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description: 'Last Updated: 2025/2/7'
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# Privacy Policy

This **Privacy Notice** outlines the privacy practices of **Spotlight Protocol** and its affiliates (collectively, "Spotlight," "we," "our," or "us") in connection with our website and platform (together, the "Services"). It also explains the rights and choices available to individuals regarding their information.

Please review this Privacy Notice carefully to understand how we collect, use, and safeguard your data. By accessing or using the Spotlight platform, you agree to the terms described herein. If you disagree with any part of this Privacy Notice, please discontinue using the Services immediately.

We may update this Privacy Notice periodically to reflect changes in laws, regulations, or our platform. If any material changes are made that could affect your privacy rights, we will take appropriate measures to notify you. Your continued use of the Services following such updates constitutes acceptance of the revised Privacy Notice.

Our platform and Services are not directed at individuals under the age of 18. If we become aware that we have inadvertently collected information from minors, we will take prompt action to delete it. Parents or guardians who believe their child has provided us with information should contact us immediately.

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### **Personal Data Controller**

"Personal Data" refers to any information that can identify an individual. It excludes data that has been aggregated or anonymized to the extent that it no longer identifies any specific individual. This Privacy Notice applies to all Personal Data processed by Spotlight.

As the data controller, Spotlight determines the purposes and means of processing your Personal Data. This includes situations where third parties process your data on our behalf under strict contractual obligations.

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### Types of Personal Data We Collect

The types of Personal Data we collect depend on your interactions with Spotlight and may include:

* **Financial Information**: Such as wallet addresses and transaction data.
* **Transaction Details**: Including sender and recipient wallet addresses, activities on the Spotlight platform, inquiries, and our responses.
* **Usage Data**: IP address, browser type, operating system, country of origin, and other identifiers related to your interactions with the platform.
* **Verification Data**: Any additional information deemed necessary to comply with applicable anti-money laundering (AML) laws and regulations.

We may also collect information about you from publicly available sources or third parties, such as blockchain explorers or social media platforms, when it is relevant to the provision of our Services.

All Personal Data requested by Spotlight is essential to provide access to our Services. Failure to provide certain information may limit your ability to use specific features of the platform.

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### Information We Automatically Collect

When you visit the Spotlight platform, we may automatically collect certain technical information to enhance your experience, such as:

* Device details (e.g., IP address, browser version, operating system).
* Activity data, such as the pages you visit, search terms, and interactions with platform features.
* Location data, where enabled.

This information is collected through cookies and similar technologies, which help us optimize platform performance and ensure a smooth user experience.

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### Cookies and Similar Technologies

We use cookies (small text files stored on your device) and similar technologies to gather data about how you interact with the Spotlight platform.

#### **How We Use Cookies**

Cookies allow us to:

* Track platform usage and performance metrics.
* Authenticate users and ensure secure logins.
* Provide tailored content and updates.

#### **Types of Cookies**

The cookies we use can be categorized as follows:

* **Strictly Necessary**: Essential for platform functionality and security.
* **Functionality**: Remember user preferences and settings for a personalized experience.
* **Performance**: Analyze how users navigate the platform to improve usability.

#### **Managing Cookies**

You can control cookie settings through your browser or device. Please note that disabling cookies may affect platform performance or limit your access to certain features.

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### **Google Analytics**

We may use Google Analytics to better understand how users interact with the platform. This tool collects data about site usage and provides insights to improve functionality. You can opt out of Google Analytics tracking by installing the browser add-on available here.

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### **Method and Basis of Processing Data**

#### **How We Process Data**

Spotlight employs industry-standard security measures to protect your Personal Data from unauthorized access or misuse. Processing is conducted using secure IT systems, adhering to organizational protocols designed to ensure data confidentiality.

#### **Legal Basis for Processing**

We process Personal Data under the following conditions:

* **Consent**: Where you have explicitly agreed to the processing of your data.
* **Contractual Obligations**: To fulfill the terms of agreements with you.
* **Legal Compliance**: To meet obligations under applicable laws and regulations.
* **Legitimate Interests**: To further Spotlight’s goals, such as improving platform features and ensuring security.

