Essential Guide: How We Protect Your Privacy at Spotlight Creative

Personal Information Processing Guidelines

Scope of Data Collection

Understanding Personal Data: What Companies Know About You

Our use of the phrase "personal information" (along with "personal data" as specified in relevant privacy laws) encompasses any details that can identify or be connected to a living individual. For clarity, we define a "natural person" as a living human being.

The scope of personal information excludes openly accessible data and information that has undergone aggregation or de-identification (also known as anonymization under privacy regulations). Once data is aggregated or de-identified, it becomes non-personal in nature. This transformation occurs when we extract all identifying elements (such as names, contact details, and physical addresses), ensuring the remaining information cannot reasonably be traced back to you.

Your Digital Footprint: How We Collect and Use Your Data

To protect your privacy, we gather only essential personal data using advanced security technologies. This includes techniques like encryption, pseudonymization, and anonymization to minimize data collection while meeting our service objectives.

Privacy Law Explained: Why We Process Your Information

Our data collection and processing activities are governed by the following legal frameworks:

• With Your Consent to collect and use your personal information for one or more purposes.
• In Performance of a Contract between you and Spotlight Creative Marketing Agency, or for the implementation of pre-contractual measures taken at your request.
• To Comply with Legal Obligations , including: (i) to comply with applicable laws, rules, and regulations; (ii) to respond to and comply with court orders, subpoenas, and warrants, and criminal, civil, or regulatory investigations; (iii) to cooperate with government bodies and law enforcement requests; and (iv) to enforce our legal interests, such as by supporting the exercise, preparation, or defense of any legal claims.
• To Protect the Vital interests of an Individual , including where there are reasonable grounds to believe that our failure to act (by not disclosing certain personal information) could result in risk of death or serious bodily harm to you or others.
• In Pursuit of Legitimate Interests , including to conduct business activities related to the products and services that we provide to you and others, and to operate our business.

Categories of Persons

Who We Collect Data From

• Marketing Service Users
• Young Users and Their Guardians (applicable when providing services requiring parental approval)
• Editorial Contributors (individuals who provide content for our digital platforms and publications)
• External Partners and Temporary Staff
• Information Recipients (individuals authorized to receive personal data transfers)
• Celebrity & Artist Members
• Business Partners
• Current and Past Personnel, Including Qualified Dependents
• Job Applicants
• Vendor Representatives
• Public Representatives and Event Hosts (participating in our live and virtual programming)
• Facility and Event Attendees
• Website Visitors

Sources of Information

Our personal information comes from these primary sources:

• Information we collect directly from you depending on which services you request from us, how you engage with our services, and what specific personal information we need from you to provide these services.
• Information your organization provides to us that is necessary for you to use our services under a contractual agreement we have with your organization.
• Information we collect automatically depending on which services you request from us, how you engage with our services, and how you configured your device, browser, and email client.
• Information we receive from other parties including our advertising, measurement and analytics, and social media partners, data brokers, financial institutions, government and regulatory bodies, payment processors, public records, and service providers.

Essential Guide: Understanding Personal Data Classifications in 2024

Below are the types of personal data we process. Note that not every category applies to all individuals:

Personal Data Classification	Examples	Third-Party Data Transfer Status
Account Information	Account Details & Login Information	Yes
Biometric Data	Unique physical, behavioral, and biological identifiers that can be linked to personal identity	No
Protected Classifications	Personal demographic details including generational, nationality, ability status, gender identity and expression, health status, service record, ethnic background, religious beliefs, and sexual orientation	No
Child Data	For services involving minors, we collect basic details like names and birthdates with parent/guardian approval	No
Commercial Information	Shopping & Preference History	Yes
Contact Information	Guest Information	Yes
Credentials	Security credentials including system access tokens, login details, and account recovery information for our enterprise users	No
Demographics Data	Demographic information such as personal characteristics, family status, professional background, and socioeconomic indicators	No
Device Data	Connected Device Information	Yes
Electronic Communications	Communication records spanning digital messages, voice interactions, and virtual meetings during our service interactions	No
Financial Information	Financial transaction details based on your chosen payment method, including card data and bank transfer information	No
Fraud & Investigations Data	Security incident documentation including reported crimes, identity theft cases, and compromised account information	No
Geocoding Data	Location Services Data	No
Non-Precision Geolocation Data	Geographic positioning data derived from your digital footprint, including broad location markers based on IP or postal information	Yes
Government Identifiers	Government-issued identification numbers collected solely for employment verification and onboarding processes	No
Identifiers	Contact and identification details encompassing digital, physical, and government-verified credentials used to reach you	Yes
Inferences & Profiling Data	Personalized insights generated through data analysis and automated systems to better understand user preferences	Yes
Internet Activities	Website Activity Tracking	Yes
Online Identifiers	Digital tracking identifiers used in online advertising, analytics, and web monitoring technologies	Yes
Employment Information	Employment-related documentation covering professional qualifications, performance metrics, and personnel administration	No
Sensitive Personal Information	Sensitive personal identifiers including biometric markers, protected status information, and secure payment details	No
Sensory Information	Multimedia recordings and sensory data captures, including visual, audio, and thermal information	No
User Feedback	User feedback collected through various channels including social media engagement, satisfaction surveys, and service evaluations	Yes
Social Media Content	Social Media Analytics	Yes

