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PRIVACY POLICY

 

Last updated August 19, 2024

 

This privacy notice for Spotlight owned by valenzelektron.com ('we', 'us', or
'our'), describes how and why we might collect, store, use, and/or share
('process') your information when you use our services ('Services'), such as
when you:

 * Download and use our mobile application (Spotlight), or any other application
   of ours that links to this privacy notice

 * Engage with us in other related ways, including any sales, marketing, or
   events

By downloading or using Spotlight you agree to this Privacy Policy and our Terms
of Service.

Questions or concerns? Reading this privacy notice will help you understand your
privacy rights and choices. If you do not agree with our policies and practices,
please do not use our Services. If you still have any questions or concerns,
please contact us at hi@valenzelektron.com.

 

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out
more details about any of these topics by following each key point.

What personal information do we process? When you visit, use, or navigate our
Services, we may process personal information depending on how you interact with
us and the Services, the choices you make, and the products and features you
use.

Do we process any sensitive personal information? We do not process sensitive
personal information.

Do we collect any information from third parties? We do not collect any
information from third parties.

How do we process your information? We process your information to provide,
improve, and administer our Services, communicate with you, for security and
fraud prevention, and to comply with law. We may also process your information
for other purposes with your consent. We process your information only when we
have a valid legal reason to do so.

In what situations and with which types of parties do we share personal
information? We may share information in specific situations and with
specific categories of third parties.

How do we keep your information safe? We have organisational and technical
processes and procedures in place to protect your personal information. However,
no electronic transmission over the internet or information storage technology
can be guaranteed to be 100% secure, so we cannot promise or guarantee that
hackers, cybercriminals, or other unauthorised third parties will not be able to
defeat our security and improperly collect, access, steal, or modify your
information.

What are your rights? Depending on where you are located geographically, the
applicable privacy law may mean you have certain rights regarding your personal
information.

How do you exercise your rights? The easiest way to exercise your rights is
by visiting https://spotlight.valenzelektron.com/delete, or by contacting us. We
will consider and act upon any request in accordance with applicable data
protection laws.

 

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when
you register on the Services, express an interest in obtaining information about
us or our products and Services, when you participate in activities on the
Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect
depends on the context of your interactions with us and the Services, the
choices you make, and the products and features you use. The personal
information we collect may include the following:

 * usernames

 * passwords

 * email addresses

Sensitive Information. We do not process sensitive information.

Application Data. If you use our application(s), we also may collect the
following information if you choose to provide us with access or permission:

 * Geolocation Information. We may request access or permission to track
   location-based information from your mobile device, either continuously or
   while you are using our mobile application(s), to provide certain
   location-based services. If you wish to change our access or permissions, you
   may do so in your device's settings.

 * Mobile Device Access. We may request access or permission to certain features
   from your mobile device, including your mobile device's camera, storage, and
   other features. If you wish to change our access or permissions, you may do
   so in your device's settings.

 * Push Notifications. We may request to send you push notifications regarding
   your account or certain features of the application(s). If you wish to opt
   out from receiving these types of communications, you may turn them off in
   your device's settings.

This information is primarily needed to maintain the security and operation of
our application(s), for troubleshooting, and for our internal analytics and
reporting purposes.

All personal information that you provide to us must be true, complete, and
accurate, and you must notify us of any changes to such personal information.

 

Google API

Our use of information received from Google APIs will adhere to Google API
Services User Data Policy, including the Limited Use requirements.

 

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your
consent.

We process your personal information for a variety of reasons, depending on how
you interact with our Services, including:

 * To facilitate account creation and authentication and otherwise manage user
   accounts. We may process your information so you can create and log in to
   your account, as well as keep your account in working order.

 * To send administrative information to you. We may process your information to
   send you details about our products and services, changes to our terms and
   policies, and other similar information.

 * To save or protect an individual's vital interest. We may process your
   information when necessary to save or protect an individual�s vital
   interest, such as to prevent harm.

