Privacy Policy

Spree Technologies, LLC ("Spree," "we," "our," or "us") respects your privacy. This Privacy Policy describes how we collect, use, disclose, share, and otherwise process information when you access or use the Spree mobile application, the website at spree-app.com and related domains, and our other services and features (collectively, the "Services").

By creating an account or using the Services, you acknowledge that you have read and understood this Privacy Policy and consent to our information practices as described. If you do not agree, do not access or use the Services.

1. Who This Policy Applies To

This Privacy Policy applies to users of the Services in the United States and to information we collect through the Services.

The Services are intended exclusively for individuals who are at least twenty-one (21) years of age. We do not knowingly collect personal information from anyone under 21. If we learn that we have collected personal information from an individual under 21, we will delete that information and terminate the associated account. If you believe we have collected information from someone under 21, contact us at [email protected] and we will take appropriate action.

2. Information We Collect

2.1 Information You Provide

When you create an account, make purchases, or otherwise use the Services, you may provide:

• Identifiers and contact information: name, phone number, email address, username, and similar identifiers. We authenticate your account with a one-time passcode sent to your phone number; we do not issue or store a consumer account password;
• Age verification information: date of birth and any documentation we may require to confirm you are at least 21 years old;
• Profile information: profile photo, display name, preferences, and similar information;
• Transaction information: purchases, passes, tickets, redemptions, refunds, and related details;
• Reservation information: details you submit when requesting a table or bottle service at a partner venue, such as requested date and time, party size, arrival window, and any preferences or notes you include;
• Communications: messages and feedback you send to us, including via email or support channels;
• Referral information: information about people you refer to Spree.

2.2 Events and Photography

If you attend an event that Spree hosts, produces, sponsors, or promotes, or a promotional activation operated by Spree or its partners, Spree and its partners may photograph, film, or record the event, and you may appear in those photographs or recordings. We may use that material for promotional, marketing, editorial, and business purposes.

Your rights and our rights with respect to photographs, recordings, and your name, image, likeness, and voice are governed by Section 13 of our Terms of Service, which you accept when you use the Services. If you do not wish to appear, you may notify event staff on site or contact us at [email protected].

2.3 Information Collected Automatically

When you access or use the Services, we and our service providers may automatically collect:

• Device information: device model, operating system, app version, language settings, browser type, unique device identifiers, and mobile network information;
• Usage information: pages, screens, and features viewed; actions taken; venues and events viewed; check-ins; passes redeemed; rewards earned; time, date, and duration of sessions; clickstream and interaction data;
• Location information: your approximate location derived from IP address or city-level signals, and, where you grant permission, precise location from your device's GPS or similar sensors. We use precise location to show you nearby venues on the map and to calculate your distance from a venue. You can grant, limit, or withdraw location permission at any time through your device settings, though map and distance features may not work without it;
• Log and diagnostic data: server logs, crash reports, performance data, IP addresses, access times, and referring URLs;
• Cookies and similar technologies: as described in Section 7.

2.4 Information From Third Parties

We may receive information about you from:

• Partner venues, hosts, and promoters in connection with your transactions, check-ins, or redemptions;
• Payment processors and fraud prevention providers, including transaction status, payment method type (but not full card numbers), and risk signals;
• Analytics and attribution partners, including third-party measurement providers;
• Other users, such as when someone refers you.

2.5 Sensitive Information

We do not intentionally collect government identification numbers, financial account credentials, precise health or medical information, biometric identifiers used for unique identification, or other categories of sensitive personal information beyond what is reasonably necessary to provide the Services (for example, date of birth for age verification, and transactional payment data processed by our payment processor). If you submit any information that includes sensitive content (for example, in a message or a profile photo), you are responsible for that submission.

