Privacy Policy

Last update: April 3, 2023

Spotlight Labs Inc. ("Spotlight Labs", "we", "our", and "us") respects your concerns about privacy and personal data protection and value our relationship with you. This Privacy Policy (the "Policy") applies solely to personal information collected through the Inquisite website, online services, applications, and web pages that post, specifically reference, and incorporate this Policy (all of the foregoing, collectively, the "Site"), whether accessed via computer, mobile device or other device (collectively, "Device").

This Policy describes the types of personal information we collect through the Site and how that personal information may be used and/or with whom it may be shared. This Policy also describes how you can reach us to update your personal information, access and control the use of the personal information, or get answers to questions you may have about our privacy practices. Please read this Policy carefully, because by accessing and using this Site you are acknowledging that you understand and agree to the terms of this Policy. In addition, please review our Terms of Use, which governs your use of this Site.

1. CONSENT

Consent to Data Collection and Processing

You hereby agree with and consent to the collection and processing of your personal information as described in this Policy.

Consent to International Data Transfers

Your personal information may be collected, processed and stored by Spotlight Labs or its services providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. You hereby agree with and consent to the transfer of your personal data to the United States and other countries where Spotlight Labs operates.

Withdrawal of Consent

You have the right, at any time, to withdraw your consent to Spotlight Labs's collection and processing of your information, or to the transfer of your personal data to the United States and other countries where Spotlight Labs operates. You may withdraw your consent by emailing Spotlight Labs at privacy@Spotlight Labs.org.

2. COLLECTION AND USE OF PERSONAL INFORMATION

As you interact with Inquisite, there may be opportunities for you to provide us with your information. Additionally, we may collect certain information about your as further described below.

You may provide us with information about you through a number of sources: Spotlight Labs websites, applications, product and related events, surveys, social media platforms, and through our customer contact centers.

The categories of information that Spotlight Labs collects about you may include, but are not limited to:

We obtain the categories of personal information listed above from the following categories of sources:

The information Spotlight Labs collects about you and your devices may be used:

Communications with you in connection with these uses may be via mail, telephone, e-mail, text message, social medial, or other electronic messages, or via our websites and applications.

Personal Information You Provide

The privacy and security of the personal information that Spotlight Labs collects from you is a priority for Spotlight Labs. When you visit this Site you may be asked or choose to provide personal information that could reasonably be used to contact you or to identify you personally including, but not limited to: your name, address, telephone number, birth date, and email address. If you choose to purchase any products or use services offered on the Site, Spotlight Labs may ask you to provide your name, mailing address, telephone number and email address, as well as certain financial information (e.g., credit card number) for the purposes of credit checks, payment and processing of any order.

You will be informed what personal information is required and what information is optional when asked to submit personal information to us. By submitting personal information to Spotlight Labs at this Site, you hereby consent to Spotlight Labs's collection, use and disclosure of such personal information.

We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources (including information from your publicly available social media profiles), and other third parties.

Passive Information Collection and Use

As you navigate around this Site, certain information can be passively collected (that is, gathered without you actively providing the information), using various technologies. We passively collect and use information in a variety of ways, including:

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. If you set your browser to reject cookies, part of the Site may not work for you.

We permit third-party advertising partners to use the foregoing tracking technologies to collect information about your browsing activities over time and across different websites when you use the Site. For example, we use advertising services providing by third-party ad partners, such as Google, to market our service to you on other websites and online services. Through a process called "retargeting," each service places a cookie on your browser when you visit the Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity. To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you could select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party ad partners honor the Do Not Track browser signal. Additionally, many advertising companies are members of the NAI or DAA and/or provide opt-outs on those industry pages at networkadvertising.org/choices or aboutads.info/choices.

