HTSPT

Privacy Policy

Last updated: 5 July 2026


1. Introduction

This Privacy Policy explains how HTSPT (“we,” “us,” or “our”), operated by Kelechi Nwoko trading as HTSPT, collects, uses, stores, and protects your personal information when you use the HTSPT mobile application and related services (the “App”).

We are committed to protecting your privacy and handling your personal data transparently and in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Privacy Policy should be read alongside our Terms and Conditions. By using the App, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of your information as described. If you do not agree with this policy, you should not use the App.

This policy was last updated on 5 July 2026.

2. Information We Collect

We collect the following categories of information when you use HTSPT:

Account Information. When you create an account, we collect your email address and any details you provide as part of setting up your profile, such as your chosen username and profile picture.

Location Information. When you use the App, we collect location data from your device in order to display nearby activity, generate the heatmap, and enable core features. This is explained in detail in the dedicated Location Data section below.

Activity Information. We collect information about how you interact with the App, including the hotspots you drop, the venues and areas you engage with, your friend connections, and your general activity within the App.

Device and Technical Information. We may automatically collect certain technical information from your device, such as device type, operating system version, unique device identifiers, app version, and general diagnostic information necessary for the App to function and remain secure.

Communications. If you contact us directly, for example by email, we will collect the information you choose to provide, such as your name, email address, and the content of your message.

We only collect information that is necessary to provide and improve the App. We do not collect sensitive personal data such as racial or ethnic origin, health information, religious beliefs, or political opinions.

3. How We Use Your Information

We use the information we collect for the following purposes:

To provide and operate the App. We use your information to create and manage your account, display the heatmap and hotspots, enable you to drop hotspots, connect you with friends, and deliver the core functionality of the service.

To personalise your experience. We use your location and activity information to show you relevant nearby activity, venues, and hotspots, and to display the activity of friends you are connected with.

To send notifications. We use your information to send you push notifications relevant to your use of the App, such as when a friend drops a hotspot or when activity occurs near you. You can control notifications through your device settings.

To maintain safety and security. We use your information to protect the integrity of the App, detect and prevent fraudulent, fake, or abusive activity, enforce our Terms and Conditions, and keep users safe.

To communicate with you. We use your contact information to respond to your enquiries, provide support, and send you important information about the App, such as changes to our Terms or this Privacy Policy.

To improve the App. We use aggregated and anonymised information to understand how the App is used, identify areas for improvement, and enhance the accuracy of the heatmap and overall user experience.

To comply with legal obligations. We may use and retain your information where necessary to comply with applicable laws, respond to lawful requests from authorities, or protect our legal rights.

4. Location Data

Because HTSPT is a location-based social map, location data is fundamental to how the App works. We treat this data with particular care, and this section explains exactly how it is handled.

What we collect. When you use the App, we collect location data from your device to determine your position, display nearby activity, generate the heatmap, and show relevant hotspots. Depending on your device permissions, we collect location data while the App is in use (in the foreground). We only collect location data in the background if you have explicitly granted background location permission through your device settings.

How we use it. Your location data is used to show you nearby venues and activity, to contribute to the heatmap in an aggregated and anonymised form, and to share your general venue-level presence with your friends when you choose to drop a hotspot.

What other users can see. Your precise location and GPS coordinates are never shared with or shown to other users. Other users can only see that you are present at a venue or area when you have actively chosen to drop a hotspot, and even then only your username and the associated venue are visible — never your exact location or live movement.

Anonymisation within the heatmap. When your location contributes to the heatmap, it is aggregated with data from other sources and anonymised so that no individual user can be identified. The heatmap reflects general levels of activity in an area, not the location of any specific person.

Your control. You are in full control of location sharing. You can enable or disable location permissions at any time through your device settings. If you disable location access, core features of the App will not function, as location is essential to how HTSPT works. You can also choose when to drop a hotspot, meaning your venue-level presence is only ever shared when you actively decide to share it.

Retention. We retain identifiable location data only for as long as necessary to provide the App’s functionality. Aggregated and anonymised location data, which cannot be linked back to you, may be retained for longer to maintain and improve the heatmap.

