Privacy Policy

Last updated March 29, 2022


This is the privacy policy (“Privacy Policy”) for any application or web service owned or operated (collectively the “App”) provided by Spaceground LLC, company registration number 6698765, with its registered office address at 5 New Street Square, Deleware, United States, EC4A 3TW (“our”, “we”, or Spaceground). Spaceground is the controller of your personal d ata collected through the App and we are committed to protecting and respecting your privacy.

This Privacy Policy explains who we are, why and how we process personal data collected through your use of the App and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.

When you supply any personal data to us we have legal obligations towards you in the way we use that data. We must collect the information fairly and explain to you how we will use it. For ease of reading, we have divided this Privacy Policy into several sections:


What information we collect
How and why we use/share your information
How long we keep your information
International Data Transfers
Your Rights
Contact Details

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice that we may provide at or around the time that we collect or process personal data about you so that you are fully aware of how and why we are using that data.

This Privacy Policy supplements other notices and legal documents including the Spaceground End-User Licence Agreement (“EULA”) and is not intended to override or replace them.

By downloading and/or using our App, you agree to its terms (including as amended from time to time) and this Privacy Policy. If, for any reason, you do not agree to the terms of this Privacy Policy, please stop using the App.

We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to e-mail all of our registered users to make sure that they are informed of such changes. However, it is your responsibility to check this Privacy Policy before each use of the App.

Please note that the App is not intended for use by nor directed at anyone under the age of 16 and we do not knowingly collect data relating to children. If you believe we have collected personal information about your child, you may contact us at and request that we remove information about them.

What information we collect

What is personal data?

Where this Privacy Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

By law all organisations who process your personal data in Europe are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Privacy Policy.

2.2 How and what types of data we collect from you when you use the App When you use the App to register an account, fill in forms provided on the App, subscribe to our services or report a problem with the App, we may collect, store and use certain personal information that you disclose to us.

The information we collect from you may include (but is not limited to): your IP address, email address, telephone number, feedback and log-in information.

We shall also collect information about you when you visit and interact with the App through the use of technologies such as cookies. The following are examples of information we may collect:

information about your device, browser or operating system; time zone setting; your IP address; information about interactions you have with the App (such as scrolling and clicks); information about the way you use and the actions you take within the App; length of time on the App and time spent within certain sections; response times; and download errors. Please refer to your device’s help material to learn what controls you can use to remove cookies, block cookies, or disable IDFA tracking. If you do this, it may affect your use of a Website or an App.

We may also partner with third parties who may collect anonymous usage or statistical data through your use of the App (including, for example, sub-contractors in technical, payment and/or delivery services, business partners, advertising networks, analytics providers).

We may also collect information about how you use the App through Google Play’s Android Advertising ID technology and Apple iOS’s Advertising Identifier. This is used only by us and our trusted third party service providers (see “Service Providers” below) for advertising and user analytics. The advertising identifier will only be connected to personally identifiable information where you have provided us with your explicit consent. We will respect your user selections for this technology and will not use the data in any way which you have asked us not to. We are committed to abiding by Google’s and Apple’s terms of use and you may contact us (at, Google or Apple directly if you have any questions regarding our use of this technology.

Updating your information If you want to update the information you have previously given to us, you can contact us at

2.3 In total, we collect the following personal data: Personal data you provide when using our Services or creating an Spaceground account Data that identifies you, such as your name, address, telephone numbers, email addresses, your username or your tax identification number that you provide when setting up your Spaceground account or at a later date. If you use our payment services as a seller, additional identification data (such as social security number or date of birth), tax identification numbers (such as VAT identification number) and other information (such as bank account number) that you provide when using our payment services as a seller. Data regarding bids, purchases, or sales that you provide in a transaction.

Content that you share with other users through our messaging tools (see Filtering of messages sent via our messaging tools under section 11. Other important information regarding data protection for more information). Financial information (e.g. credit card and account numbers, transaction details, and form of payment). Shipping, billing, and other information you provide, as well as information required for customs clearance (such as tax identification numbers or other identification numbers) and relevant shipping information (such as shipment numbers and tracking information) if shipped through one of our programs. In some cases: age, gender, country of birth, nationality, employment status, family status, interests and preferences. You may provide us with additional information through a web form or by updating or adding information to your Spaceground account, by participating in community discussions, member chats, surveys, inquiries, dispute resolution, customer service calls recorded with your consent, or if you contact us for any other reason regarding our Services. Other data that we are required or entitled by applicable law to collect and process and that we need for your authentication or identification, or for the verification of the data we collect.

