PO Box 3397, Conroe, Texas 77305, United States
This Privacy Policy explains how and why Spotlight collects, uses, and shares personal information when you interact with or use our Site or Service. It also includes any information Spotlight collects offline in connection with the Service, which we may combine with information from the Site and Service. By reading this Privacy Policy, you will understand your privacy rights and choices.
When we say “Spotlight”, we mean Spotlight Global Inc., and any of its affiliates, including Spotlight Payments, Inc. When we say “Site”, we mean https://spotlightsystems.net, and when we say “Service”, we mean the Site plus any websites, features, applications, widgets, or online services owned or controlled by Spotlight and that post a link to this Privacy Policy.
As part of the Service, Spotlight provides a marketplace which results in platform information pertaining to different parties to an interaction. Users of the Service may be Clients, Freelancers, or Agencies, or Site Visitors (as each is defined in the User Agreement). This Privacy Policy applies to Spotlight’s processing of personal information of Users where Spotlight determines the purposes and means of processing. It does not apply to processing of information by Users themselves, who may be controllers of the personal information they access through the Service. For information about how Users process your personal information, please contact them directly.
Accessibility: This Privacy Policy uses industry-standard technologies and was developed in connection with the World Wide Web Consortium's Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.
When you use the Service, you may provide us with information about you. This may include your name and contact information, financial information to make or receive payment for services obtained through the various Spotlight platforms, or information to help us fill out tax forms. When you use the Service, we may also collect information related to your use of the Service and aggregate this with information about other users. This helps us improve our Services for you.
Depending upon our relationship with you, we may collect the following categories and types of personal information from and about you:
Categories of Personal Information We Collect
Examples of Personal Information Collected
Categories of Sources of Personal Information
Business Purpose for Collection of Personal Information
Identifiers
Name, Social Media Account Information, Profile Data, IP Address
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Contact / Account Profile Information
Email Address, Billing Address, Phone Number
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communicating with You, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Sensitive Personal Information / Government Issued Identification Numbers
Social Security Number, Driver’s License, State Identification or Passport Number, VAT Identification Number, Tax Identification Number, Immigration Status, Citizenship Information
NOT COLLECTED
We do not collect this type of personal information.
Commercial Information
Transaction Data including services offered, considered, or purchased
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Financial Data/Payment Information
Credit card or other financial account information
Directly from You or Your use of the Service; Third Parties (such as affiliates, agents, service providers and other users)
Improving and Providing the Service, Identification, Communications, Security, Legal, Compliance and Regulatory Obligations.
Internet or Other Network or Device Activities Including Information from Cookies
Unique device and app identifiers, browsing history or other usage data, the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
Approximate Geolocation Information
Your approximate location
Directly from You or Your use of the Service; Cookies and Other Tracking Technologies; Third Parties (such as affiliates, agents, service providers and other users)
Developing, Improving, and Providing the Service, Identification, Communications, Marketing, Analytics, Security, Legal, Compliance and Regulatory Obligations.
System Interactions
Logins to the systems, actions in the system such as acknowledgments or changes initiated by you
Directly from You or Your use of the Service;
Providing and Improving the Service, Identification, Communications, Marketing, Security, Legal, Compliance and Regulatory Obligations.
Platform Communications
Communication Information (e.g., your name, contact information, and, with your consent, the contents of any messages you send)
Directly from You, Your use of the Service, and Users with whom you communicate
Developing, Improving, and Providing and Improving the Service, Security, Legal, Compliance and Regulatory Obligations.
Like other online companies, we receive technical information when you use our Services. We use these technologies to analyze how people use the Service, to improve how our Site functions, to save your log-in information for future sessions.
Spotlight and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movement around the website, the desktop app, and the mobile app, and to gather demographic information about our user base as a whole. The technology used to collect information automatically from Spotlight Users may include cookies, web beacons, and embedded scripts. In addition, we and our marketing partners, affiliates, analytics, and service providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.
Spotlight does not use nor implement targeted advertising services from third parties on any of our platforms.
Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Spotlight does not generally alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Global Privacy Control (GPC) is a technical specification that you can use to inform websites of your privacy preferences regarding ad trackers. If you do choose to set up GPC, it may impact the functionality of the Site, but we honor the GPC signal on a per-browser basis automatically in your cookie preferences.
The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. If we become aware that a child younger than 18 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that Spotlight has collected Personal Information from your child, please contact us at: support@Spotlightsystems.com.
We use information collected through the Service to provide and improve the Service, develop new Services and products, process your requests, prevent fraud, provide you with information and advertising that may interest you, comply with the law, and as otherwise permitted with your consent.
