Privacy Policy

Introduction

Spectra ("we," "us," "our," or "Platform") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you use our mobile application and related services (the "Service").

By using the Service, you consent to the data practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Service.

1. Information We Collect

We collect various types of information to provide and improve our Service:

1.1 Personal Identification Information

• Name (first and last name)
• Email address
• Phone number
• Physical address
• Date of birth
• Nationality

1.2 Verification and KYC Documents

When required for account verification, we may collect:

• Government-issued ID (passport, driver's license, national ID card)
• Proof of address (utility bills, bank statements)
• Selfie photographs for identity verification
• Tax identification numbers (where required)

1.3 Broker Account Information

• Broker account identifiers and account numbers
• API credentials and access tokens (encrypted)
• Broker connection status and authentication data
• Account verification details

1.4 Trading and Financial Data

• Trade history (executed trades, positions, orders)
• Account balances and portfolio values
• Profit and loss (P&L) information
• Trading performance statistics
• Copy trading settings and preferences
• Subscription payment information

1.5 Technical and Usage Data

• IP address and approximate geolocation
• Device information (device ID, model, operating system, version)
• Browser type and version
• App usage data (features used, screens viewed, time spent)
• Log files (timestamps, errors, crashes)
• Cookies and similar tracking technologies

1.6 Communications Data

• Support communications (messages, emails, chat logs)
• User feedback and survey responses
• Marketing preferences and consent records

1.7 Analytics and Marketing Data

• User behavior analytics
• Marketing campaign interactions
• Referral source information
• Engagement metrics

2. How We Collect Information

We collect information through:

2.1 Direct Collection

• Information you provide during registration and account setup
• Information you submit through forms or settings
• Communications you send to our support team

2.2 Automatic Collection

• Cookies, pixels, and similar tracking technologies
• Log files and analytics tools
• Device and network information

2.3 Third-Party Sources

• Brokers Trading data, account information (via API)
• Payment processors Subscription payment status
• Identity verification services KYC/AML verification results
• Analytics providers Usage and behavior data
• Public sources Publicly available information

3. How We Use Your Information

3.1 Primary Purposes

We use your information to:

3.2 Legal Bases for Processing (GDPR)

For users in the European Union, we process your personal data based on:

• Contract Performance Processing necessary to provide the Service
• Legal Obligation Compliance with KYC/AML, tax, and regulatory requirements
• Legitimate Interests Fraud prevention, security, service improvement, analytics
• Consent Marketing communications, non-essential cookies (you can withdraw consent)

4. How We Share Your Information

4.1 We DO NOT Sell Your Personal Information

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

4.2 Service Providers and Partners

We share information with trusted third parties who assist in operating our Service:

4.3 Legal and Regulatory Disclosures

We may disclose your information when required by law or in response to:

• Court orders, subpoenas, or legal processes
• Regulatory inquiries or investigations
• Law enforcement requests
• Protection of our rights, safety, or property
• Prevention of fraud or illegal activities

4.4 Business Transfers

If Spectra is involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred to the successor entity. You will be notified of any such change.

4.5 Aggregated and Anonymized Data

We may share aggregated, anonymized data that cannot identify you individually:

• Industry statistics and trends
• Platform usage metrics
• Performance benchmarks

5. Data Retention

5.1 Retention Periods

We retain your personal information for as long as:

• Your account is active, OR
• Necessary to provide the Service, OR
• Required by law or regulatory obligations

5.2 Specific Retention Periods

• Account data Retained while your account is active
• Trading data Retained for 7 years (regulatory requirement)
• Financial records Retained for 7 years (tax and audit requirements)
• Communications Retained for 7 years (regulatory requirement)
• Technical logs Typically retained for 1-2 years

5.3 After Account Closure

After you close your account:

• Some data may be retained for legal, regulatory, or legitimate business purposes
• Data may be anonymized and retained for analytics
• You can request deletion subject to legal retention requirements

6. Data Security

6.1 Security Measures

We implement industry-standard security measures:

6.2 No Absolute Security

IMPORTANT: While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security, and you use the Service at your own risk.

6.3 Your Responsibility

You are responsible for:

• Maintaining the confidentiality of your login credentials
• Using strong, unique passwords
• Enabling two-factor authentication if available
• Notifying us immediately of any security breaches

7. Your Rights and Choices

7.1 Access and Correction

You have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Update your account information through the app settings

7.2 Data Portability

You can request a copy of your data in a portable format (subject to technical limitations).

7.3 Deletion / Right to be Forgotten

You can request deletion of your personal information, subject to:

• Legal retention requirements
• Legitimate business needs (e.g., fraud prevention)
• Contractual obligations

7.4 Restrict Processing

You can request that we limit how we use your information in certain circumstances.

