Privacy Policy Last updated: 24/02/2024

We, referred to as "We", "Us" or "Our", are dedicated to safeguarding your Personal Data and protecting your privacy.

This Privacy Policy is designed to inform you about how we handle, collect, store, and utilize the information you provide in connection with the website (the “Website”).

We adhere to the following principles:

• Ensuring transparency in the collection and processing of your Personal Data:

At Spectra Echelon, we emphasize keeping you well-informed, empowering you to make educated decisions regarding the use of your Personal Data on our Website or when engaging in trading with a third-party platform. To this end, we utilize a variety of approaches to provide you with relevant information on how your Personal Data is handled, ensuring it is conveyed accurately and promptly.

Furthermore, if it becomes necessary to furnish you with specific information, we will ensure it is delivered at the appropriate time and place.

We are also eager to address any inquiries you might have and to offer any needed clarifications, within legal boundaries. For this purpose, you can reach out to us by sending an email to: support@

• Processing your Personal Data solely for the purposes detailed in this Policy:

The purposes for which we may process your Personal Data include, among others, to make the Website available to you andprovide you with access to third-party trading platforms (the “Services”), aimed at enhancing your experience on the Website, optimizing the Services (including the Website), safeguarding Our rights and interests, facilitating business and administrative activities that support the delivery of the Services to the Website users, and/or ensuring compliance with any legal and/or regulatory obligations.

Furthermore, We will process your Personal Data to gain insights into your specific needs and preferences.

• To allocate significant resources in upholding your rights regarding your Personal Data:

We dedicate considerable resources to enable you to exercise your rights as a data subject. Therefore, you are welcome to contact Us at any time to review your Personal Data, request amendments, deletion, cessation of use for specific purposes or overall, or its transfer to you or a third party. We will comply with your requests in accordance with the law.

•To ensure the security of your Personal Data:

While We cannot guarantee absolute protection of your Personal Data, We assure you that We employ and will continue to employ a comprehensive array of strategies and measures aimed at securing your Personal Data.

Our Comprehensive Privacy Policy

1. The Scope?

This Policy outlines the types of Personal Data the Company collects about individuals, and the methods of collection, usage, sharing with third parties, security measures, processing, etc.

In this Policy, “Personal Data” denotes any information relating to an identified or identifiable individual. An identifiable individual is one who can be identified, either directly or in conjunction with additional information that We have or have access to.

In this Policy, the “processing” of Personal Data refers to any operation or set of operations performed on Personal Data, including collection, recording, organization, structuring,storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction of Personal Data.

Our Services are crafted for a broad audience and are not designed for individuals under 18. We do not intentionally gather or request data from anyone under 18, nor do we knowingly permit such individuals to use our Services. If we discover information pertaining to a minor has been collected, we will promptly take reasonable measures to erase such data.

2. When Do We Gather Personal Data About You?

We acquire Personal Data about you whenever you engage with the Services, interact with our service channels, and browse the Website. In some scenarios, you will actively share Personal Data with us, while in others, we will gather Personal Data by analyzing your interaction with Our Services and/or service channels, or receive your data from our third-party partners.

3. No Obligation To Provide Personal Data To The Company And Its Implications

You are under no obligation to share any Personal Data with us. However, in certain cases, not providing such Personal Data may hinder us from offering you the Services, limit your ability to use the Website, and/or cause issues with the functionality of the Services and the Website.

4. What Types of Personal Data Do We Collect? Personal Data We Collect When You Browse the Website:

This includes your online activity log, traffic information (including, without limitation, IP address, time and date of access, web and mobile pages visited, language used, software crash reports, and browser type used, as well as details about the device you used. Some of this information may not personally identify you, and thus may not constitute Personal Data.

Personal Data We Receive from You: Any Personal Data you willingly provide when interacting with a third-party trading platform through Spectra Echelon.

Personal Data You specifically provide for submission to third-party platforms for trading purposes: This information includes your full name, phone number, and email address.

5. The Purposes of Processing Personal Data and Their Legal Basis

Spectra Echelon processes your Personal Data for one or more of the purposes detailed in this section, following the appropriate legal foundation.

Spectra Echelon will only process Personal Data about you if there is a legal basis for such processing. The legal bases upon which Spectra Echelon may process your Personal Data are as follows:

  • You have consented to the processing of your Personal Data for one or more specific purposes. This pertains to cases where you specifically provide your details through the website, allowing us to submit them to third-party trading platforms.
  • Processing is essential for the legitimate interests pursued by Spectra Echelon or by a third party. For instance, for the enhancement of our services, or for the exercise or defense of legal claims.
  • Processing is necessary to comply with a legal obligation to which Spectra Echelon is subject.

