Privacy Policy
Last updated: April 2026
Effective date: April 2026
1. Introduction and scope
This Privacy Policy explains how SpotlightedMe, operated by ილია კუჩერიავიხ, collects, uses, shares, and protects personal data in connection with spotlightedme.com.
By using the Service, you acknowledge this Privacy Policy. Where required by law, we will seek additional consent.
The controller responsible for the personal data described in this Policy is ილია კუჩერიავიხ, registration number 300409225, registered address: საქართველო, თბილისი, ნაძალადევის რაიონი, ზღვის უბნის დასახლება, XI მიკრო-რაიონი, III კვარტალი, კორპუსი 54A, ბინა N46.
2. Categories of personal data
Depending on your interaction with the Service, we may process:
- identifiers (name, email address, account identifiers)
- account and authentication data (hashed credentials, login events, security signals)
- profile data (photo, age range, gender, country, languages, interests, optional biographical details)
- content and submissions you provide to the Service, including review-related inputs
- payment-related metadata (transaction IDs, status, billing context) processed via payment providers
- device and technical data (IP address, device type, browser, OS, diagnostics)
- usage and behavioral data (pages visited, actions, timestamps, navigation paths)
- support and communications data (messages, attachments, follow-up records)
- security and anti-fraud data (risk indicators, abuse signals, enforcement records)
- inferred or derived data used for service integrity, safety, and feature improvement
Where photographs or video you submit incidentally reveal information such as apparent racial or ethnic origin, religious or philosophical belief, or health status, we do not analyze or infer such information; the imagery is processed solely for the purpose you submitted it (obtaining feedback), on the same legal bases described in Section 4.
3. Sources of data
We may obtain personal data from:
- you directly, when you register, interact with features, make payments, or contact support
- automatic collection through your device and browser when you use the Service
- third-party providers such as authentication, payments, analytics, and infrastructure partners
- publicly available sources where lawful and relevant
4. Purposes and legal bases
We process personal data for service delivery, security, compliance, and operations under one or more legal bases:
- contract necessity (to provide requested features and manage your account)
- legitimate interests (fraud prevention, platform security, service reliability, product improvement)
- legal obligation (tax, accounting, law enforcement, and regulatory compliance)
- consent where required by applicable law (e.g., certain tracking or optional communications)
5. Cookies and tracking
We use cookies and similar technologies as described in our Cookie Policy.
If you accept analytics cookies, we also record what happens to your order after you leave the site — payment authorised or captured, review delivered, refund, dispute, poll closed — and send those events to our analytics provider under the same pseudonymous identifier your browser uses. They carry no photos, review text, email address or name. Withdrawing consent stops this and erases the stored identifier from your orders.
6. Sharing and disclosures
We may disclose personal data in limited circumstances, including:
- to vetted service providers and processors acting on our instructions
- to comply with legal obligations, lawful requests, and court orders, and to cooperate with, and make disclosures to, law enforcement, regulators, and courts, including to report or investigate suspected unlawful activity
- to other platforms, payment providers, and anti-fraud, trust-and-safety, or industry networks, to prevent, detect, investigate, and respond to fraud, abuse, security incidents, and violations of our policies (for example, sharing that an account was suspended for fraud or prohibited content)
- to other partners and third parties where you have consented to the disclosure, or where the disclosure is otherwise permitted or required under applicable law
- in connection with mergers, acquisitions, financing, or asset transfers
- to protect rights, safety, and integrity of users, the Service, and the public
- in aggregated, de-identified, or anonymized form that no longer identifies you, which we may use and share for any purpose
7. International data transfers
Your data may be processed in countries other than your own. Where required, we apply safeguards such as EU Standard Contractual Clauses (SCCs) 2021/914, UK International Data Transfer Addendum, supplementary measures (encryption at rest and in transit, access controls) and, where offered, self-certification under the EU-US Data Privacy Framework.
8. Data retention
We retain personal data for as long as reasonably necessary to provide the Service, comply with legal obligations (tax, anti-fraud, anti-money-laundering), resolve disputes, and enforce the Terms. Retention periods vary depending on data category, legal requirements, and risk controls.
Deleting your account or an order removes the associated files (such as photos) from storage. The underlying database records are soft-deleted rather than purged on a fixed schedule: this keeps reviewer earnings, payment, and dispute records intact and auditable. If you want your personal data permanently erased rather than soft-deleted, contact us and we will process the request on a best-effort basis, subject to the retention exceptions below.
Payment and transaction records are retained for at least 7 years to meet tax, accounting, and anti-fraud obligations, and records needed for an open dispute or legal claim are retained until it is resolved.
9. Your privacy rights
Subject to your jurisdiction, you may have rights such as:
- right to access certain personal data
- right to correct inaccurate data
- right to request deletion under applicable conditions
- right to request restriction of processing in specific cases
- right to data portability where legally applicable
- right to object to certain processing activities
- right to withdraw consent where processing is based on consent
- right to file complaints with competent supervisory authorities
To exercise rights, contact us using the details in the Contact section. We may verify identity before fulfilling requests.
We aim to respond to privacy requests within 10 working days where the Law of Georgia on Personal Data Protection applies, and within 45 calendar days (extendable once, as the CCPA permits) where the California Consumer Privacy Act applies.
10. Security
We maintain technical, administrative, and organizational safeguards designed to protect personal data. No method of transmission or storage is guaranteed to be completely secure.
In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the competent supervisory authority and affected users without undue delay, to the extent and within the timeframes required by applicable law.
11. Children's data
The Service is not directed to minors. If we learn that personal data of a minor has been collected in violation of applicable law, we will take steps to delete or restrict such data.
12. Third-party links and services
The Service may contain links to third-party websites or tools. Their privacy practices are governed by their own policies, not this Privacy Policy.
13. Changes to this Privacy Policy
We may update this Privacy Policy periodically. Material changes will be reflected on this page with an updated revision date.
14. Related policies
For additional legal and operational context, review:
15. Contact and complaints
For privacy requests or general inquiries, contact:
For complaints or unresolved privacy concerns, contact: