Best interests
Data processing must prioritize the adolescent's safety, dignity, and development.
Legal · Version 1.0
Privacy Notice for Parents and Legal Guardians
This notice explains how SpotSB processes personal data relating to adolescents and their legal guardians, including authorization, location, content, safety, and data protection rights.
1. Data controller
SpotSB is operated by SpotSB Co., registered in Brazil under CNPJ No. 00.000.000/0001-03, with its registered address at Curitiba, Paraná, Brazil.
2. Purpose of this notice
This notice explains how SpotSB processes personal data relating to adolescents and their parents, guardians, or legal representatives. It supplements the Privacy Policy, Terms for Parents and Legal Guardians, and other data protection documents provided by the platform.
3. Best interests and comprehensive protection
The processing of personal data relating to children and adolescents must respect their best interests, safety, dignity, privacy, and development. Guardian authorization does not permit processing that is incompatible with these principles.
4. Minimum age
SpotSB sets a minimum age of 13 for accounts and features intended for registered users. People under the age of 13 must not create accounts unless SpotSB introduces a specific experience that is permitted by law and supervised by a legal guardian.
5. Legal guardian data
We may process the guardian's name, contact information, relationship to the adolescent, declarations of responsibility, authorization records, and information needed to confirm identity and legal authority. We avoid requesting complete documents when a less intrusive verification method is sufficient.
6. Adolescent data
Depending on the features used, we may process a name, username, date of birth or age range, language, country, city, profile, privacy settings, published content, registered spots, interactions, reports, technical information, and security records.
7. Location and maps
When location features are available and authorized, we may process coordinates, city, region, viewed or registered spots, and check-ins. SpotSB should avoid unnecessary exposure of an adolescent's real-time location, home, school, routine, or frequent travel routes.
8. Photographs, videos, and voice
Uploaded content may include a person's image, voice, and other characteristics. SpotSB does not automatically treat every photograph as biometric data. An image will be treated as biometric data only if a specific technology uses it to identify or authenticate a person, which would require appropriate notice and a valid legal basis.
9. Information that should not be submitted
Guardians and adolescents should not submit passwords, access codes, complete identity documents, financial information, medical information, or other sensitive data unless necessary and requested through an official and secure procedure.
10. Sources of personal data
Data may be provided by the adolescent or legal guardian, generated through platform use, or received from authentication, security, moderation, and infrastructure systems. We may also receive reports or correction requests submitted by other users.
11. Purposes of processing
We process data to create and protect accounts, verify age and authorization, provide maps and community features, maintain preferences, moderate content, prevent fraud and abuse, respond to requests, comply with legal obligations, and improve SpotSB's security and performance.
12. Legal bases
Processing may rely on the guardian's specific and prominent consent where required, performance of requested services, compliance with legal obligations, protection of life and physical integrity, exercise of legal rights, or legitimate interests compatible with the adolescent's rights. The adolescent's best interests must be considered in every case.
13. Consent and adolescent participation
When consent is required, we will provide clear information about the data and purposes involved. The adolescent's participation will be considered according to their age, maturity, and ability to understand, without excluding guardian participation when required.
14. Public profiles and content
Some information may become public when a user chooses to publish a profile, spot, photograph, video, comment, or other community content. Before publication, the guardian and adolescent should assess whether the material reveals location, routine, school, third-party data, or other information that could create a risk.
15. Moderation and protection
We may analyze accounts, content, reports, and technical signals to prevent harassment, exploitation, fraud, inappropriate exposure, and other violations. When a risk is identified, we may restrict features, remove content, preserve records, and notify competent authorities where necessary.
16. Automated decisions
Automated tools may assist in identifying spam, fraud, abuse, or potentially inappropriate content. When a solely automated decision materially affects an adolescent's interests, the guardian may request information and a review as provided by applicable law.
17. Data sharing
We may share data with providers of infrastructure, storage, authentication, security, communications, maps, analytics, and support, always according to the purpose of the service. Sharing may also occur to comply with legal obligations, protect rights, or respond to competent authorities.
18. No sale of personal data
SpotSB does not sell personal data relating to adolescents or their legal guardians. We also do not condition an adolescent's participation on providing personal data beyond what is reasonably necessary for the feature being used.
19. International transfers
Some providers may process data outside Brazil. In these situations, we will adopt contractual, technical, and organizational safeguards consistent with applicable law and the special protection required for children and adolescents.
20. Retention period
Data is retained for as long as necessary to provide the service, maintain security, comply with legal obligations, resolve disputes, and exercise legal rights. Authorizations and related records may be retained for as long as necessary to demonstrate compliance and protect the adolescent.
21. Security
We adopt technical and organizational controls intended to prevent unauthorized access, loss, alteration, exposure, and misuse of personal data. No system is entirely free from risk, so guardians and adolescents must also protect passwords, devices, and account recovery methods.
22. Rights of the adolescent
The adolescent, assisted or represented where necessary, may request confirmation of processing, access, correction, information about sharing, portability, anonymization, blocking, deletion, objection, and review of automated decisions, where applicable.
23. Rights of the legal guardian
The guardian may request information about processing, exercise rights on behalf of the adolescent, review or withdraw authorizations, and request protective measures. Fulfillment of a request will depend on confirmation of the requester's identity and legal authority.
24. Identity verification
To prevent third parties from obtaining an adolescent's data, we may verify the requester's identity and legal relationship to the minor. We will request only information that is proportionate and necessary for this purpose.
25. Withdrawal of consent and deletion
The guardian may withdraw consent when consent is the legal basis used. Withdrawal may restrict features or require account closure. Some data may be retained where required by law or necessary for security, fraud prevention, or the exercise of legal rights.
26. Security incidents
If an incident may cause relevant risk or harm, we will take containment and assessment measures and provide the notices required by law. The guardian should immediately report suspected account compromise, location exposure, or unauthorized access.
27. Updates to this notice
We may update this notice due to legal, technical, or operational changes. When a change materially affects the processing of an adolescent's data, we may request renewed acknowledgement or authorization from the guardian.
28. Contact
To exercise rights, review authorizations, or report a concern involving an adolescent, use https://spotsb.com/en/contact. Do not send complete documents or sensitive data unless requested through a secure procedure.
Limited collection
SpotSB seeks to use only the information needed for each feature and security procedure.
Location protection
Home, school, routine, and real-time location should not be unnecessarily exposed.
Guardian rights
A legal guardian may request information, exercise rights, and review or withdraw applicable authorizations.
Do you have a privacy request involving an adolescent?
Use the official channel to exercise rights, review an authorization, or report a safety concern.