PRIVACY POLICY

Last updated: 23 September 2026

This Privacy Policy explains how personal data is processed when you use SPT.SN.

1. Data controller

The controller responsible for the processing of your personal data is:

Alcor Consulting, poslovno svetovanje d.o.o.
Pavšičeva 3
1000 Ljubljana
Slovenia

Company registration number: 8929262000
VAT ID: SI48758523

Email: office@aihub.pro
Telephone: +386 69 607 654

2. Scope

This Policy applies to the SPT.SN website, applications and related online services.

It does not govern independent third-party websites, ticket providers, event organisers or other services that act as separate controllers of personal data.

3. Minimum account age

You must be at least 15 years old to create an SPT.SN account.

SPT.SN is not intended to collect account data from children under 15.

If we become aware that an account has been created in violation of this rule, we may take reasonable steps to restrict the account and delete personal data where appropriate, subject to legal retention requirements.

4. Personal data we may collect

Depending on the features you use, we may process the following categories of personal data.

Account and profile data

This may include:

name;
email address;
date of birth;
gender;
profile photograph or avatar;
username;
account settings;
authentication information.

Social login data

If you sign in using Google or another supported authentication provider, we receive information made available through that provider according to the permissions you approve.

Location data

If you enable location functions, we may process approximate or precise location information to provide location-based event discovery and recommendations.

Contacts

If you grant access to contacts or use contact-based features, information relating to contacts may be processed for functions such as finding contacts, sharing events or sending invitations.

We do not use imported contact information for unrelated direct marketing to those contacts.

User-generated content

We may process content that you publish or submit, including:

events;
event descriptions;
comments;
photographs and images;
messages;
Entity or Business information;
other content submitted through SPT.SN.

Publicly posted content may be visible to other users or to the public depending on the relevant feature and privacy settings.

Activity and preference data

We may process information about how you use SPT.SN, including:

viewed events;
saved or favourited events;
followed users or organisations;
interests;
searches;
recommendations viewed or interacted with;
social interactions;
participation in or interest in events.

Technical information

We may process:

IP address;
device type;
operating system;
browser information;
application version;
identifiers and cookie information;
access logs;
diagnostic and security information.

Communications

If you contact us, we process the content of your communication and related contact information.

5. Why we process personal data

We may process personal data for the following purposes.

Providing the Service

This includes:

creating and managing accounts;
authenticating users;
displaying profiles and content;
enabling creation and discovery of events;
providing social and communication features;
storing favourites and preferences.

The principal legal basis is performance of a contract or taking steps at your request before entering into a contract.

Location-based discovery

Where you choose to use location services, location data may be processed to identify relevant nearby events and improve recommendations.

Device permission and, where legally required, your consent are used for access to precise device location.

Personalisation and recommendations

We may use interests, activity and location information to personalise the Service and recommend events or content that may be relevant.

Depending on the processing involved, the legal basis may be performance of the Service, our legitimate interests in improving relevance and usability, or consent where required by law.

These recommendations are not intended to make decisions that produce legal effects or similarly significant effects concerning you.

Social features

We process information needed to enable followers, Circles, contacts, invitations, comments, chats, sharing and other social functionality.

The legal basis is generally performance of the Service requested by the user and, where applicable, legitimate interests in operating social features.

AI-assisted functionality

Search queries, event information and other relevant content may be processed using AI providers in order to provide search, recommendation, categorisation, summarisation or similar functions.

Depending on the feature, this processing may involve providers such as OpenAI and OpenRouter.

Users should avoid including unnecessary confidential or sensitive personal information in AI prompts or search requests.

Communications and service messages

We may send account, security, operational and service-related communications where necessary to provide the Service.

Newsletter and marketing communications

Where required by law, promotional email, SMS or other direct marketing communications are sent based on your consent.

You may withdraw marketing consent at any time using the unsubscribe mechanism or by contacting us.

Withdrawal does not affect service or security communications that are necessary for operation of your account.

Analytics and improvement

Subject to your consent where required, we may use analytics technologies to understand:

website and application usage;
navigation and interactions;
technical performance;
errors;
general user behaviour.

These technologies may include Google Analytics and Microsoft Clarity.

Non-essential analytics technologies will only be activated after the required consent has been obtained.

Security and abuse prevention

We may process technical information, logs and account activity to:

protect accounts;
prevent fraud;
detect abuse;
protect our infrastructure;
investigate security incidents.

The legal basis is our legitimate interest in maintaining a secure and reliable Service and, where applicable, compliance with legal obligations.

Legal obligations and claims

We may process personal data where necessary to:

comply with applicable law;
respond to lawful requests by public authorities;
establish, exercise or defend legal claims;
enforce our Terms of Use.

The legal basis is compliance with legal obligations and/or our legitimate interests.

6. Service providers and recipients

We may disclose or make personal data available to service providers where necessary to operate SPT.SN.

Current providers may include:

DigitalOcean — hosting and cloud infrastructure;
Google — Google Maps, Google Geocoding, Google Analytics and Google authentication;
Microsoft — Microsoft Clarity;
SendGrid — email delivery;
Twilio — communications services;
OpenAI — AI functionality;
OpenRouter — access to AI models and AI functionality.

