Privacy Policy

This Privacy Policy describes the management by SpecTec of any personal data relating to you and your use of the following website address owned by SpecTec: https://www.spectec.net

Purpose

This Privacy Policy outlines the steps that SpecTec takes to:

  • Keep your Personal Data confidential
  • Inform you about how and why we collect such data
  • Outline your rights and our contact information to exercise these rights
  • Address questions or concerns arising out of this Privacy Policy

Scope

This Privacy Policy applies to our products, services and websites and does not concern any websites that you may visit through external links.

Controllers and Processors of Personal Data

SpecTec, with a registered office at First floor, 163 Leontiou Street, Clerimos Building, 3022 Limassol, Cyprus l, Limassol Cyprus, and a UK office at 6N-B, Trafford House, Chester Road, Manchester, M32 0RS, United Kingdom, determines the purposes and means of Personal Data for collection and processing.

The processing operations of Personal Data (automated and non-automated), are performed on behalf of SpecTec.

Why we collect Personal Data

We only collect and use your personal data where we have a lawful reason to do so. Depending on the context, this may include:

  • Contract: To perform or prepare to perform a contract with you.
  • Legitimate interests: To operate and improve our business, prevent fraud, and provide a secure experience – while respecting your rights.
  • Legal obligation: Where we must comply with the law.
  • Consent: Where you’ve clearly agreed, for example to receive marketing emails

When you visit our website, we may collect certain information automatically (such as IP address, browser type, and pages visited) through cookies or similar technologies to help us improve our site and understand how it is used.
We may also collect personal data you provide voluntarily, for example when you fill out a contact form or subscribe to a newsletter.

We use this data:

  • To respond to your requests and provide information;
  • To analyse website performance and improve content;
  • For marketing, where you have given your consent.

If we use cookies or similar tools that are not strictly necessary, we will ask for your consent through a cookie banner when you first visit the site.

SpecTec collect, use and may disclose personal information only as deemed appropriate in accordance with the purposes stated above.  We collect as little information as possible.

Once data is irreversibly anonymised and individuals cannot be re-identified, the data is no longer ‘Personal Data”. As such, aggregated statistics and information will not contain Personal Data and cannot be used to identify you.

We may use aggregated information, which may include the preparation of aggregated user statistics and information summaries to improve efficiencies, more effectively describe SpecTec’s product and service offerings, and assist in the marketing of our products and services.

The type of Personal Data we may collect

SpecTec collects Personal Data that is relevant and necessary for the purposes described in this Privacy Policy (such as providing services, processing transactions, ensuring security, and complying with legal obligations), and always on the lawful bases identified above. During the course of using our Web Site, interacting or doing business with us (including the receipt of products and services) you may be asked to provide us with:

  • Geographic (physical) addresses
  • Demographic information
  • E-mail addresses
  • Phone numbers or other contact information
  • Names (first, and last or whatever the family identifying name is)
  • Shipping information
  • Billing information
  • Transaction history
  • Web site usage preferences
  • Feedback regarding business, services, web site and public relations
  • Source IP addresses
  • Times and dates of access to Web site servers
  • Language
  • Personal preferences
  • Product and service preferences
  • Browsers types and configurations and Miscellaneous administrative and computer traffic information

In certain circumstances, and only where necessary (for example to comply with legal obligations such as anti-money laundering or ‘know your customer” checks), we may also request government issued identification. Where this is the case, we will explain why the data is required and the lawful basis for processing it.

 

How do we collect Personal Data?

SpecTec will only collect Personal Data that you have provided (voluntarily or agreed) to us. We will not collect any Personal Data without advising you why and how that Personal Data is being collected and how such Personal Data will be used or disclosed. SpecTec may collect Personal Data through a variety of means:

  • Directly from you, for example when you use our Web Site, our services, in the course of communications with us (face-to-face, by e-mail, by phone, mail or otherwise) and in the course of feedback with us regarding our business, services, website and publications, when registering with us for services, accounts or for the download of our software
  • Customer, membership, recipient, or service lists that have been lawfully acquired from trusted partners with a lawful basis for sharing with us
  • Through the completion of manual or electronic forms
  • Website cookies – We use cookies to enhance your browsing experience, serve personalized ads or content, and analyze our traffic. Visitors can opt in or opt out of non-essential cookies. On our website you are presented with a cookie banner providing options for “Accept All”, You may fully customize your preferences. Cookies are identifiers that can be sent from a website via your browser to be placed on your computer’s hard drive. You may elect not to accept cookies by changing the designated settings on your web browser. However, not utilizing cookies may prevent you from using certain functions and features of our Web Site. Information collected from the use of cookies is used to improve our services

