Privacy Policy
Spotty Privacy Policy
Spotty helps you save kite spots, evaluate weather conditions, publish anonymous Discover spots, and receive condition alerts. This page explains which personal data Spotty processes, why, on which legal basis, who receives it, how long it is kept, and your rights.
Controller And Contact
The controller responsible for the processing described here under the GDPR is Julius Schroers, Judengasse 8, 52062 Aachen, Germany (see the Impressum). For privacy questions, access requests, deletion help, or other data-rights requests, contact support@spotty.murri.me. Spotty has no data protection officer; none is required.
What Spotty Processes And Why
Each item says what is processed, for what, on which legal basis, and for how long. Art. 6(1)(b) GDPR means the data is needed to provide the app you asked for under its terms. Art. 6(1)(f) GDPR means Spotty's legitimate interest, named in the item; you can object to it (see your right to object).
- Your account. Your email address, your Firebase account identifier, how you sign in (password, Google, or Apple), and whether your email is verified. If you sign in with Google, Firebase also stores the name and the link to the profile picture of your Google account; Spotty does not use them. Spotty asks Apple for no name. To prevent abuse, Firebase Authentication also logs the IP address you sign in from, for a few weeks. Purpose: your account and signing in. Legal basis: Art. 6(1)(b), and Art. 6(1)(f) for the IP log, Spotty's interest in protecting accounts. Kept while your account exists. An email sign-up whose address is not verified within 7 days is deleted automatically.
- Your spots and settings. Spot names, exact coordinates, wind, tide, and forecast settings, and spots you copied. Purpose: saving them and scoring their forecasts. Legal basis: Art. 6(1)(b). Kept until you delete them or your account.
- Location. Only when you allow location access. The app uses your precise location on your device to center the map. Spotty's backend gets only an approximate location, rounded to about 1 km: to sort Discover by distance, and, while your alerts use a distance filter, to choose the spots near you. Legal basis: Art. 6(1)(b); the app reads the location only after you allow it in the operating system. The approximate location for distance-filtered alerts is kept only while your alerts use a distance filter, and at most 7 days after your device last sent it. Turning alerts or the distance filter off, signing out, or deleting your account removes it. Discover does not store the location it sorts by.
- Alerts. A random identifier of this app installation, its push token, time zone, and notification permission, your alert times and score threshold, and when the app was last opened on the device. Purpose: sending condition alerts when you enable them, and keeping them accurate: on a device where Spotty has not been opened for 7 days, alerts are on hold, with one notice a day instead; once it has not been opened for 30 days, they pause, with one last notice. Opening Spotty again brings them back. Legal basis: Art. 6(1)(b). A device where Spotty has not been opened for 180 days is deleted, with its push token. Signing out removes the push token; deleting your account removes everything.
- Usage statistics. The day you last used Spotty: one date for your account, which each day you use the app replaces. From it, the day your account was created, and your time zone, Spotty's backend counts how many accounts use the app and how many come back after a day, a week, and a month. The operator sees these counts only as totals, never per account. Purpose: knowing whether and how Spotty is used, to improve it. Legal basis: Art. 6(1)(f), Spotty's interest in knowing how its app is used. Kept while your account exists.
- App version. The app sends its version and whether it runs on Android or iOS with every request. Spotty's backend uses them to tell an app too old to work that it needs an update, and counts how many accounts use each version on each platform a day, only as totals, never which account; its logs keep the version with a one-way hash of your account identifier, as under Security. Purpose: knowing which versions are still in use, so none is turned away while people use it. Legal basis: Art. 6(1)(f), Spotty's interest in keeping its app working. The daily counts are kept for 400 days.
- Operator dashboard. Spotty's operator looks after the service in a private dashboard at admin.spotty.murri.me, which only the operator can sign in to. It shows totals, such as how many accounts use the app, the published spots, which are public anyway, and private spots only as a count per area of about 110 km, never where one lies or whose it is. One account's data shows there only when the operator acts on it: a reported spot and its report while moderating them, and an account found by the email address the operator types in, to answer a data request or stop misuse: what Spotty holds about it, its export, its deletion, turning its sign-in off, or ending its sessions. An account whose sign-in is turned off for misuse is told why at its email address, as the Terms say. The dashboard logs the operator's sign-ins, and each such step with a one-way hash of the account identifier, never the email address, for a year; a deletion is also announced in the operator's private Discord channel, with that hash. Of a data request it keeps only the day it arrived and when it was answered. Purpose: running Spotty and keeping it safe, and answering your requests. Legal basis: Art. 6(1)(f), Spotty's interest in running and protecting the service; for data requests, Art. 6(1)(c) GDPR with Art. 12 to 22.