 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is
necessary and we have a valid legal reason (i.e. legal basis) to do so under
applicable law, like with your consent, to comply with laws, to provide you with
services to enter into or fulfil our contractual obligations, to protect your
rights, or to fulfil our legitimate business interests.

 

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain
the valid legal bases we rely on in order to process your personal information.
As such, we may rely on the following legal bases to process your personal
information:

 * Consent. We may process your information if you have given us permission
   (i.e. consent) to use your personal information for a specific purpose. You
   can withdraw your consent at any time. Learn more about withdrawing your
   consent.

 * Performance of a Contract. We may process your personal information when we
   believe it is necessary to fulfil our contractual obligations to you,
   including providing our Services or at your request prior to entering into a
   contract with you.

 * Legal Obligations. We may process your information where we believe it is
   necessary for compliance with our legal obligations, such as to cooperate
   with a law enforcement body or regulatory agency, exercise or defend our
   legal rights, or disclose your information as evidence in litigation in which
   we are involved.

 * Vital Interests. We may process your information where we believe it is
   necessary to protect your vital interests or the vital interests of a third
   party, such as situations involving potential threats to the safety of any
   person.

 

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission
(i.e. express consent) to use your personal information for a specific purpose,
or in situations where your permission can be inferred (i.e. implied consent).
You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to
process your information without your consent, including, for example:

 * If collection is clearly in the interests of an individual and consent cannot
   be obtained in a timely way

 * For investigations and fraud detection and prevention

 * For business transactions provided certain conditions are met

 * If it is contained in a witness statement and the collection is necessary to
   assess, process, or settle an insurance claim

 * For identifying injured, ill, or deceased persons and communicating with next
   of kin

 * If we have reasonable grounds to believe an individual has been, is, or may
   be victim of financial abuse

 * If it is reasonable to expect collection and use with consent would
   compromise the availability or the accuracy of the information and the
   collection is reasonable for purposes related to investigating a breach of an
   agreement or a contravention of the laws of Canada or a province

 * If disclosure is required to comply with a subpoena, warrant, court order, or
   rules of the court relating to the production of records

 * If it was produced by an individual in the course of their employment,
   business, or profession and the collection is consistent with the purposes
   for which the information was produced

 * If the collection is solely for journalistic, artistic, or literary purposes

 * If the information is publicly available and is specified by the regulations

 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this
section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your
data with third-party vendors, service providers, contractors, or agents ('third
parties') who perform services for us or on our behalf and require access to
such information to do that work. We have contracts in place with our third
parties, which are designed to help safeguard your personal information. This
means that they cannot do anything with your personal information unless we have
instructed them to do it. They will also not share your personal information
with any organisation apart from us. They also commit to protect the data they
hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as
follows:

 * Communication & Collaboration Tools

 * Cloud Computing Services

 * Website Hosting Service Providers

 * User Account Registration & Authentication Services

 * Data Storage Service Providers

We also may need to share your personal information in the following situations:

 * Business Transfers. We may share or transfer your information in connection
   with, or during negotiations of, any merger, sale of company assets,
   financing, or acquisition of all or a portion of our business to another
   company.

 * When we use Google Maps Platform APIs. We may share your information with
   certain Google Maps Platform APIs (e.g. Google Maps API, Places API). We
   obtain and store on your device ('cache') your location. You may revoke your
   consent anytime by contacting us at the contact details provided at the end
   of this document.

 

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and
store your information.

We may use cookies and similar tracking technologies (like web beacons and
pixels) to gather information when you interact with our Services. Some online
tracking technologies help us maintain the security of our Services and your
account, prevent crashes, fix bugs, save your preferences, and assist with basic
site functions.

We also permit third parties and service providers to use online tracking
technologies on our Services for analytics and advertising, including to help
manage and display advertisements, to tailor advertisements to your interests,
or to send abandoned shopping cart reminders (depending on your communication
preferences). The third parties and service providers use their technology to
provide advertising about products and services tailored to your interests which
may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be
a 'sale'/'sharing' (which includes targeted advertising, as defined under the
applicable laws) under applicable US state laws, you can opt out of these online
tracking technologies by submitting a request as described below under
section 'DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?'

