Privacy Policy Last updated: 24/02/2024

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

This Privacy Policy has been crafted to enlighten you on how We handle, collect, store, and utilize 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:

We emphasize ensuring you are consistently well-informed, enabling you to make educated decisions regarding the use of your Personal Data on our Website or when engaging with a third-party trading platform. To facilitate this, we implement a variety of strategies and methods designed to provide you with relevant insights into how your Personal Data is processed, ensuring this information is delivered precisely and promptly.

Moreover, if We determine you need specific information, We will deliver it to you at the appropriate time and place.

We are also eager to address any inquiries you may have and to provide you with any necessary clarifications, subject to legal restrictions. For this purpose, you can reach out to Us by sending an email to the following address: support@

•To process Personal Data about you solely for the purposes outlined in the Policy:

The purposes for which We may process Personal Data about you include, among others, to make the Website accessible to you andprovide you with a link to third-party trading platforms (the “Services”), to enrich the user experience on the Website, to enhance the Services (including the Website), to safeguard Our rights and interests, to carry out business and administrative functions that support the delivery of the Services to the Website users, and/or to comply with any legal and/or regulatory requirements.

Furthermore, We will process Personal Data about you to comprehend your individual needs and preferences.

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

We commit significant resources to enable you to exercise your rights as a data subject. Thus, you may contact Us whenever you wish to review Personal Data about you, request Us to amend it, erase it, stop using it for specific purposes or in general, or transfer it to you or to a third party. We will meet your requests in accordance with the law.

•To safeguard Personal Data about you:

While We cannot guarantee absolute security of the Personal Data about you, We assure you that We employ and will continue to employ a comprehensive range of methods and measures designed to ensure the Personal Data about you is protected.

Our Comprehensive Privacy Policy

1. The Scope?

This Policy outlines the type of Personal Data the Company collects about individuals, and how it collects, uses, shares with third parties, secures, and processes it, among other things.

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

In this Policy, the “processing” of Personal Data refers to any action or series of actions 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 cater to a general audience and are not aimed at individuals under the age of 18. We do not intentionally gather or request information from anyone under 18 years old, nor do we knowingly permit such individuals to use our Services. Should we become aware that a child's information has been collected, we will promptly take reasonable measures to remove such data.

2. When Do We Gather Personal Data About You?

We gather Personal Data about you whenever you engage with the Services, utilize the service channels, or browse the Website. In some cases, you may voluntarily provide us with Personal Data, while in others, we collect data by observing and analyzing your interactions with Our Services and/or Our service channels, or we may receive your data from our third-party partners.

3. No Requirement To Furnish Personal Data To The Company And Its Consequences

You are under no obligation to furnish us with any Personal Data. However, there may be situations where withholding such Personal Data will hinder us from delivering the Services, restrict your access to the Website, and/or cause disruptions in the functionality of the Services and the Website.

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

This information encompasses online activity logs, traffic details (including, but not limited to, IP address, access time, access date, web and mobile pages visited, language preferences, software crash reports, and the type of browser used, along with details regarding the device you used. Some of this information may not personally identify you and, therefore, does not qualify as Personal Data.

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

Personal Data You voluntarily submit for integration with third-party platforms for trading purposes: This encompasses your full name, phone number, and email address.

5. Objectives of Processing Personal Data and Their Legal Foundations

Spectra Echelon processes your Personal Data for one or more of the objectives described in this section, ensuring compliance with the appropriate legal basis.

Spectra Echelon will not handle your Personal Data unless a legal basis justifies such processing. The legal grounds for processing your Personal Data are as follows:

  • You have provided consent for the processing of your Personal Data for specific purposes. This applies when you share your details via the Website, allowing us to forward them to third-party trading platforms.
  • Processing is essential for the legitimate interests pursued by Spectra Echelon or a third party. For instance, this could be to enhance Our Services or to establish or defend legal claims.
  • Processing is necessary to fulfill a legal obligation to which Spectra Echelon is subject.

If you need further information on how the processing of your Personal Data serves the legitimate interests of our Company or a third party, please don't hesitate to contact us via email at any time.

Below, we offer a summary of the purposes for which we may process your Personal Data, along with the legal justifications for such actions:

Objective Legal Foundation
1

To provide your information to third parties upon your request to facilitate engagement in digital trading

We might gather your Personal Data to submit it to third parties, should you expressly request this.

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

To address your inquiries, requests, and/or concerns

Processing of your Personal Data is essential to respond to inquiries regarding your utilization of our Services.

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

To fulfill legal requirements or respond to judicial or administrative directives

At Spectra Echelon, we handle your Personal Data to meet our diverse legal responsibilities.

Processing is essential to adhere to a legal obligation applicable to the Company.
4

To enhance Our Services

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

Processing is crucial for the legitimate interests pursued by the Company or a third party.
5

To prevent fraud and misuse of Our Services

Processing is essential for the legitimate interests pursued by the Company or a third party.
6

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

Such tasks encompass back-office operations, business growth activities, strategic decision-making, oversight functions, and more.

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

To conduct analysis, including statistical evaluations

We utilize a range of analytical tools (including statistical ones) to guide our decision-making on numerous matters.