We utilize Google Analytics on the Site. Google Analytics is a website analysis service provided by Google, Inc. (“Google”). Google utilizes the data collected to track and examine the use of this Site, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. For more information on Google's Privacy Policy go to https://www.google.com/intl/en/policies/privacy/ . Users can opt-out of Google Analytics tracking at https://tools/google.com/dlpage/gaoptout/ . Some additional Google Analytics features that Inquisite uses are:

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

Integrated Accounts and Social Media Information

We may implement applications or "widgets" from third party providers that allow interaction, integration or content sharing with third party services. These widgets or applications may be visible on a page you visit on our Site or may require log-in through the third party provider's service. The third party providing the widget or integration may offer controls for you to manage your interactions. Any interaction with a third party widget or application typically allows the third party to collect some information about you (whether through cookies, registration information or otherwise). These third parties may even track you when you do not interact with the widget. If you have engaged any of these third party service providers, their respective privacy policies will govern their tracking and collection of information. You should review these third party policies to understand these practices.

How We Use and Disclose Information

We may disclose personal information that we collect or you provides as described in this Policy. The information may be disclosed for a business purpose to the following categories of third parties:

We use and disclose personal information you provide to us as described to you at the point of collection, such as when you (1) register for a user account, (2) submit payment or credit card information, (3) submit your name and e-mail address to receive product updates and marketing information, and (4) send e-mail messages or feedback, or transmit other information by e-mail. When you elect to engage in such activities, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), e-mail address, mobile telephone numbers, and payment information.

We also use and transfer personal information from or about you:

In addition, we use and disclose personal information collected through this Site as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with any legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use and disclose personal information collected through this Site in other ways, with your prior consent.

We also use and disclose information we collect passively as described above, under "Passive Information Collection and Use," and for any other purpose, except where we are required to do otherwise under applicable law (for example, if we are required to treat such information as personal information). In addition, we may use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

Spotlight Labs will not sell your personal information that we collect without your explicit consent.

Use of Information for Marketing Purposes

Spotlight Labs and our affiliates may send you regular promotional communications about our products, services, events and promotions. Such promotional materials may use the "Spotlight Labs" brand and may be sent to you via different channels, such as: email, phone, SMS text messages, postal mailings, and third party social networks.

In order to provide you with the best personalized experience, sometimes these communications may be tailored to your preferences (for example, as you indicate these to us, as we may have inferred from your Site visits, or based on the links you click in our emails). When required by applicable law, we will obtain your consent before starting these activities. In addition, you may withdraw your consent (opt-out) at any time.

In particular, you can opt-out from receiving marketing-related emails by following the unsubscribe instructions provided in each email. If you can sign-in to your Spotlight Labs account, you may be able to change your communication preferences under the relevant section of the Site. You can also contact us using the contact details provided below to opt-out from receiving marketing-related communications.

Please note that even if you opt-out from receiving marketing communications, you might still receive administrative communications from us, such as technical updates of our products, order confirmations, notifications about your account activities, and other important notices.

3. GENERAL PRINCIPLES FOR THE PROCESSING OF PERSONAL INFORMATION

Personal information will be collected, stored, processed and transmitted in accordance with Spotlight Labs’s established policies and applicable federal, state, local and foreign laws, rules and regulations.

The principles of Spotlight Labs with respect to the processing of personal information are as follows: (1) personal information will be processed fairly and lawfully, (2) personal information will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal information collected by Spotlight Labs will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and processed, (4) personal information collected by Spotlight Labs will be accurate and, where necessary, kept up to date to the best of our ability, (5) personal information collected by Spotlight Labs will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal information was collected, and (6) personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

If Spotlight Labs engages in the processing of personal information for purposes other than those specified in this Policy, Spotlight Labs will provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.

4. THIRD PARTY SITES AND SERVICES

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link. The availability of, or inclusion of a link to, any such site or property on this Site does not imply endorsement of it by us or by our affiliates.

