Policies

Terms of Service Privacy Policy Code of Conduct

Terms of Service

Last updated: 15/3/2026

1. Introduction

1.1 By using the Spot app ("App") and our services ("Services"), you agree to these legal terms ("Terms") applying between you and Spot Payments Limited ("Spot", "we", "us") in relation to your use of our Services. English law and courts will govern these Terms.

1.2 These Terms apply to: Individual Users (personal use only) and Freelance Users (sole traders or freelancers using Spot to receive payments from customers).

1.3 These Terms are written in English. Please contact us if anything is unclear.

2. Who We Are and How to Contact Us

2.1 Spot Payments Limited is a company registered in England and Wales (Company No. 13762907). Our registered address is 35 Ballards Lane, London, N3 1XW.

2.2 You can contact us: via mobile phone at +447778276897, via email at support@spot-app.co.uk, or by post at our registered address.

2.3 We'll contact you via the App or your registered email/phone number. Please keep your details up to date. By using the App, you consent to receiving electronic communications.

2.4 Our Privacy Policy applies to your use of our Services. Please review it at www.spot-app.co.uk.

3. Who Can Have a Spot Account

3.1 You must be at least 18 years old and resident in the UK.

3.2 If requested, you must provide accurate and complete information and may be required to verify your funding sources. We may run checks, including credit or compliance screening.

3.3 You may only have one Spot account. Duplicate or fraudulent accounts may be closed.

3.4 Individual accounts must only be used for personal purposes. Freelance accounts are for business transactions only.

3.5 Your Spot account must be in the same name as your linked bank account.

4. Using Your Spot Account

4.1 With Spot, you can: link a UK bank account, send and receive payments via payment links and QR codes, split and track group expenses, and other features.

4.2 Spot does not hold or process money. Payments are initiated via Open Banking and processed by Yapily Connect Ltd.

4.3 The max amount per payment request is £1,500 unless you complete KYC verification.

5. Types of Accounts

5.1 Individual Account: For personal, non-commercial use only.

5.2 Freelance Account: For self-employed professionals, freelancers, and sole traders to receive payments for goods or services.

5.3 Freelance users may be subject to transaction fees. These fees will be clearly displayed before you complete a transaction.

6. Changes to Terms

6.1 We may update these Terms at any time. Continued use after notice constitutes acceptance.

6.2 Immediate changes may occur without notice for legal, security, or functionality reasons.

7. Fees

7.1 Spot is free for Individual accounts.

7.2 Freelance accounts may incur transaction fees. These will be shown in advance and agreed to before processing.

8. Linking Your Bank Account

8.1 Bank account connections are made through Yapily Connect Ltd.

8.2 By linking your account, you agree to Yapily's End User Service Agreement and Privacy Notice.

8.3 We may cache consent and transaction data to improve your user experience.

8.4 You may withdraw consent at any time by deleting your account or contacting us.

9. Making Payments

9.1 Payments are processed by your bank through Open Banking via Yapily Connect. Spot does not process payments.

9.2 In case of issues, contact your bank directly.

9.3 Merchants are responsible for verifying payer identity.

9.4 When making a payment via Spot, you agree to Yapily's End User Service Agreement and Privacy Notice.

10. Keeping Your Account Safe

10.1 Keep your device and Spot credentials secure.

10.2 Contact us if you suspect unauthorized access.

10.3 Check your transaction history regularly and report any discrepancies immediately.

10.4 Do not misuse or interfere with the App.

11. App License

11.1 We grant you a limited, non-transferable license to use the App.

11.2 You may not reverse engineer, copy, or distribute the App or its content.

12. App Updates and Availability

12.1 Updates may be required for continued use.

12.2 We do not guarantee uninterrupted or error-free service.

12.3 We use personal data for authentication and performance improvements.

13. Third-Party Rights

13.1 Do not infringe on the rights of Spot or any third party.

14. Liability

14.1 We are liable for foreseeable loss caused by our breach.

14.2 Nothing in these Terms limits our liability for death or injury caused by negligence.

14.3 You agree to indemnify us for losses caused by your breach.

14.4 Neither party is liable for indirect or unforeseeable losses.

15. Complaints

15.1 Contact us at support@spot-app.co.uk for complaints.

15.2 You may escalate unresolved issues to the Financial Ombudsman Service.

16. Account Closure & Suspension

16.1 You may close your account at any time via email or WhatsApp.

16.2 We may suspend or terminate accounts for violations, inactivity, or fraud.

16.3 Upon closure, some data and links may persist for legal or transactional purposes.

17. Other Legal Terms

17.1 Not enforcing a term does not waive our right to enforce it later.

17.2 You are responsible for any mobile data charges incurred while using the App.

18. Definitions

"Business Day" means any weekday excluding public holidays. "Individual User" means someone using Spot for personal reasons. "Small Business User" means someone using Spot for business-related transactions. "Personal Data" has the meaning set out in the UK GDPR. "Services" means the Spot App, features, and functionality.

The Data Controller
Spot Payments Limited
35 Ballards Lane, London, N3 1XW
support@spot-app.co.uk

Privacy Policy

This privacy policy is designed to inform individuals about how Spot Payments Limited (the "Company") collects, uses, and shares personal information. The Company is committed to protecting the privacy and security of personal information in accordance with the General Data Protection Regulation (GDPR) and other applicable laws.

Who are we and what do we do?

The Sites and our Services are operated by Spot Payments Limited ("Spot", "we", "us" or "our") who is the data controller. Spot Payments Limited is an English company with registered company number: 13762907 and whose registered office is at 35 Ballards Lane, London, United Kingdom, N3 1XW.

