Privacy Policy

1. Identification of the Data Controller

Bright Kiosk Spotlight Media Ltd (referred to as "Bright Kiosk Spotlight", "we", "us", or "our"), a company registered in England and Wales under Company Registration Number 14892041, having its registered office at 24 St John's Square, Clerkenwell, London EC1M 4DS, United Kingdom, acts as the Data Controller responsible for your personal data under the UK General Data Protection Regulation (UK GDPR), EU General Data Protection Regulation (Regulation (EU) 2016/679), and relevant international privacy frameworks.

2. Categories of Data Collected

We process personal data only to the extent necessary to deliver high-quality editorial travel guides, itinerary tools, and interactive mapping features. Categories collected include:

• Direct Communications Data: Your name, email address, inquiry nature, and message content when submitting queries via our contact desk.
• Technical & Telemetry Data: Internet Protocol (IP) address, browser type and version, device hardware identifiers, operating system, time zone settings, and WebGL rendering capabilities used to display 3D maps smoothly.
• Usage Analytics Data: Page access duration, click paths, interactive tool preferences (such as filtering by destination style), and referring URLs.

3. Legal Bases for Processing Under GDPR

We process your data strictly pursuant to lawful bases defined under Article 6 of the GDPR:

• Legitimate Interests: To monitor application stability, secure our digital infrastructure against fraudulent requests, and optimize the rendering of travel visualization tools.
• Consent: For non-essential analytics and custom itinerary state cookies, obtained transparently via our smart cookie banner.
• Contractual / Pre-contractual Steps: To respond directly to inbound editorial or business inquiries initiated by you.

4. Cookies, LocalStorage, and Spatial WebGL Telemetry

Our platform uses lightweight, modern web technologies including localStorage keys (e.g. brightkiosk_cookie_consent) to remember your consent preferences and client-side filtering selections across browser refreshes without transmitting sensitive profiles to third parties. For full details, review our Cookie Policy.

5. International Data Transfers

Whenever data is processed through hosting infrastructure located outside the United Kingdom or the European Economic Area (EEA), we enforce Standard Contractual Clauses (SCCs) approved by the European Commission and the UK International Data Transfer Addendum to ensure your data maintains an equivalent level of security.

6. Data Retention Protocols

We retain contact inquiry correspondence for no longer than 24 months from final resolution. Aggregated technical telemetry data is anonymized within 90 days and stored solely for performance benchmarking and traffic analysis.

7. Your Statutory Rights Under UK/EU GDPR and CCPA

Subject to applicable jurisdictional laws, you hold unambiguous rights regarding your personal information:

• Right of Access: Obtain confirmation of processing and copies of your stored personal data.
• Right to Rectification: Demand correction of incomplete or inaccurate data.
• Right to Erasure ("Right to be Forgotten"): Request deletion of data where retention is no longer legally justified.
• Right to Restrict or Object: Limit processing or object to processing carried out under legitimate interest grounds.
• Right to Data Portability: Receive your provided data in a structured, machine-readable format.
• California Consumer Privacy Act (CCPA) Notice: We do not sell, rent, or monetize your personal data to third-party data brokers.

8. Data Protection Officer (DPO) Contact

To exercise any statutory rights, submit queries, or communicate with our designated Data Protection Officer, email us at: [email protected] or write to: Bright Kiosk Spotlight Media Ltd, Attn: Legal & DPO, 24 St John's Square, Clerkenwell, London EC1M 4DS, United Kingdom.