5. CHOICES AND ACCESS

We give you choices regarding our use and disclosure of your personal information. Spotlight Labs provides you with the opportunity to receive information by email, regular mail or telephone calls from Spotlight Labs, or third parties which may be of interest to you, including information relating to new products and services offered on the Site by Spotlight Labs, or other third parties. If you do not want to receive any information by email, regular mail or telephone calls, you may opt-out of further communications provided by Spotlight Labs at any time by: (i) sending Spotlight Labs an email at privacy@Spotlight Labs.org.

If applicable, and you would like to review, correct, update, or delete the personal information that you have provided via this Site, please contact us. We will try to comply with your request as soon as reasonably practicable.

6. ACCURACY

It is your responsibility to provide Spotlight Labs with accurate personal information. Except as otherwise set forth in this Policy, Spotlight Labs shall only use personal information in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, Spotlight Labs shall take reasonable steps to ensure that personal information is accurate, complete, current and relevant to its intended use.

7. YOUR RIGHTS OVER YOUR INFORMATION

By law, you have a number of important rights. In summary, those include the following:

If you would like to exercise any of these rights, please email us with the following: (1) enough information to identify you; (2) proof of your identity and address; and (3) the information to which your request relates.

California Privacy Rights

The California Consumer Privacy Act (the "CCPA") grants users of our Site that are California residents certain rights in regards to our collection of personal information. These rights include:

Under the CCPA, a data subject may only make a personal information request twice in a 12-month period. Spotlight Labs will respond to such personal information request within 45 days of receiving the personal information request.

Additionally, if you are a California resident, you have the right to request information from Spotlight Labs regarding the manner in which Spotlight Labs shares certain categories of your personal information with third parties, for the third parties’ direct marketing purposes. California law provides that you have the right to submit a request to Spotlight Labs at its designated address and receive the following information:

You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. You may make such a request by emailing privacy@Spotlight Labs.org.

Exercising Your Rights

To exercise your rights as described herein, you may submit a verifiable consumer request to us (as described above) by emailing privacy@Spotlight Labs.org. Spotlight Labs will not discriminate in any way against any users of the Site that exercise their rights provided by law.

8. RETENTION PERIOD

We retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.

9. SECURITY

Spotlight Labs has implemented security measures designed to protect personal information provided by you against unauthorized access and use. Spotlight Labs also uses commercially reasonable efforts to establish secure connections with your web browser for any transactions conducted online using a credit card or other financial information you may provide to Spotlight Labs. Please be aware, however, that no data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem.

10. USE OF SITE BY MINORS

We do not intentionally collect information from individuals under the age of 13. The Site is not directed to individuals under the age of 13 and we request that these individuals not provide personal information through this Site.

11. COMPLIANCE WITH LOCAL LAWS

This Policy is meant to guide Spotlight Labs with respect to personal information collected from or about you at this Site. While this Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to Spotlight Labs ("Local Laws") may require standards which are stricter than this Policy and, in such event, Spotlight Labs will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions. All the information you provide may be transferred or accessed by entities around the world as described in this Policy. Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Site or by providing consent to us (where required by law), you specifically acknowledge and consent to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules, and a lower standard of required protection, than in your country. Irrespective of which country your personal data is transferred, we would only share your personal data under a ‘need to know’ basis. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by organizational, technical, contractual and/or other lawful means.

12. UPDATES TO THIS PRIVACY POLICY

We may change this Policy. Please review the LAST UPDATE legend at the top of this page to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on this Site. Your use of this Site following these changes means that you accept the revised Policy.

13. COMPLIANCE

Spotlight Labs will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.

If you believe that your personal information has been processed or disclosed in violation of this Policy, Spotlight Labs encourages you to raise any concerns using the contact information provided in this Policy. Spotlight Labs will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.

14. YOUR RIGHT TO COMPLAIN

If you have a complaint as to our use of your information, you may file a complaint with us, the California Attorney General, any other governmental agency, and/or a judicial body.

A complaint may be submitted directly to Spotlight Labs in writing by sending an email to privacy@Spotlight Labs.org.