DIGITAL SPOTLIGHT, LLC

OBJECTIVE

This policy applies to all processing of personal data carried out by Digital Spotlight, LLC and has the objective of informing the user regarding the way in which Digital Spotlight, LLC carries out the processing of personal data (including details of the type of personal data collected and the purpose of processing) and regarding the rights of the user in relation to their personal data.

CONTACT – HOW CAN I CONTACT?

In case of having any questions about the Privacy Policy, the user can contact Digital Spotlight, LLC through the following means:

• Headquarters are located at: 2450 Colorado Avenue, Suite 100E, Santa Monica, California 90404 United States
• Contact phone number is: 310 879 8003

The user may establish direct and effective communication with Digital Spotlight, LLC by written communication sent to any of the indicated addresses or also by sending an email to the address: contact@digitalspotlight.com

In addition, information of the officer in charge of processing your personal data is listed below:

PROCESSING IDENTIFICATION – HOW DO WE COLLECT PERSONAL DATA?

In compliance with current regulations on the protection of personal data, especially:

• Regulation (EU) 2016/679 of the European Parliament and Council, dated April 27, 2016 on the protection of natural persons regarding the processing of personal data and the free circulation of these data (hereinafter, the ‘GDPR’).
• Argentine law No. 25,326 on the protection of personal data, its regulatory decree 1558/01 and its complementary norms (the ‘Argentine LPDP’).
• The General Data Protection Law of Brazil, Law No. 13,709, (the ‘LGPD’).
• The California Consumer Privacy Act (CCPA), Assembly bill No. 375.
• The California Privacy Rights Act of 2020 (CPRA).
• The Virginia Consumer Data Protection Act (VCDPA).
• The Colorado Privacy Act (CPA)
• The Connecticut Data Privacy Act (CTDPA)
• Canada’s Anti-Spam Legislation (CASL) & Personal Information Protection and Electronic Documents Act (PIPEDA).
  Australian Privacy Act No. 1988 (APA).
• Mexican Federal Law on the Protection of Personal Data in Possession of Private Parties (LFPDPPP).
• Colombian protection of personal data law No. 1581.
• Singapore Personal Data Protection Act 2010 (‘PDPA’).
• Thailand’s Personal Data Protection Act BE 2562 (PDPA).
• Switzerland’s new Federal Act on Data Protection (nFADP).

Digital Spotlight, LLC collects personal data in its possession when the user:

• (i). completes the forms of digitalspotlight.com (‘Site’);
• (ii). subscribes to the newsletter;
• (iii). answers a poll or completes a web form;
• (iv). completes a printed form;
• (v). sends an email or communicates by phone, which are then loaded in the corresponding forms;

PERSONAL DATA COLLECTED – WHAT PERSONAL DATA DO WE COLLECT?

Digital Spotlight, LLC collects information when visiting their web page, and mainly by completing its registration forms.

The following data is collected: full name, email and phone number.

As a rule, when personal data is requested to use a service or access certain content, its delivery will not be mandatory, except for those cases where it is specifically indicated that it is data required for the provision of the service. In this case, the user may freely choose not to register and/or not to contract the services.

The user declares and guarantees that all the data provided by him are true and correct and undertakes to keep them updated. The changes may be communicated to the Data Protection Delegate or to the address indicated in Section 2 hereof.

Likewise, the user acknowledges that the data required by Digital Spotlight, LLC are necessary, adequate, and not excessive to carry out the purposes expressed in Section 5 hereof, which would be impossible to fulfill if said data are not provided.

Any false or inaccurate statement that occurs as a result of the information and data given, as well as the damages that such information may cause, will be the responsibility of the user.

PURPOSE – WHAT DO WE USE PERSONAL DATA FOR?

The personal data requested to the user will be used for the following purposes:

• To provide our Service and fulfill your requests. We use your information to provide and maintain our Service, to process and fulfill your requests, to communicate with you about your use of our Service or changes to our Service, to respond to your inquiries, and for other customer service and business administration purposes. For example, when you enroll in a newsletter, we may use your personal information to deliver that newsletter to you.
• Identification and authentication purposes. We may use your information for identification and authentication purposes. For example, when you enter your account login ID and password to enter one of our registration or login portals, we use your login credentials to authenticate your identity.
• Personalization. We use your information to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experience while using the Service. For example, if you allow us to collection geolocation data, we use this information to deliver content that is around your specific location and identify business location/listings around your location.
• Marketing and promotional purposes. We may use your information and mobile data to send you news and newsletters, event updates, and to communicate with you about new features, offers, events, or products, or to otherwise contact you about information we think may be of interest to you. We may also use your information to display advertisements to you on our site (including to sell advertising space on the Service) and on other unaffiliated websites and services.
• Research and reporting. We may use your information to administer surveys and questionnaires (online and offline) for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products, services, and educational information we provide. The survey responses may be utilized to determine the effectiveness of our Service, various types of communications, advertising campaigns and/or promotional activities.
• Combining information. We (and our third party business partners on our behalf) may merge, co-mingle, or otherwise combine information, including your personal information, in furtherance of the purposes described above.
• To comply with legal obligations. We may use your information to comply with our legal obligations or to exercise or defend our rights or the rights of a third party, including complying with law enforcement or government authority requests and participating in compliance audits.
• To protect us and others. We may use your information where we believe it necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, situations involving potential threats to the safety of any person or to otherwise enforce this Policy, our Terms and Conditions, and the integrity of the Service.
• Deidentified data. We may also deidentify or anonymize your data in such a way that you may not reasonably be re-identified by us or another party, and we may use this deidentified data for any purpose permitted under applicable law. To the extent we deidentify any data originally based on personal information, we will maintain and use such data in deidentified form and will not attempt to reidentify the data.

The data subject to treatment will not be used for purposes other than or incompatible with those mentioned above and that motivated its collection. Notwithstanding the foregoing, it is stated that the recorded data may be used, in addition to the purposes for which it was expressly collected, for the purpose of carrying out statistics, managing incidents or conducting market studies. However, in the event that personal data is processed for a purpose other than that initially specified when collecting said data, a compatibility analysis will be carried out by Digital Spotlight, LLC in accordance with applicable regulations. The processing will only be authorized if the original purpose is compatible with the new purpose or allowed in accordance with an independent legal basis. In these cases, the user will be informed of the changes in purpose or legal justification for the processing of their data.

We remind the user that they can oppose the sending of commercial communications (unsubscribe) and stop receiving emails from Digital Spotlight, LLC, reliably notifying Digital Spotlight, LLC, which will proceed to interrupt in the shortest possible time after receiving such communication. For this purpose, it may send an email to the address indicated in Section 2, a postal mail addressed to the address indicated in Section 2 hereof, or directly follow the unsubscribe instructions detailed at the end of each email of Digital Spotlight, LLC.

HOW DO WE USE YOUR INFORMATION?

We will use the information we collect about you for the following purposes:

• Administration info
• Testimonials
• Customer feedback collection
• Enforce T&C
• Support
• Targeted advertising
• Administration info
• Site protection
• Dispute resolution

If we want to use your information for any other purpose, we will ask for your consent and use your information only when we receive your consent and then only for the purpose(s) for which consent will be granted, unless we are required by law to do otherwise.

We will retain your personal information with us for 12 months after user accounts remain idle or for as long as necessary to fulfil the purposes for which it was collected, as detailed in this Privacy Policy.

CONSENT

By providing personal data to Digital Spotlight, LLC, the user declares to accept its processing fully and without reservation by Digital Spotlight, LLC. The user gives his/her free, express and informed consent to Digital Spotlight, LLC’s use of the data collected for the purposes indicated in Section 5, as well as its incorporation into a Digital Spotlight, LLC database.

Our processing of your personal data based on consent includes explicit consent mechanisms for non-essential data collection and marketing communications. You can withdraw your consent at any time by contacting our privacy officer. Each consent notice clearly outlines the purpose of the data collection and how the data is used.

The Digital Spotlight, LLC carries out the processing of legitimised user data: (i) the contracting of Digital Spotlight, LLC services by the user, in accordance with the terms and conditions that are made available to the user at the end of the completion of the service request form (prior to possible contracting) and which the user (after reading them), and if the user agrees, can accept by ticking the box that has been included for this purpose; and (ii) the free, informed and unambiguous consent of the user, made after reviewing this privacy policy, where Digital Spotlight, LLC informs you of the processing it will carry out with your data, and if you agree, by ticking the box that has been included for this purpose in the service request form. Data processing that is not covered by any of the above legal bases will be carried out if Digital Spotlight, LLC considers it necessary to protect a legitimate interest and only if it does not infringe the fundamental rights and freedoms of the user.

VALIDITY – HOW LONG DO WE KEEP IT?

The data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes described in Section 5 above. In particular, personal data will be kept for as long as the business relationship is in force (and to the extent that you have not previously requested their deletion) and for as long as obligations, indemnities and/or liabilities may arise under the business relationship or for the services provided.

Digital Spotlight, LLC informs you that it will retain information essential to identify the origin of the data stored for the duration of the client’s relationship with Digital Spotlight, LLC and/or revocation of the user’s consent in accordance with the information in Section 5 of this Privacy Policy and/or as long as required by applicable law.