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

To safeguard Our and third parties' interests, rights, and assets, including initiating, exercising, or defending legal claims

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

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

6. Transfer Of Personal Data To Third Parties

At Spectra Echelon, we might share your Personal Data with third parties that assist us with services like storage and hosting, IP address information, user experience analysis, as well as research, technical, analytical, and diagnostic services.

Furthermore, if you specifically request, we can transmit certain Personal Data about you to third-party trading platforms. In such instances, we will provide the Personal Data you supply for this purpose to those third parties, who will handle your Personal Data in accordance with their own privacy policies. We may distribute your Personal Data to multiple third-party trading platforms.

Spectra Echelon may also disclose Personal Data about you to our affiliated entities and business partners, who offer us resources to enhance and elevate the quality of services and products we deliver to our users.

Your Personal Data may be shared with governmental, local, official, and regulatory bodies if such disclosure is necessary to safeguard our interests, rights, and assets, or those of third parties, including the initiation, exercise, or defense of legal claims.

Additionally, we may reveal Personal Data about you to potential buyers, investors, or lenders of Spectra Echelon and/or any entity within our corporate group, or in the context of any comparable transaction (including asset sales of Spectra Echelon and/or any entity within our corporate group), as well as in connection with any merger, reorganization, consolidation, or bankruptcy of Spectra Echelon and/or any entity within our corporate group.

7. Cookies and Third Party Services

Spectra Echelon may engage certain third-party services, like analytics companies or those delivering advertisements on our website, which might use cookies or other technologies, and their practices and providers are governed by their own policies.

A cookie, which is a small text file, may be installed on the device you use to visit or access the website. These cookies enable the collection of information about you and your behavior to

enhance your user experience, remember your preferences and settings, and tailor products and services that might catch your interest. Cookies also help in gathering statistics and conducting analytics.

Some cookies we utilize are session cookies, which are temporarily downloaded to your device and remain until you close your browser. Others are persistent cookies that stay on your device after you finish browsing the Website and assist in recognizing you as a returning visitor when you revisit the Website.

Categories of cookies:

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

Type of Cookie Purpose Additional Information
Strictly Necessary Cookies

These cookies are crucial for enabling navigation of the Website and utilizing features you have requested. They are employed to deliver the content, products, and services you have requested from Spectra Echelon.

Such cookies are indispensable for your device to download or stream information, allowing you to navigate the Website, use its features, and revisit pages you have previously accessed.

These cookies gather Personal Data about you, like username and last login date, and identify you as logged in to the Website.

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

Functionality Cookies These cookies are designed to identify you when you revisit the Website, enabling Us to recall your preferences and selections. These cookies remain active even after your web browser is closed, persisting until they reach their designated expiration date.
Performance Cookies These cookies are utilized to compile aggregated statistics concerning the Website's performance, aiding in testing and enhancement for a superior user experience. Furthermore, they enable Us to perform analytical functions on the Website.

These cookies gather anonymized data that cannot be linked to a specific individual.

The lifespan of these cookies varies; some are removed when you close your browser, while others have no set expiration date.

Blocking and removing cookies

You have the ability to modify your browser settings to block and remove certain or all cookies. Below are links to instructions on how to achieve this for some of the most widely used web browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

Please be aware that by doing so, certain features and functionalities of the Website may not operate as intended.

ONLINE TRACKING NOTICE

PLEASE NOTE, THIS SERVICE DOES NOT CURRENTLY SUPPORT DO-NOT-TRACK SIGNALS.

8. Retention Of Personal Data

Spectra Echelon will retain your Personal Data for the duration necessary to achieve the purposes outlined in this Policy, or longer if required by applicable laws, regulations, policies, and orders.

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

To ensure that Personal Data is not retained longer than necessary, we regularly review the data we hold to determine if any can be securely 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 country of residence) or to international organizations. In such cases, Spectra Echelon will implement suitable safeguards to protect your data and ensure that enforceable rights and effective legal remedies are available to data subjects.

If you reside in the EEA (European Economic Area), please be assured that these safeguards and protections will be in place if any of the following conditions are met:

  • The transfer involves a third country or an international organization that the EU Commission has determined offers an adequate level of protection for the Personal Data being transferred, as per 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 according to Article 46(2)(a) of the GDPR; or
  • The transfer adheres to standard data protection clauses established by the EU Commission pursuant to Article 46(2)(c) of the GDPR. These clauses can be accessed at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

You can request that the Company provide details regarding the safeguards it uses to protect your Personal Data transferred to a third country or an international organization by sending an email to the following address: support@

10. Safeguarding Your Personal Data

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

While we strive for error-free performance in protecting your Personal Data, we cannot guarantee it, and 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 may be required to transfer your Personal Data to third parties,entities like public authorities. In these situations, our influence over the security measures that such third parties apply to your Personal Data is limited.

It's important to note that transmitting Personal Data over the internet is not entirely secure. As a result, Spectra Echelon cannot guarantee the safety of your Personal Data during its internet transfer to us.