Unless you request that we delete certain information (see Your Choices and Rights below), we will only retain your personal information for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements, as well as ongoing fraud prevention, backup, and business continuity purposes.
We do not sell your Personal Information for monetary consideration, and we do not share your Personal Information with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to opt-in to or opt-out of such sharing. Spotlight sets opt-out by default on any information sharing. We may also share information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as otherwise described in this Privacy Policy, or for the following business or commercial purposes:
Legal and Investigative Purposes
Spotlight will share information with government agencies as required by law including (without limitation) in response to lawful requests by public authorities to meet national security or law enforcement requirements and in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law.
We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect the property and rights of Spotlight or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
Internal and Business Transfers
Spotlight may share information, including Personal Information, with any current or future subsidiaries or affiliates, primarily for business and operational purposes, including activities such as IT management, for them to provide services to you, or support and supplement the Services we provide. We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.
Non-Identifying Information and De-Identified Information
We may share aggregated Non-Identifying Information and we may otherwise disclose Non-Identifying Information (including, without limitation, Hashed Information) or De-Identified Information to third parties.
Categories of Personal Information We Have Shared in the Preceding 12 Months
Categories of Third Parties with whom We Share Personal Information
Whether This Category is Used for Targeted Advertising
Identifiers
Analytics Companies, Identity Verification Companies, Advertising Partners, Payment Processors, Other Merchants, Spotlight Users, Government Agencies (as required by law)
Yes
Contact Information
Analytics Companies, Advertising Partners, Payment Processors, Other Merchants, Spotlight Users, Government Agencies (as required by law)
Yes
Sensitive Personal Information / Government Issued Identification Numbers
Identity Verification Companies, Security Companies, Other Merchants, Spotlight Users, Government Agencies (as required by law)
No
Commercial Information
Payment Processors, Security Companies, Analytics Companies, Other Merchants, Spotlight Users, Government Agencies (as required by law)
No
Financial Data/Payment Information
Payment Processors, Security Companies, Other Merchants, Spotlight Users, Government Agencies (as required by law)
No
Internet or Other Network or Device Activities Including Information from Cookies
Analytics Companies, Advertising Partners, Other Merchants, Government Agencies (as required by law)
Yes
Approximate Geolocation Information
Analytics Companies, Advertising Partners, Other Merchants, Spotlight Users, Government Agencies (as required by law)
Yes
Sensory Information
Other Merchants, Spotlight Users, Government Agencies (as required by law)
No
You may have certain choices and rights associated with your personal information, including opting out of targeted advertising or other disclosures to third parties. Residents of certain locations may have the right to have an authorized agent submit requests on your behalf. You or your authorized agent may request that Spotlight honor these rights by contacting us as outlined in the “Contact Us” section below, or submitting a request here.
Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights.
Verifying Your Request: Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. In the case of access and deletion, your request must be verifiable before we can fulfill such request. Verifying your request will require you to provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information or a person authorized to act on your behalf. We will only use the personal information that you have provided in a verifiable request in order to verify your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority. Please note that we may charge a reasonable fee or refuse to act on a request if such request is excessive, repetitive or manifestly unfounded.
“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.
California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA): The CCPA, as amended by the CPRA, provides California residents and/or their authorized agents with specific rights regarding the collection and processing of their personal information.
Your Right to Know: California residents have the right to request that we disclose the following information to you about our collection and use of your personal information over the past twelve (12) months. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Upon verification, we will disclose to you:
Your Right to Opt-Out of “Sale” or “Sharing” of Personal Information: California residents have the right to opt-out of the “sale” or “sharing” of their personal information as defined by the CCPA by clicking here or by contacting us using the information in the “Contact Us” section below.
Please note that we do not knowingly “sell” the personal information of any individuals under the age of 18.
Where we are “sharing” your personal information with third parties for the purposes of cross-context behavioral advertising or profiling, you may opt-out of such sharing at any time by submitting a request as directed on the homepage of our website or by contacting us using the information in the “Contact Us” section below.
Your Right to Limit Use of Sensitive Personal Information: California residents may have the right to request that businesses limit the use of any sensitive personal information to those uses which are necessary to perform the Services or for other specifically-enumerated business purposes under the CCPA, as amended by the CPRA. Please note that we do not use sensitive personal information other than as necessary to perform the Services or as specifically permitted under the CCPA.
Your Right to Delete: California residents have the right to request that we delete any of the personal information collected from you and retained by us, subject to certain exceptions. We may ask you to provide certain information to identify yourself so that we may compare it with our records in order to verify your request. Once your request is verified and we have determined that we are required to delete the requested personal information in accordance with the CCPA, we will delete, and direct our service providers to delete your personal information from their records. Your request to delete personal information that we have collected may be denied if we conclude it is necessary for us to retain such personal information under one or more of the exceptions listed in the CCPA.