2.4 Personal data we collect automatically when you use our Services or create an Spaceground account Data that is generated as part of one of your transactions (bids, purchases, sales) or that is linked to your Spaceground account as a result of a transaction in which you are involved, such as transaction amounts, time and location of transactions and form of payment or payout method. Data that is generated through your other actions when you use our Services and which is linked to your Spaceground account, e.g. when you place items in your shopping cart, place items on the watch list, save sellers, searches or interests, or follow users. Data regarding all other interactions with our Services, your advertising preferences, and your communications with us. Location data, including your general location data (e.g., IP address) and, with your permission, the precise location data of your mobile device. Please note that for most mobile devices, you can manage or disable the use of precise location services for all applications in the settings menu of your mobile device. Computer and connection information, such as statistics regarding your use of our Services, information on data traffic to and from websites, referral URL, information on advertisements, your IP address, your access times including accessed pages within our Services, your language settings and your weblog information.

2.5 Personal data we collect in connection with the use of cookies and similar technologies We use cookies, web beacons and similar technologies to collect data in connection with our Services. We collect this data from the devices (including mobile devices) that you use our Services with. The data collected includes the following usage- and device-related information: Data about the pages you visit, the access time, frequency and duration of visits, the links on which you click and other actions you take as part of your use of our Services and in advertising and email content. Data about your activities and interactions with our advertising partners including data about the advertisements you were shown, how often they were shown, when and where they were shown, and whether you took any action, such as clicking on an advertisement or making a purchase. The user segment or category into which you as a user fall, for example: female, 20-49 years old, interested in sneakers. Model or device type, operating system and version, browser type and settings, device ID or individual device identifier, advertisement ID, individual device token, and cookie-related data (e.g. cookie ID). The IP address from which your device accesses our Services. Location data, including your general location data (e.g., IP address) and, with your permission, the precise location data of your mobile device. Please note that most mobile devices allow you to manage or disable the use of precise location services for all applications in the settings menu. For more information about our use of these technologies and your choices, see section 9. Cookies & similar technologies.

2.6 Personal data from other sources We also collect personal data about you from other sources and from third parties to the extent permitted by applicable law. In particular, this includes the following data:

Data from public sources (e.g. demographic data) Data from credit agencies or bureaus (e.g. credit reports/checks, identity confirmation, data for risk modeling and setting of credit limits) Data from data providers (e.g. "Know Your Customer"/identity verification, demographic, interest-based and online advertising related data) With regard to our payment services for sellers: data from government or other sources concerning any previous convictions of the respective seller, to the extent permitted by applicable law We combine or connect the personal data we collect from you with data from these other sources. Where personal data is disclosed to us by third parties, we take steps to ensure that these third parties are legally permitted to disclose your personal data to us. We also receive access to personal data about you from other members of the Spaceground LLC corporate family.

2.7 Social network data you share with us We allow you to use social networks (such as Facebook) or other providers of single sign-on services (such as Google or Apple) with whom you already have an account to create an Spaceground account or to link your Spaceground account to such single sign-on services. You can determine the personal data that we can access when authorizing the connection with the single sign-on service. We allow you to share personal data with social networks (such as Facebook) or to link your Spaceground account to a social network. These social networks may automatically provide us with access to certain personal data they have stored about you (e.g. content you have viewed or enjoyed, information about the advertisements you have been shown or clicked on, etc.). You can determine the personal data that we can access through the privacy settings of each social network. We may also use plug-ins or other technologies from various social networks. If you click on a link displayed through a social network plug-in, you voluntarily connect to that social network.

2.8 International data transfers Some recipients of your personal data are located outside your country or have offices in countries where data protection laws may provide a different level of protection than the laws in your country. When transferring personal data to such recipients, we provide appropriate safeguards.

