1. WHO WE ARE
We are Global Military Expert Consulting & Instruction DBA Spotlight Labs (“we”, “us”, “our”). We may share data (as described further below) with its affiliated entities (collectively, “Spotlight Labs”). Like any company, we use a variety of third-party businesses and partners to market and provide our Services to you. These third parties that we partner with support our operations so we can provide the best experience to you.
2. HOW SPOTLIGHT LABS USES AND SHARES THE INFORMATION WE COLLECT
When you visit or use the Spotlight Labs Site and/or Services, we collect and use the information you provide in connection with our Site and Services for our business purposes, including to:
Perform services requested by you, such as to respond to your comments, questions, and requests and provide customer service;
Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
Prevent and address fraud, breach of policies or terms, and threats or harm;
Keep you informed regarding Spotlight Labs and our software and services;
Develop and send you direct marketing, including advertisements and communications about our and third-party products, updates, special offers, promotions, rewards, events, and services;
Help Spotlight Labs enhance products and services;
Contact you for market research and to survey your satisfaction with Spotlight Labs software and services;
Encourage you to participate in our user groups and invite you to events that may be of interest, including trainings, webinars, and conferences;
Improve our Site; and
Analyze information for trends and statistics, which may entail providing this information to an agent acting on Spotlight Labs’s behalf to assist in data analytics.
If you supply Spotlight Labs with your postal address, you may receive periodic mailings from us with information on new products and services or upcoming events. If you supply us with your telephone number online, you may receive telephone calls from us with information regarding orders and/or requests you have placed online – such as a software demonstration request or general business inquiries.
If you supply Spotlight Labs with your email address, you may receive email messages from us for marketing purposes such as providing information on new products and services or upcoming events. We may track when you open our email messages or click on the links contained within them.
You have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “preferences” or “opt-out” link in the marketing emails we send you. To opt out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details under the “Contact Us” heading below.
Note that by opting in to allow Spotlight Labs and its event sponsors/industry partners to receive your contact information through an event in accordance with this Privacy Notice, you will be subject to each event sponsor/industry partner’s communications and privacy Notice as well and must opt-out with them directly.
We also use information about you for commercial purposes with your consent, including to:
Serve advertising tailored to your interests on our Service and Third-Party Services; and
Fulfill any other purpose disclosed to you and with your consent.
We may use information that does not identify you (including information that has been de-identified) without obligation to you except as prohibited by applicable law.
Subject to recent changes in the law, which may include a different definition of “sell” from those previously used in this Notice (further discussed below), Spotlight Labs does not sell or rent your information. Spotlight Labs will disclose information it has about you for our business purposes including, but not limited to, those described as follows:
Sharing with Service Providers
We will occasionally hire other companies or contract with third-party consultants to provide limited services on our behalf. Spotlight Labs will only provide those companies the information they need to deliver services and they are prohibited from using that information for any other purpose.
Sharing with Others
We also share information about you as follows:
We will share your information to respond to duly authorized requests from governmental authorities as required by law, or in circumstances in which we believe disclosure is necessary or reasonably appropriate to protect the rights, property, or safety of us or others. Please note that Spotlight Labs is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Spotlight Labs does not generally sell personal information as the term “sell” is traditionally understood. However, to the extent, the California Consumer Privacy Act (“CCPA”) is interpreted to include advertising technology activities such as those disclosed below in the Section entitled “Cookies and Other Tracking Technologies And Choices Regarding the Same” as a “sale,” Spotlight Labs will comply with applicable law as to such activity. For more information about how to opt out of the sale of personal information, see the Section below entitled “California Privacy Rights.”
3. HOW WE RESPOND TO DO NOT TRACK SIGNALS
Do-Not-Track (“DNT”) is a preference that can be set in your browser to notify websites you visit that you do not want them to collect certain information about you. Spotlight Labs does not respond to DNT signals at this time and will not do so unless and until the law is interpreted to require such response. As discussed in this Notice, we and third parties may track your visits to our Site to provide targeted advertising.
4. COOKIES, OTHER TRACKING TECHNOLOGIES, INTEREST-BASED ADVERTISING, AND CHOICES REGARDING THE SAME
App Technologies. There are a variety of tracking technologies that may be included in our apps, and these are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include third-party SDKs, which is code that sends information about your use to a server and is in effect the app version of a pixel. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your social media account.
Location-Identifying Technologies. GPS, WiFi, Bluetooth, and other location-aware technologies may be used to collect precise location data when you enable location-based services through your device. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.
