Privacy Policy — Spotlight Digital

Spotlight Digital LLC Privacy Policy

Spotlight Digital LLC, and it’s affiliates (“Spotlight”, “Spotlight Digital”, “we”, “us”, “our”)

provide this privacy policy to set forth our privacy practices with respect to information

collected from users who access our website or otherwise share personal information

with us.

Grounds for data collection

Processing of your personal information (meaning any information which may potentially

allow your identification with reasonable means; hereinafter "Personal Information") is

necessary for the performance of our contractual obligations towards you and providing

you with our services, to protect our legitimate interests and for compliance with legal

and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other

uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make

informed decisions.

What information we collect

(1) We collected the following categories of Personal Information:

A. Identifiers, such as name and government-issued identifier (e.g., Social Security

number);

B. Personal information including without limitation, name, signature, SSN, physical

characteristics or description, address, telephone number, passport number, driver’s

license or state identification card number, insurance policy number, education,

employment, employment history, bank account number, credit card number, debit card

number, or any other financial information, medical information, or health insurance

information;

C. Characteristics of protected classifications including without limitation, age, gender,

medical conditions, marital status, sex (including pregnancy, childbirth, breastfeeding,

and related medical conditions), race, color, religion or creed, ancestry, national origin,

disability, genetic information, AIDS/HIV status, sexual orientation, gender identity and

expression, citizenship, primary language, immigration status, military/veteran status,

political affiliation/activities, domestic violence victim status, and request for leave;

D. Commercial information, such as transaction information and purchase history;

E. Biometric information, such as face scans, fingerprints and voiceprints;

F. Internet or network activity information, such as browsing history and interactions with

our websites;

G. Geolocation data, such as device location;

H. Audio, electronic, visual and similar information, such as call and video recordings;

I. Professional or employment-related information, such as work history and prior

employer;

J. Education information subject to the federal Family Educational Rights and Privacy

Act, such as student records and directory information; and

I. Inferences drawn from any of the Personal Information listed above to create a profile

or summary about, for example, an individual’s preferences and characteristics.

We may use this Personal Information to operate, manage, and maintain our business,

for our employment purposes, and to otherwise accomplish our business purposes and

objectives. Our business purposes and objectives include, for example, developing and

improving our services and programs for our employees; conducting research,

analytics, and data analysis; maintaining our facilities and infrastructure; undertaking

quality and safety assurance measures; conducting risk and security controls and

monitoring; detecting and preventing fraud; performing identity verification; performing

accounting, audit, and other internal functions, such as internal investigations;

complying with law, legal process, and internal policies; maintaining records; and

exercising and defending legal claims.

(2) We disclosed the following Personal Information to third parties, such as our service

providers and affiliates, for our operational business purposes:

A. Identifiers, such as name and government-issued identifier (e.g., Social Security

number);

B. Personal information including without limitation, name, signature, SSN, physical

characteristics or description, address, telephone number, passport number, driver’s

license or state identification card number, insurance policy number, education,

employment, employment history, bank account number, credit card number, debit card

number, or any other financial information, medical information, or health insurance

information;

C. Characteristics of protected classifications including without limitation, age, gender,

medical conditions, marital status, sex (including pregnancy, childbirth, breastfeeding,

and related medical conditions), race, color, religion or creed, ancestry, national origin,

disability, genetic information, AIDS/HIV status, sexual orientation, gender identity and

expression, citizenship, primary language, immigration status, military/veteran status,

political affiliation/activities, domestic violence victim status, and request for leave;

D. Commercial information, such as transaction information and purchase history;

E. Biometric information, such as fingerprints and voiceprints;

F. Internet or network activity information, such as browsing history and interactions with

our websites;

G. Geolocation data, such as device location;

H. Audio, electronic, visual and similar information, such as call and video recordings;

I. Professional or employment-related information, such as work history and prior

employer;

J. Education information subject to the federal Family Educational Rights and Privacy

Act, such as student records and directory information; and

K. Inferences drawn from any of the Personal Information listed above to create a profile

or summary about, for example, an individual’s preferences and characteristics.