Should you need further information on how the processing of your Personal Data aligns with the legitimate interests of Spectra Echelon or an external party, please do not hesitate to contact us via email at any time.

Below, we offer a concise overview of the reasons we might process your Personal Data, along with the legal justifications for these actions:

Objective Legal Justification
1

To share your information with third parties upon your request in order to engage with digital trading

We may gather your Personal Data to share it with third parties, should you expressly request this.

You have provided consent for your Personal Data to be processed for one or more specified purposes.
2

To address your inquiries, requests, and/or complaints

Processing of your Personal Data is necessary to address any inquiries related to your use of the Services.

Processing is essential for the legitimate interests pursued by the Company or a third party.
3

To meet any legal responsibilities or comply with judicial or administrative directives

We handle your Personal Data to ensure we meet our legal responsibilities.

Processing is essential to fulfill a legal obligation that Spectra Echelon is bound by.
4

To enhance Our Services

We may utilize your Personal Data to refine Our Services. This process will include, among other things, any crash logs or other malfunction reports related to the Services.

Processing is necessary to serve the legitimate interests pursued by Spectra Echelon or a third party.
5

To prevent fraud and misuse of Our Services

Processing is necessary to serve the legitimate interests pursued by Spectra Echelon or a third party.
6

To execute and sustain various activities that support the delivery of Our Services

Such activities encompass back-office operations, business development initiatives, strategic planning, supervisory frameworks, and more.

Processing is essential to fulfill the legitimate interests pursued by the Company or by a third party.
7

For conducting analysis, including statistical evaluations

We apply a variety of analytical techniques, including statistical ones, to inform our decisions on numerous matters.

Processing is essential to fulfill the legitimate interests pursued by the Company or by a third party.
8

To safeguard Our and third parties' interests, rights, and assets, including the initiation, exercise, or defense of legal claims

We may process your Personal Data to protect Our interests, rights, and assets, or those of third parties, in compliance with any applicable law, regulation, or agreement, including any of Our terms, conditions, and policies.

Processing is essential to fulfill the legitimate interests pursued by the Company or by a third party.

6. Transfer Of Personal Data To Third Parties

Spectra Echelon might also disclose your Personal Data to third parties that assist us with services like storage, hosting, IP address data, user experience analysis, and other technical, analytical, or diagnostic services.

Furthermore, if you expressly ask us to share specific Personal Data with third-party trading platforms, we will transmit the information you provide to us for that purpose. These third parties will manage your Personal Data according to their privacy policies. Your data might be shared with several third-party trading platforms.

Spectra Echelon may also share your Personal Data with affiliated entities and business partners, enhancing our capacity to deliver superior services and products to our users.

We may also disclose your Personal Data to governmental, local, official, and regulatory bodies if required to safeguard our interests, rights, and assets, or those of third parties, including initiating, exercising, or defending legal claims.

Additionally, we might reveal your Personal Data to potential buyers, investors, or lenders to Spectra Echelon or any associated companies, in scenarios such as asset sales, mergers, reorganizations, consolidations, or bankruptcy involving Spectra Echelon or any related entities.

7. Cookies and Third Party Services

We may engage third-party services, such as analytics firms or advertisers on our Website, that may utilize cookies or similar technologies, governed by their respective policies.

A cookie (a small text file) may be placed on the device you use to visit or access the Website. These cookies help collect information about you and your behavior, allowing us to

enhance your user experience, remember your preferences and settings, and tailor our products and services to your interests. Cookies may also assist in gathering statistics and conducting analytics.

We may employ session cookies, which are temporarily stored on your device and remain until you close your web browser, as well as persistent cookies, which continue to exist on your device after you stop browsing and help the Website recognize you as a returning visitor upon your next visit.

Categories of cookies:

The cookies we may utilize are categorized based on their function, as follows:

Cookie Category Function Additional Details
Essential Cookies

These cookies are crucial for enabling navigation of the Website and the use of its requested features. They are used to deliver the content, products, and services you have requested from us.

Such cookies are vital for helping your device download or stream information, allowing you to move around the Website, use its features, and revisit previously accessed pages.

These cookies collect Personal Data about you, like your username and last login date, and recognize you as being logged into the Website.

These cookies vanish once you shut your web browser (session cookies).

Functionality Cookies Designed to identify you upon returning to the Website, these cookies enable us to recall your preferences and selections. These cookies persist beyond the closure of your browser, remaining active until they reach their designated expiration.
Performance Cookies Utilized to gather aggregated statistics about the Website's performance, these cookies assist in testing and enhancing performance for an improved user experience. They also support our analytical tasks on the Website.