- Discover. Spots you publish, your votes and copies, spots and contributors you hide, and reports you file, with their reason and the details you write. Purpose: Discover, and keeping it safe. Legal basis: Art. 6(1)(b) for Discover; Art. 6(1)(f) for moderation, Spotty's interest in a safe Discover and in meeting its duties under the EU Digital Services Act. Published spots stay public until you unpublish them, delete the spot, or delete your account. A report stays as a moderation record, without your account identifier once your account is deleted; the details you wrote are deleted 90 days after the report was resolved. A new report is announced in a private Discord channel with its reason and shortened one-way hashes of the account and spot identifiers, without names, coordinates, or your words. The app shows you what moderation decided on the reports you filed. When moderation takes a spot off Discover, Spotty keeps with the spot the rule of the Community Guidelines it breaks, why, and how moderation came to it, and shows them to the spot's owner in the app, never who reported it; they are deleted when moderation releases the spot, or with the spot. Legal basis for telling the reporter and the owner: Art. 6(1)(c) GDPR with Art. 16 and 17 of the EU Digital Services Act.
- Crash reports. When the app crashes, Firebase Crashlytics receives the crash's stack trace, details of the device such as its model, operating system, free memory and disk space, and whether it is rooted, the app version, installation identifiers, and a one-way hash of your account identifier. Nothing else: no log lines and no reports of errors the app handled. Crash reports are off until you turn them on in the app under Profile, Privacy, Send crash reports. You can turn them off again at any time, which also deletes reports not sent yet. Purpose: finding and fixing crashes. Legal basis: your consent (Art. 6(1)(a) GDPR, and § 25(1) TDDDG for the data the report stores on your device). Firebase starts deleting a crash report 90 days after it arrived.
- Security. Firebase App Check confirms that requests come from the real app (Play Integrity on Android, App Attest on iOS). To stop abuse, the backend counts requests per account and per keyed hash of your IP address, and forgets each count after at most 10 minutes. The backend's own logs record each request with a one-way hash of your account identifier, without your IP address; the operator's dashboard shows these log lines of the last 24 hours, and how many requests each part of the backend answered, as totals. Legal basis: Art. 6(1)(f), Spotty's interest in a secure service that resists misuse.
- Maps. The map loads its map tiles from Mapbox, so Mapbox receives your device's IP address and the area you look at. A spot's screen shows a map image that your device loads from Mapbox with the spot's exact coordinates. The app turns Mapbox's telemetry off, so the map sends Mapbox no usage or location events; the map still reports its use to Mapbox for billing, with an identifier that Mapbox rotates and hashes. Mapbox deletes IP addresses after 30 days. Place searches go to Mapbox through Spotty's backend, without your IP address. Legal basis: Art. 6(1)(b).
- Weather. Spotty's backend gets forecasts from Open-Meteo, Switzerland, for an area of about 1 km around each spot. No personal data reaches Open-Meteo.
- Email to support. When you write to support: your email address, your name if you give it, and your message, in the support mailbox, which Zoho Mail hosts in its data centers in the EU. The operator's dashboard shows only how many mails are unread. Purpose: answering you, handling notices of illegal content and requests to review a moderation decision, and showing how a data request was handled. Legal basis: Art. 6(1)(c) GDPR with Art. 12 to 22 for data requests, and with Art. 16 of the EU Digital Services Act for notices; otherwise Art. 6(1)(f), Spotty's interest in answering questions and in reviewing its decisions. Kept until the end of the third year after the request.
- Backups. Database backups, which contain the data above, are kept for at least 30 days and are deleted by the first new backup after that; the newest backup always stays, so the service can be restored. An encrypted copy of each backup is kept in the operator's Google Drive, in case the server is lost, and is deleted the same way. Each copy is encrypted on Spotty's server before it leaves, with a key Google does not have, so Google cannot read it. Copies of backups that the operator downloads are deleted the same way. If a backup is ever restored, accounts deleted after it was made are deleted again. For this, and to block a deleted account's earlier sign-in, Spotty keeps a deleted account's Firebase identifier and the time of deletion for 60 days. Legal basis: Art. 6(1)(f), Spotty's interest in not losing your data.
This Website
This website sets no cookies and loads nothing from other websites. Its web server logs each request without your IP address, referrer, or browser. The reverse proxy in front of the website and the backend keeps no access log for Spotty's addresses; its error log, which records the IP address and the requested address of a request that failed, starts a new file each week that had errors and keeps the ten files before it. Legal basis: Art. 6(1)(f), Spotty's interest in a secure and working service.