We may also disclose data:

to event or ticket providers where necessary for a feature requested by you;
to professional advisers and contractors subject to confidentiality obligations;
to public authorities where required by law;
in connection with a merger, acquisition, restructuring or transfer of business, subject to applicable data protection requirements.

Third-party ticket providers or event organisers may act as independent controllers for data that they collect directly from you.

7. International transfers

Some service providers may process personal data outside Slovenia or outside the European Economic Area.

Where personal data is transferred outside the EEA, we use legally recognised transfer mechanisms where required, which may include:

a European Commission adequacy decision;
Standard Contractual Clauses approved by the European Commission;
other safeguards permitted under applicable data protection law.

Additional information about relevant safeguards may be requested by contacting us.

8. Tickets and external providers

When SPT.SN directs you to, or technically integrates with, an external ticket or booking provider, that provider may collect personal data directly from you.

Unless expressly stated otherwise, SPT.SN does not act as the seller or payment recipient for the ticket.

The relevant ticket provider's privacy policy governs its independent processing of your personal and payment data.

9. Cookies and similar technologies

SPT.SN may use cookies, local storage and similar technologies.

Strictly necessary technologies

These may be used without optional consent where necessary for functions such as:

authentication;
security;
session management;
storing privacy or consent choices;
technical operation of the Service.

Analytics technologies

Analytics tools such as Google Analytics and Microsoft Clarity are non-essential.

Where consent is legally required, these technologies must not be activated before you provide consent.

You must be able to reject non-essential technologies and later withdraw or modify your choice.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

10. Google Maps and location services

SPT.SN uses Google Maps and Google Geocoding for mapping and location-related functionality.

When these functions are used, technical and location-related information may be transmitted to Google.

Google may process such information under its own privacy documentation and, depending on the implementation, as a processor or independent controller for particular processing activities.

11. Analytics

Subject to consent where required, we may use:

Google Analytics to analyse traffic and use of the Service.

Microsoft Clarity to analyse interactions with website interfaces and understand usability.

We may also use Google Search Console and developer tools to understand search visibility, application operation and technical performance. These services do not necessarily receive the same categories of data as browser-based analytics tools.

12. Email and messaging

We may use SendGrid and Twilio to deliver transactional messages, verification messages, notifications or communications requested through the Service.

Marketing communications will be handled in accordance with applicable consent and electronic communications requirements.

13. Data retention

We retain personal data only for as long as necessary for the purpose for which it was collected, taking into account legal, accounting, security and dispute-resolution requirements.

In general:

account data is retained while the account remains active;
User Content is retained while published or otherwise needed to provide the Service;
deleted information may remain temporarily in backups;
security and technical logs may be retained for a reasonable period for security and troubleshooting;
consent records may be retained as evidence of compliance;
information required by law or necessary for legal claims may be retained for the applicable limitation or statutory period.

When personal data is no longer required, it is deleted or anonymised where reasonably possible.

14. Account deletion

You may request deletion of your account.

Deleting an account does not necessarily result in immediate deletion of every piece of information.

We may retain information where necessary:

to comply with law;
to resolve disputes;
to investigate fraud or abuse;
to establish or defend legal claims;
in temporary backup systems.

Content that involved other users, such as messages or discussions, may need to be retained or de-identified to preserve the integrity of conversations or records.

15. Your data protection rights

Subject to the conditions and limitations of applicable law, you may have the right to:

obtain information about processing;
access your personal data;
correct inaccurate data;
request deletion;
request restriction of processing;
object to processing based on legitimate interests;
receive certain data in a portable format;
withdraw consent at any time where processing is based on consent;
lodge a complaint with a supervisory authority.

Where you object to direct marketing, we will stop using your data for that purpose.

Requests may be sent to:

office@aihub.pro

We may need to verify your identity before processing a request.

16. Supervisory authority

You have the right to lodge a complaint with the competent data protection supervisory authority.

In Slovenia, the supervisory authority is the Information Commissioner of the Republic of Slovenia (Informacijski pooblaščenec).

17. Security

We use reasonable organisational and technical measures designed to protect personal data against unauthorised access, alteration, disclosure, loss or destruction.

No online system can be guaranteed to be completely secure.

Users are responsible for keeping account credentials confidential and should notify us if they suspect unauthorised access.

18. Public information and social functionality

Information that you intentionally publish publicly may be visible outside your immediate social circle and may be copied or shared by others.

Before publishing personal information, photographs or location-related information, consider whether you want that information to be public.

19. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in the Service, technology, providers or legal requirements.

The current version will be published through SPT.SN with the date of the latest update.

Where changes materially affect registered users, we will provide additional notice where required by law.

20. Contact

For privacy questions or requests:

Alcor Consulting, poslovno svetovanje d.o.
Pavšičeva 3
1000 Ljubljana
Slovenia

Email: office@aihub.pro
Telephone: +386 69 607 654