Privacy Policy

1. Scope

This Policy applies to data collected through:

• The Spotlight web application and interfaces; and
• Any linked API integrations (e.g., Amazon Selling Partner API); and
• Communications with Spotlight for support, billing, or onboarding.

It does not apply to third-party websites or services operated by publishers, marketplaces, or affiliates (such as Amazon, Walmart, or Costingtons). Those parties have their own privacy policies.

2. Information We Collect

We collect the following categories of information when you use the Platform:

A. Account Information

Information you provide during registration or account setup:

• Name, business name, and contact details
• Payment credentials (processed securely via Stripe or ACH provider)
• Login credentials and authentication data
• Company identifiers such as Amazon Seller ID or Marketplace ID

B. Seller & Transaction Data

• Product identifiers (e.g., ASINs)
• Sales volumes, commissions, and performance metrics
• Engagement data from the publisher network
• Records of commission approvals, disputes, and invoices

C. Attribution & API Data

• Tracked Sales data reported by publishers
• Marketplace attribution and analytics data from APIs you connect (e.g., Amazon Selling Partner API, Amazon Attribution)
• Non-personal technical identifiers, such as timestamp, marketplace region, and product link data

D. Technical Data

• Device type, browser, IP address, and operating system
• Session activity and log data
• Cookies or similar identifiers used to maintain sessions and improve functionality

E. Communications

• Support requests, email messages, or chat logs
• Survey responses or feature-use feedback

3. How We Use Information

We use your information to:

• Provide and operate the Platform, including billing, reporting, and payments processing.
• Integrate with Costingtons’ network to attribute, track, and display Publisher performance.
• Maintain, improve, and develop features and ensure platform reliability and security.
• Comply with legal obligations and enforce our Terms of Service.
• Communicate with you, including responding to inquiries or sending essential service notices.
• Analyze aggregated usage to enhance functionality and performance.

We do not sell or “share” personal data for cross-context behavioral advertising. The only instance in which we may share this information is within other divisions of Worldeye Technologies, Inc.’s Seller Suite platform, including but not limited to BidX, DataHawk, and Intellifox.

4. Data Sources

Spotlight obtains data from:

• You directly (through account setup, usage, and connected payment methods);
• Costingtons, which provides Tracked Sales data from its publisher network;
• Marketplaces (e.g., Amazon) through APIs you authorize; and
• Third-party vendors who provide payment, analytics, or hosting services.

5. Legal Bases for Processing (for EEA/UK users)

Where applicable law requires a legal basis, Spotlight processes your personal data on one or more of the following grounds:

• Performance of a contract (to deliver the Platform);
• Legitimate interests (to operate and improve the service);
• Compliance with legal obligations; or
• Your consent, when required (for example, connecting an external API).

6. Data Sharing

We may share information as follows:

• With Costingtons: to deliver tracking, attribution, and publisher-level commission data.
• With Payment Providers: Stripe, banks, and ACH processors that enable secure transactions.
• With Service Providers: vendors assisting with infrastructure, analytics, and customer support, bound by confidentiality obligations, including but not necessarily limited to other divisions within Worldeye Technologies, Inc.’s Seller Suite platform, including but not limited to BidX, DataHawk, and Intellifox.
• With Marketplaces: such as Amazon, only to the extent you authorize access.
• For Legal Reasons: to comply with subpoenas, court orders, or regulatory requests.
• In Corporate Transactions: in the event of a merger, acquisition, or sale of assets.

7. Cookies & Tracking

Spotlight uses strictly necessary and performance cookies to:

• Maintain session continuity and authentication;
• Measure site and feature usage; and
• Detect fraud or security anomalies.

You can adjust browser settings to limit cookies, though some functionality may not work properly.

8. Data Retention

We retain information:

• As long as your account remains active;
• For as long as necessary to fulfill the purposes described in this Policy; and
• As required by law or for legitimate business purposes (e.g., record-keeping, dispute resolution).

Once data is no longer needed, it is securely deleted or anonymized.

9. Security

We implement administrative, technical, and organizational measures—including encryption in transit (SSL/TLS), access controls, and regular audits—to protect information from unauthorized access, disclosure, alteration, or destruction.

However, no system is perfectly secure, and we cannot guarantee absolute protection.

10. International Data Transfers

Spotlight operates in the United States. If you access the Platform from outside the U.S., you consent to the transfer and processing of your information in the U.S., where privacy laws may differ from those in your jurisdiction.

For users in the EEA, UK, or Switzerland, Spotlight relies on Standard Contractual Clauses or other appropriate safeguards for such transfers.

11. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access or obtain a copy of your personal information;
• Request correction or deletion;
• Object to or restrict certain processing;
• Withdraw consent where processing is based on consent; and
• Lodge a complaint with your local data protection authority.

To exercise these rights, contact us at privacy@spotlight.worldeye.com. We may verify your identity before fulfilling a request.

12. Children's Privacy

Spotlight is intended for users 18 years or older. We do not knowingly collect personal information from children. If we become aware that we have done so, we will delete such data promptly.

13. Data Relationships

• Seller Data Controller: Sellers act as data controllers with respect to customer or transaction data they upload or authorize through APIs.
• Spotlight Data Processor: Spotlight processes such data solely on behalf of Sellers to provide Platform functionality.
• Costingtons Data Processor: Costingtons separately processes Publisher and sales attribution data under its own terms.

Each party is responsible for maintaining its own compliance with data protection laws.

14. Updates to this Policy

We may update this Policy from time to time. The “Last Updated” date above indicates the most recent revision. Substantial changes will be communicated through the Platform or by email prior to taking effect.

15. Contact Us

If you have questions, comments, or requests regarding this Policy, please contact:

Spotlight Legal Office
Worldeye Technologies, Inc.
12110 Sunset Hills Rd, Suite 600
Reston, VA 20190
Email: spotlight@worldeye.com