Privacy Policy Last updated: 24/02/2024

We at Spectra Echelon are fully dedicated to safeguarding your Personal Data and ensuring your privacy.

This Privacy Policy has been crafted to inform you about how Spectra Echelon manages, collects, stores, and uses the information you provide in connection with the website (the “Website”).

We will adhere to the following principles:

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

At Spectra Echelon, we prioritize keeping you well-informed, enabling you to make knowledgeable decisions regarding the use of your Personal Data on our Website or when engaging with a third-party trading platform. To ensure this, we utilize a variety of strategies and methods to provide you with relevant information on how your Personal Data is processed, ensuring this information is communicated clearly and promptly.

Furthermore, if it's necessary to provide you with specific information, we will ensure you receive it at the appropriate time and place.

We are also available to address any questions you may have and to provide any clarification you require, within legal constraints. For this purpose, you can reach out to us by sending an email to the following address: support@

•To process your Personal Data solely for the purposes outlined in this Policy:

The purposes for which Spectra Echelon may process your Personal Data include, among other things, to make the Website available to you andprovide you with integration to third-party trading platforms (the “Services”), aiming to elevate the user experience on the Website, enhance the Services (including the Website), safeguard Our rights and interests, execute business and administrative activities supporting the delivery of the Services to the Website users, and/or to meet any legal and/or regulatory obligations.

Moreover, We will handle Personal Data about you to better comprehend your individual needs and preferences.

• To allocate substantial resources to uphold your rights concerning Personal Data about you:

We dedicate significant resources to empower you to exercise your rights as a data subject. Hence, you may reach out to Us at any time to review Personal Data about you, request amendments, deletion, cessation of use for specific purposes or altogether, or to have it transferred to you or a third party. We will comply with your requests in accordance with the law.

•To protect Personal Data about you:

While We cannot guarantee absolute protection of the Personal Data about you, We assure that We employ and will continue to employ a comprehensive range of methods and measures aimed at securing the Personal Data about you.

Our Comprehensive Privacy Policy

1. The Scope?

This Policy outlines the type of Personal Data the Company collects about natural persons, how it collects, uses, shares with third parties, secures, processes, etc.

In this Policy, “Personal Data” refers to any information related to an identified or identifiable natural person. An identifiable natural person is one who can be recognized, 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 the 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 intended for individuals under 18 years of age. We do not intentionally gather or request information from those under 18, nor do we knowingly permit such individuals to access our Services. If we discover that we have inadvertently collected data from a child, we will promptly take reasonable measures to erase such information.

2. When Do We Collect Personal Data About You?

We gather Personal Data about you whenever you engage with the Services, utilize our service channels, or visit the Website. At times, you may actively provide us with Personal Data, while in other situations, we will collect this information by analyzing your interactions with our Services and service channels, or by obtaining 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 furnish us with any Personal Data about yourself. However, there are scenarios where withholding such information may hinder our ability to deliver the Services to you, restrict your use of the Website, and/or result in the improper functioning of the Services and the Website.

4. What types of Personal Data do We collect? Personal Data We collect upon each browsing onto the Website:

This encompasses details like online activity logs, traffic information (including, but not limited to, IP address, access times and dates, pages visited on web and mobile, language preferences, software crash reports, and browser type), and device information. Some of this data may not personally identify you, and thus may not qualify as Personal Data.

Personal Data We receive from you: Any Personal Data you voluntarily provide to us when interacting with a third-party trading platform through Spectra Echelon.

Personal Data You Provide for Third-Party Trading Platform Submissions: This encompasses your full name, contact number, and email address.

5. Objectives and Legal Basis for Processing Personal Data

At Spectra Echelon, we process your Personal Data for one or more of the objectives detailed in this section, adhering to the relevant legal grounds.

We ensure that Personal Data about you is processed only when there is a lawful basis for such actions. The legal bases that allow Spectra Echelon to process your Personal Data include:

  • Your explicit consent to process your Personal Data for one or more particular purposes. This applies when you provide your information through our platform to be forwarded to a third-party trading platform.
  • Processing is crucial for pursuing the legitimate interests of Spectra Echelon or a third party. For instance, enhancing our services or defending against legal claims.
  • Processing is essential to comply with a legal obligation that Spectra Echelon is bound by.