Specific information about how we use such technologies and how you can refuse
certain cookies is set out in our Cookie Notice.

 

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the
purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for
the purposes set out in this privacy notice, unless a longer retention period is
required or permitted by law (such as tax, accounting, or other legal
requirements). No purpose in this notice will require us keeping your personal
information for longer than the period of time in which users have an account
with us.

When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymise such information, or, if this is
not possible (for example, because your personal information has been stored in
backup archives), then we will securely store your personal information and
isolate it from any further processing until deletion is possible.

 

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system
of organisational and technical security measures.

We have implemented appropriate and reasonable technical
and organisational security measures designed to protect the security of any
personal information we process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so we cannot
promise or guarantee that hackers, cybercriminals, or other unauthorised third
parties will not be able to defeat our security and improperly collect, access,
steal, or modify your information. Although we will do our best to protect your
personal information, transmission of personal information to and from our
Services is at your own risk. You should only access the Services within a
secure environment.

 

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions,
such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and
Canada, you have rights that allow you greater access to and control over your
personal information. You may review, change, or terminate your account at any
time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain
rights under applicable data protection laws. These may include the right (i) to
request access and obtain a copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the processing of your personal
information; (iv) if applicable, to data portability; and (v) not to be subject
to automated decision-making. In certain circumstances, you may also have the
right to object to the processing of your personal information. You can make
such a request by contacting us by using the contact details provided in the
section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable data
protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing
your personal information, you also have the right to complain to your Member
State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection
and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your
personal information, which may be express and/or implied consent depending on
the applicable law, you have the right to withdraw your consent at any time. You
can withdraw your consent at any time by contacting us by using the contact
details provided in the section ' HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?' below.

However, please note that this will not affect the lawfulness of the processing
before its withdrawal nor, when applicable law allows, will it affect the
processing of your personal information conducted in reliance on lawful
processing grounds other than consent.

 

Account Information

If you would at any time like to review or change the information in your
account or terminate your account, you can:

 * Log in to your account settings and update your user account.

 * Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your
account and information from our active databases. However, we may retain some
information in our files to prevent fraud, troubleshoot problems, assist with
any investigations, enforce our legal terms and/or comply with applicable legal
requirements.

If you have questions or comments about your privacy rights, you may email us
at hi@valenzelektron.com.

 

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications
include a Do-Not-Track ('DNT') feature or setting you can activate to signal
your privacy preference not to have data about your online browsing activities
monitored and collected. At this stage, no uniform technology standard
for recognising and implementing DNT signals has been finalised. As such, we do
not currently respond to DNT browser signals or any other mechanism that
automatically communicates your choice not to be tracked online. If a standard
for online tracking is adopted that we must follow in the future, we will inform
you about that practice in a revised version of this privacy notice.

California law requires us to let you know how we respond to web browser DNT
signals. Because there currently is not an industry or legal standard
for recognising or honouring DNT signals, we do not respond to them at this
time.

 

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware,
Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon,
Tennessee, Texas, Utah, or Virginia, you may have the right to request access to
and receive details about the personal information we maintain about you and how
we have processed it, correct inaccuracies, get a copy of, or delete your
personal information. You may also have the right to withdraw your consent to
our processing of your personal information. These rights may be limited in some
circumstances by applicable law. More information is provided below.

