Legal
Privacy Statement
Last updated: April 6, 2026
1) Controller and contact
- Controller: Spotlight Ventures Limited.
- Company number: 17076611.
- Registered in England and Wales.
- Privacy contact: harry97thomas@gmail.com.
2) What this statement covers
- Spotlight Ventures website-level contact, enquiry, and account data where onboarding, support, or service operations apply.
- Technical, security, and operational telemetry needed for reliability, fraud prevention, abuse response, and service integrity.
- Compliance, audit, legal, and accounting records where required.
- Service-specific app and product data categories described in each product’s own privacy notice.
Where a product has its own privacy notice, that product-specific notice should be used for the most detailed explanation of how that service handles personal data.
3) Lawful bases
- Contract: service delivery, account operation, and support handling.
- Legitimate interests: security, anti-fraud, service integrity, product quality, and incident response.
- Legal obligation: legal or compliance duties, accounting, and lawful authority requests.
- Consent (where required): optional marketing and non-essential cookies.
4) Sharing, transfers, and retention
- Data is shared with contracted providers only where needed for hosting, support, communications, security, and operations.
- Data may be processed outside the UK under appropriate transfer safeguards required by UK law.
- Data is retained only for operational, legal, security, and accounting needs, then deleted or anonymised when no longer required.
Spotlight Ventures does not sell personal data.
5) Rights and service-specific requests
- You may request access, correction, deletion, restriction, objection, and portability where applicable.
- Requests: harry97thomas@gmail.com.
- For Club SOBO app or web privacy requests, use the live Club SOBO privacy pages and rights routes listed below.
- Complaint route: ico.org.uk/make-a-complaint.