If you seek further clarification on how the processing of your Personal Data supports the legitimate interests of Spectra Echelon or another entity, please don't hesitate to contact us via email at any time.

Below is an overview of why we may process your Personal Data and the legal justifications for such processing:

Purpose Legal Basis
1

To share your details with third parties upon your request for engaging in digital and trading activities.

We may gather Personal Data about you to forward it to third parties, if that is your explicit request.

You have consented to the processing of your Personal Data for one or more specific purposes.
2

To address your inquiries, requests, and/or complaints

Handling of your Personal Data is essential to respond to your inquiries regarding your use of the Services.

Processing is necessary for the legitimate interests pursued by Spectra Echelon or by a third party.
3

To adhere to any legal mandates or judicial and administrative directives

We handle your Personal Data to fulfill our various legal responsibilities.

Processing is required to meet a legal obligation applicable to the Company.
4

To enhance Our Services

We might utilize your Personal Data to refine Our Services. This processing will encompass, among other things, any crash logs or malfunction reports related to Services.

Processing is essential for pursuing the legitimate interests of the Company or a third party.
5

To prevent fraud and misuse of Our Services

Processing is essential for pursuing the legitimate interests of the Company or a third party.
6

To conduct and sustain various activities supporting the delivery of Our Services

These activities encompass back-office operations, business development efforts, strategic decision-making, and oversight mechanisms, among others.

Processing is essential for the pursuit of legitimate interests by the Company or a third party.
7

For conducting comprehensive analysis, including statistical evaluations

We employ various analytical tools (including statistical methods) to inform our decision-making processes on multiple issues.

Processing is essential for the pursuit of legitimate interests by the Company or 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 defend 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 for the pursuit of legitimate interests by the Company or a third party.

6. Transfer Of Personal Data To Third Parties

At Spectra Echelon, we might also disclose your Personal Data to third parties that assist us in delivering our services. This includes storage and hosting providers, as well as those who analyze user experiences and conduct research, technical, analytical, and diagnostic services.

Moreover, should you request, we will transmit specific Personal Data about you to external trading platforms. In such scenarios, the Personal Data you provide to us will be shared with these third parties, and their usage of your Personal Data will adhere to their respective privacy policies. We might share your Personal Data with multiple third-party trading platforms.

Spectra Echelon might also share your Personal Data with affiliated entities and business partners that supply us with resources to enhance and elevate the services and products we offer to our users.

We may 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 in the initiation, exercise, or defense of legal proceedings.

Furthermore, we may reveal your Personal Data to potential buyers, investors, or creditors of Spectra Echelon or any company within our corporate group, or during any similar transactions (including asset sales of Spectra Echelon or any related company), as well as in the context of mergers, reorganizations, consolidations, or bankruptcy of Spectra Echelon or any affiliated company.

7. Cookies and Third Party Services

Spectra Echelon may utilize third-party services, such as analytics providers or advertising companies on our Website. These services might use cookies or other technologies, and their practices are governed by their own policies.

A cookie (a small text file) is installed on the device you use to visit or access our Website. These cookies enable us to gather information about you and your behaviors toenhance your user journey, to remember your preferences and settings, and to tailor and offer you products and services that might capture your interest. Cookies may also be utilized for gathering statistics and conducting analytics.

Some cookies we may employ are session cookies, which are temporarily downloaded to your device and remain until you close your web browser. Others are persistent cookies, which stay on your device even after you stop browsing the Website and can be used to help the Website recognize you as a returning visitor when you revisit.

Types of cookies:

The cookies we may use are categorized based on their functionality, as follows:

Type of Cookie Purpose Additional Information
Strictly Necessary Cookies

These cookies are essential to allow you to navigate the Website and utilize the features you have requested. They are employed to deliver our content, products, and services that you have requested.

Such cookies are crucial to help your device download or stream information, enabling you to move around the Website, utilize its features, and revisit pages you have previously explored.

These cookies gather Personal Data about you, such as your user name and last login date, and identify you as logged in to the Website.

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

Functionality Cookies These cookies help us recognize you when you revisit the Spectra Echelon platform and enable us to remember your selections and preferences. These cookies persist even after you close your web browser, lasting until their designated expiry time.
Performance Cookies These cookies are utilized to provide cumulative statistics concerning the platform's performance and to test and enhance it, thereby ensuring a superior user experience. Additionally, they allow us to conduct analytical tasks on Spectra Echelon.