CONFIDENTIALITY / ASSIGNMENT / INTERNATIONAL TRANSFER – DO WE DISCLOSE DATA TO THIRD PARTIES?

Digital Spotlight, LLC will keep collected personal data private and confidential, and will not use it for purposes other than those set out in Section 5 hereof. Digital Spotlight, LLC requires its employees and third parties providing services that access the contents of the databases to sign confidentiality and personal data processing agreements (or include such obligations in the service agreements it signs with such providers, as indicated in the following paragraph).

The user’s personal data collected by Digital Spotlight, LLC will not be transferred, sold, exchanged, transmitted and/or communicated to third parties outside Digital Spotlight, LLC without the user’s consent, except for legal obligation and/or for the purpose of providing the services to the user. This does not include certain employees and service providers enabling Digital Spotlight, LLC to keep the Site operational, fulfil the objectives set out in Section 5 of this document and/or provide services to the user, who have undertaken the obligation to maintain the confidentiality of the data provided and undertake to comply with applicable regulations on the protection of personal data, at the time of contracting. Contracts with service providers stipulate the purpose, scope, content, duration, nature and purpose of data processing, the type of personal data, the categories of data subjects and the obligations and responsibilities of Digital Spotlight, LLC and contracted third parties.

In particular:
Digital Spotlight, LLC may share the personal information provided with parent companies, affiliates, subsidiaries, related companies and/or intermediaries related to Digital Spotlight, LLC.

SECURITY – HOW DO WE ENSURE DATA SECURITY?

Digital Spotlight, LLC declares its intention to adopt the necessary technical and organisational measures to ensure the security, integrity and confidentiality of the data in accordance with the provisions of RGPD,, ,the Argentine LPDP,, ,LGPD,, ,CCPA,, ,VCDPA,, ,CPA,, ,CTDPA,, ,PIPEDA-CASL,, ,APA,, ,LFPDPPP,, ,Colombian Law,, ,PDPA Singapore,, ,PDPA Thailand, and ,nFDPA Swiss in order to prevent its tampering, loss, consultation or unauthorised processing.

Digital Spotlight, LLC does not guarantee absolute privacy when using the Site, since the possibility that unauthorised third parties may have knowledge of it cannot be excluded. The user acknowledges that the existing technical means that provide security are not impregnable and that even when all reasonable security precautions are taken, it is possible to suffer manipulation, destruction and/or loss of information. In the event that a security incident is detected and entails a significant risk to the data owner, such event will be reported without delay to the competent control authority, together with the corrective and remedial measures implemented and/or to be implemented.

Digital Spotlight, LLC is not responsible for the loss or deletion of data by users. Similarly, Digital Spotlight, LLC accepts no responsibility for possible damage caused by computer viruses.

Finally, the user must also take measures to protect their information. Digital Spotlight, LLC insists that you take every precaution to protect your personal information while on the Internet. At the very least, it is advisable to change your password periodically, using a combination of letters and numbers, and to make sure you are using a secure browser.

SECURITY – HOW DO WE ENSURE DATA SECURITY?

Digital Spotlight, LLC declares its intention to adopt the necessary technical and organisational measures to ensure the security, integrity and confidentiality of the data in accordance with the provisions of RGPD,, ,the Argentine LPDP,, ,LGPD,, ,CCPA,, ,VCDPA,, ,CPA,, ,CTDPA,, ,PIPEDA-CASL,, ,APA,, ,LFPDPPP,, ,Colombian Law,, ,PDPA Singapore,, ,PDPA Thailand, and ,nFDPA Swiss in order to prevent its tampering, loss, consultation or unauthorised processing.

Digital Spotlight, LLC does not guarantee absolute privacy when using the Site, since the possibility that unauthorised third parties may have knowledge of it cannot be excluded. The user acknowledges that the existing technical means that provide security are not impregnable and that even when all reasonable security precautions are taken, it is possible to suffer manipulation, destruction and/or loss of information. In the event that a security incident is detected and entails a significant risk to the data owner, such event will be reported without delay to the competent control authority, together with the corrective and remedial measures implemented and/or to be implemented.

Digital Spotlight, LLC is not responsible for the loss or deletion of data by users. Similarly, Digital Spotlight, LLC accepts no responsibility for possible damage caused by computer viruses.

Finally, the user must also take measures to protect their information. Digital Spotlight, LLC insists that you take every precaution to protect your personal information while on the Internet. At the very least, it is advisable to change your password periodically, using a combination of letters and numbers, and to make sure you are using a secure browser.

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
  Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

APPOINTMENT OF A DATA PROTECTION OFFICER

Digital Spotlight, LLC has appointed delegate for the application and control of this Privacy Policy and the relationship with the application authority to Ash Aryal who can be contacted by the following means:

CALL US :

310 879 8003

EMAIL :

contact@digitalspotlight.com

TRAINING – DO WE TRAIN?

The staff of Digital Spotlight, LLC whose functions are related to the processing of personal data are trained in order to ensure better protection of personal data and the rights of data subjects.

LINKS TO THIRD PARTIES – DOES OUR SITE CONTAIN LINKS TO OTHER WEBSITES?

The Site may contain links to third party websites, with or without advertising content, whose privacy policies are foreign to Digital Spotlight, LLC. The linked sites are not related to Digital Spotlight, LLC and, their existence in no way presupposes that there is any kind of suggestion, invitation or recommendation to visit the target sites or any kind of link or association between Digital Spotlight, LLC and such sites. Digital Spotlight, LLC is not responsible for the content, use and activities of these linked sites, or for any actual or potential, material or moral, direct or indirect damages suffered by users and derived from the information contained in such sites or the relationship that users may establish with third parties whose services have been published on the Site. Notwithstanding the above, any feedback on these linked sites will be useful to Digital Spotlight, LLC in order to improve the services and/or ensure the integrity of the Site. Digital Spotlight, LLC undertakes to do everything possible to prevent the existence on its Site of links to sites with illegal content.

CHILDREN’S PRIVACY

At Digital Spotlight, LLC, we recognize the importance of protecting the privacy of children. Our commitment to safeguarding the personal information of minors is unwavering. We may collect and process personal information from children under the age of 13, but only in compliance with all applicable laws and regulations, including obtaining parental or guardian consent as required.

If you are a parent or guardian and you believe that we have collected personal information from your child without appropriate consent, please contact us immediately, and we will take prompt action to address the situation.

For residents of California: We do not sell the personal information of California consumers who are 16 years old or younger unless we have obtained prior parental authorization. If your child is under the age of 13, we insist on receiving parental or guardian consent for the collection and processing of their personal information. If your child falls within the age range of 13 to 16 years, they can opt-in to allow the sale of their personal information. Our websites and services designed for children will incorporate age verification and ensure the necessary consents are obtained.

For EU residents: We do not collect or process personal information of individuals in the EU under the age of 16 without explicit consent from a parent or guardian. Our websites and services directed towards children will include age verification and require the appropriate consents.

COOKIES – DO WE USE COOKIES?

When you visit the Site, Digital Spotlight, LLC may store certain information on your computer in the form of a “cookie” or similar file. The Site uses cookies to (i) track advertising, (ii) collect traffic data from the Site, and (iii) improve the user experience when using the Site.

The user should be aware that, in order to browse the Site, it is not necessary for him or her to allow the installation of cookies sent by the Site. This may only be required in relation to certain services. You may delete cookies from your computer hard drive, prevent access to your computer through your browser or by choosing the corresponding option when asked about the possibility of using cookies for these purposes and in accordance with Digital Spotlight, LLC Cookie Policy.

Cookies are files of information that a website or the provider of certain services on the site transfers to the hard drive of the user’s computer via the browser. Cookies by themselves cannot personally identify the user (although they may contain the user’s IP address) but they allow them to recognise the user’s browser, and to capture and store certain data (the user’s operating system, the domain name of the website from which the Site was linked, among others). Digital Spotlight, LLC reserves the right to hire the services of third parties to analyse and understand the users of the Site, who may not use the information collected for purposes other than improving Digital Spotlight, LLC’s services.

APPROVAL

Your use of the Site constitutes your acknowledgement and approval of Digital Spotlight, LLC’s Privacy Policy and Digital Spotlight, LLC’s Terms and Conditions, if any. Likewise, the user accepts Digital Spotlight, LLC’s Privacy Policy and Digital Spotlight, LLC’s Terms and Conditions by completing the request for services.

DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

You may have certain rights regarding our processing of your personal information under applicable local law. If our processing of your personal information is governed by such laws, this section provides you with additional information regarding your rights and our processing of your personal information under applicable local law.

MODIFICATIONS – IS THIS THE MOST CURRENT VERSION?

This is the current version of the Digital Spotlight, LLC Privacy Policy, updated on February 27, 2024.

Digital Spotlight, LLC may at any time and without prior notice, modify this Privacy Policy. Such modifications will be operative from their publication on the Site or when they are notified to users by any means, whichever occurs first. The user must keep informed about the terms included here by entering periodically