Recipients
Spotty does not sell personal data and does not use it for advertising or tracking. Personal data goes only to these recipients:
- Hetzner Online GmbH, Gunzenhausen, Germany, hosts the backend, its database, and this website on a server in the EU, as Spotty's processor.
- Google (Firebase Authentication, App Check, Cloud Messaging, and Crashlytics) as Spotty's processor, for signing in, app integrity, push notifications, and crash reports. When you sign in with Google, Google learns that you use Spotty, under Google's own privacy policy. Google Drive stores the encrypted copies of the backups, which Google cannot read (see Backups).
- Apple Distribution International Limited, Ireland, for Sign in with Apple, App Attest, and delivering push notifications to iPhones, under Apple's own privacy policy.
- Mapbox, Inc., United States, for maps, map images, and place search: as Spotty's processor, and for some of its own processing, such as billing and security, as a controller under its own privacy policy.
- Zoho Corporation GmbH, Germany, hosts the support mailbox as Spotty's processor, in the EU data centers of Zoho Corporation B.V., Netherlands.
- Discord Inc., United States, hosts the private channels for the moderation alerts and the operator dashboard's alerts described above, which carry no names and only one-way hashes of identifiers.
- Other users see what you publish in Discover, without your name, email, or account identifier.
- Authorities, only when the law requires it: for example, the Bundeskriminalamt when content suggests a threat to someone's life or safety (Art. 18 of the EU Digital Services Act, § 13 DDG).
Every provider that receives personal data from Spotty gives it the same or equal protection as this policy describes. Hetzner, Google, Mapbox, and Zoho are bound by their data processing terms to use it only to provide their service to Spotty. Apple, Discord, and Mapbox for its own processing are bound by their own privacy policies.
Transfers Outside The EU
Google, Mapbox, and Discord process data in the United States; Firebase Authentication, for example, processes it only there. Google LLC, Mapbox, Inc., and Discord Inc. are certified under the EU-U.S. Data Privacy Framework, for which the European Commission decided on July 10, 2023 that it ensures an adequate level of protection (Art. 45 GDPR). Google's and Mapbox's data processing terms add the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR). Apple transfers data from the EU under Standard Contractual Clauses, as its privacy policy says. Zoho keeps the support mailbox in the EU; staff of other Zoho companies, also outside the EU, may reach it for support only, under Standard Contractual Clauses within the Zoho group. You can get a copy of the clauses from support.
Your Rights
Under the GDPR you have the right to:
- access the data Spotty has about you, and get a copy (Art. 15);
- have wrong data corrected (Art. 16);
- have your data deleted (Art. 17): delete your account in the app, or ask support;
- restrict processing (Art. 18);
- receive the data you provided in a machine-readable format (Art. 20);
- object to processing based on Art. 6(1)(f) (Art. 21, below);
- take back your consent or a permission at any time, without affecting what happened before: crash reports in the app, location and notifications in your device's settings (Art. 7(3));
- lodge a complaint with a data protection authority (Art. 77), in particular where you live or work. The authority for Spotty is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Kavalleriestraße 2-4, 40213 Düsseldorf, Germany, www.ldi.nrw.de.
To use a right, write to support@spotty.murri.me. You need an email address, or a Google or Apple account, to create an account; everything else is optional, and without it only the feature that needs it is unavailable. Spotty makes no automated decisions about you that have legal or similarly significant effects.
Your Right To Object
You have the right to object at any time, on grounds relating to your particular situation, to processing of your data based on Art. 6(1)(f) GDPR (Art. 21 GDPR). Spotty then stops that processing, unless it shows compelling legitimate grounds that override your interests, rights, and freedoms, or it needs the data to establish, exercise, or defend legal claims. To object, write to support@spotty.murri.me.
Account Deletion
You can delete your account in the app under Profile, Danger Zone, Delete account. Deletion removes account data, Firebase Auth sign-in access, saved spots, settings, notification preferences, FCM token, and user-linked private data from active backend tables. On the phone, the app then deletes what it kept about your account, and removes Spotty's access to your Google account if you signed in with Google. If you cannot access the app, use the public deletion page or email support.
Children
Spotty is not directed to children. You must be at least 16 years old to use Spotty, as the Terms say; if you are under 18, you need the permission of a parent or guardian.
Policy Updates
Spotty may update this policy when the app, providers, or legal requirements change. Material changes will be reflected by updating the date on this page.
Contact
For privacy questions or deletion help, contact support@spotty.murri.me.