Information Commissioner's Office Details:
Registration reference: ZB540059
Date registered: 24 April 2023
Registration expires: 23 April 2026

How to contact us?

If you have any questions about this Privacy Policy, please contact us by sending an e-mail to support@spot-app.co.uk or writing to us at: Spot Payments Limited, 35 Ballards Lane, London, United Kingdom, N3 1XW.

What personal information do we collect and how do we use it?

Our primary goals in collecting personal information include: verifying your identity ("Know Your Customer" checks), improving our services, carrying out your requests, investigating disputes, complying with applicable laws, enforcing our agreements, protecting rights and safety, and providing support for our Services.

We may share your information with third parties such as credit reference agencies for identity verification and fraud prevention. Suspicious activity may be reported to law enforcement.

The information we may collect for "Know Your Customer" includes: full name, e-mail address, phone number, proof of identity, and proof of address.

Spot may also collect financial information such as bank account numbers, transaction information, bank balance information, and direct debit details (collected via Yapily Connect Ltd).

We use third-party analytics and attribution providers including AppsFlyer, PostHog, and Facebook SDK (Meta Platforms Inc.) to understand how users interact with our services and improve our offerings.

How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent at the time we collect your personal information or by informing us by e-mail or post.

Our use of cookies and similar technologies

Spot uses certain cookies, pixels, beacons, SDKs, log files, and other technologies. We use third-party technologies such as AppsFlyer cookies and SDKs, PostHog, and Facebook SDK. These tools may collect device data, browsing behaviour, app events, and approximate location.

Storage and Sharing of Personal Information

We store some personal data in data centres in the United Kingdom. Data may be transferred to the EEA or other jurisdictions, including the United States. We ensure such transfers are compliant using appropriate safeguards such as Standard Contractual Clauses.

Third Party Links and Services

Our Sites may contain links to third-party websites and services. When you use a link to go from our Sites to another website, this Privacy Policy no longer applies.

How long do we keep your personal information for?

We keep your personal information for a period of 6 (six) years from the date of our last interaction with you or such longer period as is required by law or regulation.

Confidentiality and security of your personal information

We have implemented information security policies, rules and technical measures to protect personal information from unauthorised access, improper use or disclosure, unauthorised modification, and unlawful destruction or accidental loss.

How to access your information and your other rights?

You have the right to: access your personal information, rectify inaccurate data, request erasure, restrict processing, object to processing, request data portability, withdraw consent, and lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk/concerns or by calling 0303 123 1113.

The Data Controller
Spot Payments Limited
35 Ballards Lane, London, United Kingdom, N3 1XW

Code of Conduct

Spot Payments Limited is committed to conducting business in an ethical manner and demonstrating the highest standard of integrity. This policy outlines our approach to preventing ethical conduct by anyone associated with the firm, considering our obligations under the Bribery Act 2010 and guidance issued by the Ministry of Justice.

1. Scope

This policy applies to all full-time and part-time employees, temporary contractors, interns, agents, and all subsidiaries or branches of Spot Payments operating in the UK, EEA, or any other country. Failure to comply may result in disciplinary action.

2. What is Bribery?

Bribery, as defined by the Bribery Act 2010, is giving or receiving a financial or other advantage in connection with the improper performance of a position of trust. Bribery can take many forms including gifts, lavish treatments, tickets, hospitality, and promising favours.

3. What is Corruption?

Corruption is the abuse of entrusted power for private gain. It includes not only bribery but also other forms of misconduct or improper behaviour that may distort competition, create cartels, or illicitly influence decision-making.

4. Zero Tolerance

Spot Payments does not tolerate bribery or corruption in any form. Representatives are prohibited from offering, promising, requesting or receiving anything of value that would entail improperly performing their position or assisting to facilitate a crime.

5. Responsibilities

Responsible Officer: Charlie Pentol-Levy has been appointed as the Responsible Officer for implementing, maintaining and monitoring compliance with this policy since 01/01/2023.

Senior Management: Fully endorses the policy and is responsible for ensuring the firm conducts business with integrity and developing a corporate culture which prevents bribery and corruption.

Employees: Required to follow this policy, update the gifts and hospitality register, and attend regular training.

6. UK Legislation

Spot Payments adheres to the Bribery Act 2010, FCA Financial Crime Guide, and Ministry of Justice guidance. Key offences include bribing another person, accepting a bribe, bribing a foreign public official, and failure to prevent bribery — all subject to significant penalties including up to 10-year jail terms and unlimited fines.

7. Risk-Based Approach

In line with Ministry of Justice guidance, Spot Payments has adopted a risk-based approach incorporating the six principles: Proportionate Procedures, Top-Level Commitment, Risk Assessment, Due Diligence, Communication (including training), and Monitoring and Review.

8. Due Diligence

Spot Payments applies due diligence measures proportionate to identified risk levels, including identification and verification, scrutiny of business relationships, adverse media checks, and where necessary, direct investigations and research.

9. Training

All employees and agents receive ethical conduct training upon induction and annually thereafter, covering our zero-tolerance approach, key legislation, risk identification, and reporting obligations.

10. Reporting Suspicious Activity

All employees have a responsibility to report incidents or suspicions of bribery to their line manager, who will notify the Responsible Officer. Where appropriate, the Serious Fraud Office (SFO) and Financial Conduct Authority (FCA) will be informed.

11. Record Keeping

Spot Payments maintains records of client identities, verification evidence, business relationships, transaction details, and monitoring records for a minimum of five years after termination of the business relationship.