Privacy statement Spotler Engage

In this privacy statement you can read how OBI4wan B.V. (the entity behind Spotler Engage) handles the processing of personal data within the context of the General Data Protection Regulation (GDPR) with regard to its own processing of personal data, as well as for the processing of personal data on behalf of its customers.

Spotler Engage is located at (1506 MA) Zaandam, Korte Hogendijk 2. Spotler Engage is registered as OBI4wan in the Business Register of the Dutch Chamber of Commerce under 53021029.

1. For whom is this statement relevant

This Privacy Statement applies to all users of our services and visitors to our website. This privacy statement explains how we collect, process and use personal data about you.

2. Who is Spotler Engage ?

Spotler Engage is a private limited company with its registered office at Korte Hogendijk 2, 1506 MA Zaandam in the Netherlands and registered with the Chamber of Commerce under number 53021029.

3. What does Spotler Engage do?

Spotler Engage offers software solutions with the following names (Media Monitor, Engage and Bots) for brand monitoring, centralized digital customer service communication related to webcare, messaging, social media publishing and monitoring and chatbots.

3.1 Media Monitoring & Reputation Management:

The goal of Media Monitor is to enable customers to learn more about their brand, their consumers, their competitors, and act with greater confidence in their marketing and communications. For the purpose of Media Monitor, Spotler Engage obtains data through search queries, web crawling or by contracting directly with content providers to access the data. This information is then collected, indexed and stored in the database to assess current trends in the brand image and enable the customer to take action on these trends. Spotler Engage offers clients access to its database, as well as analyzes of the data in that database.

3.2 Web Care & Messaging:

The goal of Engage is to centralize customer service communications between customers and organizations. Engage includes webcare, messaging, social media publishing and monitoring functions. It combines the social media accounts owned or managed by organizations in one tool. This enables organizations to send public and private messages to customers, publish content and manage social media accounts.

Based on the organization’s permission, Spotler Engage collects the information related to the social media accounts and messaging applications and centralizes it in its solution so that it is only available to the organization itself. Engage also integrates brand monitoring capabilities as part of Spotler Engage’s ongoing process to merge Engage and Media Monitor products into one.

3.3 Insights:

The goal of Insights is to help customers gain insights from their data. A team of professional media analysts help companies with insights into, among other things, the impact, reputation, target group, media value and KPIs of their organization.

All insights, conclusions and advice are presented clearly and clearly in reports. Infographics, key take-outs, management summaries and the corporate identity of the customer organization bring the data to life. In this way, the customer can immediately share the information with its stakeholders.

3.4 Chatbots & Communication:

The goal of Bots is to help customers automatically answer customer questions 24/7 through digital channels combined in one solution. This includes live chat, messaging and social media accounts (Facebook messenger, Whatsapp, Twitter DM and custom channels).

These automatic answers are established by the organization and the chatbot is trained to recognize questions based on previous conversations by the organization itself, so that it can perform its customer service functions. Note that the employees of Spotler Engage’s customers can also create and exchange message content via OBI Chatbot.

4. Why we collect personal data and from what sources

Spotler Engage collects information, including personal data, from a large number of sources in order to provide the above services to its customers. Spotler Engage collects two types of information, namely publicly available information from the public domain and private information from a specific customer.

4.1 Publicly available information

Publicly available information is information that has not been obtained directly from the data subject but has been expressly made public by the data subject on the Internet by publishing it on public websites, internet forums and social media platforms. This publicly available information is obtained through searches, web crawling, or by contracting directly with content providers to access the data.

This publicly available information may include the following personal data:

  • Identifiers: name, username, handle or other identifier;
  • Content Information: the post content published under that name, username, avatar or other identifier (e.g., comments, expressions, opinions, posts, etc.);
  • Audio/visual information: profile picture or other images or videos that have been posted or interacted with;
  • Location information: location (level of detail depends on what is provided by data source). (is consciously activated by the user himself)

4.2 Private information

Private information is information obtained by the customer under Article 5 of the GDPR from the data subject and for which Spotler Engage only acts as the processor of that information on behalf of the customer. This information is used exclusively to support that specific customer with its customer communication through a SaaS platform from Spotler Engage.

This private information may contain the following personal data:

  • Identifiers: name, username, handle, or other identifier;
  • Content information: the content published under that name, username, handle, or other identifying information (e.g., comments, expressions, opinions, messages, etc.);
  • Audio/visual information: profile picture or other images or videos that have been posted or interacted with;
    Demographic information: interests and gender;
  • Location information: location (level of detail depends on what is provided by data source). (is consciously activated by the user himself)

4.3 Information sources

Spotler Engage collects, processes and stores both publicly available information and private customer information from, among others, the following platforms and websites:

  • Social media platforms
  • Review websites
  • forums
  • Blogs
  • News websites

In addition, Spotler Engage also offers its customers, under a paid license, content from newspapers, publishers and platforms:

5. How we use your personal information

Spotler Engage uses the information collected, including any personal data, to provide the services mentioned in paragraph 3 to our customers.

Our legal basis for this type of data processing is that we have a legitimate interest in operating our business and providing our services to our customers, including providing technology that enables our customers to act with greater certainty in a way that is easy and user-friendly. is..