These cookies gather anonymized data, unlinked to any identified or identifiable individual.

Their lifespan varies; some are erased when you close your browser, while others remain indefinitely.

Blocking and Removing Cookies

You have the option to adjust your browser settings to block and remove certain or all cookies. Below are links to guides on performing these actions for some popular web browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

Please be aware that altering these settings may cause certain features and functionalities of the Website to not operate as expected.

ONLINE TRACKING NOTICE

CURRENTLY, THIS SERVICE DOES NOT ACCOMMODATE DO-NOT-TRACK SIGNALS.

8. Retention Of Personal Data About You

Spectra Echelon will maintain your Personal Data for the necessary duration to achieve the processing purposes outlined in this Policy, or for a longer period if mandated by applicable laws, regulations, policies, or directives.

We will share your information with third-party trading platforms for a 12-month duration and, with your consent, may extend this period for an additional 12 months.

To prevent retaining your Personal Data longer than necessary, we regularly review our records to determine if any Personal Data can be deleted.

9. Transfers of Personal Data To A Third Country Or An International Organization

Your Personal Data may be transferred to countries outside your own jurisdiction or to international organizations. Spectra Echelon will implement appropriate safeguards to ensure your data is protected and that enforceable rights and effective legal remedies are available to data subjects.

If you reside in the EEA (European Economic Area), rest assured that these protections will be in place under any of the following conditions:

  • The transfer is directed to a third country or an international organization that the EU Commission has determined provides an adequate level of protection for the Personal Data being transferred, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
  • The transfer complies with a legally binding and enforceable instrument between public authorities or bodies as per Article 46(2)(a) of the GDPR; or
  • The transfer adheres to standard data protection clauses adopted by the EU Commission as outlined in Article 46(2)(c) of the GDPR. These clauses can be reviewed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

You are welcome to request details regarding the safeguards [Spectra Echelon] employs to protect your Personal Data when transferred to a third country or international organization by sending an email to the following address: support@

10. Protection Of Your Personal Data

We apply robust technical and organizational measures to maintain an appropriate level of security for Personal Data, considering the risks associated with processing, especially against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to Personal Data that is transmitted, stored, or otherwise processed.

While we strive for excellence, we cannot assure, nor do we claim, flawless performance in protecting your Personal Data. We are not liable for any indirect, incidental, consequential, or punitive damages related to the use or release of your Personal Data, including, but not limited to, disclosure due to transmission errors, unauthorized third-party access, or other causes beyond our reasonable control.

Due to legal or other obligations beyond our control, we might be required to transfer your Personal Data to third parties,such as governmental bodies. In these situations, our ability to manage the level of protection provided to your Personal Data by these external parties is limited.

Transmitting Personal Data over the internet can never be completely secure. Therefore, Spectra Echelon cannot guarantee the safeguarding of your Personal Data when it is transferred to us online.

11. Links To Websites of Third Parties

The Website might offer links to third-party websites and/or applications. Spectra Echelon does not manage these websites and applications, nor do we oversee the collection and/or processing of your Personal Data by them. We bear no responsibility for these external sites and applications, nor for their privacy and data protection policies and activities. This Policy is not applicable to any actions conducted via these websites and/or applications.

When you visit these third-party websites and/or applications, we strongly suggest that you thoroughly review their privacy policies before using these websites and/or applications and before sharing any of your Personal Data.

13. Your Rights in Respect Of The Personal Data About You

Generally, you hold the right to request confirmation from us regarding the collection of your Personal Data, to review the data, to correct it if necessary, and to request the deletion of Personal Data no longer needed by Spectra Echelon. You may also limit your consent to certain processing of your Personal Information.

If you are an EEA resident please read this section below:

You are entitled to specific rights concerning your Personal Data. To exercise these rights, you may send a request to exercise your rights to the following email address:

Right of access

You are entitled to obtain confirmation from Spectra Echelon regarding whether your Personal Data is being processed, and if so, access to the Personal Data and the following

Here’s what you need to know: (1) the objectives behind processing; (2) the types of Personal Data involved; (3) who has received or will receive your Personal Data, especially those outside the European Economic Area (EEA) or international entities; (4) if feasible, how long your Personal Data will be kept, or if not, the criteria for determining that duration; (5) your right to request correction or deletion of your Personal Data or to limit its processing, or to object to such processing; (6) the right to file a complaint with a regulatory body; (7) if your Personal Data wasn’t obtained from you directly, any available information about its source; (8) the existence of profiling; and (9) if your Personal Data is sent to a country outside the EEA or to an international organization, the relevant protections for the transfer.