Your Right to Correct: Under the CCPA, as amended by the CPRA, California residents have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes for which we are processing such personal information. We will use commercially reasonable efforts to correct such inaccurate personal information about you.
Non-Discrimination: You will not receive any discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.
Under Nevada law, certain Nevada residents may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.
We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by emailing support@spotlightsystems.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
The laws of your state of residence (“Applicable State Law”) may provide you with certain rights, including the following:
Your Right to Confirm and Access: You have the right to confirm whether we are processing personal information about you and access the personal information we process about you.
Your Right to Portability: You have to right to obtain a copy of the personal information we maintain and process about you in a portable and, to the extent technically feasible, readily-usable format.
Your Right to Delete: You have the right to request that we delete the personal information we maintain or process about you.
Your Right to Correct: You have the right to request that we correct inaccuracies in the personal information we maintain or process about you, taking into consideration the nature and purpose of such processing.
Your Rights to Opt-Out: You have the right to opt-out of certain types of processing of personal information, including:
Please note, as explained above, we do not “sell” personal information as that word is traditionally defined. However, we do share personal information with third parties to provide you with personalized advertising from us and to better understand how you interact with our Services. Through the use of cookies, we may also make available certain personal information to third parties for targeted advertising. You may opt-out from any of these disclosures under Applicable State Law by clicking here.
Certain information may be exempt from the rights described above under applicable law. If we deny your request in whole or in part, you may have the right to appeal the decision. In such circumstances, we will provide you with information regarding the appeals process. Depending on your location, you may also email support@spotlightsystems.com with the subject “Data Privacy Request Appeal” to provide us with details about why you are appealing the decision.
If you have an unresolved privacy or data use concern that we have not addressed to your satisfaction, please contact our U.S.-based third-party dispute resolution provider free at https://feedback-form.truste.com/watchdog/request.
We take a number of steps to protect your data, but no security is guaranteed.
Spotlight takes reasonable steps to help protect and secure the information it collects and stores about Spotlight Users. We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information that we receive against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use.
Because we are a U.S. company, we process and store your information in the United States and our service providers may process and store it elsewhere.
Spotlight does not knowingly share personal information with any third party entities.
Spotlight Global Inc. has certified that its U.S. operations adhere to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks (“Privacy Shield”) with respect to the personal Information that they receive in reliance on the Privacy Shield. In July 2023, all members of the Privacy Shield, including Spotlight, automatically became members of the Data Privacy Framework (“DPF”). Our DPF certification is available at https://www.dataprivacyframework.gov/s/participant-search. To learn more about the DPF program, please visit https://www.dataprivacyframework.gov/s/.
When Spotlight or one of its affiliates receives Personal Information under the DPF and then transfers it to a third party service provider acting as an agent on their behalf, Spotlight or its affiliate may have certain responsibility under the DPF if both (i) the agent processes the information in a manner inconsistent with the DPF and (ii) Spotlight or its affiliate is responsible for the event giving rise to the damage.
Covered European residents should contact Spotlight at the contact information below regarding Spotlight’s or its affiliates' compliance with the DPF. Spotlight will attempt to answer your questions and satisfy your concerns in a timely and complete manner as soon as possible. If, after discussing the matter with Spotlight, your issue or complaint is not resolved, Spotlight and the above-named affiliates have agreed to participate in the DPF independent dispute resolution mechanisms listed below, free of charge to you. PLEASE CONTACT Spotlight FIRST.
For other Personal Information Spotlight or its affiliates receive under the DPF, Spotlight and its affiliates have committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Data Privacy Framework Principles to an independent dispute resolution mechanism, JAMS Data Privacy Framework Dispute Resolution, operated by JAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information and to file a complaint.
If your complaint still is not resolved through these channels, under limited circumstances, an additional binding arbitration option may be available before a DPF panel, as described at https://www.dataprivacyframework.gov/s/. Every individual also has a right to lodge a complaint with the relevant supervisory authority.
Our Service can contains links to other websites. If you choose to click on a third-party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.
We may change this Privacy Policy. If we make substantial changes, we will provide notice.
This Privacy Policy is effective as of the date stated at the top of this page. Spotlight may update this Privacy Policy at any time and any changes will be effective upon posting. By accessing or using the Service after we notify you of such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.
To request that Spotlight honor any of the rights described in this Policy submit a request here, or contact us as outlined below.
If you have any questions about this Privacy Policy, please contact us at support@spotlightsystems.com or by mail addressed to Spotlight Systems LLC, Attn: Legal, 9775 Pozos Ln, Conroe, TX 77303, USA. You may also contact us by phone at 346-202-4831.
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