As discussed in our Cookie Statement, we also work with ad serving services, advertisers, and other third parties to serve advertisements on the Site, Services, and/or on Third-Party Services. These third parties may use Tracking Technologies on our Sites, Services, and Third-Party Services (including in e-mails and advertisements) to track your activities across time and services for purposes of associating the different devices you use and delivering relevant ads and/or other content to you on the Site, Services, and Third-Party Services or third-party devices after you have left the Service (“Interest-based Advertising”).
We serve ads on and through Third Party Services, such as Facebook/Instagram, LinkedIn, and Google, that are targeted to reach people (or people similar to people) who have visited our Site or are identified in one or more of our databases (“Matched Ads”). This is done by us uploading a list of contacts to the Third-Party Service or incorporating a pixel from the Third-Party Service on our Site, and the Third-Party Service matching common factors between our data and their data. To opt-out of receiving Matched Ads, please contact the applicable Third-Party Service. If we use Facebook Custom Audiences to serve Matched Ads on Facebook services, you should be able to hover over the box in the right corner of such Facebook ads and find out how to opt out. We are not responsible for such Third-Party Service’s failure to comply with your opt-out instructions.
You can reset your device advertising ID at any time through your device settings, which is designed to allow you to limit the use of information collected about you. For information on how to do this on Apple devices, visit Apple.com. For information on how to do this on Android devices, visit Google.com. You can stop all collection of information via an app by uninstalling the app.
The location data collected through an app depends on your device settings and app permissions. You can exercise choice over the location data collected through our apps by (i) for GPS data, disabling location in your device settings or disabling location permissions to that app; (ii) for Bluetooth data, disabling Bluetooth and any Bluetooth scanning option in your device settings; or (iii) for WiFi data, disabling WiFi and any WiFi scanning option in your device settings. You can stop the collection of all location data via an app by uninstalling the app.
Some of the third parties that collect information from or about you on the Site or Services in order to provide more relevant advertising to you participate in the Digital Advertising Alliance (“DAA“) Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized location where users can make choices about the use of their information for online behavioral advertising. To learn more about the DAA and your opt-out options for their members, please visit (i) for website opt-out, https://www.aboutads.info/choices; and (ii) for mobile app opt-out, https://www.aboutads.info/appchoices. In addition, some of these third parties may be members of the Network Advertising Initiative (“NAI“). To learn more about the NAI and your opt-out options for their members, please visit https://www.networkadverstising.org/choices/. Please note that if you opt-out of online behavioral advertising using any of these methods, the opt-out will only apply to the specific browser or device from which you opt-out. Further, opting-out only means that the selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for the effectiveness of, or compliance with, any third-parties opt-out options or programs or the accuracy of their statements regarding their programs.
You may also limit our use of information collected from or about your mobile device for purposes of serving online behavioral advertising to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt Out of Interest-Based Ads” (for Android devices).
Please be aware that if you disable or remove Tracking Technologies some parts of the Service may not function correctly.
Spotlight Labs has always considered our advertising technology partners to be Service Providers. However, regulators may interpret newer data protection laws such as the CCPA as characterizing certain kinds of digital advertising activities as “sales.” In such an event, Spotlight Labs will comply with applicable laws in connection with its use of such advertising technology services on its Services.
For further information about the types of Tracking Technologies we use, why, and how you can control such Tracking Technologies, please see our Cookie Statement.
5. BULLETIN BOARDS AND CHAT ROOMS
Occasionally, portions of the Site/App may allow you to post information that other visitors to the Site will be able to access (i.e., a “bulletin board” or interactive “chat”). If you choose to post information on a bulletin board or through a chat session, it becomes available to the public, and Spotlight Labs has no ability to control or limit the use of information that is available to the public. Spotlight Labs and its affiliates will utilize any information you post through the Site in connection with the operation of its business. Spotlight Labs encourages you not to post any information you consider private or sensitive on the Site. To request removal of your information from such bulletin boards or chat sessions, please contact us using the contact details provided under the “Contact US” heading below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
6. YOUR PRIVACY RIGHTS: CONTROLLING YOUR PERSONAL INFORMATION (ACCESS AND REMOVAL)
You can opt out of receiving promotional emails from us at any time by emailing us at the email address set forth in the section entitled “Contact Us” below with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that you cannot opt out of non-promotional emails, such as those about your account, transactions, servicing, or Spotlight Labs’s ongoing business relations. To opt out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided under the “Contact Us” heading below.
If you have opted-in to receive push notifications on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.
Please note that your opt-out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.
California consumers may have additional rights as set forth in the sections entitled “California Privacy Rights,” below. For more information about choices regarding Tracking Technologies, see the section on “Cookies and Other Tracking Technologies and Choices Regarding the Same” above.
