SPOTLIGHT LEGALS

CIPS values the trust you place in us when you use spotlight.id and our other affiliated websites, applications or tools (collectively, our “Websites”). This Privacy Policy describes our collection, use, and disclosure of your information and applies to our Websites that link to it, regardless of how you access or use them, including through mobile devices.

If you do not agree to the terms of this Privacy Policy, please do not use our Websites. We may make changes to this Privacy Policy from time to time. We will post any changes to our Websites. Your continued use of our Websites following the posting of any changes will mean you accept those changes.

We collect, process, and retain information from you and any devices you may use when you access our Websites, use our services, register for an account with us, provide us information on a web form, update or add information to your account, participate in community discussions, chats, or otherwise correspond with us. The specific information we collect depends upon your use of the Websites, as described below.

• Information You Give Us: We receive and store information you enter on our Websites or give us in any other way, including your name, physical address, phone number, email address, and payment information.

• Information About Your Interaction With Our Websites: We collect information about your interactions with our Websites, such as the purchases you make or the pages you visit.

• Information We Automatically Collect: We receive and store certain types of information whenever you interact with us or our Websites. Our Websites use “cookies,” tagging and other tracking technologies. This information includes computer and connection information such as statistics on your page views, traffic to and from our Websites, referral URL, ad data, your IP address, and device identifiers; this information may also include your browsing history, transaction history, and your web log information.

• Location Information: We may receive information about your location and your mobile device, including a unique identifier for your device.

• Information From Other Sources: We may supplement the personal information we collect with information from third parties and add it to your account information. Information from third parties may include, but is not limited to, demographic information that is publically available, additional contact information, group affiliations, occupational information, and educational background.

We use your information to help us personalize and continually improve your experience on the Websites, including fulfilling your orders and requests for information, analyzing and compiling trends and statistics, and communicating with you. For information about how to manage your information and the choices you have, see how to limit the use of your information below.

General Uses

We may use your information to:

• Provide, maintain, and improve the Websites for internal or other business purposes;

• Fulfill requests for information;

• Provide, produce, and ship the products that you order or the services you request; Provide customer support; Track and evaluate the use of the Websites;

• Communicate with you about your Customer Account, Content Owner Account, profile or transactions with us, * changes to our policies or terms;

• Send you information about features and enhancements on or to our Websites; Send you newsletters or other materials;

• Send you offers, promotions, or other communications about our products and services, including special or promotional events, including services, products, or events for which we collaborate or co-offer with a third party;

• Detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal;

• Optimize or improve our products, services and operations; and

• Perform statistical, demographic, and marketing analyses of users of the Websites and their viewing patterns.

We may use the information from one portion of the Websites on other portions of the Websites, and we may combine information gathered from multiple portions of the Websites into a single record. We may also use or combine information that we collect offline or we collect or receive from third-party sources for many reasons, including to enhance, expand, and check the accuracy of our records.

We do not share your personal information with third parties, except as set forth below. We may disclose information that does not specifically identify you, such as aggregate information, device identifiers or other unique identifiers to third parties to third parties in any manner we deem appropriate. For information about how to manage your information and the choices you have, see how to limit the use of your information below.

Third-Party Service Providers: We have affiliates and service providers that perform functions on our behalf, including, but not limited to: payment processing, hosting, content syndication, content management, technical integration, marketing, analytics, and fraud protection. These third parties may have access to your personal information when needed to perform their functions. If we share information with these third parties that personally identifies you, such as your name, address, or phone number, we will require the third parties to maintain the confidentiality and security of your personal information, and they will be restricted from using, selling, or distributing this information in any way other than to provide the requested services to the Websites.

Sale, Assignment or Change of Control: We may change our ownership or corporate organization while providing the Websites. We may transfer to another entity or its affiliates some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any business, other change of control transaction or financing. Under such circumstances, we would request the acquiring party to follow the practices described in this Privacy Policy. Nevertheless, we cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Privacy Policy.

Law Enforcement, Legal Process, and Emergency Situations: We may also use or disclose your personal information if required to do so by law or on the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Site; (b) protect and defend our rights or property, the Websites or our users, or (c) act to protect the personal safety of us, users of the Websites or the public.

We take the security of your information seriously. We use technical and administrative security measures such as but not limited to encryption techniques and authentication procedures, among others, to maintain the security of your online session. Please understand, however, that while we try our best to safeguard your personal information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

You can help protect the privacy of your own information by using encryption and other techniques to prevent unauthorized interception of your personal information. You are responsible for the security of your information when using unencrypted, public or otherwise unsecured networks.

We take steps to ensure that the personal information we collect is accurate and up to date, and that you have the ability to access and make corrections to it, including giving you the ability to see, review, and change your personal information by signing in to your account.

We may not be able to delete your personal information without also deleting your user account. You will not be permitted to examine the personal information of any other person or entity. In order to verify your identity, you may be required to provide us with personal information prior to accessing any records containing information about you. We may not accommodate a request to change or delete personal information if we believe doing so would violate any law or legal requirement, or cause the information to be incorrect.

In many instances, you have choices about the information you provide and limiting how we use your information. These choices, and any related consequences, are described in detail below.

• Personal information: You may choose not to provide your personal information, such as your name, address, phone number or payment information, but then you might not be able to take advantage of many of our site and/or checkout features.

• Emails, Newsletters, and other communications: When you create an account through our Websites, you are required to provide us with an accurate e-mail address through which we may contact you. Registration through our Websites or apps constitutes your express acknowledgment that Sencillo Inc may use your e-mail address to communicate with you about product offerings from us. While you cannot opt-out of receiving notifications and other communications regarding your account or your transactions, you can opt-out of receiving newsletters and promotional emails and other marketing communications from us by using the “unsubscribe” feature in our marketing e-mails and newsletters.

• Location Tracking: Most mobile devices allow you to control or disable the use of location services by any application on your mobile device through the device’s settings’ menu.

Although most changes are likely to be minor, spotlight.id may change its Privacy Policy from time to time, and in spotlight.id' sole discretion. spotlight.id encourages visitors to frequently check this page for any changes to its Privacy Policy. If you have a spotlight.id account, you should also check your social network dashboard for alerts to these changes. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such change.

For questions about our Privacy Policy, to make choices about receiving promotional communications, to update your personal information, or to place an order, you can contact us at: support@spotlight.id