This privacy policy applies to the processing of personal data by Spenn Group AS (hereinafter referred to as ‘Spenn Group’, ‘we’ or ‘us’) when you are in contact with us and in connection with your use of Spenn and the Spenn platform. The privacy policy applies to both our website, www.spenn.no and the Spenn platform.
Personal data means any information relating to an identified or identifiable natural person. This statement contains information about your privacy rights and how we process your personal data.
Spenn Group is the data controller for the personal data we process. This means that we are responsible for ensuring that the processing takes place in accordance with data protection legislation.
We would like to hear from you if you have any questions or objections to how we process your personal data or if you wish to exercise your rights.
You can contact our data protection officer at privacy@spenngroup.com
Our contact information:
Company name and business registration number: Spenn Group AS, 932 435 888
Address: Inkognitogata 33, 0256 OSLO, Norway
Email: privacy@spenngroup.com
Please note that the providers of the loyalty programmes that issue Spenn are responsible for their processing of your personal data unless otherwise specified.
For information about your rights and how you can exercise them, please see Section 8 below.
By becoming a Spenn user, you will be able to receive personalised content, recommendations and marketing messages based on your interests and preferences and you can earn and use Spenn across various eligible partners and loyalty programmes. The Spenn platform aims to unify and make available the benefits of different loyalty programmes through a single app with the same flexible point and offer Spenn users added value beyond what each individual partner and loyalty programme provides. The Spenn platform does not replace the partners' loyalty programmes.
See www.spenngroup.com/terms-conditions (‘terms and conditions’) for further details on the Spenn platform and Spenn's flexible points.
4.1 Create and manage your Spenn account
We collect and process your name, address, telephone number, email address, year of birth and country of residence in order to create and administer your Spenn user account. This information is collected when you register on the Spenn platform and make changes to your account or may be received from a loyalty program of which you are a member. We use your birth year to make sure that you are old enough to use Spenn. The minimum age to create a Spenn account is 16 years old. We need to know which country you live in to show you content in the correct language and to provide you with Spenn based on the correct currency. We assign you internal, system-generated identifiers (e.g. Spenn user ID and administrator ID if you have a Spenn account) that will be associated with your Spenn account in our systems. We may process the personal data for these purposes because it is necessary to enter into and fulfil our agreement with you (terms and conditions).
4.2 Customise the Spenn platform to your preferences and interests
One of the main purposes of the Spenn platform is to provide you with personalised content, recommendations and marketing messages, so that you can get the most out of your membership. For example, it may be to show you relevant product categories in the Spenn app based on which Deals you have clicked on and used or to show you new partners in the Spenn universe based on which other partners you shop with. You may also be offered benefits, discounts or rewards when you use Spenn to purchase goods and services from our partners. In order to offer you personalised service, we need to know more about your interests and preferences. We acquire these by processing personal data about you, including:
How you use the Spenn app and the rest of the Spenn ecosystem;
Which loyalty programmes you have joined;
Your country of residence and, if applicable, your city/town of residence;
Your age;
Purchase history that we obtain from the loyalty programmes associated with your Spenn account (if the loyalty programme shares purchase history);
How you respond to recommendations and campaigns; and
Responses to surveys and contests.
We collect the personal data from you, from our partners when you make purchases or from other third parties, such as advertising partners and analytics service providers.
We use various techniques, including artificial intelligence, to process the personal data. With the help of the analyses, we create a profile. The profile helps us understand which goods and services you are interested in, so that we can show you relevant content, recommendations and marketing messages.
Sometimes, we place you in a segment with other customers with similar interests and preferences, so that you can get similar content, recommendations and marketing messages.
We'll show you personalised content, recommendations and marketing messages through various channels, including:
Spenn app home screen;
Email;
SMS;
Push notifications;
In external channels that we do not control personally, such as our partners' apps, social media (such as Instagram, Facebook and Snapchat) or in online newspapers (such as Schibsted or Amedia).
When we show you marketing messages in external channels, we need to exchange personal data with the relevant channel. We do this so that they can see whether you have a user account with them and show you the right content from us. We always share as little personal information as possible and whenever possible, we mask any personal information that could easily help identify you (such as your phone number and email address). The external channel is not permitted to use any personal data it receives for purposes other than those we determine.