Learn more about section 6 2.9 Data transfers to Spaceground LLC. The transmission of personal data between different Spaceground LLC. corporate family members (e.g. to enable cross border transactions and for other legally permitted purposes) is based on our worldwide data protection principles, which are binding internal data protection regulations (Binding Corporate Rules, BCRs), or on the basis of other appropriate safeguards (e.g. standard data protection clauses issued or approved by the European Commission (2021/914/EU, 2010/87/EU, 2001/497/EC or 2004/915/EC)). Through our Binding Corporate Rules, the Spaceground LLC. corporate family members undertake to protect your personal data and to comply with data protection obligations. Further information on our binding company-wide guidelines and our worldwide data protection principles can be found in the Spaceground Privacy Center. Other data transfers (from the European Economic Area to third countries) We may transfer your personal data to recipients (see section 5. Purposes and legal basis for data processing and categories of recipients) who may be located anywhere in the world. We will only transfer your personal data from the European Economic Area (EEA), United Kingdom or Switzerland to third countries, i.e. countries outside the EEA, on the basis of appropriate safeguards or if otherwise authorized by applicable law. Third countries providing an adequate level of data protection according to the European Commission currently include Andorra, Argentina, Canada (for companies covered by the Personal Information Protection and Electronic Documents Act), Switzerland (for transfers out of the EEA), the Faroe Islands, Guernsey, the State of Israel, the Isle of Man, Japan, Jersey, New Zealand, the United Kingdom and Uruguay. In other cases, Spaceground provides the necessary safeguards, e.g. through the conclusion of data protection contracts adopted by the European Commission (e.g. standard data protection clauses (2021/914/EU, 2010/87/EU, 2001/497/EC or 2004/915/EC)) with the recipients, or through other measures provided for by law. A copy of the documentation of the measures taken by us is available on request. We regularly reevaluate the measures taken to assess requirements deriving from new regulatory guidance and case law, e.g. from the Court of Justice of the European Union (CJEU) decision in the matter C-311/18.

How and why we use/share your information

Lawful basis for processing your information We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:

Where you have asked us to do so, or consented to us doing so; Where we need to do so in order to perform a contract we have entered into with you; Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and Where we need to comply with a legal or regulatory obligation. Marketing You will receive marketing messages from us if you have given us your consent to do so or if you have provided feedback on our App and have not opted out of receiving marketing messages.

To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us to inform us if you do not wish to receive any marketing materials from us.

Sharing your information Depending on how and why you provide us with your personal data, we may share it in the following ways:

we may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006; with selected third parties including business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you (see “Service Providers” below); or with analytics that assist us in the improvement and optimisation of the App. We may also disclose your personal information to third parties in the following events:

if we were to sell or buy any business or assets, in which case we might disclose your personal information to the prospective seller or buyer of such business or assets; if Spaceground or substantially all of its assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets; or if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply the EULA; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. Service Providers Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. At present Amazon Web Services, Google Analytics, Amplitude, Branch, SendGrid, and Firebase are trusted third party service providers of ours.

Other Disclosures During your use of the App, your app store provider and mobile network operator may also collect personal information about you regarding your use of the App such as your identity, your usage and location.

These third parties shall act as separate and independent controllers of that personal data and shall process it in accordance with their own privacy policy.

Links to third party sites The App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. We may also provide links to third party websites that are not affiliated with the App. All third party websites are out of our control and are not covered by this Privacy Policy. If you access third party sites using the links provided, the operators of these sites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.

How long we keep your information

We will hold your personal information on our systems only for as long as required to provide you with the products and services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


Spaceground takes the protection of your information very seriously. We have put in place appropriate physical, electronic and managerial security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers, passwords and industry standard encryption for data both in transit and at rest (for data in transit we use up-to-date versions of SSL and for data at rest we use AES-256).

Where we have given you a password that enables you to access certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

International Data Transfers

Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your request for information, products and services, the processing of your payment details and the provision of support services.

Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. Transfers of personal data are either made:

to a country recognised by the European Commission as providing an adequate level of protection; or to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection. By submitting your personal information, you agree to this transfer, storing or processing. If you would like more information about how the mechanism via which your personal data is transferred please contact

Your Rights

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have as well as how you can exercise them.

Right of Access You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”). Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data. You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right.

You may also ask us to erase personal data that we control if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”). Although we will do everything to respect your request and personal data it may not always be possible to erase all of your personal data as there may be legal requirements to keep certain personal data or technical limitations to the data we can delete; for example, we are not able to satisfy requests to erase records and information recorded on the blockchain, including, but not limited to, your chosen user name, your transaction history and your account balance.

There may also be legitimate interests in keeping certain data including, amongst others, if the data is required for the App to function. If this is the case we will continue to process this data.

If erasure is not technically possible or we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you this and our reasoning at the time we respond to your request.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing Where we process your personal data on the basis of a legitimate interest you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request. Your Right to Portability Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to object to processing You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

Your Right to stop receiving communications For details on your rights to ask us to stop sending you various kinds of communications, please contact us.

Your Right to object to automated decision making and profiling You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Withdrawal of consent Where we are relying on consent to process your personal data you may withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Exercising your rights When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at

You also have the right to lodge a complaint to the Information Commissioner’s Office (ICO), the US supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.