3. How We Use Information

We use the information we collect for the following purposes:

• Operating the Services, including authenticating users, processing purchases and redemptions, validating QR codes, issuing and tracking SpreePoints and rewards, and providing customer support;
• Personalizing your experience, including surfacing venues, events, and offers we think may interest you, and tailoring content and recommendations;
• Communicating with you, including sending transactional messages, service announcements, security alerts, promotional communications (subject to your preferences), and responses to your inquiries;
• Securing the Services, including detecting, investigating, and preventing fraud, abuse, unauthorized access, account takeover, chargeback fraud, rewards or referral abuse, and violations of our Terms of Service or applicable law;
• Measuring, analyzing, and improving the Services, including conducting research, modeling, A/B testing, and product development;
• Marketing the Services, including measuring the effectiveness of our own marketing campaigns;
• Working with partner venues, hosts, and promoters to coordinate events, promotions, attendance, and analytics;
• Conducting research and analytics on nightlife behavior, trends, and patterns at the venue, neighborhood, city, and market levels;
• Complying with legal obligations, responding to lawful requests from government authorities, and enforcing our agreements and policies;
• Corporate transactions, including diligence, financing, merger, acquisition, sale of assets, bankruptcy, or similar transactions, and related disclosures;
• Any other purpose disclosed to you at the time of collection or with your consent.

4. De-Identified and Aggregated Data

Spree may, at any time, create de-identified, anonymized, or aggregated data from information collected through the Services ("De-Identified Data"). De-Identified Data is data that cannot reasonably be used to identify, relate to, describe, or be linked with a particular consumer or device, either alone or in combination with other reasonably available information.

De-Identified Data is not personal information and is not subject to this Privacy Policy. We retain all right, title, and interest in De-Identified Data and may use it for any lawful purpose, including internal research, analytics, modeling, and product development, and publication or licensing of aggregated trend insights and market intelligence regarding nightlife activity.

Performance reporting we provide to partner venues, hosts, and brand sponsors regarding their venues, events, or sponsorships is provided in aggregated or de-identified form, except for the limited operational identifiers described in Section 5.2 that are necessary to validate a pass or resolve a dispute at the point of service.

Before we publish De-Identified Data externally or license it to a third party, we apply a minimum cohort threshold. We do not publish or license any figure, trend, or insight derived from fewer than twenty (20) distinct individuals within the relevant venue, time period, or other reporting unit. Where a reporting unit falls below that threshold, the underlying figures are suppressed or combined with other units until the threshold is met. This threshold applies to external publication and licensing; it does not apply to our internal research, analytics, and product development, or to the operational reporting described in Section 5.2.

We commit to maintain De-Identified Data in de-identified form, not to attempt to re-identify it, and to require by contract that recipients of De-Identified Data agree to the same.

5. How We Share and Disclose Information

In addition to our use and disclosure of De-Identified Data under Section 4, we may share or disclose personal information as follows:

5.1 Service Providers

We share information with vendors and service providers who perform services on our behalf, including cloud hosting and infrastructure, payment processing, authentication, fraud prevention, customer support, communications, push notifications, email and SMS delivery, analytics, attribution measurement, mapping, identity verification, and similar services. These service providers are authorized to use information only as necessary to provide services to us and are prohibited by contract from using it for their own purposes.

5.2 Partner Venues, Hosts, and Promoters

We share information with partner venues, hosts, and promoters to operate the Services, including: validating your QR code or pass at a venue, processing redemptions, transmitting and coordinating table and bottle service reservation requests, coordinating events and promotions, reporting verified attendance and transaction performance to venues and to brand sponsors of events, and providing analytics regarding their venue or event. Information we share with a venue or partner may include limited identifiers (such as first name or initials), pass details, redemption status, and check-in activity at that venue.

Where you submit a table or bottle service reservation request, we share the information necessary for the venue to evaluate, accept, and honor it. That may include your name, the reservation details you provided, and contact information the venue needs to reach you about the reservation. The venue's use of that information is governed by the venue's own privacy practices, not this Privacy Policy.