Purpose for Processing

Here's why we gather and process your personal data:

• Ensuring proper benefits delivery to current staff, retirees and their eligible dependents
• Service Updates & Communications
• Meeting regulatory requirements while protecting our legal rights and interests
• Establishing and maintaining your user profile to better serve your needs
• Celebrity Marketing Services
• Optimizing our promotional activities and marketing initiatives
• Meeting our agreed-upon commitments and responsibilities
• Enhancing our products, services and user satisfaction levels
• Streamlining company operations to serve you better
• Personalized Recommendations
• Implementing comprehensive security measures against unauthorized access and fraudulent activities
• Ensuring smooth order completion and delivery
• Delivering responsive and helpful assistance when you need it
• Creating impactful social media presence for high-profile individuals
• Evaluating digital marketing performance through detailed metrics
• Confirming you meet age requirements and validating your identity

Keeping Kids Safe Online: Our Child Protection Policy

Age Requirement: 18+

Children's Privacy Protection

Digital Safety: How We Verify Parent Permission

Parental Consent Guidelines

• Collection, Processing, and Retention: We will provide notice to the parent or legal guardian and obtain their written authorization for the service and verifiable parental consent before collecting and processing personal information about their child.
• Disclosure: We will provide a separate notice to the parent or legal guardian and obtain their written authorization before disclosing personal information about their child to our service providers and third parties.
• Sale: Under no circumstances do we knowingly sell personal information about children.

Who Sees Your Data? Our Information Sharing Guidelines

Third-Party Service Providers

The following types of organizations may receive access to personal information:

• Within our Corporate Group of affiliate companies and subsidiaries to provide our celebrity marketing services and support our business operations
• With our Contractors and Service Providers who perform services on our behalf including cloud service providers, social media analytics tools, marketing platforms, payment processing services, and website hosting
• With our Third-Party Providers who provide cross-context behavioral advertising services for our celebrity marketing campaigns
• Corporate Transactions: We may share or disclose personal information in connection with any sale of company assets, merger, acquisition, or corporate reorganization
• Legal, Regulatory, and Law Enforcement Bodies: We may disclose information as required to comply with applicable laws, court orders, subpoenas, and regulatory investigations

How Long Do We Keep Your Data? Storage Policy Explained

Data Retention Period

We leverage cutting-edge privacy technologies to minimize data collection and storage, ensuring we retain only essential personal information.

Key data retention timeframes include:

• For customers: We typically retain your personal information for up to six (6) years after your contractual relationship with us ends or your last account transaction occurred
• For employees: We typically retain your personal information for up to six (6) years after your employment relationship with us ends
• For unsuccessful applicants: We typically retain your personal information for up to four (4) years after we have communicated our hiring decision to you

Safeguarding Your Privacy: Our Security Measures

We implement robust security measures to protect your data, including technical safeguards, administrative controls, and physical security protocols to prevent unauthorized access or data loss.

Our robust protection framework features:

• Comprehensive security protocols and detailed incident management strategies
• Advanced encryption systems protecting data both during transmission and storage
• Strict authentication controls limiting data access to authorized personnel only
• Regular staff cybersecurity awareness and compliance training
• Regular system backups to ensure data preservation

Take Control: Managing Your Profile and Preferences

Access our user-friendly dashboard to control your account settings:

• Account Information: Update your name, business name, mailing address, email address, and account password
• Subscription Services: Add, modify, pause or cancel your subscription services
• Orders & Tracking: View order history, track orders, and re-order
• Payment Methods: Add, modify or remove your payment information
• Addresses: Add, modify or remove your addresses
• Favorites: Add, modify or remove your favorites

For assistance managing your account, contact our customer service at +17862934510 .

Your Choice Matters: Customizing Marketing Communications

Get tailored updates and offers about our celebrity marketing - manage your preferences or unsubscribe anytime through your account settings.

If you require help managing your contact preferences, contact our customer service at +17862934510 .

Stop Auto-Decisions: Control AI-Driven Processing

Systems that process your data to make important decisions without human oversight, using AI, analytics, and statistical models.

We employ smart technology to customize celebrity marketing experiences. If you prefer not to participate in automated personalization, simply submit an opt-out request through our Privacy Rights portal.

Browse Your Way: Managing Cookies and Ad Preferences

Our online services use cookies, pixel tags, tracking scripts, and similar technologies to authenticate users, enable secure online purchasing, deliver our celebrity marketing services, and personalize content and offers. Our Cookie Notice provides instructions on how to opt-out from or remove our cookies from your device or browser.