 

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past
twelve (12) months:

 

Category

Examples

Collected

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile
contact number, unique personal identifier, online identifier, Internet Protocol
address, email address, and account name

 

YES

 

B. Personal information as defined in the California Customer Records statute

Name, contact information, education, employment, employment history, and
financial information

 

NO

 

C. Protected classification characteristics under state or federal law

Gender, age, date of birth, race and ethnicity, national origin, marital status,
and other demographic data

 

NO

D. Commercial information

Transaction information, purchase history, financial details, and payment
information

 

NO

E. Biometric information

Fingerprints and voiceprints

 

NO

F. Internet or other similar network activity

Browsing history, search history, online behaviour, interest data, and
interactions with our and other websites, applications, systems, and
advertisements

 

NO

G. Geolocation data

Device location

 

YES

H. Audio, electronic, sensory, or similar information

Images and audio, video or call recordings created in connection with our
business activities

 

YES

I. Professional or employment-related information

Business contact details in order to provide you our Services at a business
level or job title, work history, and professional qualifications if you apply
for a job with us

 

NO

J. Education Information

Student records and directory information

 

NO

K. Inferences drawn from collected personal information

Inferences drawn from any of the collected personal information listed above to
create a profile or summary about, for example, an individual�s preferences
and characteristics

 

NO

L. Sensitive personal Information

 

NO

 

We may also collect other personal information outside of these categories
through instances where you interact with us in person, online, or by phone or
mail in the context of:

 * Receiving help through our customer support channels;

 * Participation in customer surveys or contests; and

 * Facilitation in the delivery of our Services and to respond to your
   inquiries.

We will use and retain the collected personal information as needed to provide
the Services or for:

 * Category A - As long as the user has an account with us

 * Category G - As long as the user has an account with us

 * Category H - As long as the user has an account with us

 

Sources of Personal Information

Learn more about the sources of personal information we collect in 'WHAT
INFORMATION DO WE COLLECT?'

 

How We Use and Share Personal Information

Learn about how we use your personal information in the section, 'HOW DO WE
PROCESS YOUR INFORMATION?'

 

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to
a written contract between us and each service provider. Learn more about how we
disclose personal information to in the section, 'WHEN AND WITH WHOM DO WE SHARE
YOUR PERSONAL INFORMATION?'

We may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration.
This is not considered to be 'selling' of your personal information.

We have disclosed the following categories of personal information to third
parties for a business or commercial purpose in the preceding twelve (12)
months:

The categories of third parties to whom we disclosed personal information for a
business or commercial purpose can be found under 'WHEN AND WITH WHOM DO WE
SHARE YOUR PERSONAL INFORMATION?'

We have sold or shared the following categories of personal information to third
parties in the preceding twelve (12) months:

The categories of third parties to whom we sold personal information are:

The categories of third parties to whom we shared personal information with are:

 * User Account Registration & Authentication Services

 

Your Rights

You have rights under certain US state data protection laws. However, these
rights are not absolute, and in certain cases, we may decline your request as
permitted by law. These rights include:

 * Right to know whether or not we are processing your personal data

 * Right to access your personal data

 * Right to correct inaccuracies in your personal data

 * Right to request the deletion of your personal data

 * Right to obtain a copy of the personal data you previously shared with us

 * Right to non-discrimination for exercising your rights

 * Right to opt out of the processing of your personal data if it is used for
   targeted advertising (or sharing as defined under California�s privacy
   law), the sale of personal data, or profiling in furtherance of decisions
   that produce legal or similarly significant effects ('profiling')

Depending upon the state where you live, you may also have the following rights:

 * Right to obtain a list of the categories of third parties to which we have
   disclosed personal data (as permitted by applicable law,
   including California's and Delaware's privacy law)

 * Right to obtain a list of specific third parties to which we have disclosed
   personal data (as permitted by applicable law, including Oregon�s privacy
   law)

 * Right to limit use and disclosure of sensitive personal data (as permitted by
   applicable law, including California�s privacy law)

 * Right to opt out of the collection of sensitive data and personal data
   collected through the operation of a voice or facial recognition feature (as
   permitted by applicable law, including Florida�s privacy law)

 

How to Exercise Your Rights

To exercise these rights, you can contact us by
visiting spotlight.valenzelektron.com/delete, by emailing us
at hi@valenzelektron.com, or by referring to the contact details at the bottom
of this document.

You can opt out from the selling of your personal information, targeted
advertising, or profiling by disabling cookies in Cookie Preference Settings.

Under certain US state data protection laws, you can designate
an authorised agent to make a request on your behalf. We may deny a request from
an authorised agent that does not submit proof that they have been
validly authorised to act on your behalf in accordance with applicable laws.

 

Request Verification

Upon receiving your request, we will need to verify your identity to determine
you are the same person about whom we have the information in our system. We
will only use personal information provided in your request to verify your
identity or authority to make the request. However, if we cannot verify your
identity from the information already maintained by us, we may request that you
provide additional information for the purposes of verifying your identity and
for security or fraud-prevention purposes.

If you submit the request through an authorised agent, we may need to collect
additional information to verify your identity before processing your request
and the agent will need to provide a written and signed permission from you to
submit such request on your behalf.

 

Appeals

Under certain US state data protection laws, if we decline to take action
regarding your request, you may appeal our decision by emailing us
at hi@valenzelektron.com. We will inform you in writing of any action taken or
not taken in response to the appeal, including a written explanation of the
reasons for the decisions. If your appeal is denied, you may submit a complaint
to your state attorney general.

 

California 'Shine The Light' Law

California Civil Code Section 1798.83, also known as the 'Shine The Light' law,
permits our users who are California residents to request and obtain from us,
once a year and free of charge, information about categories of personal
information (if any) we disclosed to third parties for direct marketing purposes
and the names and addresses of all third parties with which we shared personal
information in the immediately preceding calendar year. If you are a California
resident and would like to make such a request, please submit your request in
writing to us by using the contact details provided in the section ' HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?'

 

11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

 

Australia and New Zealand

We collect and process your personal information under the obligations and
conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act
2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy
Acts, in particular: what personal information we collect from you, from which
sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfil their
applicable purpose, it may affect our ability to provide our services, in
particular:

 * offer you the products or services that you want

 * respond to or help with your requests

 * manage your account with us

 * confirm your identity and protect your account

At any time, you have the right to request access to or correction of your
personal information. You can make such a request by contacting us by using the
contact details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE
THE DATA WE COLLECT FROM YOU?'

If you believe we are unlawfully processing your personal information, you have
the right to submit a complaint about a breach of the Australian Privacy
Principles to the Office of the Australian Information Commissioner and a breach
of New Zealand's Privacy Principles to the Office of New Zealand Privacy
Commissioner.

 

Republic of South Africa

At any time, you have the right to request access to or correction of your
personal information. You can make such a request by contacting us by using the
contact details provided in the section 'HOW CAN YOU REVIEW, UPDATE, OR DELETE
THE DATA WE COLLECT FROM YOU?'

If you are unsatisfied with the manner in which we address any complaint with
regard to our processing of personal information, you can contact the office of
the regulator, the details of which are:

 

The Information Regulator (South Africa)

General enquiries: enquiries@inforegulator.org.za

Complaints (complete POPIA/PAIA form
5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

 

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with
relevant laws.

We may update this privacy notice from time to time. The updated version will be
indicated by an updated 'Revised' date at the top of this privacy notice. If we
make material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a
notification. We encourage you to review this privacy notice frequently to be
informed of how we are protecting your information.

 

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us
at hi@valenzelektron.com or contact us by visiting https://valenzelektron.com:

__________

Schaffhausen 8200

Switzerland

 

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US,
you may have the right to request access to the personal information we collect
from you, details about how we have processed it, correct inaccuracies, or
delete your personal information. You may also have the right to withdraw your
consent to our processing of your personal information. These rights may be
limited in some circumstances by applicable law. To request to review, update,
or delete your personal information,
please visit: spotlight.valenzelektron.com/delete.

 

15. LANGUAGE

This Privacy Policy was written in English. If you are reading a translation and
it conflicts with the English version, please note that the English version
controls.