OUR DATA PRIVACY POLICY
User privacy is important to Flashlight Security Services Inc., d/b/a Flashlight NOW ("Flashlight Security"). Please read this privacy policy (the “Policy”) carefully to understand how we use personal data. If you do not agree with this Policy, your choice is not to use the FlashlightSecurity.com site and mobile applications and its related sites, applications, services and goods or any other website operated by Flashlight Security that links to this Policy (the “Site”). By accessing or using this Site you agree to this Policy.
This notice also governs Flashlight Security’s other collections of personal data in connection with Flashlight Security’s services. For example, we may collect personal data in connection with our mapping technology and features. All those subject to this notice are referred to as “Users” in this notice.
This notice describes how Flashlight Security collects and uses personal data. This notice applies to all Users of our apps, websites, features, or other services. This notice specifically applies to the following Users:
Customers: individuals who request or receive Protective Agents services or Private Detectives services, including those who receive Protective Agents services or Private Detectives services requested by another individual
Protective Agents and/or Private Detectives: individuals who provide or submit applications to Flashlight Security to provide Protective Agent services or Private Detective services individually or through partner Protective Agent services or Private Detective services companies and/or firms.
UPDATES TO THIS NOTICE
We may occasionally update this notice. Changes to this Policy are effective as of the stated "Last Updated" date. Use of our services after an update constitutes your consent to the updated notice to the extent permitted by law.
We may occasionally update this notice. If we make significant changes, we will notify Users in advance of the changes through the Flashlight Security website or through other means such as email. We encourage Users to periodically review this notice for the latest data on our privacy practices.
1. Personal Data We Collect
1.1 Flashlight Security collects data provided by Users to Flashlight Security, during account creation and data created during use of our services, such as assignment dates and locations.
1. 2 User profile data is collected by or on behalf of Flashlight Security when Users create or update their Flashlight Security accounts. This may include name, email, telephone number(s), login name and password, Facebook, Apple or Google account login details and username, address, profile picture, payment or banking data (including related payment verification data), government identification documents, including Protective Agents or Private Detectives license number and expiration date. We also collect data about your communications with Flashlight Security as well as communication with other Users of Flashlight Security.
1.3 Background check and identity verification: We collect background check and identity verification data for Protective Agent and/or Private Detective partners. This may include data such as security license number and expiration date. We may use the photos submitted by providers to verify their identities, such as through facial recognition technologies. This data may be collected by an authorized vendor on Flashlight Security’s behalf.
1.4 We may collect demographic data about Users, including through User surveys.
1.5 We collect the data that Users submit when they contact Flashlight Security customer support, provide ratings or compliments for Protective Agents, Private Detectives or other Users, or otherwise contact Flashlight Security. This may include feedback, photographs or other recordings collected by Users.
2. Data created during use of our services.
2.1 We collect location data about where the security or investigative provider will be performing services.
2.2 We collect transaction data related to the use of our services, including the type of services requested or provided, order details, date and time the service was provided, amount charged, distance traveled, and payment method.
2.3 We collect usage data about how Users interact with our services. This includes data such as access dates and times, web pages viewed, website crashes and other system activity, type of browser and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Notice.
2.4 We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
Communications data: We enable Users to communicate with each other and Flashlight Security through Flashlight Security’s website. For example, we enable Protective Agents or Private Detectives to call, text, or send other files to the customers of Protective Agents or Private Detectives who have selected them for an assignment (generally without disclosing their telephone numbers to each other). To provide this service Flashlight Security receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. Flashlight Security may also use this data for customer support services (including to resolve disputes between Users), for safety and security purposes, to improve our products and services and for analytics.
3. Data from other sources.
This includes:
User feedback, such as ratings, feedback, or compliments.
Flashlight Security account owners who request services for or on behalf of other Users or who enable such Users to request or receive services through their accounts.
Users or others providing data in connection with claims or disputes.Flashlight Security business partners through which Users create or access their Flashlight Security account, such as payment providers, social media services, or apps or websites that use Flashlight Security’s application programming interface (API) or whose APIs Flashlight Security uses.Vendors who help us verify Users’ identity and background data for regulatory, safety, and security purposes.Publicly available sources.Marketing service providers.Flashlight Security may combine the data collected from these sources with other data in its possession.
4. How we use personal data
Flashlight Security collects and uses data to enable reliable and convenient Protective Agents services and/or Private Detectives services. We also use the data we collect:
To enhance the safety and security of our Users and ServicesFor customer supportFor research and developmentTo enable communications between UsersTo send marketing and non-marketing communications to UsersIn connection with legal proceedings
Flashlight Security does not sell or share User personal data with third parties for their direct marketing except with the Users’ consent.
