Privacy Policy

This Privacy Policy explains what data we collect when you use the Spectrum Finance website https://spectrum.fi, and all of our other properties, products, and services (referred to as the “Services“). It also explains why we process this data and how we secure it. In this document, “we“, “us“, and “our“ refer to Spectrum Labs Inc. (the “Company“) and “you“ refers to you, the user.

By using or browsing Services provided by the Company you acknowledge that you have read, understood and agreed to this policy.

Your use of the Services is subject to this Policy as well as our Terms of Service.

1. High-level summary

• Spectrum Labs Inc. is an incorporated company based in Panama that operates the https://app.spectrum.fi web application among other products and services. Spectrum Labs Inc. complies with Panamanian laws and regulations.

• Ergo Spectrum Finance Protocol is a set of smart contracts deployed in the Ergo blockchain. It is not governed by Spectrum Labs.

• Cardano Spectrum Finance Protocol is a set of smart contracts deployed in the Cardano blockchain. It is not governed by Spectrum Labs.

• Spectrum Labs collects non-identifiable data, such as public on-chain data, and limited off-chain data like device type and browser version. This data is used to improve the Services and guide our product development, **not to track users**.

• Spectrum Labs endeavors to refine its practices by exploring methods to further protect consumer privacy such as opt-out prompts, migrating to privacy-centric tooling, and deploying proxies to anonymize network traffic.

• Spectrum Labs may request your personal data to grant you access to specific services. Spectrum Labs uses third-party services to collect and process personal data and does not store personal data on its servers.

• Users are empowered to explore client-side privacy techniques and tools.

• Any material changes to privacy will be reflected in an updated privacy policy.

2. Principles

Privacy is one of the core principles of the Company. We believe in transparency and try to be open about the limited data we collect. We do not have user accounts and do not store personal data like your name, date of birth, email address, or IP address.

The Services are a privacy-focused, non-custodial trading platform built on the decentralized Cardano and Ergo blockchain technologies. We pledge not to collect, generate, or process any unnecessary personal or identifiable user data unless it is strictly necessary for providing these Services.

3. Data we collect

3.1. Account Data

The Services do not require a separate registration process. You can log in using any Ergo or Cardano wallet. If you use a third-party service to log in, you may be subject to the third party's terms of use. The Company does not store any data that links login methods to your IP address, browser, hardware, or other identifying information, or to each other.

3.2. Information from localStorage and other tracking technologies

We and our third-party service providers may collect certain information through the use of localStorage, mobile deviceID, cookies, web beacons, and other similar technologies in order to provide and personalize the Services for you across multiple sessions. This information may be used to remember tokens you import or settings of your application, as well as to understand your preferences, your usage of the Services, and our interactions with you. The data we collect from these technologies may include details such as your browser type, referring/exit pages, operating system, device or browser language, and other device information. By analyzing and grouping this data collectively, we aim to improve the overall user experience of our product.

3.3. Survey or usability information

If you participate in a survey or usability study with us, we will record any personal information you provide (such as your name, email, and job title), the responses you give, and your interactions with the Services.

3.4. Information from other sources

We may receive information about your wallet address or transactions made through the Services from our service providers in order to comply with our legal obligations and prevent the use of our Services in connection with fraudulent or other illicit activities.

We may use third-party services like KYC (know your customer) and AML (anti-money laundering) to provide specific services to you. These services may be incorporated into our Services or you may be redirected to them.

3.5. Correspondence

We may receive communications and information from you when you contact us through email, customer support channels, social media platforms, or other support channels (such as Twitter or Discord), or when you participate in surveys or questionnaires. This may include any personal information you choose to disclose to us, such as your name, email address, and any responses or comments you provide.

3.6. Personal data

We only process your personal data if this is necessary to provide a functional website or to provide you with our content and services. The processing of personal data only takes place based on the appropriate legal basis and as permitted by law.

3.6.1. Duration of Processing

We only store your data for as long as necessary to serve the purpose of the processing and we delete Personal Data or block access to it as soon as such purpose ceases to apply.

Furthermore, Personal Data may be stored if this has been provided for by the applicable law (for example for bookkeeping or mandatory archiving purposes). The data will also be blocked or deleted if a storage period prescribed by the applicable law expires unless there is a need for further storage of the data for the conclusion or fulfillment of a contract.

