User Privacy Policy

If you are a Spotlite User, this is what you need to know:

Welcome to our User Privacy Policy! Here we explain:

For the purposes of this policy, the User is the employee or agent of our Client. A person can only be made a User of Spotlite by the Client Administrator and the Client will have wider responsibilities in respect to the User’s privacy. As a result, this document must be read in conjunction with the Spotlite Terms and Conditions, specifically section 4, and in the context of the whole agreement between CDD Management Services and the Client.

Our Data Controller determines the purpose and means of processing personal data. This is: -

CDD Management Services Ltd
2 Mount Street,
Manchester,
M2 5WQ,
United Kingdom

The contact details for our Data Protection Officer are: -

David Crack
CDD Management Services Ltd
2 Mount Street,
Manchester
M2 5WQ
United Kingdom

For the purposes of due diligence, correspondence, security and prevention of abuse, we will require some information about you. The details of how we collect, use and share your information are given below.

This is the information we collect about you

We will collect your name, a facial photo, Photo ID, mobile number and email. We will also record the date, time and location where you initiated the due diligence on an Applicant, the Services you used and the outcome from those Services.

How we use your information

We use your information to:

Where we share or disclose your information

We will only share your information with our third-party data and service providers where it is necessary for us to do so to fulfil the Services requested by you. We may otherwise share or disclose your information for the following reasons: –

How long do we store your personal data

Your personal data will be stored while your organisation authorises you to be a Spotlite user. Once your usage of Spotlite has ceased, we will retain your data for one year for our records and then we will delete your personal data.

Where we store your personal information

The information that we collect from you is stored in the UK or, where it is necessary to disclose it to our processors located outside the UK, other jurisdictions which are acceptable according to guidance provided by the Information Commissioner and/or where appropriate legal and security safeguards are in place.

Information Security

We use a range of technical and organisational measures to safeguard access to and use of, your personal information. These include structured access controls to systems, network protection, intrusion detection, physical access controls and staff training.

Subject Access Requests

The information we hold about you as a Spotlite User is obtainable via the app and/or our website. It is illegal for us to disclose to you information pertaining to reporting our suspicions concerning your potential criminal behaviour or of ongoing criminal or regulatory investigations concerning your information.