Privacy Policy

1. Introduction

This Privacy Policy explains how Total Veracity Limited trading as SpruceUp ("SpruceUp", "we", "us", "our") collects, uses, processes, stores, transfers, and protects personal data when you access or use the SpruceUp website, mobile application, dashboards, payment systems, and related services (the "Platform").

SpruceUp is committed to protecting personal data in accordance with:

The General Data Protection Regulation (EU) 2016/679 ("GDPR")

The Irish Data Protection Act 2018

The ePrivacy Directive

Applicable European Union data protection laws

By using the Platform, you acknowledge that your personal data will be processed in accordance with this Privacy Policy.

2. Data Controller

The data controller is:

Total Veracity Limited

Trading as SpruceUp

Ireland

Email:

Support@spruceup.ie

SpruceUp acts as data controller in respect of user account data, booking data, platform activity, and payment facilitation data.

In certain circumstances, we may act as a data processor for limited activities.

3. Categories of Personal Data Collected

We may collect and process the following categories of personal data:

3.1 Identity Data

Full name

Date of birth

Government issued ID

Photograph

Identity verification results

3.2 Contact Data

Email address

Telephone number

Address

Location data

3.3 Financial Data

Bank account details

Payment card details (processed via payment providers)

Transaction history

Earnings data

3.4 Technical Data

IP address

Device identifiers

Browser type

Operating system

Log files

3.5 Usage Data

Platform interactions

Booking history

Session data

Feature usage

3.6 Communication Data

Messages between Users

Support requests

Complaints and dispute records

3.7 Verification and Compliance Data

Background checks where applicable

Fraud screening results

Risk scoring indicators

4. How We Collect Personal Data

We collect data:

Directly from you during registration or booking

Automatically through use of the Platform

From third party service providers such as:

-Identity verification providers

-Payment processors

-Hosting providers

-Analytics providers

5. Legal Basis for Processing

5.1 Contract Necessity

Processing required to:

Create and manage accounts

Facilitate bookings

Process payments

Provide Platform functionality

5.2 Legitimate Interests

Processing required for:

Fraud prevention

Platform security

Abuse detection

Service improvement

Business operations

Enforcement of terms

We ensure legitimate interests do not override your rights.

5.3 Legal Obligations

Processing required to:

Comply with tax laws

Respond to legal requests

Maintain financial records

Prevent unlawful activity

5.4 Consent

Processing based on consent includes:

Marketing communications

Optional cookies

Certain analytics tools

You may withdraw consent at any time.

6. How We Use Personal Data

We use personal data to:

Create and manage user accounts

Verify identity

Facilitate bookings and payments

Hold and release funds

Detect and prevent fraud

Investigate disputes

Enforce platform rules

Improve services

Comply with legal obligations

Communicate with users

7. Data Sharing

7.1 Service Providers

Payment processors

Identity verification providers

Cloud hosting providers

Analytics providers

Email communication providers

7.2 Other Users

Limited information may be shared between Customers and Cleaners to enable bookings.

7.3 Legal Authorities

Where required by law or to protect legal rights.

7.4 Corporate Transactions

In connection with mergers, acquisitions, financing, or asset sales.

We require service providers to process data securely and lawfully.

8. International Transfers

SpruceUp currently stores data within the European Union.

Where personal data is transferred outside the European Economic Area, we implement appropriate safeguards, including:

Standard contractual clauses

Adequacy decisions

Contractual data protection measures

9. Data Retention

We retain personal data only as long as necessary.

Typical retention periods:

Account and transaction data: up to 6 years after account closure

Financial records: as required by tax law

Dispute records: up to 6 years

Verification records: as required for compliance

We may retain data longer where necessary to establish, exercise, or defend legal claims.

10. Data Security

We implement appropriate technical and organisational measures including:

Encryption

Access controls

Authentication measures

Secure hosting environments

However, no system is completely secure. Users are responsible for safeguarding login credentials.

11. Automated Decision Making

SpruceUp may use automated systems for:

Fraud detection

Risk assessment

Platform abuse detection

Account suspension triggers

Such processing may significantly affect Users.

You may request human review of automated decisions by contacting Support@spruceup.ie.

12. Your GDPR Rights

You have the right to:

Access your personal data

Request rectification

Request erasure

Restrict processing

Object to processing

Data portability

Withdraw consent

Lodge a complaint with the Irish Data Protection Commission

To exercise your rights, contact Support@spruceup.ie.

13. Cookies and Tracking

SpruceUp uses cookies in accordance with the SpruceUp Cookie Policy.

Non essential cookies require consent.

14. Children

The Platform is not intended for individuals under 18 years of age.

We do not knowingly collect personal data from children.

15. Changes to This Policy

We may update this Privacy Policy from time to time.

The updated version will be posted on the Platform with a revised effective date.

16. Contact

For privacy related questions:

Support@spruceup.ie

Total Veracity Limited

Trading as SpruceUp

Ireland