Spectra Echelon will provide you with a copy of your Personal Data being processed and may charge a fair fee for any additional copies you request. If you request electronically, and unless you specify otherwise, the information will be delivered in a widely used electronic format.

Your right to access a copy of your Personal Data should not infringe on the rights and freedoms of others. Thus, if fulfilling your request affects others' rights and freedoms, Spectra Echelon may choose not to fulfill it or may do so in a restricted way.

Right to Rectification

You are entitled to request that Spectra Echelon corrects any inaccurate Personal Data about you. Considering the processing purposes, you also have the right to complete any incomplete Personal Data, possibly by providing a supplementary statement.

Right to Erasure

The following reasons may apply: (a) the Personal Data is no longer needed for the original purposes for which it was collected or processed; (b) you revoke your consent on which the processing relies and there’s no other legal basis for processing; (c) you object at any time, due to reasons related to your particular situation, to the processing of Personal Data concerning you that is based on the legitimate interests pursued by us or a third party, and there are no superior legitimate grounds for processing; (d) you object to the processing of your Personal Data for direct marketing purposes; (e) the

Personal Data has been processed unlawfully; or (f) it is necessary to erase your Personal Data to comply with a legal obligation under European Union or Member State law applicable to the Company.

This right does not apply if the processing is necessary (a) to comply with a legal obligation requiring processing under European Union or Member State law applicable to the Company; or (b) for establishing, exercising, or defending legal claims.

Right to Restrict Processing

You are entitled to request that the Company limit the processing of your Personal Data if any of the following conditions are met: (a) you dispute the accuracy of your Personal Data, allowing the Company time to verify it; (b) the processing is unlawful, and you prefer restriction over erasure; (c) the Company no longer requires your Personal Data for processing, but you need it for legal claims; (d) processing is necessary for the Company's or a third party's legitimate interests, unless compelling legitimate grounds for processing override your interests, rights, and freedoms, or for legal claims; or (e) if your Personal Data is used for direct marketing, including profiling related to such marketing.

If processing of your Personal Data is restricted at your request, it will only be processed, apart from storage, with your consent, for legal claims, to protect another person's rights, or for significant public interest of the European Union or a Member State.

Right to Data Portability

You have the right to receive your Personal Data, which you have provided to the Company, in a structured, commonly used, and machine-readable format. You are also entitled to transfer that data to another organization if processing is based on your consent or a contract you are involved in, and the processing is automated.

When exercising your data portability rights, you can request that your Personal Data be transferred directly from the Company to another entity, provided it's technically feasible. This right does not interfere with your or the Company's rights concerning data deletion. Additionally, using this right must not infringe on the rights and freedoms of others.

Right to Withdraw Consent

You can withdraw your consent for us to process your Personal Data at any time, without affecting the legality of processing carried out prior to your withdrawal.

Right to Object

You are entitled to object to the processing of your Personal Data at any time, especially if it pertains to your particular circumstances and the processing is justified by the legitimate interests of the Company or a third party. This includes any profiling related to these interests. Upon objection, we will cease processing your Personal Data unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

You also have the right to oppose the processing of your Personal Data for direct marketing purposes at any time, including any related profiling.

Right to Lodge a Complaint with a Supervisory Authority

You have the right to file a complaint with a supervisory authority established by a Member State to protect the fundamental rights and freedoms of individuals concerning the processing of Personal Data within the European Union.

Your rights regarding your Personal Data as outlined in this section 13 may be restricted by European Union or Member State law to which the Company is subject.

We will provide you with the information requested in accordance with your rights outlined in this section 13 without undue delay and, in any case, within one month of receiving the request. This period may be extended by two additional months if necessary, considering the complexity and number of requests. We will inform you of any such extension within one month of receiving your request, along with the reasons for the delay.

The information requested according to your rights outlined in this section 13 shall be provided free of charge, unless otherwise stated in this section 13. Where requests are manifestlydeemed baseless or overly repetitive, we reserve the right to either (a) impose a fair charge to cover the administrative costs involved in processing the information or communication or executing the requested action; or (b) decline to fulfill the request.

Spectra Echelon may ask you to provide additional information needed to verify your identity, to proceed with your request as per the rights detailed in this section 13, especially if we have reasonable doubts regarding the identity of the individual making the request.

12. Modifications To This Policy

We may periodically update the terms of this Policy. When changes are made, we will notify you by posting the revised Policy on the Website. Moreover, for significant updates, we will make every effort to inform you through communication methods we consider reasonably suitable and by posting a notice on the Website. Unless specified otherwise, all changes will become effective once the updated Policy is published on our Website.