However, the legal basis for our processing of data may also be where we have your consent (for example where consent is required to send certain marketing communications) or where the processing is necessary to comply with our legal obligations (for example where we receive requests from regulatory authorities ).

6. How long we keep your Personal Data

6.1 Publicly available information

Information that Spotler Engage collects from public sources is kept for a period of 3 years. This gives Spotler Engage customers the opportunity to compare information with previous periods and to make analyzes based on historical data. After a period of 3 years, this data is permanently deleted from our databases and not collected again.

6.2 Private Information

The private information that Spotler Engage processes for its customers is kept in accordance with the customer’s information retention period. The customer determines how long the information should be kept and if the customer terminates its agreement with Spotler Engage, all private information of the customer is permanently removed from all systems and databases of Spotler Engage.

The only possible exception to the aforementioned retention periods is if Spotler Engage is legally obliged to keep this information for longer or if a data subject requests to delete his/her information.

7. Who We May Share Your Personal Data With

7.1 Internal

For the processing of information and to support customers, it is necessary that employees of Spotler Engage have access to the collected and stored information. It is Spotler Engage’s policy to limit the number of employees with access to the information to a minimum. In addition, all Spotler Engage employees have signed a confidentiality agreement.

7.2 Customers

The collected information is only made available to customers by Spotler Engage through its SaaS products. The publicly available information may be shared with all customers. The private information is only made available to the customer for whom the information was collected and is never shared with third parties.

7.3 Sub-processors

Spotler Engage uses so-called sub-processors to collect, process and store information. These sub-processors are part of the production process and it is therefore technically necessary for these parties to gain access to the information. However, the sub-processors are not entitled to view or use the information for their own purposes. Spotler Engage has agreements with all its sub-processors in which the use of this information is protected from use and misuse.

8. YouTube API Disclosure

Additional Information Concerning Use or Access to YouTube Services.

Spotler Engage uses YouTube application programming interface (API) services (YouTube API Services) to make it easier for an organization’s administrative users to retrieve and share video content with Individual users. When an administrative user makes use of or accesses YouTube API Services, such use and access is subject to the YouTube API Services – Developer Policy.

The API Client stores, accesses, or collects (or allows third parties to do so) information directly or indirectly on or from users’ devices, including by placing, accessing, or recognizing cookies or similar technology on users’ devices or browsers.

Spotler Engage does not use YouTube API Services to collect, access, share with external parties, or serve third party advertisements to Individual users, including by way of Google or YouTube end user credentials. Spotler Engage use of the YouTube APIs is subject to Spotler Engage Privacy Policy.

When an Individual or Organizational user makes use of or accesses YouTube (whether through the YouTube API Services or otherwise), such use or access is governed by YouTube’s Terms of Service and Google Privacy Policy.

9. How We Protect Your Personal Information

9.1 Protection of personal data

Spotler Engage complies with the legislation as laid down in the General Data Protection Regulation (“GDPR”) and, as a processor of personal data, also makes every effort to protect the rights of the data subject.

Spotler Engage has appointed a Data Protection Officer (“DPO”) who supervises the application and compliance with the General Data Protection Regulation within the organization.

9.2 Information security

Spotler Engage is ISO 27001 certified for its information security. Spotler Engage’s information security management system is documented and audited annually by an independent third party.

9.3 Service conditions

Spotler Engage provides its services under the terms of service of the social media platforms from which the information is obtained. Spotler Engage does not change the messages and passes on the information unedited to its customers.

Spotler Engage also does not use algorithms to make automated decisions about you that violate applicable law or in any way that has significant legal effect.

10. Where we store your data

Spotler Engage uses two secured Dutch data centers for the processing and storage of the information. In view of the large amount of data, Spotler Engage also uses cloud services from renowned providers such as Google Cloud and Amazon Web Services. All personal data is stored and processed within the European Economic Area.

11. Your privacy rights

You have rights in relation to your data under applicable data privacy laws. Subject to applicable law, you can:

  • request access to the Personal Data we hold about you;
  • ask us to update, correct, delete, opt-out of sale or block your Personal Information;
  • request that we stop using any personal data we hold about you;
  • lodge a complaint about our use of your Personal Data with the data protection authority of the country in which you reside. If you have a complaint about our data practices, we hope you contact us first so we have a chance to resolve your concerns;
  • not be discriminated against for exercising your privacy rights.

To exercise any of these rights, ask us questions, raise concerns, or request a copy of this statement in a different format, please submit a verifiable request to us at:

email us at;


call us on (+31)85-210 5060

Only you, or a person you have authorized to act on your behalf, may make a request regarding your Personal Data. If you make a request through an authorized agent, the agent must provide a signed written consent to act on your behalf, and you may also be required to independently verify your identity with us.

To protect your personal information, we may ask you to provide additional personal information so that we can verify your identity. Any information you provide will only be used as part of the process to confirm your identity and complete your request. To protect your personal information, if we are unable to verify your identity, we will not be able to comply with your request.

After you submit a request, you can expect an initial response from the Spotler Engage Privacy Team within a reasonable time, depending on where you live. Except where the law does not require or permit us to do so, any information we hold about you will be provided in an easily accessible and portable format once we receive your verifiable request. We will adhere to the appropriate response timeline that applies to you, depending on where you live. We may request additional time in accordance with applicable law if necessary.