Privacy Policy

Last update: February 28th, 2022
Table of contents
​Effective Date: February 28th, 2022

This Privacy Notice (“Notice“) applies to all websites (including, platforms, mobile applications and other products and services (collectively, “Services“), that are owned and operated by Spooler Media, Inc, a company incorporated in Delaware, USA, with company number 6208006 (“Spooler“, “we“, “us“, “our“). Spooler is the data controller of personal data that is processed in connection with your use of the Services and we can be contacted by email at [email protected] [or by using the “Contact us” link on our website].

This Notice explains how we collect, use, maintain and disclose information collected about you, including when you visit or use our Services or otherwise interact with us. Your privacy is important to us, and we recognize the importance of protecting information collected about you.


We may change this Notice from time to time. If we make any changes, we will notify you by revising the “Effective Date” at the top of this Notice. In some cases, we may provide you with additional notices (such as adding a statement to our Services, or by sending you an email notification). We encourage you to review this Notice whenever you access our Services to stay informed about our information practices and the ways you can help protect your privacy. Your continued use of our Services after any change to this Notice will constitute your acknowledgement of such change.


When you use or access our Services or otherwise interact with us, we may collect a variety of information about you and others, as described below. Such information includes, but is not limited to, information about you which is in a form that permits us to identify you (your “personal data“).

Information you provide to us. We collect information that you provide to us, or that someone on your behalf provides to us. For example, when you inquire about our Services, request our marketing materials, create a user account on our Services, access and use our Services, or communicate with us by phone, email, via third-party social media sites or otherwise. The types of information we collect may include:

  • Contact data, such as your full name, username or similar identifier, postal address, email address, telephone numbers, social media accounts, etc.
  • Information about you, such as your age and date of birth, location, language spoken, interests in using the Services, content preferences, etc.
  • Credentials, such as passwords, password hints or similar security information used for authentication and account access, etc.
  • Marketing data, such as your preferences in receiving marketing from us, etc.

We do not anticipate routinely processing ‘special category personal data’. Special category personal data includes data concerning your health, data revealing your racial or ethnic origin, data relating to your religious or philosophical beliefs, and data concerning your sex life or sexual orientation.

Information we collect automatically. When you use or access our Services, we may also collect certain information through automated means, including but not limited to some or all of the following:

  • Device data, such as your mobile phone number, unique device ID, device type, brand and model, the version of the application you are using and the operating system you are using the application on, machine ID, geolocation information, computer and connection information, browser type, Internet Protocol (“IP“) address (a number that is automatically assigned to your computer or device when you use the Internet, which may vary from session to session), domain name, and date and time stamps for your visits.
  • Log data, including information associated with your activities on our Services, information about the way you interact with our Services, the frequency of interactions and when you open notifications, number of sessions and session duration, when you use our Services, statistics regarding your use of and traffic to and from our Services, and the number of bytes transferred, hyperlinks clicked, and other actions you take. We may also track information such as the URL that you visited before you come to our Services and the URL to which you next go.
  • Account data, including any in-app purchases that you may make, and promotions that you have engaged with.

Cookies and similar tracking technologies. As with most websites and other digital services, we employ cookies, pixel tags, web beacons, and similar technologies to collect and store certain information about visitors to our Services. We use this information to improve our Services, and to help us remember you and your preferences when you next visit our Services. For more information about our practices in this area, please see our Cookie Notice.


We process your personal data for the purposes set out in this Notice only where we have a valid legal basis for doing so under applicable data protection law. The precise legal basis will depend on the specific purpose for which we process your personal data. We have set out the most common processing purposes, and our legal bases for these, below:

Where processing is necessary for the performance our contract with you under the applicable terms and conditions for the relevant Service, or to answer questions or take steps at your request prior to entering those terms, including:

  • to create and maintain your user account, to keep a record of any purchase you have made, and to manage registration with any promotions;
  • to provide, operate and maintain the Services;
  • to manage use of the Services, respond to enquiries and comments and provide customer service and support;
  • to process and complete transactions, and send related information, including transaction confirmations and invoices;
  • to send technical alerts, updates, security notifications, and administrative communications; and
  • to respond to requests or inquiries.

Where processing is necessary for certain legitimate interests, of us or another third party, provided such interests are not overridden by your fundamental rights or freedoms, including:

  • to deal with any enquiries or complaints you or others make, to troubleshoot and diagnose problems, repair issues and provide other customer care and support services;
  • to confirm, update and improve our records, and to analyse and develop our relationship with you;
  • to personalize the Services that you engage with (e.g., by recommending audio content based on your use of the Services);
  • for internal administrative and technical operations to keep our Services, network and information systems updated, patched and secure;
  • to continually improve our Services, including adding new features or capabilities, and to develop new products and services;
  • to investigate and prevent fraudulent activities, unauthorized access to our Services, and other illegal activities; and
  • to respond to requests from competent authorities and to protect our interests, rights, safety or property, and/or that of our partners, you or others.