5. Legal Basis for Processing

Under the UK GDPR, we must have a valid legal basis for processing your personal data. We rely on the following legal bases, depending on the type of data and the purpose for which it is used:

Performance of a contract. We process your account information, location data, and activity information because it is necessary to provide the App and its features to you under our Terms and Conditions. Without this data, we cannot deliver the service you have signed up for.

Consent. We rely on your consent for certain types of processing, in particular the collection of your location data, which you provide through your device permissions. Where we rely on consent, you have the right to withdraw it at any time by disabling the relevant permissions or by deleting your account. Withdrawing consent will not affect the lawfulness of any processing carried out before you withdrew it.

Legitimate interests. We process certain information where it is necessary for our legitimate interests, provided these are not overridden by your rights and freedoms. This includes processing to keep the App safe and secure, to prevent fraud and abuse, to improve the App using aggregated and anonymised data, and to communicate with you about the service.

Legal obligation. We process and retain certain information where necessary to comply with our legal obligations, such as responding to lawful requests from authorities or complying with applicable laws and regulations.

Where we rely on legitimate interests, you have the right to object to that processing. You can do so by contacting us using the details at the end of this policy.

6. How We Share Your Information

We do not sell your personal data to any third party. We only share your information in the limited circumstances described below.

With other users. When you drop a hotspot, your username and the associated venue are shared with the friends you are connected with, as part of the core social functionality of the App. Your precise location is never shared. Aggregated and anonymised activity contributes to the heatmap, but this cannot be traced back to you individually.

With service providers. We share information with trusted third party service providers who help us operate the App. This includes our hosting and backend provider, Supabase, which stores the data necessary to run the service. These providers process data on our behalf and are contractually required to protect it and use it only for the purposes we specify.

With third party data providers. The heatmap combines user activity with venue foot traffic data supplied by third party providers. This process does not involve sharing your personal data with those providers; their data is used to supplement and enhance the activity shown within the App.

For legal and safety reasons. We may disclose your information where we believe in good faith that doing so is necessary to comply with a legal obligation, respond to a lawful request from a public authority, enforce our Terms and Conditions, prevent fraud or abuse, or protect the rights, safety, or property of our users, the public, or ourselves.

In the event of a business transfer. If HTSPT is involved in a merger, acquisition, restructuring, or sale of assets in the future, your information may be transferred as part of that transaction. We will notify you of any such change and of any choices you may have regarding your information.

7. Third Party Services

HTSPT relies on a number of third party services to operate. These providers may process limited data on our behalf or provide data that supports the App’s functionality. We choose our providers carefully and expect them to maintain appropriate standards of data protection and security.

Hosting and backend. We use Supabase to host our backend infrastructure and securely store the data required to operate the App, including account and activity information. Supabase processes this data on our behalf as our data processor.

Mapping services. The App uses third party mapping services to display the map and location features. When you use the App, your interaction with these map services may be subject to their own terms and privacy policies.

Venue foot traffic data. The heatmap is enhanced using venue activity data supplied by third party providers. This data helps estimate general activity levels at venues and does not involve the sharing of your personal data with those providers.

Push notifications. The App uses platform-level push notification services provided by Apple to deliver notifications to your device. These services are governed by the relevant provider’s own terms and privacy practices.

Each third party provider operates under its own privacy policy. We encourage you to review the privacy policies of these providers to understand how they handle data. We are not responsible for the privacy practices of third party services, but we take reasonable steps to work only with providers who uphold appropriate data protection standards.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including providing the App, complying with our legal obligations, resolving disputes, and enforcing our agreements.

Account information. We retain your account information for as long as your account remains active. If you delete your account, we will delete or anonymise your personal account information, except where we are required to retain certain data for legal or regulatory reasons.

Location data. Identifiable location data is retained only for as long as necessary to provide the App’s real-time functionality. Once it is no longer needed for this purpose, it is deleted or anonymised. Aggregated and anonymised location data, which cannot be linked back to you, may be retained for longer to maintain and improve the heatmap.

Activity data. Information about your activity within the App, such as hotspots you have dropped, is retained for as long as it is relevant to the functioning of the service or your account. Expired or historic activity may be deleted or anonymised over time.

Communications. If you contact us, we retain your correspondence for as long as necessary to respond to and resolve your enquiry, and for a reasonable period afterwards for our records.