These cookies gather anonymized data that does not relate to any identified or identifiable individual.

The validity of these cookies varies; some are erased once you close your browser, while others have an indefinite duration.

Blocking and removing cookies

You have the ability to adjust your browser settings to block and delete some or all cookies. Please refer to the following links for instructions on how to do this for some of the most widely-used web browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

Be aware, however, that if you proceed, certain features and functionalities of the Website may not operate as designed.

ONLINE TRACKING NOTICE

PLEASE NOTE THAT THIS SERVICE CURRENTLY DOES NOT ACCOMMODATE DO-NOT-TRACK SIGNALS.

8. Retention Of Personal Data About You

[Spectra Echelon] will keep your Personal Data for as long as necessary to achieve the processing purposes outlined in this Policy, or longer if required by applicable laws, regulations, policies, and directives.

Your information will be shared with third-party trading platforms for a period of 12 months, and with your consent, this period may be extended by an additional 12 months.

To prevent retaining your Personal Data longer than necessary, we conduct periodic reviews of the data we hold to determine if any can be deleted.

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

Your Personal Data may be transferred to a third country (i.e., outside your residence jurisdiction) or international organizations. In such cases, [Spectra Echelon] will implement appropriate safeguards to ensure the protection of your Personal Data and ensure enforceable rights and effective legal remedies are available to you.

For EEA (European Economic Area) residents, these safeguards and protections are ensured if any of the following conditions are met:

  • The transfer is to a third country or an international organization that the EU Commission has determined offers an adequate level of protection for the Personal Data transferred to it 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 is executed based on a legally binding and enforceable agreement between public authorities or bodies in line with Article 46(2)(a) of the GDPR; or
  • The transfer complies with standard data protection clauses approved by the EU Commission pursuant to Article 46(2)(c) of the GDPR. You can view these clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

You may request that Spectra Echelon provide you with details regarding the safeguards it employs to protect your Personal Data when transferred to a third country or an international organization by sending an email to the following address: support@

10. Protection Of Personal Data About You

We implement effective technical and organizational measures to ensure an appropriate level of security for Personal Data, considering the risks associated with processing, particularly from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data that is transmitted, stored, or otherwise processed.

We cannot guarantee, nor do we promise, that your Personal Data will be free from errors regarding privacy, and we will not be 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.

We may be obligated, due to legal or other obligations beyond our control, to transfer your Personal Data to third parties,

such as public authorities. In these situations, we have limited influence over how third parties protect your Personal Data.

Any transfer of Personal Data over the internet cannot be completely safeguarded. Thus, Spectra Echelon cannot guarantee the security of your Personal Data during internet transfers to us.

11. Links To Third-Party Websites

The website might offer links to third-party websites and/or applications. Spectra Echelon does not govern these sites or apps, nor the collection and/or processing of your Personal Data by them, and we are not liable for these sites and apps or their privacy and data protection policies and activities. This policy does not cover actions taken via such websites and/or applications.

Whenever you visit these third-party websites and/or applications, we suggest you thoroughly review their privacy policies before using them and before disclosing any of your Personal Data.

13. Your Rights Regarding Your Personal Data

Generally, you have the right to request that we confirm whether your Personal Data is being collected by us, to review such data, to correct the content if necessary, and to erase any Personal Data no longer needed by us. 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 have the following rights concerning your Personal Data. To exercise these rights, you may send a request to the following email address:

Right of Access

You are entitled to receive confirmation from Spectra Echelon as to whether your Personal Data is being processed and, if so, access to that Personal Data and the following details.information: (1) the objectives behind processing; (2) the types of Personal Data involved; (3) the individuals or groups to whom the Personal Data has been or will be shared, especially those outside the European Economic Area (EEA) or with international bodies; (4) if feasible, the anticipated duration for storing Personal Data, or, if not feasible, the criteria used to decide that duration; (5) the option to request from Spectra Echelon the correction or deletion of your Personal Data or limitation of its processing, or to oppose such processing; (6) the right to file a complaint with a regulatory authority; (7) if Personal Data isn't collected from you, any accessible information regarding its source; (8) the presence of profiling; and (9) if Personal Data is moved to a third country outside the EEA or to an international organization, the relevant safeguards regarding the transfer.