Flashlight Security uses the data it collects for purposes including:
4.1. Providing services and features. Flashlight Security uses the data we collect to provide, personalize, maintain, and improve our products and services. This includes using the data to:
Create and update Users’ accounts.Verify the identity of providers. This may include data such as license number and expiration date.Enable transportation and other services.Offer, process, or facilitate payments for our services.Track and share the progress of assignments, rides, or other services.Enable features that allow Users to share data with other people, such as when customers submit a compliment about a Protective Services Agent or Private Detective.Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research and to monitor and analyze usage and activity trends.
4.2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and Users. This includes:
Using data submitted to Flashlight Security for safety and security purposes. We have the right to notify and provide data to law enforcement and regulatory authorities If we believe a provider or User is or may be engaged or has engaged in criminal activities or regulatory violations.
Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.
Using User ratings and feedback to encourage compliance with our Community Guidelines and as grounds for deactivating Protective Agents and/or Private Detective partners with low ratings or who otherwise violated those guidelines.
4.3. Customer support. Flashlight Security uses the data we collect (including recordings of customer support calls with notice to and the consent of the User) to provide customer support, including to:
Direct questions to the appropriate customer support personInvestigate and address User concernsMonitor and improve our customer support responses and processes
4.4. Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the User experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.
4.5. Enabling communications between Users. For example, a provider may message or call a customer to confirm an assignment location, or a customer may contact a provider with data or instructions.
4.6. Marketing. Flashlight Security may use the data we collect to market our services to our Users. This includes sending User’s communications about Flashlight Security services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.
We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on User location, past use of Flashlight Security’s services, and User preferences and settings.
4.7. Non-marketing communications. Flashlight Security may use the data we collect to generate and provide Users with receipts inform them of changes to our terms, services, or policies or send other communications that are not for the purpose of marketing the services or products of Flashlight Security.
4.8. Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Flashlight Security’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
4.9. Automated decision-making. We use personal data to make automated decisions relating to use of our services. This includes:
Enabling dynamic pricing, in which the price of Protective Agents and/or Private Detectives is determined based on constantly varying factors such as the provider’s assignment location, the provider’s estimated time and distance from the assignment location, the duration of the security assignment, environmental factors that make an assignment inherently dangerous, and the number of customers and providers using Flashlight Security at a given moment.
Matching available providers to Users requesting services. Users can be matched based on availability, proximity, and other factors.
Determining User ratings, and deactivating customers and providers with low ratings.
Deactivating Users who are identified as having engaged in potential criminal activity, fraud or activities that in the sole discretion Flashlight Security that may otherwise harm Flashlight Security, its Users, and others. In some cases, such behavior may result in automatic deactivation.
5. Cookies and third-party technologies
Flashlight Security uses cookies and other identification technologies on our apps, website, emails, and online ads for purposes described in this notice.
Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Flashlight Security uses cookies and similar technologies for purposes such as:
• Authenticating Users
• Remembering User preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of advertising campaigns
• Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services.
We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.
6. Data sharing and disclosure
Some of Flashlight Security’s products, services, and features require that we share data with other Users or at a User’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.
Flashlight Security may share the data we collect:
1. With other Users. This includes sharing:
Customers’ first name, rating, and security assignment locations with providers.For providers we may share data with the customer(s), including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during assignment); average rating provided by Users; total number of Flashlight Security assignments; contact data and security provider profile, including compliments and other feedback submitted by past Users. We also provide customers with receipts containing data such as a breakdown of amounts charged, provider’s first name, photo, assignment map, and such other data required on invoices in the region(s) where provider operates.
2. With the general public
Questions or comments from Users submitted through public forums such as Flashlight Security blogs and Flashlight Security social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a User.
3. With the Flashlight Security account owner
If a User requests services or places an order using an account owned by another party, we may share their order or assignment data, including real-time location data, with the owner of that account.
4. With Flashlight Security service providers and business partners
We do not sell or rent your personal data to third parties for their marketing purposes without your explicit consent. Flashlight Security provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:
Payment processors and facilitatorsBackground check and identity verification providersCloud storage providersMarketing partners and marketing platform providers, including social media advertising services.Data analytics providersThis Site is also protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply with respect to data collected by reCAPTCHA. The use of Google reCAPTCHA is required to prevent fraud and misuse of the Site by use of automated machines. To learn more please see Google's privacy policy.Research partners, including those performing surveys or research projects in partnership with Flashlight Security or on Flashlight Security’s behalfVendors that assist Flashlight Security to enhance the safety and security of its apps.Consultants, lawyers, accountants, and other professional service providersInsurance and financing partnersIf you link, connect, or login to your Flashlight Security account with a third-party service (e.g., Google, Facebook, LinkedIn), we receive certain data, such as your registration and profile data from that service. This data varies and is controlled by that service or as authorized by you via your privacy settings at that service.