Additional opt-out options for personalized advertising are available via these industry platforms:

• Digital Advertising Alliance:
  • WebChoices to opt-out using your browser
  • YourAdChoices to opt-out using your email address or telephone number
• Network Advertising Initiative:
  • Network Advertising Initiative Opt-Out

Inbox Control: Customize Your Mail Communications

To stop receiving our promotional messages, follow the unsubscribe instructions in any communication. We'll process your request within 10 business days.

• For direct mail: Opt-out by contacting our customer service at +17862934510
• For email messages: Opt-out by clicking on the "Unsubscribe" link in the email message we sent or by contacting our customer service

Text Updates: How to Manage Message Notifications

For text messaging services, you can opt-out by replying STOP, END, CANCEL, UNSUBSCRIBE or QUIT to any text message you receive from Spotlight Creative Marketing Agency. You may receive one final text message confirming your request. For help, reply HELP to any text message or contact us at +17862934510 .

How to Stop Companies from Selling Your Personal Data: Complete Guide

While we don't sell your data for money, we use targeted advertising services. See Privacy Rights to control how your information is shared.

For our workforce and candidates, we maintain strict privacy standards, never selling or sharing personal data for cross-platform advertising.

Your Ultimate Guide to Universal Opt-Out Settings & Digital Privacy

Our platform recognizes Global Privacy Control signals and other universal opt-out tools, confirming your choice with "Opt-Out Request Honored."

Understanding Your Privacy Rights: A Consumer's Essential Handbook

Your privacy rights vary by location and request type. Check your eligible data protection options.

Available privacy options include:

• Right to Access your personal information and be informed about what processing, sharing, or disclosure we have done
• Right to Correct inaccuracies to your personal information
• Right to Delete your personal information from our business systems
• Right to Data Portability to your personal information in a machine-readable format
• Right to Restrict Processing to your personal information under certain conditions
• Right to designate an Authorized Agent to act on your behalf regarding your personal information
• Right to Opt-out from targeted advertising, the sale or sharing of your personal information, and automated decision-making technology
• Right to Withdraw Consent to our collection, use, and disclosure of your personal information
• Right to Appeal Decisions we have made about your personal information and privacy rights
• Right to File Complaint with your applicable data protection authority

To activate these privacy features:

• Online: Use our Privacy Form
• Email: [email protected]
• Phone: +17862934510

Protect Your Rights: Why Privacy Choices Won't Affect Your Service Quality

We treat all customers equally regardless of privacy choices - same prices, service quality, and access to products.

Risk Assessment Guide: Safeguarding Your Personal Information Online

We conduct thorough risk evaluations of our data processing systems, considering scope, context, and purpose while ensuring compliance with relevant privacy regulations.

Data Breach Alert: What Happens When Your Information Is Compromised

We investigate security incidents promptly and notify affected users via email if their data is compromised.

Cross-Border Data Protection: Understanding Global Information Flow

As a U.S.-based organization, Spotlight Creative Marketing Agency operates exclusively within American territories.

Your information may be stored on servers worldwide, including countries with different privacy standards than your own.

Our data transfer practices utilize secure, industry-standard protocols and safeguards to protect your personal information when sharing across systems.

• Adequacy Decisions: European Commission adequacy decisions and UK adequacy decisions
• By Contract: EU standard contractual clauses ("EU SCCs"), the UK International Data Transfer Addendum to the EU SCCs ("UK Addendum"), or equivalent model clauses
• With Your Consent: Where you have provided consent to the proposed transfer after being informed of possible risks

Privacy Laws by Region: Your Country-Specific Data Protection Guide

For detailed information about privacy regulations and rights specific to your location, please review these region-specific privacy guidelines:

• California Privacy Notice
• GDPR Privacy Notice

Essential Privacy Terms: What's Included in Your Data Protection Agreement

• For clients, customers, users, and web visitors, you must read this Global Notice together with our Terms of Service
• External websites linked from our platform operate under their own privacy policies.

Resolve Privacy Concerns: Expert Solutions for Data Protection Issues

We are committed to resolving your questions, issues, and complaints about this Global Notice and related privacy management practices by emailing [email protected] or calling +17862934510 .

Should you feel your privacy concerns haven't been adequately addressed, you may escalate the issue to our senior leadership team. If you remain dissatisfied with the outcome, you retain the right to file a formal complaint with your local data protection regulatory authority.

Who Controls Your Data? Key Contacts for Information Security

The organization responsible for overseeing and managing your personal data collection under our Global Privacy Notice is:

Meet Your Privacy Guardians: Data Protection Officers Directory

Reach our Data Protection Team

Stay Informed: Latest Updates to Our Global Privacy Standards

This Global Notice may undergo periodic updates or revisions. Any modifications will become effective on the date specified in the "Last Updated" section at the beginning of this document.

Any material change to this Global Notice will be effective upon posting the revised Global Notice to our services at https://www.txw-legend.com/legal/global-privacy-notice.html or by emailing a copy of these changes to the email address on file for your account or by any other means consistent with applicable law. It is your responsibility to check this Global Notice for changes prior to each use of our services.

Effective Date: June 24, 2025
Last Review Date: June 24, 2025
Next Scheduled Review: December 2025