11. Links To Websites of Third Parties

Our Website might contain links to third-party websites and/or applications. Spectra Echelon does not oversee these sites or apps, nor the way they gather and handle your Personal Data. Consequently, we are not accountable for their privacy practices or data protection policies. This Policy does not govern any activities conducted via these external websites and/or applications.

When navigating to these third-party sites and/or apps, we strongly advise you to thoroughly review their privacy policies before engaging with them or sharing any of your Personal Data.

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

In general, you are entitled to ask Spectra Echelon for confirmation regarding the collection of your Personal Data, to review this data, amend it if necessary, and request its deletion when it is no longer needed by us. You can also limit your consent to specific types of processing of your Personal Information.

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

You have specific rights regarding your Personal Data. To invoke these rights, please send a request to the following email address:

Right of access

You are entitled to receive confirmation from Spectra Echelon about whether your Personal Data is being processed. If it is, you have the right to access this data and the following details:information: (1) the objectives of the processing; (2) the types of Personal Data involved; (3) the recipients or categories of recipients to whom the Personal Data has been or will be shared, especially those in countries outside the European Economic Area (EEA) or international organizations; (4) if feasible, the intended duration for which the Personal Data will be stored, or, if not feasible, the criteria used to determine that duration; (5) the right to request from Spectra Echelon correction or deletion of Personal Data or restriction of processing of Personal Data concerning you or to object to such processing; (6) the right to file a complaint with a supervisory authority; (7) if the Personal Data is not gathered from you, any available information regarding its source; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate measures relating to the transfer.

Spectra Echelon shall provide a copy of the Personal Data being processed and may impose a reasonable fee for any additional copies you request. If you make the request electronically, and unless otherwise requested by you, the information shall be provided in a commonly used electronic format.

The right to obtain a copy of the Personal Data shall not negatively impact the rights and freedoms of others. Therefore, if the request infringes on the rights and freedoms of others, Spectra Echelon may not fulfill your request or may do so in a limited way.

Right to rectification

You are entitled to obtain from Spectra Echelon the correction of inaccurate Personal Data about you. Considering the objectives of the processing, you have the right to have incomplete Personal Data about you completed, including by providing a supplementary statement.

Right to erasure

the following conditions apply: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw your consent on which the processing is based and there is no other legal basis for the processing; (c) you object at any time, on grounds related to your particular situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by Spectra Echelon or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) thePersonal Data has been improperly handled; or (f) it is necessary to erase the Personal Data concerning you to comply with a legal obligation in European Union or Member State law applicable to the Company.

This right is not applicable where processing is necessary (a) to fulfill a legal obligation that requires processing under 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 the processing of your Personal Data if any of the following circumstances apply: (a) you dispute the accuracy of the Personal Data, allowing the Company time to verify its accuracy; (b) the processing is unlawful, and you oppose the deletion of your Personal Data, opting instead for a restriction on its use; (c) the Company no longer requires your Personal Data for processing purposes, but you need it to establish, exercise, or defend legal claims; (d) if the processing is necessary for the legitimate interests pursued by the Company or a third party, unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims; or (e) if your Personal Data is processed for direct marketing purposes, including profiling, to the extent it is connected to such direct marketing.

If the processing of your Personal Data has been restricted following your request, such data shall only be processed, aside from storage, with your consent, or for the establishment, exercise, or defense of legal claims, or for protecting the rights of another natural or legal person, or for significant public interest reasons 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. Furthermore, you have the right to transfer this data to another entity if the processing is based on your consent or a contract you are involved in, and if the processing is automated.

When you exercise your right to data portability, you can request your Personal Data to be transferred directly from the Company to another organization, where it is technically feasible. This right does not interfere with your or the Company's rights regarding data deletion. Additionally, exercising this right must not negatively impact the rights and freedoms of others.

Right to Withdraw Consent

You have the option to revoke your consent at any time, which permits 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 are entitled to challenge the processing of your Personal Data at any time, particularly if it pertains to your unique circumstances, and when the processing is based on the legitimate interests of the Company or a third party. This includes any profiling related to these interests. If you object, we will cease processing your Personal Data unless we can provide 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 associated profiling.

Right to lodge a complaint with a supervisory authority

You are entitled to file a complaint with a supervisory authority established by a Member State to safeguard the fundamental rights and freedoms of individuals regarding the processing of Personal Data within the European Union.

Your rights concerning Personal Data about you, 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 according to 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 the 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 will be provided free of charge, unless stated otherwise in this section 13. Where requests are manifestlyif they are unfounded or overly repetitive, we may choose to either (a) impose a reasonable fee to cover the administrative expenses involved in fulfilling the request or (b) decline to process the request.

Spectra Echelon may request that you provide additional information necessary to verify your identity before fulfilling your request, as described in this section 13, if we have legitimate doubts about the identity of the individual making the request.

12. Updates To This Policy

From time to time, we may revise the terms of this Policy. Whenever changes are made, we will notify you by updating the Policy on the Website. Additionally, for significant amendments, we will make efforts to inform you through communication channels we deem appropriate and by posting a notice on the Website. Unless specified otherwise, all changes will become effective upon the updated Policy being published on our Website.