PRIVACY POLICY

Last updated May 31, 2026

This Privacy Notice for Milman Tech (doing business as Spotter) ("we", "us", or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Download and use our mobile application (Spotter), or any other application of ours that links to this Privacy Notice.
Use Spotter. Spotter is a gym-locked, chat-free mobile dating and social app for meeting people in person at your gym. Users select a single gym, verify they are 18 or older via photo ID, and confirm their presence by checking in at the gym's location. Members can send a "green light" to indicate someone may approach them; a mutual green light creates a match so the two can meet in person. The app collects profile photos, government-issued photo ID (for age verification), approximate location (to confirm gym check-ins), date of birth, gender, and training schedule. There is no in-app messaging.
Engage with us in other related ways, including any marketing or events.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at milmantec@gmail.com.

SUMMARY OF KEY POINTS

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services.

Do we process any sensitive personal information? Yes — with your consent or as permitted by law, we process sexual orientation, biometric data (facial images for photo verification), government-issued ID, approximate location, and (where you provide them) race/ethnic origin and religious or philosophical beliefs.

Do we collect information from third parties? We do not collect any information from third parties.

How do we process your information? To provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

With whom do we share information? Service providers/vendors only: Supabase (database, auth, storage), Expo / Apple APNs / Google FCM (push notifications).

How do we keep your information safe? We use appropriate organisational and technical measures, though no system is 100% secure.

What are your rights? Depending on where you live, you may have rights to access, correct, or delete your personal information.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide when you register, use the Services, or contact us. This may include: names; email addresses; contact preferences; date of birth; gender; sexual orientation; profile photos; government-issued photo ID (for age verification); training schedule and gym preferences; and profile bio.

Sensitive Information. With your consent or as permitted by law, we process: data about sexual orientation; biometric data; government identifiers; government-issued photo ID (driver's licence or passport) for age verification; approximate location (gym check-in); and, where you choose to provide them, information revealing race or ethnic origin and religious or philosophical beliefs.

Information automatically collected

We automatically collect log and usage data, device data, and location data (precise/approximate geolocation for gym check-in). We also derive Gym Data: inferred gym attendance patterns and match compatibility scores derived from check-in history and stated training schedule. We use the camera, photo storage, and push notifications with your permission.

2. HOW DO WE PROCESS YOUR INFORMATION?

To facilitate account creation and authentication.
To deliver and facilitate delivery of services to users.
To respond to user inquiries and offer support.
To send administrative information.
To enable user-to-user communications.
To protect our Services (fraud monitoring and prevention).
To evaluate and improve our Services and your experience.
To identify usage trends.
To comply with our legal obligations.
Age and identity verification. To confirm users are 18 or older and verify their identity using a government-issued photo ID before their profile becomes active.
Gym presence verification. To confirm users are physically present at their selected gym through location-based check-ins, which is required to be visible to other members.
Match ranking and suggestions. To rank and suggest potential matches based on each user's training schedule, gym check-in history, age, gender, and stated preferences.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your data with third-party vendors and service providers who perform services for us and require access to do that work. We have contracts in place to safeguard your personal information. The third parties we share with are:

Functionality and Infrastructure Optimisation: Supabase
User Account Registration and Authentication: Supabase
Push notification delivery: Expo, Apple Push Notification service (APNs), Google Firebase Cloud Messaging (FCM)

We may also share information for Business Transfers (merger, acquisition) and with Other Users — when you share information or interact in public areas of the Services, other verified members of your gym can view your profile.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your personal information for as long as you have an account with us. When you delete your account, we delete or anonymise your information, except where retention is required by law.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organisational security measures. However, no transmission over the Internet or storage technology can be guaranteed 100% secure.

6. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that information from a user under 18 has been collected, we will deactivate the account and delete the data. Contact milmantec@gmail.com if you believe we have collected such data.

7. WHAT ARE YOUR PRIVACY RIGHTS?

You may review, change, or terminate your account at any time. Withdrawing consent: where we rely on consent, you may withdraw it at any time by contacting us. Account Information: log in to your account settings to update your information, or delete your account from Settings, which deactivates and deletes your account and data from our active databases.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

We do not currently respond to DNT browser signals as no uniform standard has been finalised.

9. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

Australia and New Zealand

We collect and process your personal information under Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. You have the right to request access to or correction of your personal information. If you believe we are unlawfully processing your personal information, you may complain to the Office of the Australian Information Commissioner (OAIC) or the Office of the New Zealand Privacy Commissioner.

10. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. The "Last updated" date reflects the latest revision.

11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments, you may contact our Data Protection Officer (DPO) by email at milmantec@gmail.com, by phone at +61473749039, or by post at:

Milman Tech
Data Protection Officer
35 Birdwood Street
Box Hill South, Victoria 3128
Australia

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You may have the right to request access to, correct, or delete your personal information, or withdraw consent. To do so, email us at milmantec@gmail.com, or delete your account directly in the app under Profile > Settings > Delete account.