(3) We have not “sold” Personal Information.

For purposes of this Privacy Notice, “sold” or “sale” means the disclosure of Personal

Information for monetary or other valuable consideration but does not include, for

example, the transfer of Personal Information as an asset that is part of a merger,

bankruptcy, or other disposition of all or any portion of our business.

User Rights

You may request to:

1. Receive confirmation as to whether or not Personal Information concerning you

is being processed, and access your stored Personal Information, together with

supplementary information.

2. Receive a copy of Personal Information you directly volunteer to us in a

structured, commonly used and machine-readable format.

3. Request rectification of your Personal Information that is in our control.

4. Request erasure of your Personal Information.

5. Object to the processing of Personal Information by us.

6. Request to restrict processing of your Personal Information by us.

7. Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own

legitimate interests and regulatory requirements.

Retention

We will retain your Personal Information for as long as necessary to provide our

services, and as necessary to comply with our legal obligations, resolve disputes, and

enforce our policies. Retention periods will be determined taking into account the type of

information that is collected and the purpose for which it is collected, bearing in mind the

requirements applicable to the situation and the need to destroy outdated, unused

information at the earliest reasonable time. Under applicable regulations, we will keep

records containing client personal data, account opening documents, communications

and anything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time

and at our own discretion.

We and our trusted partners use cookies and other technologies in our related services,

including when you visit our Site or access our services.

A "cookie" is a small piece of information that a website assigns to your device while

you are viewing a website. Cookies are very helpful and can be used for various

different purposes. These purposes include allowing you to navigate between pages

efficiently, enable automatic activation of certain features, remembering your

preferences and making the interaction between you and our Services quicker and

easier. Cookies are also used to help ensure that the advertisements you see are

relevant to you and your interests and to compile statistical data on your use of our

Services.

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in

order to allow normal use of the system and are deleted from your device when the

browser is closed;

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a

fixed period and are not deleted when the browser is closed. Such cookies are used

where we need to know who you are for repeat visits, for example to allow us to store

your preferences for the next sign-in;

c. 'third party cookies' which are set by other online services who run content on the

page you are viewing, for example by third party analytics companies who monitor and

analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal

Information that we store about you may be linked, by us, to the information stored in

and obtained from cookies. You may remove the cookies by following the instructions of

your device preferences; however, if you choose to disable cookies, some features of

our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the

Site. Google Analytics collects information such as how often users access the Site,

what pages they visit when they do so, etc. We use the information we get from Google

Analytics only to improve our Site and services. Google Analytics collects the IP

address assigned to you on the date you visit sites, rather than your name or other

identifying information. We do not combine the information collected through the use of

Google Analytics with personally identifiable information. Google’s ability to use and

share information collected by Google Analytics about your visits to this Site is restricted

by the Google Analytics Terms of Use and the Google Privacy Policy .

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To

the extent you disclose your information to other parties or sites throughout the internet,

different rules may apply to their use or disclosure of the information you disclose to

them. Accordingly, we encourage you to read the privacy policy of each third party that

you choose to disclose information to.

This Privacy Policy does not apply to the practices of companies that we do not own or

control, or to individuals whom we do not employ or manage, including any of the third

parties which we may disclose information as set forth in this Privacy Policy.

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your

information. We employ industry standard procedures and policies to ensure the safety

of the information we collect and retain, and prevent unauthorized use of any such

information, and we require any third party to comply with similar security requirements,

in accordance with this Privacy Policy. Although we take reasonable steps to safeguard

information, we cannot be responsible for the acts of those who gain unauthorized

access or abuse our Site, and we make no warranty, express, implied or otherwise, that

we will prevent such access.

Transfer of data outside the EEA

Please note that some data recipients may be located outside the EEA. In such cases

we will transfer your data only to such countries as approved by the European

Commission as providing an adequate level of data protection, or enter into legal

agreements ensuring an adequate level of data protection.