When personal data is no longer required, we will securely delete or irreversibly anonymise it. Anonymised data, which can no longer identify you, may be retained and used indefinitely for analytical and improvement purposes.

9. Your Rights

Under the UK GDPR, you have a number of rights over your personal data. We are committed to helping you exercise these rights. They include:

The right to be informed. You have the right to be told how your personal data is collected and used, which is the purpose of this Privacy Policy.

The right of access. You have the right to request a copy of the personal data we hold about you and to be informed about how it is being processed.

The right to rectification. You have the right to ask us to correct any personal data that is inaccurate or incomplete.

The right to erasure. You have the right to request that we delete your personal data in certain circumstances, such as where it is no longer necessary for the purposes for which it was collected. You can delete your account at any time through the App.

The right to restrict processing. You have the right to ask us to limit how we use your personal data in certain circumstances.

The right to object. You have the right to object to the processing of your personal data where we are relying on legitimate interests as our legal basis.

The right to data portability. You have the right to request a copy of the personal data you have provided to us in a structured, commonly used, and machine-readable format.

The right to withdraw consent. Where we rely on your consent to process your data, such as for location data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us at hello@htsptapp.co. We will respond to your request within one month, as required by law. There is usually no charge for exercising your rights, although we may charge a reasonable fee or decline a request if it is clearly unfounded, repetitive, or excessive.

If you are not satisfied with how we have handled your personal data or responded to your request, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s data protection authority, at www.ico.org.uk.

10. Data Security

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, loss, misuse, or alteration.

Your data is stored using our backend provider, Supabase, which provides secure, industry-standard infrastructure including encryption of data in transit and at rest. Access to personal data is restricted to what is necessary to operate and maintain the App.

We use secure authentication methods to protect access to your account, and we design the App so that sensitive information, such as your precise location, is never exposed to other users.

While we take reasonable steps to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. We cannot therefore guarantee absolute security, but we continually work to protect your information and to review and improve our security practices.

You also play an important role in keeping your account secure. You should keep your login details confidential, use a secure email account, and notify us immediately if you believe your account has been compromised.

11. Children’s Privacy

HTSPT is intended for users aged 18 and over. The App is not directed at children, and we do not knowingly collect personal data from anyone under the age of 18.

By using the App, you confirm that you are at least 18 years of age. If we become aware that we have collected personal data from a person under the age of 18, we will take steps to delete that information as quickly as possible.

If you are a parent or guardian and you believe that a person under 18 has provided us with personal data, please contact us at hello@htsptapp.co so that we can take appropriate action.

12. International Users & Data Transfers

HTSPT is operated from the United Kingdom, and our data practices are designed to comply with UK data protection law. The App is available through the App Store, and may be accessed by users in other countries.

If you access the App from outside the United Kingdom, you should be aware that your information may be transferred to, stored in, and processed in countries other than your own, including the United Kingdom. Data protection laws in these countries may differ from those in your country of residence.

Some of our service providers may store or process data outside the United Kingdom. Where personal data is transferred outside the UK, we take steps to ensure that appropriate safeguards are in place to protect your information, in line with UK data protection requirements. This may include relying on adequacy decisions or using approved contractual safeguards such as standard contractual clauses.

By using the App, you understand that your information may be transferred and processed as described in this Privacy Policy, subject to the protections set out here.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the App, legal or regulatory requirements, or for other operational reasons.

Where we make material changes to this Privacy Policy, we will take reasonable steps to notify you, such as by displaying a notice within the App or contacting you via the email address associated with your account. We encourage you to review this policy periodically to stay informed about how we protect your information.

The date at the top of this policy indicates when it was most recently updated. Any changes will take effect from the date the updated policy is published within the App.

Your continued use of the App after any changes have been made will constitute your acknowledgement of the updated Privacy Policy. If you do not agree with any changes, you should stop using the App and may delete your account.

14. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or how your personal data is handled, you can contact us using the details below.

HTSPT

Kelechi Nwoko

Email: hello@htsptapp.co

We are the data controller responsible for your personal data. We will do our best to respond to your enquiry promptly and to resolve any concerns you may have.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection matters. Further information can be found at www.ico.org.uk.