Where we have your consent to process personal data. Such consent can be withdrawn at any time, although this will not affect the legality of processing that has previously been carried out in reliance on this consent. For example:

  • When you sign up to our marketing list;
  • Where you freely decide to provide us with additional information, for example when corresponding with us via email; or
  • Where you elect to provide us with special category personal data, then your provision of such data constitutes your consent for us to process it in accordance with this Notice. This consent can be withdrawn at any time.

In some limited circumstances, we may also process your personal data where it is necessary to comply with legal obligations to which we are subject and/or where it is necessary for the exercise, establishment, or defence of legal claims.


Spooler is not intended to be attractive for use by individuals who are under the age of 13. This age limit may be higher in certain jurisdictions where required by local laws. We do not knowingly collect personal data from children under the age of 13. If you are under the age of 13, please don’t provide us with any personal data. If you become aware that we have processed the personal data of a child under the age of 13, please notify us immediately so that we may take steps to delete the personal data.


Access to your data is restricted to certain technical and administrative individuals within Spooler who need to process your data as part of providing our Services to you. However, there are circumstances where we may wish to share or are compelled to share your personal data with third parties. This will only take place in accordance with the applicable law. We may share or disclose your personal data to the following third parties:

  • Trusted third-party service providers who perform services on our behalf in connection with our Services. The services provided by such third parties include the following categories: processing payments on our behalf, sending marketing communications on our behalf, helping us to create or maintain our applications and databases, helping us to research or analyse visitors to our Services and maintaining the security of our Services, backend support services and data analysis and visualization support services.
  • Another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, restructure, reorganisation, change of legal form, dissolution or similar event.
  • A successor organisation or other legal entity, in the case of a merger, financing, acquisition or dissolution, transition, or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.
  • Public authorities and other third parties, to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce other agreements you may have with Spooler, or to protect our rights, property or safety or the rights, property or safety of our users or others (e.g., to a reporting agency for fraud protection). We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.
  • Our professional advisors, such as our auditors, accountants, and lawyers.
  • Any other third party where you have provided your consent.

We may also share aggregated or anonymous information that cannot identify you with third parties. For example, we may disclose general statistics regarding the users of our Services. The receiving third parties will not be able to identify you from such data.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.


We will store your personal data for no longer than is necessary for the purpose for which such personal data is processed.

Please note, however, that we may retain and use your personal data as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements and rights, or if it is not technically and reasonably feasible to remove such information from our databases, which means that we may retain and use your personal data as necessary after you stop using our Services.


We ensure the security of any personal data we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information in compliance with standards required by data protection laws.

Your personal data is generally collected directly from you for processing and storage in the USA. We may transfer personal data to third parties also located in the USA, or other jurisdictions that have not been deemed to offer an adequate level of protection of personal data in accordance with applicable data protection laws. We will ensure such transfers are protected by an appropriate safeguard. This may include the Standard Contractual Clauses approved by the EU Commission and/or the UK Government. For details of these, and copies where appropriate, please contact us using the details at the top of this Notice.


You are not obliged to provide us with any personal data. You can always opt not to disclose information to us, but keep in mind some information may be needed to create a user account or to take advantage of some of our Service features. Other information about you may be collected automatically in connection with your use of our Services.

Marketing communications

We only send you direct marketing communications where you have given us your express consent to do so, or where you have signed up for our Services and have not opted out of marketing at that time. Any email marketing messages we send are done so through an email marketing service provider (“EMS”). An EMS is a third party service provider of software or applications that allows marketers to send out email marketing campaigns to a list of users.

Any email marketing messages we send are in accordance with applicable data protection and privacy legislation. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences, and the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences.


In certain circumstances you have rights under data protection laws in relation to your personal data that we hold about you—specifically:

  • The right to be informed. You have the right to be informed about how your data is collected and used (which is the purpose of this Notice).
  • The right of access. You may have the right to request access to any personal data we hold about you as well as related information, including our purposes for processing the personal data, the recipients or categories of recipients with whom the personal data has been shared, where possible, the period for which the personal data will be stored, the source of the personal data, and the existence of any automated decision making.
  • The right of rectification. You may have the right to obtain without undue delay the rectification (or correction) of any inaccurate personal data we hold about you.
  • The right of erasure. You may have the right to request that personal data held about you be deleted.
  • The right of restriction of processing. You may have the right to prevent or restrict processing of your personal data.
  • The right of data portability. You may have the right to request transfer of your personal data directly to a third party where this is technically feasible.

You have the right to make a complaint at any time to the supervisory authority for data protection issues in the jurisdiction in which you are located (e.g., the Information Commissioner’s Office in the UK). We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority so please contact us in the first instance.


Our Services may contain links to other websites that are not covered by this Notice and where information practices may be different from ours. Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave our Services and go to another website. During this process, another entity may collect information from you. We have no control over, do not review, and are not responsible for the privacy practices or the content of such other websites. Please be aware that the terms of this Notice do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.