needed to verify your identity. You may also complain to a competent supervisory authority, in particular in the EU/EEA member state of your habitual residence, workplace or the alleged infringement. In Poland, this is the President of the Personal Data Protection Office (UODO), uodo.gov.pl.

8. Cookies, analytics and tracking

The Spotka web app uses cookies for essential session management and authentication. These cannot be disabled without breaking sign-in.

For optional browser and app analytics and session recordings we ask for consent. Cookie-free counts and server-side events are described separately below. On spotka.co, in the web app and in the Android and iOS apps you can choose Accept or Decline. We use PostHog (hosted in the EU) for analytics and Sentry for error reports.

Before you answer

If you accept

If you decline, or your browser sends Do Not Track or Global Privacy Control

Your browser sends us no analytics at all: no PostHog, no page-load counter, no session recordings and no Meta. The only exception is a single anonymous note, without cookies, that you pressed Decline on a spotka.co page. We treat Do Not Track and Global Privacy Control as a Decline.

Events recorded by our servers

When you use your account, our servers record some of your actions as events tied to your account ID, for example creating an account, finishing onboarding, joining a gathering or sending a message. We use them to run the service, to check that it works and to improve it (legitimate interest). They are not read from your device, so declining analytics in your browser or app does not stop them. You can object to them at [email protected].

Emails

We do not track whether you open our update and marketing emails, and we do not track clicks on their links. We keep delivery records (sent, delivered, bounced) so we stop mailing addresses that fail.

Advertising measurement and Meta

If, and only if, you accept advertising cookies on our marketing pages, we measure Meta ad performance via the Meta Pixel (page views, sign-ups) and the Meta Conversions API (a SHA-256 hash of your email sent server-side on sign-up so Meta can match the event; the hash remains personal data). Declining does not stop you signing up. Meta acts as an independent controller for data it receives.

Changing your mind

Withdrawing consent is as easy as giving it: clear this site's cookies and choose Decline (in the apps, reinstall the app and choose Decline), or email [email protected].

9. Data security

We apply technical and organisational measures appropriate to the risks of processing, as required by data protection law. No system can guarantee absolute security. Contact us if you suspect a security incident. We notify supervisory authorities and affected individuals where required by law.

10. International transfers

Sponic Gardens sp. z o.o. is established in Poland (EU). Some service providers process data outside the EEA, in particular in the United States. Where this happens we rely on appropriate safeguards: the EU Standard Contractual Clauses and, where applicable, the EU-US Data Privacy Framework.

11. Children's privacy

Spotka is not directed to children under 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a child, contact us so we can assess the situation and take the action required by law.

12. Changes to this policy

We may update this policy. The last-updated date identifies the latest revision. Where required by applicable law, we will inform you of changes and obtain consent before processing data for a new purpose.

13. Contact and complaints

Sponic Gardens sp. z o.o.
al. „Solidarności" 68/121, 00-240 Warsaw, Poland
[email protected]  ·  spotka.co

If you are not satisfied with our response, you have the right to complain to a competent supervisory authority, in particular in the EU/EEA member state of your habitual residence, workplace or the alleged infringement. In Poland, this is the President of the Personal Data Protection Office (UODO), uodo.gov.pl.