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SPOTLOCK PRIVACY POLICY

Effective Date: October 18, 2023

1.  INTRODUCTION

This Spotlock Privacy Policy (“Policy”) outlines what personal data is collected by Spotlock Ltd. (“Spotlock”, “we”, “us” or “our”), how we use such personal information, the choices you have with respect to such personal information, and other important information.

 

We keep your personal information personal and private. We will not sell, rent, share, or otherwise disclose.

2. FROM WHOM WE COLLECT PERSONAL INFORMATION?

This Policy applies to Spotlock’s collection, use, and disclosure of the personal information of the following categories of individuals:

  • Website Visitors: Individuals who visit our Website and who may volunteer certain personal data (such as their email address) to receive communications from Spotlock. For the purposes of this Policy, “Website” shall refer collectively to https://www.spotlock.co), including Spotlock's platform available to its users upon setting up an Account.

  • Customers: Those who register on their own or on behalf of an entity or organization to use any of the Spotlock Services (as defined below), by setting up an online account for the purpose of using the Services (“Account”). For the purposes of this Policy, “Services” shall refer to all products or service offerings made available by Spotlock, including Transactions, through Spotlock’s platform, as further detailed in Spotlock’s Terms of Use, available at https://www.spotlock.co/terms.

3.  WHAT PERSONAL INFORMATION WE COLLECT?

Website Visitors:

  • Log Files. Just as when you visit and interact with most websites and services delivered via the Internet, when you visit our Website, we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and locale and language preferences.

  • Name, email address, and other contact information. We ask for and-at your option-collect your contact data (such as name and email address) from you when you submit web forms on our Website, including opportunities to sign up for and agree to receive email communications from us. We also may ask you to submit such personal information if you choose to use interactive features of the Website, including participation in surveys, requesting customer support, or otherwise communicating with us. We will send such communications in accordance with applicable law.

  • Other Personal Information. Please be aware that that any information that you upload or submit on the Website might be read, collected, and used by others who access it.

Customers:

  • Customer Account Information. When you set up an Account, we collect your email address and other contact data (such as your name and phone number). We also collect any information you upload to the Website. We refer to this information as “Customer Information” for the purposes of this Policy. Customer Information is required to identify you as a Customer and permit you to access your Account. By voluntarily providing us with such Customer Information, you represent that you are the owner of such personal information or otherwise have the requisite consent to provide it to us.

  • Information Collected During the Services. Information related to the Services that you submit to us will be stored alongside other Personal Data that we collect.

  • Payment Information. When you sign up for one of our paid Services, you must provide billing information. The information you will need to submit depends on which billing method you choose. For example, if you choose to pay via wire transfer, we will collect the bank account information associated with the payment.


4. HOW WE USE PERSONAL INFORMATION WE COLLECT?

Spotlock only processes personal information in a way that is compatible with, and relevant for, the purpose for which it was collected or authorized. As a general matter, for all categories of data we collect, we may use the information we collect (including personal information, to the extent applicable) to:

  • provide, operate, maintain, improve, and promote the Website and Services;

  • enable you to access and use the Website and Services;

  • process and complete transactions, and send you related information, including purchase confirmations and invoices;

  • send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages;

  • send commercial communications, in accordance with your communication preferences, such as providing you with information about services, features, surveys, newsletters, offers, promotions, contests, and events about us and our partners; and send other news or information about us and our partners.

  • monitor and analyze trends, usage, and activities in connection with the Website and Services and for marketing or advertising purposes;

  • comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;

  • personalize the Website and Services, including by providing features or content that match your interests and preferences; and

  • process for other purposes for which we obtain your consent. We may combine information we collect as described above with personal information we obtain from third parties. For example, we may combine information entered on an Spotlock sales submission form with information we receive from a third-party sales intelligence platform vendor to enhance our ability to market our Services to Customers or potential Customers.

5. HOW WE SHARE YOUR PERSONAL INFORMATION?

We work with other companies who help us run our business (“Service Providers”). These companies provide services to help us store information (such as cloud storage companies), deliver customer support, monitor and analyze the performance of our Services and Website, manage and contact our existing Customers as well as sales leads, provide marketing support, provide fraud prevention services, and otherwise operate and improve our Services. These Service Providers may only process personal information pursuant to our instructions and in compliance with both this Privacy Policy and other applicable confidentiality and security measures and regulations.

Specifically, we do not permit our Service Providers to use any personal information we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us.
If you are a Customer, we may also share your personal information with our suppliers, in order to provide you with our Services.

In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances:

  • In the event of a merger, sale, change in control, or reorganization of all our parts of our business;

  • When we are required to disclose personal information to respond to subpoenas, court orders, or legal processes, or to establish or exercise our legal rights or defend against legal claims;

  • Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use of, or as otherwise required to comply with our legal obligations;

  • or as you may otherwise consent to from time to time.

6. INTERNATIONAL INFORMATION TRANSFERS

Please note that our businesses, as well as our trusted partners and Service Providers, are located around the world. Any information that we collect (including your personal information) is stored and processed in various jurisdictions around the world, for the purposes detailed in this Privacy Policy, including in jurisdiction which may provide different rights, with respect to personal information, than the rights provided in the jurisdiction in which you reside. We ensure through contractual measures that processing of personal data will be adequately safeguarded.

7. DATA SUBJECT RIGHTS

You may contact us at any time and request:

  • To access or delete any Personal Information relating to you;

  • To change or update any Personal Information relating to you (for example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted). Note that you may also request that we will correct errors with regard to your Personal Information (except in cases where the information is required to be kept in its original format under any applicable laws and regulations);

  • That we will restrict or cease any further use of your Personal Information

Please note that these rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations and subject to our legitimate interests. We may also rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion, in accordance with our internal policies.

8. RETENTION

We will retain your personal information for as long as necessary to operate our Website or provide the Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods shall be determined taking into account the type of information that is collected and the purpose for which it is collected for, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

9. DATA SECURITY

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal information.

While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security and privacy of your personal information or other content you transmit using the Services or Website, and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the personal information you choose to disclose.

10. NOTE FOR MINORS

We do not knowingly collect or solicit personal information from anyone under the age of consent (as determined under the applicable laws where the individual resides; “Age of Consent”). By accessing, using or interacting with our Website or Services, you certify to us that you are not under the Age of Consent. In the event that we learn that we have collected personal information from an individual under the Age of Consent without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about an individual under the Age of Consent, then please contact us through the contact details available below.

11. CHANGES TO OUR PRIVACY POLICY

We reserve the right to change this Policy at any time, so please re-visit this page frequently. All changes to this Policy are effective as of the stated “Effective Date”, and your continued use of the Website or Services after the Effective Date will constitute acceptance of, and agreement to be bound by, those changes.

12.  CONTACT INFORMATION

Spotlock Ltd.

4 Harimon st., Shilat, Israel 7318800

office@spotlock.co

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