7.5 Object to Processing

You can object to certain types of processing, such as:

• Marketing communications (opt-out anytime)
• Processing based on legitimate interests

7.6 Withdraw Consent

Where processing is based on consent, you can withdraw consent at any time (this does not affect prior processing).

7.7 Marketing Opt-Out

You can opt-out of marketing communications by:

• Clicking "unsubscribe" in emails
• Adjusting preferences in app settings
• Contacting our support team

7.8 Cookie Management

You can control cookies through:

• Browser settings
• Third-party opt-out tools
• Our cookie consent manager (if available)

Note: Disabling certain cookies may affect Service functionality.

8. GDPR Rights (EU Residents)

If you are located in the European Union, you have additional rights under the General Data Protection Regulation (GDPR):

8.1 Data Controller

Spectra is the data controller responsible for your personal data.

8.2 Lawful Bases

We process your data based on:

• Necessity for contract performance
• Legal obligations (KYC/AML)
• Legitimate interests (fraud prevention, analytics)
• Your consent (marketing, optional features)

8.3 Your GDPR Rights

• Right to access your data
• Right to rectification (correction)
• Right to erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority

8.4 Data Protection Officer

For GDPR-related inquiries, contact our Data Protection Officer:
Email: privacy@spectra.com or dpo@spectra.com

8.5 International Transfers

Your data may be transferred outside the EU. We ensure adequate safeguards through:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by the European Commission
• Other approved transfer mechanisms

9. CCPA Rights (California Residents)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA):

9.1 Information About Data Collection

See Section 1 for categories of personal information collected.

9.2 Your CCPA Rights

• Right to Know What personal information we collect, use, disclose
• Right to Delete Request deletion of your personal information
• Right to Opt-Out We do NOT sell personal information
• Right to Non-Discrimination We will not discriminate for exercising your rights

9.3 How to Exercise Rights

Contact us at: privacy@spectra.com or support@spectra.com
We will verify your identity before processing requests.

9.4 Authorized Agents

You may designate an authorized agent to make requests on your behalf (written authorization required).

9.5 California Shine the Light

We do not share personal information with third parties for their direct marketing purposes without your consent.

10. International Data Transfers

10.1 Global Operations

Spectra operates globally. Your information may be transferred to, stored, and processed in:

• United Arab Emirates (our primary location)
• United States (cloud hosting, service providers)
• Other countries where our service providers operate

10.2 Safeguards

When transferring data internationally, we use:

• Standard Contractual Clauses (EU approved)
• Data Processing Agreements with service providers
• Encryption and security measures
• Compliance with applicable data protection laws

10.3 Your Consent

By using the Service, you consent to the international transfer of your information as described in this Privacy Policy.

11. Children's Privacy

11.1 Age Restriction

The Service is NOT intended for individuals under 18 years of age. We do not knowingly collect information from minors.

11.2 Parental Notice

If you believe we have collected information from a minor, please contact us immediately, and we will delete such information.

12. Cookies and Tracking Technologies

12.1 What Are Cookies

Cookies are small text files stored on your device that help us provide and improve the Service.

12.2 Types of Cookies We Use

12.3 Third-Party Cookies

Our Service may include cookies from:

• Google Analytics
• Payment processors
• Social media platforms
• Advertising networks (with consent)

12.4 Managing Cookies

You can control cookies through browser settings, but disabling essential cookies may affect functionality.

13. Third-Party Links

The Service may contain links to third-party websites or services. We are NOT responsible for their privacy practices. Please review their privacy policies before providing any information.

14. Data Breach Notification

14.1 Our Commitment

We take data security seriously and will:

• Investigate any suspected breaches
• Take immediate remedial action
• Notify affected users as required by law
• Notify relevant authorities within required timeframes

14.2 Your Action

If you suspect a security breach affecting your account, contact us immediately.

15. Changes to This Privacy Policy

15.1 Right to Modify

We may update this Privacy Policy from time to time. Changes will be effective when posted.

15.2 Notification of Changes

We will notify you of material changes by:

• Posting the updated policy on the Platform
• Sending email notification
• In-app notification
• Updating the "Last Updated" date

15.3 Your Acceptance

Your continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy.

16. Contact Us

16.1 Privacy Inquiries

For questions, requests, or concerns about this Privacy Policy or how we handle your data:

Email: privacy@spectra.com or support@spectra.com

Support: Available through the Platform

Address: Spectra, Dubai, United Arab Emirates

16.2 Data Protection Officer

For GDPR-related inquiries:

Email: dpo@spectra.com or privacy@spectra.com

16.3 Supervisory Authority

EU residents have the right to lodge a complaint with your local data protection authority.

17. Consent

By using the Service, you acknowledge that you have read, understood, and agree to this Privacy Policy.

For certain activities (e.g., marketing), we will obtain your explicit consent before processing your data.