5.3 Analytics and Measurement Partners

We may share device identifiers, IP addresses, and information about your activity in the Services with analytics and attribution providers to measure and improve the Services and our own marketing. These providers act as our service providers and are contractually restricted from using the information for their own purposes or for advertising to you on other services.

We do not share personal information with third parties for cross-context behavioral advertising, and we do not use third-party advertising SDKs, pixels, or tags in the Services or on our website. If this changes, we will update this Privacy Policy and provide any legally required notice and opt-out mechanism before doing so, as described in Section 6.

5.4 Mobile Information and SMS Consent

We use your phone number to authenticate your account with one-time passcodes and to send service-related text messages you have consented to receive. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of the text message services necessary to deliver messages to you. Message and data rates may apply. You can opt out of non-essential text messages at any time by replying STOP.

5.5 Corporate Affiliates and Transactions

We may share information with current or future affiliates and subsidiaries for purposes consistent with this Privacy Policy. In the event of a merger, acquisition, financing, sale of assets, reorganization, bankruptcy, or similar transaction, information may be transferred or disclosed as part of that transaction, including during diligence.

5.6 Legal and Safety

We may disclose information if we believe in good faith that disclosure is necessary or appropriate to: (a) comply with applicable law, legal process, subpoena, or governmental request; (b) enforce our Terms of Service or other agreements; (c) detect, prevent, or address fraud, security, or technical issues; (d) protect the rights, property, safety, or well-being of Spree, our users, venues, or the public; or (e) cooperate with law enforcement.

5.7 With Your Consent

We may share information for other purposes with your consent or at your direction.

6. We Do Not Sell Personal Information

We do not sell personal information, and we do not share personal information with third parties for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act (as amended by the California Privacy Rights Act) and similar state privacy laws. We do not knowingly sell or share the personal information of consumers under 16 years of age.

If our practices change in the future, including if we adopt third-party advertising or measurement technologies that constitute a sale or share under applicable law, we will update this Privacy Policy, revise the effective date, provide notice through the Services, and make available any legally required opt-out mechanism, including a "Do Not Sell or Share My Personal Information" link, before engaging in any such sale or sharing.

7. Cookies and Tracking Technologies

The spree-app.com website uses only the cookies and local storage necessary to operate and secure the site. We do not use third-party advertising SDKs, pixels, web beacons, or advertising tags on the website or in the Spree app.

Within the Spree app, we and our service providers use device identifiers and similar technologies to authenticate you, keep your account secure, diagnose errors, and measure product performance.

You can control cookies through your browser settings and reset or limit identifiers through your device's privacy settings. On iOS and Android, you can also limit ad tracking or reset your advertising identifier through your device settings. Disabling certain technologies may affect the functionality of the Services.

7.1 Do Not Track and Opt-Out Preference Signals

Some browsers transmit "Do Not Track" ("DNT") signals. There is no common industry or legal standard for recognizing or honoring DNT signals, and the Services do not currently respond to them.

As described in Section 6, we do not sell personal information or share it for cross-context behavioral advertising. There is therefore no sale or sharing to which an opt-out preference signal, including the Global Privacy Control ("GPC"), would apply, and no such signal changes how we handle your information.

If our practices change as described in Section 6, we will honor opt-out preference signals transmitted to our website by a browser or extension and will make an account-level opt-out mechanism available at that time. You may contact us at [email protected] with any question about how we handle your information.

8. Data Retention

We retain personal information for as long as necessary to provide the Services, comply with our legal, tax, and accounting obligations, resolve disputes, prevent fraud and abuse, defend legal claims, and enforce our agreements. When information is no longer needed for these purposes, we delete it or de-identify it.

Because retention needs vary by data type, we set retention periods using the following criteria:

Where you delete your account, we anonymize or delete your personal information in accordance with the criteria above. We may retain information where necessary to comply with a legal obligation, resolve a pending dispute, complete a transaction, or enforce our agreements.

9. Security

We use commercially reasonable administrative, technical, and physical safeguards designed to protect personal information against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. These safeguards include encrypted connections (TLS), access controls, secure authentication, and regular security review. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. Because we authenticate your account using a one-time passcode sent to your phone number, you are responsible for maintaining control of that phone number and the device that receives it.

10. Your Rights and Choices

Depending on where you live, you may have certain rights regarding your personal information. These may include the right to:

• Know or access the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes for collecting, using, and sharing, and the categories of third parties with whom we share;
• Correct inaccurate personal information;
• Delete personal information we have collected from you, subject to legal exceptions;
• Opt out of the sale or sharing of personal information (as described in Section 6, we do not sell or share personal information);
• Limit the use and disclosure of sensitive personal information to the extent applicable;
• Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects, where applicable;
• Receive a portable copy of certain personal information;
• Withdraw consent where we rely on consent as the legal basis;
• Not be discriminated or retaliated against for exercising your rights.

Deleting your account. You can delete your Spree account at any time directly in the Spree app through your account settings. Deletion is confirmed by a one-time passcode sent to the phone number on the account. Deleting your account forfeits all SpreePoints and unredeemed passes and rewards, as described in the Terms of Service. You may also request deletion by emailing [email protected].

Account deletion is the only right you can exercise directly in the app. To exercise any other right, email [email protected]. We will verify your request consistent with applicable law, which may require us to confirm information already in our possession. You may use an authorized agent to submit a request on your behalf, subject to verification.

If we deny your request, you may appeal our decision by replying to our response with the word "Appeal" in the subject line. We will respond to your appeal in accordance with applicable law.

Notifications and permissions. You can manage push notifications and location permission through your device settings, which the Spree app links to from your account settings. You can opt out of non-essential text messages at any time by replying STOP, as described in Section 5.4.

11. State-Specific Disclosures

11.1 California Residents

If you are a California resident, the CCPA gives you the rights described in Section 10.

Categories of personal information we have collected in the past twelve (12) months correspond to the categories identified in the CCPA: identifiers; customer records information; commercial information; internet or other electronic network activity information; geolocation data (approximate, unless you grant permission for precise location); audio, electronic, visual, or similar information (for example, a profile photo you submit); inferences drawn from any of the above; and, in limited circumstances, sensitive personal information (date of birth for age verification and payment-related information).

The sources of that information, the business and commercial purposes for collecting it, and the categories of third parties to whom we disclose it are described in Sections 2, 3, and 5. The criteria we use to set retention periods for each category are described in Section 8.

We have not sold or shared personal information in the preceding twelve (12) months. We do not use or disclose sensitive personal information for purposes other than those permitted by the CCPA. Our response to opt-out preference signals is described in Section 7.1.

California Civil Code Section 1798.83 ("Shine the Light") permits California residents to request information regarding our disclosure of personal information to third parties for those third parties' direct marketing purposes. To make such a request, email [email protected].

11.2 Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and Other States

If you are a resident of a state with a comprehensive consumer privacy law that gives you rights similar to those described in Section 10, those rights apply to you. You may exercise them as described in Section 10.

11.3 Nevada Residents

Nevada residents may direct us not to sell certain covered information to a third party by emailing [email protected]. As described in Section 6, we do not sell covered information.

12. International Users

The Services are operated from the United States. If you access the Services from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States and other countries where our service providers operate. By using the Services, you consent to this transfer.

13. Third-Party Links and Services

The Services may contain links to third-party websites, apps, or services, including venue websites, social media platforms, and payment processors. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies.

14. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the Services or by other reasonable means. The "Last Updated" date above indicates when this Privacy Policy was last revised. Your continued use of the Services after the effective date of any update constitutes acceptance of the updated Privacy Policy.

15. Contact Us

If you have questions or concerns about this Privacy Policy or our information practices, contact us:

Spree Technologies, LLC
Attn: Privacy
9393 N 90th St, Suite 102 #37
Scottsdale, AZ 85258
[email protected]