7. CALIFORNIA PRIVACY RIGHTS
Shine The Light Customer Rights
Customers in the State of California may request a list of categorized third parties and in some cases affiliates to whom we may have disclosed their personal information specifically for those third parties’ and/or affiliates’ own marketing purposes, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit a written request to the email or address provided below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided e-mail address or mail address.
California Consumer Rights Under The CCPA
Right to Know and Delete.
Consumers who are California residents (and not representatives of businesses, whether those businesses are our customers or others) have the right to know certain information about our data practices in the preceding 12 months. In particular, they have the right to request the following from us:
The categories of personal information we have collected about them;
The categories of sources from which the personal information was collected;
The categories of personal information about them that we disclosed for a business purpose or sold;
The categories of third parties to whom the personal information was disclosed for a business purpose or sold; and
The business or commercial purpose for collecting or selling personal information.
In addition, in certain circumstances, California consumers have the right to delete the personal information we have collected from them.
To exercise any of these rights, California consumers should email us at Communications@Spotlight Labs.com, or call us at (866) 582-3713. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.
If we have processed personal information about you as a service provider on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer and will support them to the extent required by applicable law in responding to your request.
Do Not Sell My Personal Information.
Spotlight Labs will always seek your affirmative direction/consent to intentionally disclose personal information to third parties in ways that might otherwise be construed to be a “sale” under the CCPA.
8. SECURITY MEASURES
We have implemented industry-standard controls, intrusion detection network monitoring, and reasonable security measures designed to protect the personal information that you submit through the Services and Site. These measures include physical access controls, access authorization controls, and firewalls. We also periodically review our information collection, storage, and processing practices to help prevent loss, misuse, unauthorized access, alteration, or other destruction of information we collect. When accessing secure sections of the Site, we use Transport Layer Security (TLS) encryption to secure the communication of information passing between your browser and our servers. Additionally, only authorized administrators, Spotlight Labs employees, and third-party contractors have access to systems containing such information.
Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information.
9. PRIVACY OF CHILDREN
The Site and Services are intended for a general audience and not directed to children under sixteen (16) years of age. We do not market products or services to children, and we do not knowingly collect personal information from children at any time, including as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) or personal information as defined under the CCPA from anyone under the age of 16 without verification of consent. If you are under the age of 16, please do not provide personal information of any kind whatsoever, and please do not use Spotlight Labs Site and Services or participate in Spotlight Labs’s surveys, contests, events, and other promotions. If you are a parent or guardian and believe Spotlight Labs has collected such information without parental consent, please contact us as set forth in the section entitled “Contact Us” below and we will remove such data to the extent required by COPPA or other applicable law.
10. DATA RETENTION
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).
11. PRIVACY NOTICE CHANGES
Spotlight Labs may change this Privacy Notice at any time. When we update this Notice, we take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes if and where this is required by applicable data protection laws. You can see when this Notice was last updated by checking the “effective” date displayed at the top of this Notice. Spotlight Labs recommends that you review this Privacy Notice regularly for any revisions. Your continued use of the Site or Services after such revisions will constitute your acknowledgment of the amended Notice.
12. CONTACT US
If you have any comments or questions regarding our Privacy Notice or want to exercise your data protection rights, please send a message to:
Global Military Expert Consulting & Instruction DBA Spotlight Labs
ATTN: Data Protection Officer
433 Market Street
Camden, NJ 08102
13. COOKIES STATEMENT
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work or to work more efficiently, as well as to provide reporting information.
Cookies set by the website owner (in this case, Spotlight Labs) are called “first party cookies”. Cookies set by parties other than the website owner are called “third-party cookies”. Third-party cookies enable third party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.
What type of information is collected through the use of tracking technologies?
We collect the following types of personal data through the use of tracking technologies:
Web Visit tracking
Partner Reference Tracking
We use first-party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Websites. Third parties serve cookies through our websites for advertising, analytics, and other purposes. This is described in more detail below.
The specific types of first- and third-party cookies served through our websites and the purposes they perform are essential website, performance, and functionality, analytics, and customization, advertising, and social networking cookies, etc. These cookies are strictly necessary to provide you with services available through our websites and to use some of its features, such as access to secure areas. These cookies are served by Spotlight Labs, Google, Salesforce, Pardot, Demandbase, and PRL. Because these cookies are strictly necessary to deliver the Websites to you, you cannot refuse them. You can block or delete them by changing your browser settings.
What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Websites or the files viewed on our site. This allows us, for example, to monitor the traffic patterns of users from one page within our Websites to another, to deliver or communicate with cookies, to understand whether you have come to our Websites from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
How can I control cookies?
In addition, most advertising networks offer you a way to opt-out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices (external link) or http://www.youronlinechoices.com (external link). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
How often will you update this Cookie Statement?
The date at the top of this website indicates when this Cookie Statement was last updated.