You choose whether you want to consent to personalised content, recommendations and marketing messages. You can withdraw your consent at any time by changing the settings in your Spenn account. If you agree, we will show you personalised content, recommendations and marketing messages in the Spenn app. You can choose whether you want personalisation through the other channels mentioned above. You do this by changing your communication options in the Spenn app.
4.3 AI system training
In order to be able to show you personalised content, recommendations and marketing messages, the AI systems we use to create the profile about you must be adapted to the purpose. This requires that the AI systems must be trained and continuously improved. For this purpose, we use, among other things, the personal data described in other sections of this privacy policy.
We may process personal data for this purpose because it is necessary to fulfil our legitimate interests in providing our members with relevant and personalised content, recommendations and marketing messages. We have determined that our legitimate interests do not disproportionately interfere with the rights, freedoms and interests of our members. You have the right to object to our use of personal data for training and improving algorithms.
4.3 Earning and using Spenn
We process information received from our business partners in order to issue Spenn to you and information about your use of Spenn to ensure that the correct amount of Spenn is deducted from your account when you use Spenn.
The types of personal data that are processed include user data, transaction history (if the loyalty programme shares this with us), Spenn earned or used in the transaction, payment information and consent information.
The processing described in this section is necessary for the performance of our agreement with you (terms and conditions).
4.5 Verify whether our services are available in your country
You will be asked to provide information about your country of residence when you create a Spenn account, so that we can link that country to your account. This enables us to provide services that meet the legal, linguistic and content-related requirements of your region.
The types of personal data processed include account data.
The processing described in this section is necessary for the performance of our agreement with you (terms and conditions).
4.6 Spenn Together
When a Spenn Together administrator invites you to join their Spenn Together account, we receive some personal information about you from the administrator and send you an email invitation. If you accept, your Spenn account will be linked to the Spenn Together account in our systems.
The types of personal data that are processed in order to invite you to a Spenn Together account and link you to the Spenn Together account are user data and account data.
The legal basis for this processing is our and the administrator's legitimate interest in extending the benefits of the Spenn Together account to you. This processing activity does not constitute a disproportionate interference with your rights and freedoms, as it is assumed that the invitations come from someone you know and that the invitation typically comes at the user's request.
4.7 We process personal data to communicate with you
4.7.1 When you contact our customer service team
When you contact us either via our platform or social media, we process personal data about you. The personal data we typically collect includes user data and any other information you provide to us that is necessary for us to respond to you.
The processing described in this section is necessary for the performance of our agreement with you (terms and conditions). If you do not have a Spenn account, we may process personal data for this purpose because it is necessary to fulfil both your and our legitimate interests when you contact customer service. The processing of personal data does not constitute a disproportionate interference with your rights, freedoms or interests.
4.7.2 To send you important notifications about our services
We have an obligation to keep you updated on changes and updates to our services, which include our terms and conditions, privacy policy and other technical and security notifications.
This information can be provided through various channels, such as email, SMS, in-app messages or notifications. This communication is important and you cannot choose not to receive it.
The types of personal data processed include user data, account data, consent data and technical data.
4.8 Evaluate the effectiveness and performance of our services and features
We analyse how the Spenn app and website function to understand how our services and features are used, how often they are used and how they can be improved.
For this purpose, the following types of personal data will be processed: usage data, user data, payment data and purchase data.
The legal basis for our processing is our legitimate interest in improving and developing the Spenn platform for the benefit of our users.
4.9 Product and service development
We use user feedback and other pseudonymised or anonymised personal information to develop, test and evaluate new services and features, including design and adoption measurements.
For this purpose, the following types of personal data are processed: user data, usage data, payment data, purchase data, technical data, anonymised insights from profiles and segments used to personalise content, recommendations and marketing messages.
The legal basis for our processing is our legitimate interest in improving and developing the Spenn platform for the benefit of our users.
4.10 Analysis, forecasting and reporting purposes
We measure and analyse how our services function and prepare internal reports that form the basis for business decisions, marketing campaigns and product development. We use anonymised information for this purpose.
The types of personal data that are anonymised for this purpose include user data, usage data, payment data, purchase data and technical data.
The legal basis for the anonymisation is our legitimate interest in improving and developing Spenn's services and the user experience.
4.11 We process data to diagnose, troubleshoot and resolve technical and security issues
We collect information about errors, crashes, bugs and other technical issues and security incidents from your device. This data is processed in our internal logging systems to help resolve issues and prevent future incidents.
The types of data processed for this purpose include user data, payment data and technical data. The processing described in this section is necessary for the performance of our agreement with you (terms and conditions).
