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Privacy Policy

SPRUCEUP 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