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Privacy Policy

Last modified: March 16, 2023

This Privacy Policy explains what data we collect when you use the Spectrum Finance web app (https://app.spectrum.fi), 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.

This privacy policy is part of our terms of use and shall be subject to and read along with our terms of use, available at https://spectrum.fi/terms.

Please read this Privacy Policy carefully before using the Services or availing our Services. By visiting the Platform, You accept and agree to be bound by this Privacy Policy. IF YOU DO NOT CONSENT TO THE COLLECTION AND USE OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM.

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. Eligibility

By accessing our Services, you represent and warrant that you are at least eighteen (18) years of age. If you are under the age of eighteen (18) years, you may not, under any circumstances or for any reason, use the Platform.

4. Data we collect

4.1. 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.

4.2. 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.

4.3. 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.

4.4. 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.

4.5. 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.

4.6. 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.

4.6.1. 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.

4.6.2. 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.

5. 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 Services. We may use the information we collect to provide, personalize, maintain, and improve our products and Services, including as we described in the Terms of Service.

• Customer support. We may use information we collect to provide customer support, including to:
1. direct questions to the appropriate customer support person;
2. investigate and address user concerns; and
3. monitor and improve our customer support responses and processes.

• Safety and security. We may use your information to help maintain the safety, security, and integrity of you and our Services, including to:
1. protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
2. monitor and verify identity or service access, combat spam, malware or security
3. perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational problems;
4. enforce our agreements with third parties, and address violations of our Terms of Service or agreements for other products or services; and
5. comply with applicable security laws and regulations.

• Research and Development. We may use the information we collect for testing, research, analysis, and product development to improve your experience. This helps us to improve and enhance the safety and security of our Services, improve our ability to prevent the use of our Services for illegal or improper purposes and develop new features and products relating to our Services.

• Legal and Regulatory Compliance. We may verify your identity by comparing the personal information you provide against third-party databases and public records. We may use the information we collect to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

6. How we share your data

We will disclose or share your data, without notice, for the primary purposes for which it was collected in accordance with this Privacy Policy, including, without limitation.

• With service providers or third party. We work with Our Service Providers or third party to execute various functionalities of the Platform and 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 coordination with government investigations, 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 subject to standard confidentiality arrangement.

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

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

7. Security of Your Information

We strive to maintain the security and safety of your Data in line with industry standards. Once We have received your information or Data, We use strict procedures and security features as per industry standards and the Data Protection Laws to try to prevent unauthorised access, loss, misuse, unauthorised disclosure and dissemination, destruction and alteration of Your Personal Data.

Steps taken to ensure Personal Data security:
1. All data is hosted on third-party servers of third-parties.
2. We employ industry standard data security practices to keep Your Personal Data safe from cyber-attacks and threats.
3. We undertake periodic assessments of the Platform’s safety and security practices.

While We sincerely strive to protect Your Data, We cannot guarantee its security, or warrant that no harmful code will enter the Platform (including but not limited to viruses, bugs, trojan horses, spyware, malware, forks or adware). Transmission of information through the internet is not completely secure. You should be aware of the risks associated with disclosing any information or transacting over the internet or when using online portals. We urge You to take every precaution when using the internet to disclose Your Personal Data to Us, including using strong passwords, changing Your password regularly and using a secure browser. ANY INFORMATION YOU PROVIDE US IS AT YOUR OWN RISK AND DISCRETION.

You agree to immediately notify Us if You discover or otherwise suspect any security issues related to any of Our Services or Your User Account. You can contact Us at [email protected]

8. 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. A cookie is a text file that is placed on Your hard drive by a web page server. Cookies cannot be used to run programs or deliver viruses to Your device. Cookies are uniquely assigned to You and can only be read by a web server in the domain that issued the cookie to You. Cookies do not typically contain any information that personally identifies a user, but personal information that We store about You may be linked to the information stored in and obtained from cookies. Cookies on the Platform may be used to ensure a smooth User experience, perform analytics, and for showing relevant advertisements. Please note that service providers or third parties may also use cookies, over which we have no control. These services may be provided by Google and other third-party companies. Most web browsers automatically accept cookies 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.

9. Restrictive User

User and/or You is not a citizen, resident (tax or otherwise), domiciliary and/or green card holder or other similar certificate of residency of a country (A) where participation in ISPO and/or token sales is prohibited, restricted or unauthorized by applicable law, decree, regulation, treaty, or administrative act, or (B) where it is likely that the sale of tokens would be construed as the sale of a security (howsoever named), financial service or investment product including without limitation the Afghanistan, Albania, Algeria, Australia, Bangladesh, Barbados, Belarus, Bolivia, Burkina Faso, Cambodia, Canada, Cayman Islands, Congo (Democratic Republic), Democratic People’s Republic of Korea (DPRK), Ecuador, Egypt, Eritrea, Haiti, Iran, Iraq, Japan, Jordan, Lebanon, Mali, Morocco, Myanmar, Nepal, Nigeria, People’s Republic of China, Philippines, Qatar, Russian Federation, Senegal, Somalia, Sudan, Syria, Tunisia, Ukraine, United States of America (USA), Yemen, Zimbabwe, nor User and/or You is purchasing tokens from any Restricted Country, nor is the User and/or You an entity (including but not limited to any corporation or partnership) incorporated, established or registered in or under the laws of a Restricted Country, nor is the User and/or You purchasing tokens on behalf of any person or entity from a Restricted Country. The User and/or You is not a citizen or resident of a geographic area in which access to or participation in such interface is prohibited by applicable law, decree, regulation, treaty, or administrative act.

10. 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.

11. Data Retention and Data Transfer

Data Retention. The Company may retain the Personal Data for a limited duration, not exceeding the time required for fulfillment of purposes described in Articles 4.7.1 of this Privacy Policy. Further, we may retain Personal Data for an additional period permitted or required under applicable Laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes. We will cease to retain Your Personal Data or remove how the data can be associated with You as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected and is no longer necessary for legal or business purposes.

Data Transfer. The Data collected by us may be stored and processed in analytics systems like Amplitude or Posthog or in any other country where we or service providers maintain facilities. If we decide to transfer your data to other countries, we will take all commercially reasonable steps required to ensure that the data is stored, processed, and used according to the provisions of this Policy, and the requirements of applicable Law wherever the data is located. Further, no transfer of your Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

12. 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. If You do not agree with the changes, please refrain from using the Platform. It is Your responsibility to review this Privacy Policy (and the applicable conditions) from time to time. If any provision of this Privacy Policy shall be held to be invalid, illegal, or unenforceable for any reason whatsoever, the validity, illegality, and enforceability of the remaining provision of this Privacy Policy shall not in any way be affected or impaired thereby.We will post a summary of any significant change on this page (https://spectrum.fi/privacy).

13. 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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