4.12 Test whether our services are functioning properly
We anonymise user data and technical data so that we can test to ensure that our services and features are functioning properly.
The processing described in this section is necessary for the performance of our agreement with you (terms and conditions).
4.13We process data to comply with legal obligations
We are required by law to process personal data in certain cases, such as to document compliance with obligations related to tax, accounting or legal processes. In this regard, it may be necessary to process personal data about you. This may be necessary, for example, if your name is listed on an invoice or contract that is subject to a retention obligation.
The legal basis for such processing is the legal obligation to which we are subject. The data will be deleted when the purpose of the processing has been fulfilled, such as when the reporting obligation has been fulfilled or we are no longer required to store the data.
The personal data we process is collected directly from you, such as when you provide us with information in connection with the registration of your Spenn account or through your use of the Spenn app. Furthermore, we receive information from our partners, who offer you various benefit programmes when using Spenn, advertising partners and providers of analysis services.
6.1 Data processors
Your personal data will be accessible to those of our suppliers who process personal data on our behalf. We have entered into data processing agreements that ensure, among other things, our control and that your personal data cannot be used for other purposes.
Some of our suppliers are located in countries outside the EU/EEA, which means that personal data may be transferred to or is accessible from a country with regulations that do not provide the same level of protection of personal data compared to the rules in Norway. To ensure your privacy, such transfer will only take place if we can ensure that your data has the same level of protection as in the EU/EEA through other measures.
You can obtain an overview of our data processors by contacting us.
6.2 Our partners
Spenn Group's partners receive personal data about Spenn users to the extent necessary to facilitate the earning and use of Spenn or other functions on the Spenn platform that require us to disclose personal data to partners.
Data sharing with our partners will only take place to the extent that this is legally permitted and necessary to implement, market and operate the Spenn platform and create and offer value-adding analyses and insights that each partner could not have created outside of the Spenn platform.
The categories of personal data that Spenn Group shares with partners include user data (SpennID), usage data and transaction data.
To learn more about the types of data our partners share and collect about you, we recommend that you read the privacy policies of the partners' loyalty programmes of which you are a member.
In some cases, Spenn Group and our partners will act as joint data controllers and together ensure that your personal data is processed in accordance with the GDPR. In this case, you will receive information about how we have determined to share the responsibility for protecting your personal data between us.
We only retain personal data that we have received from you or our business partners for as long as it is necessary to fulfil the purposes for which it was collected. At your request, we will delete all personal data about you within 30 days, as long as the data is not subject to any legal obligation that requires us to keep it. If our legal basis for processing is your consent, we will delete the data if you withdraw your consent. You can withdraw your consent at any time through the settings in the Spenn app by following the steps described in marketing emails or SMS received from us or by submitting a request as described in Section 8.
You have the privacy rights listed below. Certain conditions must be met in order for them to be enforceable and exceptions to the rights may apply.
Access: You have the right to request information about how we process your personal data and to obtain a copy of the personal data.
Rectification: You have the right to request the correction of inaccurate personal data about you and to have incomplete personal data about you completed if incomplete.
Object: You have the right to object to the processing of your personal data, which is based on our legitimate interests.
Erasure: You have the right to request the deletion of your personal data (subject to certain conditions).
Automated decision-making: You have the right to object to a decision being made about you that is based solely on automated processing, if that decision has a legal impact on you or significantly affects you. We do not use automated individual decision-making for such purposes.
Restriction: You have the right to ask us to restrict the processing of your personal data, so that we no longer process this data until the restriction is lifted.
Data portability: You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to have the data transferred to another organisation in certain circumstances.
Withdraw consent: You have the right to withdraw your consent to processing that requires consent at any time. To exercise any of these rights, please contact privacy@spenngroup.com. You can contact our data protection officer for assistance with any questions or issues related to the exercising of your rights. The contact details of the data protection officer can be found in Section 2.
Complaint: You have the right to complain to the Norwegian Data Protection Authority (Datatilsynet) if you have reason to believe that the processing of your personal data is not in accordance with data protection legislation. Visit their website (www.datatilsynet.no) for information on how to appeal.
We update this privacy policy if there are changes to how we process personal data. You can always find the most up-to-date privacy policy on www.spenngroup.com/privacy-policy. We inform you directly on our website and in the Spenn app before substantial changes are made to this privacy policy.
Date of last update: 24.04.2026