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

The right to access a copy of the Personal Data must not infringe on the rights and freedoms of others. Consequently, if fulfilling the request impacts the rights and freedoms of others, Spectra Echelon may not comply with your request or may do so in a restricted manner.

Right to rectification

You are entitled to request Spectra Echelon to correct any inaccurate Personal Data concerning you. Considering the objectives of processing, you are also entitled to have incomplete Personal Data completed, potentially through a supplementary statement.

Right to erasure

under the following circumstances: (a) the Personal Data is no longer required for the purpose it was gathered or otherwise processed; (b) you withdraw the consent on which processing is based, and no other legal basis for processing exists; (c) you object at any time, for reasons related to your specific situation, to the processing of your Personal Data based on the legitimate interests pursued by us or a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of your Personal Data for direct marketing purposes; (e) thePersonal Data has been processed unlawfully; or (f) compliance with a legal obligation requires the erasure of the Personal Data concerning you under European Union or Member State law to which the Company is subject.

This right does not apply when the processing is necessary (a) to comply with a legal obligation requiring processing by European Union or Member State law applicable to the Company; or (b) for the establishment, exercise, or defense of legal claims.

Right to Restrict Processing

You are entitled to request from the Company a restriction on processing your Personal Data if one of the following conditions is met: (a) you dispute the accuracy of your Personal Data, allowing the Company time to verify it; (b) the processing is unlawful, and you oppose the erasure of your Personal Data, opting instead to limit its use; (c) the Company no longer requires your Personal Data for processing purposes, but you need it for establishing, exercising, or defending legal claims; (d) if the processing is necessary for the Company's or a third party's legitimate interests, unless compelling legitimate grounds for processing that override your interests, rights, and freedoms are demonstrated, or for the establishment, exercise, or defense of legal claims; or (e) if your Personal Data is processed for direct marketing purposes, including profiling related to such marketing.

If processing of your Personal Data has been restricted at your request, it will, except for storage, only be processed with your consent, for legal claim establishment, exercise, or defense, to protect another natural or legal person's rights, or for important public interest reasons of the European Union or a Member State.

Right to Data Portability

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

When exercising your data portability right, you can request that your Personal Data be transferred directly from the Company to another entity, where technically feasible. This right does not impact your or the Company's rights concerning data deletion. Furthermore, exercising this right should not negatively affect the rights and freedoms of others.

Right to Withdraw Consent

You have the option to revoke your consent at any time, allowing us to process your Personal Data. This action will not affect the legality of any processing carried out before your withdrawal.

Right to Object

You hold the right to contest the processing of your Personal Data at any time, particularly if it pertains to your specific circumstances and when the processing is justified by the legitimate interests of the Company or a third party. This includes any profiling based on these interests. If you object, we will cease processing your Personal Data unless we can demonstrate compelling legitimate grounds for the processing that override 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 in relation to the processing of Personal Data within the European Union.

Your rights concerning Personal Data about you, as described in this section 13, may be limited by European Union or Member State law to which the Company is subject.

We will provide you with the requested information in accordance with your rights outlined in this section 13 without undue delay and, in any event, within one month of receiving the request. That period may be extended by two additional months if necessary, taking into account 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 in accordance with your rights outlined in this section 13 shall be provided free of charge, unless otherwise stated in this section 13. Where requests are manifestlyunfounded or excessive, particularly due to their repetitive nature, we may either (a) impose a reasonable fee considering the administrative costs involved in providing the requested information or communication, or (b) decline to fulfill the request.

Spectra Echelon may ask you to provide further details to verify your identity to process your request in accordance with your rights described in this section 13, if we have reasonable doubts about the identity of the individual making the request.

12. Changes To This Policy

We may occasionally update the terms of this Policy. When we do so, we will notify you of the changes by posting the revised Policy on the Website. Additionally, if we make significant updates to this Policy, we will make efforts to notify you of these changes through communication methods we consider appropriate, and by placing a notice about these changes on the Website. Unless stated otherwise, all amendments will become effective upon the publication of the updated Policy on our Website.