Privacy Policy & Cookies

1. Summary

This Privacy Policy describes the manners in which we, Spectrum, collect, use and protect personal data received from Third Parties.

Third Parties include applicants, clients, subcontractors, vendors, investors and visitors to Spectrum’s website (such parties referred to herein individually as a “Third Party” or collectively as “Third Parties”).

By providing personal information to Spectrum, Third Parties consent to the collection and use of information as set forth herein.

2. Personal Data Collected

“Personal Data” and “Personal Information” are used interchangeably herein and refer to information that can be used to identify a Third Party.

Spectrum collects personal data entered by Third Parties on Spectrum’s website or through cookies used by Spectrum as specified below, or given in any other way such as writings or phone calls during any transactional or administrative communications.

Subject to applicable law, Personal Data and/or Personal Information collected may include, but is not limited to, the following:

  • Personal Information such as date of birth, gender, marital status, and identification numbers including driver’s license, tax identification, passport numbers and CV;
  • contact information, such as name, company name, address, phone number, fax number, and e-mail address;
  • financial and billing information, such as billing name and address, payment information (which might include credit card and/or bank account information);
  • additional information such as title, department name, fax number, and additional company information, such as shareholders names, annual revenues, number of employees, or industry.

3. Intended Use of Personal Data

A. Purpose
Spectrum uses Personal Information collected from Third Parties for the purposes of Company operations and activities management, training programs, and recruiting job Applicants.

B. Onward Transfer
When the processing of Personal Data is outsourced to a third party processor, data processing will be subject to a written agreement between Spectrum and the relevant third party processor. This written agreement will require that the third party processor (i) has at least the level of security measures in place as required by or to comply with applicable laws to which the third party processor will be bound and (ii) will process Personal Data in strict compliance with Spectrum’s specific written instructions only for the purpose(s) mentioned in the said agreement.

In certain circumstances, Spectrum may be requested or required to disclose Personal Data in response to valid legal process or under applicable law. Such circumstances may include a search warrant, court order, or other request from a government or regulatory authority or agency. Spectrum also reserves the right to disclose such information in response to any such legitimate government or regulatory request or requirement.

In the event that Spectrum or any portion of its assets are acquired, sold or transferred, Spectrum may disclose Personal Information with the company involved to perform the operation and complete the transition, on a limited basis in compliance with applicable law.

C. Personal Data Security
Spectrum maintains commercially reasonable safeguards to store Personal Data collected from Third Parties in a secure-access environment and in a manner that complies in all material respects with applicable laws and industry standards to guard Personal Data against loss, destruction, misuse, improper disclosure, and unauthorized access or modification. These safeguards are routinely tested internally and periodically audited by outside firms.

In addition, Spectrum makes reasonable efforts to ensure that the Personal Data it collects and maintains is reliable for its intended use, and is accurate, complete, and current for the purposes for which it was collected.

D. Personal Data Access, Correction and Objection
Any Third Party has a right to request access to its Personal Data and to correct any inaccuracies or to request deletion if no longer needed.
Upon written request Spectrum will allow a Third Party to review the Third Party’s Personal Data that Spectrum stores and maintains about that Third Party in his or her personnel file, including information relevant to the use and disclosure of that person’s Personal Data. However in certain limited circumstances Spectrum may not be able to provide a Third Party with access to all of his or her Personal Data where such refusal is permitted or required by applicable law or regulation.

Should any Personal Data concerning a Third Party be found to be no longer needed, inaccurate or incomplete or if a Third Party has withdrawn consent, Spectrum will take reasonable steps to erase or correct or update the information it maintains unless applicable laws or regulations exempt Spectrum from doing so.

E. Website
An individual can access Spectrum’s website without providing any personally identifiable information. However, should you choose, you may provide us with certain Personal Information Spectrum may use this information:

  • to correspond with you;
  • to allow you to participate in features or services we offer on this website;
  • to provide you with a subscription or newsletter; or,
  • to transmit your CV within Spectrum for possible employment opportunities.

If you subscribe to any service provided by Spectrum through Spectrum’s website or otherwise, and you wish to terminate that subscription and have all Personally Identifiable information about you removed from any list we maintain, please contact Spectrum informing us of your request. We will promptly make reasonable efforts to remove all Personal Information about you from our data banks. In addition, e-mail communications from Spectrum inform the recipient how to stop receiving further communication.

Spectrum does not automatically log Personal Data about visitors to our website. Spectrum does not use cookies to store Personal Data, nor does Spectrum link non-personal information stored in cookies with Personal Data about specific individuals. We may collect certain non-personally identifiable information from a visitor to our website such as what browser was used, what pages were accessed, and the Internet address of the service provider in order to compile statistics and analyze this data for trends.

4. Enforcement, Recourse and Liability
Spectrum will monitor its compliance with this Policy and address questions and concerns regarding its adherence.

Spectrum agrees to comply in all material respects with all applicable privacy laws, rules and regulations.

Spectrum is committed to resolve complaints about collection and/or use of Personal Information. Any inquiry or complaint regarding this Third Party Privacy Policy should first be referred to Spectrum.

Spectrum will strive to acknowledge any complaint or enquiry and take appropriate action to remedy any raised issue. However, if Spectrum is unable to satisfactorily resolve the issue, a complaint can be submitted free of charge to the EU data protection authorities (DPAs). To contact the DPAs directly please visit:

5. Changes to this Third Party Privacy Policy
Spectrum reserves the right to make changes to this Third Party Privacy Policy from time to time in order to reflect changes in legal or regulatory obligations, or changes in the manner in which the company manages personal data. This Third Party Privacy Policy was last updated in May 2018.

Cookies Policy
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit

These cookies are used to collect information about how visitors use our site, which we use to help improve it. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

User data is all anonymous. You can find out more about Google’s position on privacy as regards its analytics service at
To opt out of being tracked by Google Analytics visit