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Privacy Policy

Last updated: April 14, 2026

Spotter is a product operated under Haipe Studio, a brand of BUZZVEL LDA. This Privacy Policy explains how we collect, use, store, share, and protect personal data when you visit the Spotter website, contact us, or use the Spotter product and related services.

We are committed to handling personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable data protection laws.

1. Data Controller

The data controller responsible for processing personal data in connection with Spotter is:

BUZZVEL LDA

Tax ID: PT516182005

Haipe Studio operates as a brand of BUZZVEL LDA.

Email: privacy@haipestudio.com

2. What Personal Data We Collect

Depending on how you interact with Spotter, we may collect the following categories of personal data:

a) Information you provide directly

  • Name
  • Email address
  • Company name, if provided

Any information you submit through contact forms, demo requests, onboarding forms, support requests, or direct communications

b) Product and collaboration data

If you use Spotter, we may process:

  • Comments, feedback, annotations, and task-related content you submit
  • Screenshots or visual references generated as part of feedback workflows
  • Page URLs, interface locations, and contextual metadata related to comments or bug reports
  • Team member names, email addresses, roles, and workspace activity, where applicable

c) Technical and usage data

  • IP address
  • Browser type and version
  • Device information
  • Operating system
  • Referral source
  • Website and product usage logs
  • Cookie identifiers and similar technologies

This reflects the current Spotter website, which presents the product as a feedback tool where users can click on an interface, leave comments, and generate contextual task information, and also includes a contact form requesting name, email, and acceptance of terms.

3. How We Collect Personal Data

We may collect personal data through:

  • Website forms, including contact and demo request forms
  • Direct communications by email
  • Your use of the Spotter website and product
  • Cookies and similar technologies
  • User actions within the product, such as comments, annotations, and collaboration activity

Haipe Studio’s current privacy policy also states that personal data may be collected through website forms, cookies, and direct communications.

4. Purposes of Processing, Legal Basis, and Retention

We process personal data only where we have a valid legal basis to do so.

a) To respond to inquiries and demo requests

  • Data: Name, email, message content
  • Legal basis: Consent and pre-contractual steps
  • Retention: Up to 12 months after the last relevant interaction

b) To provide access to Spotter and operate the service

  • Data: Account details, collaboration data, screenshots, comments, technical data
  • Legal basis: Performance of a contract, or legitimate interest where applicable
  • Retention: For the duration of the service relationship, and for a limited period afterward as needed for operational, legal, or security purposes

c) To manage feedback workflows and contextual collaboration features

  • Data: Comments, interface markers, screenshots, page context, metadata, workspace activity
  • Legal basis: Performance of a contract and legitimate interest in providing and improving the service
  • Retention: As long as needed to provide the service and maintain workspace history, unless deletion is requested and legally permissible

d) To maintain security, prevent abuse, and troubleshoot technical issues

  • Data: IP address, logs, device and browser data, usage events
  • Legal basis: Legitimate interest
  • Retention: Up to 24 months, where appropriate

e) To analyze and improve website and product performance

  • Data: Usage data, cookies, analytics data
  • Legal basis: Consent, where required for non-essential cookies, and legitimate interest for strictly necessary service improvement
  • Retention: Generally up to 24 months, depending on the type of data and tool used

f) To comply with legal obligations

  • Data: Any data required by applicable law, accounting, tax, dispute resolution, or law enforcement obligations
  • Legal basis: Legal obligation
  • Retention: For the period required by law

This structure follows the legal and operational model already used in Haipe Studio’s current privacy policy, including consent, legitimate interest, and operational/security purposes.

5. Cookies and Similar Technologies

We use cookies and similar technologies to:

  • Ensure the website functions properly
  • Improve performance and security
  • Understand usage and traffic patterns
  • Support analytics and service improvement

Non-essential cookies should only be used with your prior consent. Haipe Studio’s current privacy policy already states that non-essential cookies are only used with prior consent and references a Cookie Policy powered by Cookiebot.

You should also provide a separate Cookie Policy or cookie declaration for Spotter if cookies are active on this website.

6. Sharing Data with Third Parties

We may share personal data with trusted third-party service providers only where necessary to operate Spotter and support our business, such as:

  • Hosting and infrastructure providers
  • Analytics providers
  • Customer communication tools
  • Support and operational tools
  • Security and monitoring providers
  • Project management or integration platforms used in connection with Spotter features

We require third-party providers to process personal data only on our instructions, to apply appropriate security measures, and to comply with applicable data protection laws. Haipe Studio’s current privacy policy already states that data may be shared with trusted providers for hosting, analytics, and communication tools under contractual obligations.

7. International Data Transfers

If personal data is transferred outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place, such as:

  • Adequacy decisions adopted by the European Commission
  • Standard Contractual Clauses (SCCs)
  • Other lawful transfer mechanisms recognized under GDPR

This is aligned with Haipe Studio’s current privacy policy.

8. Data Subject Rights

Under GDPR, you have the right to:

  • Access your personal data
  • Rectify inaccurate or incomplete data
  • Request deletion of your personal data
  • Restrict processing in certain circumstances
  • Object to processing based on legitimate interests
  • Request data portability, where applicable
  • Withdraw consent at any time, where processing is based on consent

To exercise any of these rights, contact us at:

privacy@haipestudio.com

You also have the right to lodge a complaint with the Portuguese Data Protection Authority:

CNPD – Comissão Nacional de Proteção de Dados. Haipe Studio’s current privacy policy identifies CNPD as the relevant authority.

9. Security of Personal Data

We implement appropriate technical and organizational measures to protect personal data, including:

  • Encrypted communications
  • Access controls and authentication measures
  • Monitoring, logging, and incident response processes
  • Regular maintenance and security updates
  • Role-based access where applicable

Haipe Studio’s current privacy policy also states that it uses encrypted communications, secure access controls, and regular monitoring and updates.

While we take security seriously, no method of transmission or storage is completely secure.

10. Beta Product Notice

Spotter is currently presented as a beta product on its public website. During beta phases, certain features, integrations, workflows, and data handling operations may evolve as the service is improved and stabilized. The Spotter website currently explicitly states that the product is in beta.

Where material changes affect the way personal data is processed, we will update this Privacy Policy accordingly.

11. Third-Party Services and Links

Spotter may integrate with or link to third-party tools, platforms, or websites. We are not responsible for the privacy practices of third-party services that operate independently from us. You should review their privacy policies separately.

This section is also consistent with Haipe Studio’s current privacy policy regarding third-party websites.

12. Children’s Privacy

Spotter is not intended for children, and we do not knowingly collect personal data from individuals who are not legally able to use the service under applicable law.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal requirements, technical implementation, or business operations. Any updates will be posted on this page together with a revised “Last updated” date.

Haipe Studio’s current privacy policy follows the same update approach.

14. Contact

If you have questions about this Privacy Policy or about how your personal data is handled, please contact: privacy@haipestudio.com