5. For legal reasons or in the event of a dispute
Flashlight Security may share Users’ personal data if we believe it is required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms of Service, User agreements, or other policies; to protect Flashlight Security’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including Protective Agents and/or Private Detective assignment or Protective Agents and/or Private Detectives data, with the owner of that credit card.
This provision also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
6. With consent
Flashlight Security may share a User’s personal data other than as described in this notice if we notify the User and they consent to the sharing.
7. Data retention and deletion
Flashlight Security retains User profile, transaction, and other personal data for as long as a User maintains a Flashlight Security account.
Flashlight Security may retain certain User data after receiving an account deletion request if necessary, such as to comply with legal requirements.
Flashlight Security retains User profile, transaction, and other data for as long as a User maintains their Flashlight Security account. For providers Flashlight Security also retains license data for as long as they maintain a Flashlight Security account.
Customers may request deletion of their account at any time by emailing the request to [email protected] Following such requests Flashlight Security deletes the data it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, Flashlight Security retains location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, Flashlight Security may be unable to delete a User’s account, such as if there is an outstanding credit on the account, an unresolved claim or dispute regulatory or governmental investigative demand, or request or as otherwise required by law or court rules. Upon resolution of the issue preventing deletion, Flashlight Security will delete the account as described above.
Flashlight Security may also retain certain data if necessary, for purposes of safety, security, and fraud prevention. For example, if Flashlight Security deactivates a User’s account because of unsafe behavior or security incidents, Flashlight Security may retain certain data about the account to prevent that User from opening a new Flashlight Security account in the future.
8. Grounds for processing
We only collect and use personal data where we have lawful grounds to do so. These include processing User’s personal data to provide requested services and features, for purposes of Flashlight Security’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent. Such grounds generally include processing personal data:
a. To provide requested services and features. To provide our services, we must collect and use certain personal data. This includes:
User profile data, that we use to establish and maintain User accounts; communicate with Users about their orders and accounts; and enable Users to make payments or receive earnings.License data, is used to verify an applicant’s eligibility to be a Protective Agent and/or Private Detective partnerProviders’ location data, that we use to track assignments and assist with navigation.Usage data, that is necessary to maintain, optimize, and enhance Flashlight Security’s services, including to connect customers and providers and calculate costs of assignments and employee earnings.Transaction dataData relating to customer support.
b. For purposes of the legitimate interests of Flashlight Security or other parties. This includes using personal data to maintain and enhance our Users’ safety and security. For example, we use personal data to prevent use of our services by Users who have engaged in inappropriate or dangerous behavior such as by retaining data of banned Users to prevent their use of Flashlight Security’s scheduling services. We also use data to prevent matching of customers and providers for whom there is a higher risk of conflict (for instance because they have been the subject of prior complaints from other Users).
This also includes purposes such as combating fraud, improving our services, direct marketing, research, and development, and enforcing Flashlight Security’s Terms of Service.
In addition, it includes using personal data to the extent necessary for the interests of other people or the general public such as in connection with legal or insurance claims and to protect the rights and safety of others.
c. To fulfill Flashlight Security’s legal obligations.
For example, Flashlight Security is subject to laws and regulations that require it to collect and retain data about our Users’ assignments, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.
Flashlight Security may also share data with law enforcement regarding criminal acts or threats to public safety or requests by third parties pursuant to legal processes.
d. With consent
Flashlight Security may collect and use personal data based on the User’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.
A User who has provided consent to the collection or use of their personal data can revoke it at any time. However, the User will not be able to use any service or feature that requires collection or use of that personal data.
9. Choice and transparency
Flashlight Security enables Users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that Flashlight Security restrict its processing of User personal data.
Flashlight Security provides Users with assignment status notifications and updates related to activity on their account. These notifications are a necessary part of using the Flashlight Security scheduling services and cannot be disabled without deletion of the account.
10. Ratings look-up
After every protective agent or investigation assignment, customers can rate providers on a scale from 1 to 5. An average of those ratings is associated with a providers account and is displayed to other Users. For example, provider ratings are available to their customers.
Flashlight approves or disapproves ratings prior to publication. Accountability helps create a respectful, safe environment for Providers, their staff, and customers.
11. Site and Data Security
We take great care in maintaining the security of the Site and your data and in preventing unauthorized access, loss, misuse, alteration, destruction or damage to it through industry standard technologies and internal procedures. Among other things we regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification (with respect to payment by credit cards). In addition, we contractually ensure that any third party processing your personal data equally provides for confidentiality and integrity of your data in a secure way. However, the transmission of data via the internet is not completely secure and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site. Any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.
Users who have registered to the Site agree to keep their password in strict confidence and not disclose such password to any third party.
Last Updated May 8, 2021
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