Cookie Policy

SPRUCEUP COOKIE POLICY

1. Introduction

This Cookie Policy explains how Total Veracity Limited trading as SpruceUp (“SpruceUp”, “we”, “us”, “our”) uses cookies and similar technologies when you access or use the SpruceUp website, mobile application, dashboards, and related services (the “Platform”).

SpruceUp complies with:

• Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”)
• The Irish Data Protection Act 2018
• The ePrivacy Directive
• Guidance issued by the Irish Data Protection Commission

This Policy should be read together with our Privacy Policy.

2. What Are Cookies and Similar Technologies

Cookies are small text files placed on your device when you visit a website. They enable websites to recognise your device and store certain information.

We may also use similar technologies, including:

• Local storage
• Web beacons
• Pixels
• Software development kits in mobile applications
• Server side tracking mechanisms

Cookies may be:

• Session cookies, deleted when you close your browser
• Persistent cookies, stored for a defined period or until manually deleted

3. Legal Basis for Using Cookies

Under GDPR and ePrivacy rules:

• Strictly necessary cookies do not require consent
• All other cookies require prior, informed, freely given consent

SpruceUp relies on:

• Contract necessity and legitimate interests for strictly necessary cookies
• Consent for analytics, functional, and marketing cookies

You may withdraw consent at any time.

4. Categories of Cookies We Use

4.1 Strictly Necessary Cookies

These cookies are essential for the operation and security of the Platform and cannot be disabled.

They are used to:

• Enable secure login and account authentication
• Maintain session integrity
• Enable booking functionality
• Facilitate payment processing
• Prevent fraud and abuse
• Store cookie preferences
• Protect system security

Without these cookies, the Platform cannot function correctly.

Legal basis: Contract necessity and legitimate interests.

Retention: Session or up to 12 months depending on function.

4.2 Analytics and Performance Cookies

These cookies help us understand how Users interact with the Platform so we can improve performance and usability.

They may collect:

• Pages visited
• Time spent on pages
• Navigation paths
• Device type and browser type
• Error and performance data
• Traffic source information

We may use analytics providers such as:

• Google Analytics
• Hosting provider analytics
• Fraud monitoring tools

Analytics cookies are only placed after you provide consent.

Legal basis: Consent.

Typical retention: Up to 24 months.

4.3 Functional Cookies

These cookies enable enhanced functionality and personalisation.

They may store:

• Language preferences
• Region settings
• Dashboard display preferences
• Non essential user settings

Legal basis: Consent.

Typical retention: Up to 12 months.

4.4 Marketing and Advertising Cookies

Where used, these cookies may:

• Deliver relevant advertising
• Measure marketing effectiveness
• Prevent repetitive advertising

SpruceUp does not deploy marketing cookies without explicit prior consent.

Legal basis: Consent.

Retention varies depending on provider.

5. Third Party Cookies

Certain cookies may be placed by third party service providers that support SpruceUp operations, including:

• Payment processors
• Identity verification providers
• Analytics providers
• Cloud hosting providers
• Email communication providers

These providers may act as independent data controllers or data processors. SpruceUp requires third party providers to implement appropriate safeguards under GDPR. You should review their respective privacy and cookie policies for further details.

6. Consent Management

When you first visit the Platform, you will be presented with a cookie banner allowing you to:

• Accept all cookies
• Reject non essential cookies
• Customise cookie preferences

Non essential cookies are blocked until valid consent is provided.

SpruceUp maintains a record of consent decisions, including:

• Date and time of consent
• Categories accepted or rejected
• Anonymous identifier

Consent records are retained for compliance and audit purposes. You may change or withdraw consent at any time via the “Cookie Settings” link available on the Platform.

7. Managing Cookies Through Your Browser

You may control cookies through your browser settings by:

• Blocking cookies
• Deleting stored cookies
• Restricting third party cookies

Please note that disabling strictly necessary cookies may impair Platform functionality.

8. International Data Transfers

Some third party providers may process data outside the European Economic Area.

Where personal data is transferred outside the EEA, SpruceUp ensures appropriate safeguards are in place, including:

• Standard contractual clauses approved by the European Commission
• Adequacy decisions
• Additional contractual and technical safeguards where required

9. Data Retention

Cookie retention periods vary depending on type:

• Session cookies: deleted when browser closes
• Strictly necessary persistent cookies: up to 12 months
• Analytics cookies: up to 24 months
• Marketing cookies: provider specific

Retention periods are reviewed periodically.

10. Your Rights Under GDPR

You have the right to:

• Withdraw consent at any time
• Access personal data
• Request rectification
• Request erasure
• Restrict processing
• Object to processing
• Lodge a complaint with the Irish Data Protection Commission

To exercise your rights, contact:

Support@spruceup.ie

11. Children

The Platform is not intended for individuals under 18 years of age. We do not knowingly deploy cookies for child profiling.

12. Changes to This Policy

SpruceUp may update this Cookie Policy from time to time. Any updates will be published with a revised effective date.

13. Contact Information

Total Veracity Limited
Trading as SpruceUp
Ireland
Support@spruceup.ie