PRIVACY POLICY

Introduction

We are on a mission to help you focus more on your mental health - to use meditation to build strength, resilience and calm. This care extends to the way we handle your data.

We have never and will never sell or trade any personal details of any sort with any other company and consider the loyalty and on-going support of our community to be the main driver to our success. All data stored is only ever used to improve the product and for directly communicating with you as agreed.

This Privacy Policy applies to all forms of communication including sign-ups to the waiting list, in-app data and responses to any feedback or surveys. It provides detailed information on when and why we collect your personal information, how we use it, how we keep it secure and the extremely limited conditions under which we may disclose it to others (when forced to by law).

Spoke is owned by Spoke World Ltd registered office Stanley Villa, 1a Kenmure Road, London, E8 1JU. Our data controller can be emailed at hello@spoke.world.

Personal data we collect

When you sign up to any form, provide survey results, feedback, contact our support team or create an account within the app you are passing us some personal data, for example your email address, gender, age and name.

When you sign up for the app you are also agreeing to share usage data that allows us to improve the product by understanding how our users are interacting with eth content.

We do not store any payment information at all. This is collected, stored and processed by Apple for iOS apps and Google for Google Play apps. Each of these companies have their own separate data and privacy policies.

If at any stage you share personal information about other people, you agree that you have notified any such people whose personal data you are providing and, where necessary, have obtained their consent so that we can lawfully process their personal data in accordance with this policy.

All personal data that you provide to us must be true, complete and accurate. If you provide us with inaccurate or false data, and we suspect or identify fraud, we will record this.

During the Pioneer Testing phase of the product, we may also – with your explicit consent- record video or audio phone calls further analysis and to help us build the best product possible. We will always let you know before any recording is made to allow you to opt-out.

Apple handles all billing for in-app purchases made on iOS devices. Google handles all billing for in-app purchases made on Google Play devices. (Together the “Vendors” or “Vendor”).

The Vendors handle all personal information related to your Vendor platform account and credit card. None of this information is ever passed to SPOKE. Refunds and other issues related to payments must therefore be sent directly to the Vendor.

Data we automatically collect

When you visit the SPOKE website, use the SPOKE app or complete any survey or feedback questionnaire, we, or third parties on our behalf, may automatically collect and store information about your device and your usage activities. This information could include (a) your computer or other device's unique ID number; (b) technical information about your device such as type of device, web browser or operating system; (c) your preferences and settings such as time zone and language; and (d) statistical data about your browsing actions and patterns.

This information would only ever be for analytical and research purposes and is collected on an anonymous basis to help us improve our website experience.

Any data that is collected in this way is collected in accordance with the Cookie section of this policy (below).

Marketing Communications

When you opt-in to receive marketing communications from us you consent to the processing of your data to send you such communications, which may include content or feature release news, marketing offers and newsletters. We retain a record of your consent.

You can choose to no longer receive marketing communications by contacting us at hello@spoke.world or clicking unsubscribe from any marketing email. If you do unsubscribe to marketing communications, it may take up to 5 business days for your new preferences to take effect.

We will retain your personal data in our records for so long as we believe it is of value to you or until you notify us that you no longer wish to receive marketing emails from us.

Lawful processing of your personal data

We will use your personal data in order to deliver you a personalised app experience, to improve the overall app and Spoke experience and -where you have opted in- to send you communications as outlined in this document.

We may also use your personal data for other legitimate needs, including dealing with any customer service concerns, enforcing the terms of any other agreement between us, for regulatory and legal purposes (for example anti-money laundering), for audit purposes and to contact you about changes to this policy.

Who do we share your data with?

Any data submitted to us via the website, app or socials are never shared with anyone outside of Spoke. Support emails or contact made with our customer services team are only used in-house and are never shared with anyone else.

Under certain circumstances we may have to disclose some personal data under applicable laws and/or regulations, for example, as part of anti-money laundering processes or protect a third party's rights, property, or safety.

On occasion, we may share your personal data with service providers, sub-contractors and agents that we directly appoint to perform specific functions on our behalf and in accordance with our instructions, for example accountants, auditors or lawyers.

We may also share your personal data in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

Where we hold and process your personal data

Some or all of your personal data may be stored or transferred outside of the UK and European Union (the EU) for any reason, including for example, if our email server is located in a country outside the EU or if any of our service providers or their servers are based outside of the EU. We shall only transfer your personal data to organisations that have provided adequate safeguards in respect of your personal data.

Cookies

A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a website to the hard drive of your computer. The cookie identifies your browser but will not let a website know any personal data about you, such as your name and/or address. These files are then used by websites to identify when users revisit that website.

Spoke’s website and customer surveys may use cookies to remember who you are and tailor the experience for you, recognising when you return and personalising your settings and preferences.

Most browsers are initially set up to accept cookies. You can change your browser settings either to notify you when you have received a cookie, or to refuse to accept cookies. Please note that our websites may not operate efficiently if you refuse to accept cookies.

We also use Google Analytics to monitor how the app is being used. Google Analytics collects information anonymously and generates reports detailing information such as the number of listens to a session, which features are most used and how long users stayed in app.

Security

We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. All information you provide to us is stored on our secure servers. Any payment transactions are encrypted using SSL technology (and are handled by our payment-partner Stripe).

Where we have given, or you have chosen a password, you are responsible for keeping this password confidential.

However, you acknowledge that no system can be completely secure. Therefore, although we take these steps to secure your personal data, we do not promise that your personal data will always remain completely secure.

Your rights

You have the right to obtain from us a copy of the personal data that we hold for you, and to require us to correct errors in the personal data if it is inaccurate or incomplete. You also have the right at any time to require that we delete your personal data. To exercise these rights, or any other rights you may have under applicable laws, please contact us at hello@spoke.world.

Please note, we reserve the right to charge an administrative fee if your request is manifestly unfounded or excessive.

If you have any complaints in relation to this policy or otherwise in relation to our processing of your personal data, you should contact the UK supervisory authority: the Information Commissioner, see www.ico.org.uk.

Our website, socials and app may contain links to outside third parties. Once you have used these links to leave our domain, you should note that we do not have any control over that other site. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites and such sites are not governed by this policy. You should exercise caution and look at the privacy policy applicable to the site in question.

Retention

If you receive marketing communications from us, we shall retain your personal data until you opt-out of receiving such communications.

If you create an account and sign-up to the app, we shall retain your personal data until you delete your account.

If you have contacted our team including customer services with any question or comment, we shall retain this personal information to allow us to respond to any further queries you might have unless requested to delete it.

General

If any provision of this policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.

This policy shall be governed by and construed in accordance with the law of England and Wales, and you agree to submit to the exclusive jurisdiction of the English Courts.

We may change the terms of this policy from time to time. You are responsible for regularly reviewing this policy so that you are aware of any changes to it. If you continue to use any Spoke service at the time of the update, you will have accepted the changes.