Privacy Policy

Name: Spectra FX Solutions LLC

Address: 55 Fifth Avenue, Unit 1401 New York, NY, 10003

Phone Number: + (1) 212-398-6020

E-mail: sales@spectrafx.com

Name: Spectra FX Solutions LLP

Address: 21 Ironmonger Lane, 1st Floor, London, EC2V 8EY

Phone Number: +44 (0) 207-161-1450

E-mail: sales@spectrafx.com

Spectra Solutions FX is a data controller of personal data. The Spectra group offers an exclusive outsourced execution and advisory service across a spectrum of foreign exchange products for top tier FX market participants. In this regard, Spectra offers the following range of financial instruments: Spot and Forward Cash Transactions in G20 currencies as well as Emerging Markets; OTC Vanilla and Exotic Swaps; and Non-Deliverable Forwards (NDFs).

For this notice where we refer to Spectra, we are referring to all companies within the Spectra group, including subsidiaries, holding companies and any associated and affiliated companies.

We currently collect and process the following information:

• Personal identifiers, contacts, and characteristics (for example, name and contact details including email addresses)
• Personal information relating to Employees, Partners, and Directors
• Information that you provide to us via our website.
• If you contact us or we contact you, we will keep a record of that correspondence and all telephone calls and other methods of communications are recorded for regulatory compliance and record keeping purposes; and
• Details of your visits to our site and the materials and information that you access.
• For recruitment purposes. If you apply for a job with us, we may collect personal information from you and where relevant, from third parties
• We operate CCTV cameras on our business premises, if you attend our offices your image could be captured on CCTV.

We endeavour to make sure that all data usage complies with applicable law. Most of the personal information we process is provided to us directly by you for one of the following reasons:

• The use of your personal information as described herein for our legitimate business interests.
• The use of your personal information to comply with applicable law and regulations.
• The use of your personal information to establish, exercise or defend our legal rights or for the purpose of legal or regulatory proceedings
• To undertake statistical analysis for business improvement

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

• To conduct our contractual obligation
• To fulfill our legal obligation

Because of the international nature of our business, we may need to transfer your personal data within the Spectra group, and to third parties, as noted in the section above, in connection with the purposes set out in this policy. For this reason, we may transfer your personal data to other countries that may have different laws and data protection compliance requirements, including data protection laws of a lower standard to those that apply in the country in which you are located. We will make sure that we take all necessary steps to comply with applicable legal requirements.

Where we transfer your personal data to other countries, in accordance with our regulatory requirements:

• Adequacy decisions.
• suitable standard contractual clauses; and / or
• other valid transfer mechanisms.

If you would like further information regarding the safeguards applied to international transfers of personal data, please use the contact details provided below.

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 will dispose your information by removing all records from internal storage including cloud-based storage and permanently deleting these. If any physical records have been received these will be disposed safely and securely, protecting all data held within.

Under data protection laws, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information.

Your 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.

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.

Your 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.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact mpett@spectrafx.com or write to Spectra FX Solutions 21 Ironmonger Lane, 1^st Floor, London ECV2 8EY if you wish to make a request.

The only cookies on our websites are essential and/or necessary for the websites to function properly. These cookies do not store any personally identifiable information. Our websites currently do not use any third-party cookies.

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, 1^st 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.

This Privacy Policy will be reviewed at least every 12 months and updated to reflect our personal information handling practices.  We reserve the right to amend this Privacy Policy at any time, for any reason, without additional notice to you, other than through posting the updated Privacy Policy on our Website. We invite you to return to this page to ensure you are informed of any updates we make about how we collect, use, and protect customer information. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the bottom of this page.

Name: Spectra Markets

Address: 50 Washington Street, Suite 1006, Norwalk, CT, 06854, USA

E-mail: info@spectramarkets.com

• Personal identifiers, contacts, and characteristics (for example, name and contact details including email addresses)
• Personal information relating to Employees, Partners, and Directors
• Information that you provide to us via our website.
• If you contact us or we contact you, we will keep a record of that correspondence and all telephone calls and other methods of communications are recorded for regulatory compliance and record keeping purposes; and
• Details of your visits to our site and the materials and information that you access.
• For recruitment purposes. If you apply for a job with us, we may collect personal information from you and where relevant, from third parties
• We operate CCTV cameras on our business premises, if you attend our offices your image could be captured on CCTV.

We use Stripe for payment, analytics, and other business services. Stripe collects and processes personal data, including identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection and prevention. You can learn more about Stripe and its processing activities via privacy policy at https://stripe.com/privacy.

We endeavour to make sure that all data usage complies with applicable law. Most of the personal information we process is provided to us directly by you for one of the following reasons:

• The use of your personal information as described herein for our legitimate business interests.
• To undertake statistical analysis for business improvement
• To manage your account, subscription, and any purchases you make through our website.

The only cookies on our websites are essential and/or necessary for the websites to function properly. These cookies do not store any personally identifiable information. Our websites currently do not use any third-party cookies.