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### **How We Use Personal Data**

We use the Personal Data we collect to:

* Operate and improve the Spotlight platform and user experience.
* Process transactions and send relevant notifications.
* Monitor for fraudulent or malicious activities and enhance security.
* Conduct analytics to understand user behavior and optimize the platform.
* Enable beta testing of new features and functionality.
* Authenticate user credentials and manage accounts.
* Comply with legal obligations, including AML and KYC regulations.
* Respond to inquiries and provide customer support.
* Protect the rights and interests of Spotlight, our users, and partners.
* Facilitate social and community engagement features on the platform.
* Integrate with external social networks and third-party platforms.
* Provide location-based services where applicable.
* Manage tags for analytics and performance tracking.
* Enhance traffic optimization and load distribution.

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### **How We Share Personal Data**

We may share your Personal Data with:

* **Service Providers**: To assist in delivering and supporting our Services.
* **Affiliates**: To align operations and improve the platform experience.
* **Authorities**: To comply with legal obligations or enforceable government requests.
* **Business Partners**: In connection with joint ventures or collaborations.
* **Potential Buyers**: If Spotlight undergoes a business transaction such as a merger, acquisition, or sale of assets.

All third parties accessing your Personal Data are bound by confidentiality obligations and are prohibited from using your data for any purpose other than as directed by Spotlight or required by law.



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### **Data Retention**

We retain Personal Data for as long as necessary to fulfill its intended purpose, comply with legal obligations, or resolve disputes. The retention period is determined based on:

* The sensitivity of the data.
* The potential risks of unauthorized access or misuse.
* Applicable legal, regulatory, or contractual obligations.

Once the retention period expires, Personal Data is deleted or anonymized. Certain blockchain-based transaction data may remain immutable due to the nature of public ledgers.

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### **Blockchain Transactions**

Spotlight utilizes blockchain technology, meaning certain transaction data may be recorded on a public blockchain. Public blockchains are decentralized networks outside of Spotlight's control. As such, we cannot alter or delete data stored on these ledgers, and users should be aware that blockchain data may be linked to other publicly available data, potentially revealing personal information.

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### **Data Security**

We prioritize the security of your Personal Data through administrative, technical, and physical safeguards. While we strive to protect your data, no system is entirely secure, and we cannot guarantee complete protection against unauthorized access.

We recommend that you use strong passwords and keep your account credentials confidential.

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### **Privacy Technology Practices**

#### **Links to Third-Party Sites**

The Spotlight platform may contain links to third-party websites or services. These links do not signify endorsement or affiliation. Spotlight is not responsible for the privacy practices of third-party sites and encourages you to review their privacy policies before engaging.

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### **Overseas Data Disclosure**

Spotlight operates globally, which means your Personal Data may be transferred and processed outside your country of residence. Such transfers are conducted under applicable legal frameworks to ensure adequate data protection. By using the Spotlight platform, you consent to this cross-border data processing.

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### **Your Privacy Rights**

Depending on your jurisdiction, you may have the following rights regarding your Personal Data:

* **Access**: Request confirmation of the data we process about you.
* **Correction**: Update inaccurate or incomplete data.
* **Erasure**: Request deletion of your data, subject to legal and contractual obligations.
* **Restriction**: Limit the processing of your data in certain circumstances.
* **Portability**: Receive your data in a structured, machine-readable format.
* **Objection**: Opt-out of certain data processing activities.
* **Withdraw Consent**: Revoke previously given consent.

To exercise these rights, please contact us via Discord or other applicable channels with sufficient information to verify your identity and the nature of your request.

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### **Complaints and Disputes**

If you believe your privacy rights have been violated or you have concerns about our data practices, please contact us via Discord or other applicable channels. We will investigate and respond to your complaint promptly. If you remain unsatisfied, you may also contact your local data protection authority.

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### **General**

This Privacy Policy outlines how Spotlight collects, uses, and protects your Personal Data. It may be updated periodically to reflect changes in our practices or legal requirements.

For further questions or concerns, please contact us via Discord or other applicable channels.

