Privacy Policy

This Privacy and Cookie Policy applies to the following entities within the Spectra group:

• Spectra FX Solutions LLP (UK) ;
• Spectra FX Solutions LLC (USA) ; and
• Spectra Markets (USA)

For the purposes of UK GDPR and Data Protection Act 2018, Spectra FX Solutions LLP is the data controller for personal data processed within the UK and is registered with the Information Commissioner’s Office (ICO)

Spectra FX Solutions LLP (UK)

21 Ironmonger Lane, 1st Floor, London, EC2V 8EY
Phone: +44 (0) 207-161-1450
Email: sales@spectrafx.com

Spectra FX Solutions LLC (US)

55 Fifth Avenue, Unit 1401, New York, NY 10003
Phone: +1 212-398-6020
Email: sales@spectrafx.com

Spectra Markets

50 Washington Street, Suite 1006, Norwalk, CT, 06854, USA
Email: info@spectramarkets.com

We collect and process the following categories of personal data:

• Personal identifiers (name, email address, contact numbers);
• Employment related data (job title, employer, application information);
• Website usage data (page views);
• Communication data (emails, call recordings, Bloomberg correspondence);
• CCTV footage (when visiting our premises);
• Payment information (via Stripe, if applicable and for Spectra Markets only).

We collect personal data directly from you when:

• you contact us or fill out a form on our website;
• you engage in business with us or apply for a role; or
• we communicate via phone, email, Bloomberg or in person.
• We may also collect data from third-party sources (e.g. recruitment agencies or payment providers like Stripe).

Under UK GDPR, the legal basis we rely on include:

• Contractual necessity: to perform a contract with you;
• Legal obligation: to comply with regulatory requirements;
• Legitimate interests: to manage our business operations; or
• Consent: where explicitly provided (e.g. for marketing, optional cookies).

Each processing activity is assessed to ensure it aligns with a lawful basis.

For individuals in the United States, we collect and use personal data in accordance with applicable federal and state laws, including but not limited to:

• California Consumer Privacy Act (CCPA): granting rights to access, delete, and opt-out of the sale of personal data for California residents
• Connecticut Data Privacy Act (CTDPA), and similar state laws

Our collection practices are limited to disclosed purposes and we do not sell personal information.

Your data may be transferred outside the UK and EEA. When we do so, we ensure appropriate safeguards are in place, including:

• Adequacy regulations (UK/EU);
• International Data Transfer Agreements (IDTAs) or Standard Contractual Clauses (SCCs); or
• Binding Corporate Rules (BCRs), where applicable

Your information is securely stored and all employees handling and processing personal data have been regularly trained to ensure consistent protecting and our internal controls and process ensure personal data is always protected.

We keep personal data and information collected for up to a 6-year period after our relationship has ceased. We implement technical and organisational measures to protect your personal data. These include access controls, encryption, staff training, and secure data disposal procedures.

You have the following rights under UK and EU data protection laws:

• Right of Access: You have the right to ask us for copies of your personal information.
• Right to Rectification: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Right to Erasure: You have the right to ask us to erase your personal information in certain circumstances.
• Right to restriction of Processing: You have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Right to Object to Processing: You have the right to object to the processing of your personal information in certain circumstances.
• Right to Data Portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

US residents have the following rights under CCPA and other state laws:

• Know what personal information we collect, use, disclose and share;
• Request deletion of personal data (subject to exemptions);
• Opt-out of the sale or sharing of personal data (Note: we do not sell your data);
• Non-discrimination for exercising privacy rights.

New York State Privacy Compliance:

If you are a resident of New York, we comply with the New York SHIELD Act and other applicable state privacy laws. This includes implementing reasonable administrative, technical, and physical safeguards to protect your private information.

We also comply with New York’s data breach notification requirements. In the event of unauthorized access to personal information, affected New York residents will be notified in accordance with New York General Business Law.

To exercise your rights, email: mpett@spectrafx.com or write to Spectra FX Solutions LLP, 21 Ironmonger Lane, London, EC2V 8EY. We will respond within one month under GDPR, and 45 days for CCPA.

Our websites use only essential cookies necessary for operation. These do not store personal data. We do not use third party or tracking cookies.

A cookie banner is displayed on entry to confirm use of essential cookies only. For more details, contact us.

We engage third-party service providers, such as Stripe (Spectra Markets only), for payments and analytics. These providers process your data under contract and only for specified purposes.

For details on Stripe’s privacy practices, visit: https://stripe.com/privacy

If you have any concerns about our use of your personal information, you can make a complaint to us at mpett@spectrafx.com or write to us at Spectra FX Solutions 21 Ironmonger Lane, 1st Floor, London ECV2 8EY

If you are a UK resident, you can also complain to the Information Commissioner Office (ICO) if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO Website: https://www.ico.org.uk

If you are outside of the UK then, you may have the right to complain to your local Data Protection Authority, details can be found on the following link.

US residents may lodge complaints with state attorneys general or refer to applicable state privacy regulators.

We review this policy at least annually. Changes will be posted on our website with the updated date below. Please check regularly for updates.