3.6.2. Disclosure of Personal Information to Third Parties

We use third-party services to provide our Services and meet legal and regulatory requirements relevant to the Company, and such third-party services use your Personal Data in delivering their services to the Company or in complying with regulatory requirements.

The Company may share the information collected with service providers to retain personal information and help us analyze how people use our services to improve the Website's functions properly and securely.

The Company may be required to share collected personal data with supervisory authorities, law enforcement agencies, or government officials. We will only do this if we are required to do so by law or a formal request, if it is necessary to prevent physical injury or financial loss, or if we are required to report illegal activity.

4. How we use your data

In accordance with your instructions and any applicable terms in our Terms of Service, as well as any relevant laws and regulations, we may use the data we collect for the following purposes:

• Providing and maintaining the Services. We use the data to deliver, operate, and improve the Services and their various features.

• Customer support. The data may be used to provide support and respond to inquiries regarding the Services.

• Safety and security. To protect against, investigate, and prevent fraudulent, unauthorized, or illegal activity, we may use the data. It may also be used to address security risks, solve security issues such as bugs, enforce our agreements, and protect our users and Company.

• Legal compliance. To comply with applicable laws and regulations, we may use the data as needed or requested by regulators, government entities, and law enforcement.

• Aggregated data. We may use some of the data we collect or access to create aggregated data that helps us understand how users interact with the Services and identify areas for improvement.

5. How we share your data

We may share or disclose the data we collect in the following circumstances:

• With service providers. In order to provide, deliver, and improve the Services, we may share your information with our service providers and vendors. For instance, we may share your wallet address with service providers to provide technical infrastructure services, your wallet address with blockchain analytics providers to detect and prevent financial crime and other illicit or harmful activities, and your activity on our social media pages with our analytics provider to learn more about your interactions with us and the Services.

• To comply with legal obligations. We may share your data in the course of litigation, regulatory proceedings, compliance measures, or when compelled by subpoena, court order, or other legal process. We may also share data when we believe it is necessary to prevent harm to our users, our Company, or others, and to enforce our agreements and policies, including our Terms of Service.

• For safety and security. To protect against, investigate, and stop fraudulent, unauthorized, or illegal activity, we may share data. It may also be used to address security risks, solve security issues such as bugs, enforce our agreements, and protect our users, Company, and ecosystem.

• During business changes. If there is a merger, acquisition, bankruptcy, dissolution, reorganization, asset or stock sale, or other business transaction, we may transfer or share data to another entity.

• With your consent. If you provide us with your consent, we may share your information at any time.

We do not share your information with any third parties and for any marketing purposes.

6. Third-party cookies

We may utilize third-party services that utilize tracking technology, such as cookies, device IDs, and localStorage, to collect information regarding your use of the Services and our interactions with you. These services may be provided by Google and other third-party companies. If you wish to opt out of having your online activity and device data collected through these third-party services, you may do so by:

• Blocking cookies in your browser through the appropriate settings in your browser.

• Blocking or limiting the use of your advertising ID on your mobile device through the device settings.

• Using privacy plug-ins or browsers that are specifically designed to block third-party cookies and trackers.

• Utilizing the platform opt-out provided by Google at https://adssettings.google.com. You may review Google's privacy policy for further information about how Google uses your data at https://policies.google.com/privacy.

Please note that if you choose to opt out of having your online activity and device data collected by these third-party services, certain features of the Services may be limited or unavailable to you.

7. Third-party services and links

Our policy only addresses the use and disclosure of information we obtain about you. To the extent that you disclose your information to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third-party sites or to the content or privacy practices of those sites, and that this Privacy Policy does not apply to any such third-party products and services. You are knowingly and voluntarily assuming all risks of using third-party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

8. Changes to this Privacy Policy

We reserve the right to revise and modify this policy at our sole discretion. While we do not anticipate frequent changes, you should check this page frequently to stay updated on the latest version.

We will post a summary of any significant change on this page (https://spectrum.fi/privacy).

9. Contact us

If you have any questions about this Policy or how we collect, use, or share your information, please feel free to contact us at [email protected]

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