  • Web beacons – Web beacons are small, graphic images that allow a website operator to collect certain information and monitor user activity on its website. A web beacon is a very small pixel which is invisible to the user.  Where these involve Personal Data, they are treated in accordance with this Privacy Policy.
  • Clickstreaming – Clickstreaming is a technology that allows a website operator to track the paths that surfers take as they access a website and look at the site’s pages, and as they use links to other sites. We collect such information from visitors to our Web Site; and
  • Website traffic information, which is monitored and analyzed in order to determine which products, services or features may be of interest to visitors, so we may improve our website, products, services, features or other offerings.

In addition, we may review and analyze your use of products and services, to improve their performance, develop new features, and provide recommendations that may be relevant to you. This may involve profiling your interactions with our services, but we do not use automated decision-making that produces legal or similarly significant effects without your explicit consent. We ensure that such collection is done in compliance with applicable data protection laws. You can object to the use  of your Personal Data at any time – see the “Data Subject Rights” section below.

 

How we may disclose Personal Information

SpecTec does not sell any Personal Data it collects to third parties. We may share Personal Data with affiliates, subsidiaries, employees, contractors and agents in the course of providing you with our business services, support, or the fulfilment or delivery of products or services, subject to confidentiality obligations.

We may disclose Personal Data if it is required to do so:

  • To comply with any legal process served on us
  • Maintain, uphold or protect our rights or property
  • Protect and ensure the personal safety of the public or other of our clients
  • Protect against criminal or quasi-criminal activities
  • Detect, prevent, investigate allegations of, or address, misrepresentation or fraud.

SpecTec reserves the right that in the event of a bankruptcy filing, mergers with third parties, acquisition by third parties, sale of assets (all or partial), or any other transfer of our relevant assets to a third party, that we shall be entitled to share the Personal Data provided by you to that third party. In such cases, we will ensure that your Personal Data continues to be protected in accordance with this Privacy Policy.

Retention and Disposal

SpecTec keeps information only for so long as it is reasonably necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting or reporting requirements.  We will securely destroy or delete information when it is no longer needed.

We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Security and Storage

SpecTec implements appropriate physical, procedural and technical security with respect to its and Processor’s offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Data. This also applies to our disposal or destruction of Personal Data.

We keep Personal Data collected about you strictly confidential. Only authorized personnel have access to this Personal Data. Personnel of ours who have access to Personal Data receive training regarding privacy protection.

Our security specialists build security by design and by default into our computer systems. The aim is to protect information at all times, when it is stored in data files or handled by our employees. SpecTec’s systems are also designed to protect information when it is transmitted, for example, between our data processing facilities and corporate offices.

International transfers

SpecTec’s website is hosted and administered in Mississauga, Ontario, Canada. We may transfer your personal data to other SpecTec entities or trusted service providers located outside the EU or the UK. In all cases, we ensure that your data is protected and that appropriate safeguards are in place to maintain a similar level of data protection as required under applicable laws.

You can request more details by contacting us.

 

SpecTec does, and shall continue to use, industry-standard technology to maintain the security of Personal Data, and for our connections to the internet. However, we cannot and do not guarantee the privacy, security, authenticity or non-corruption of any information transmitted through the internet or any for information stored in any third-party system connected to the internet.

SpecTec shall not be responsible for any claims, damages, costs or losses whatsoever arising out of or in any way related to third-party connections to or through the use of the Internet.

We cannot and do not ensure the protection of any Personal Data that you provide to a third-party web site that may reference, be referenced or link to our Web Site. Personal Data collected by these third parties is not subject to, or governed by, this Privacy Policy.

To the extent permitted by law, SpecTec shall not be liable for any loss or damage resulting from circumstances beyond its reasonable control, including the actions or policies of third-party websites linked to our services, user negligence, internet or network failures, or other external events.

Nothing in this section limits or excludes any legal obligations or liabilities that SpecTec may have under applicable data protection laws.

Data Subjects’ Rights

You have the right to:

  • Request access to your Personal Data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
    • If you want us to establish the data’s accuracy;
    • Where our use of the data is unlawful but you do not want us to erase it;
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us (see Contact details) If you have concerns about how your personal data is handled, you have the right to lodge a complaint with the Office of the Commissioner for Personal Data Protection (Cyprus) or with the Information Commissioner’s Office (ICO) in the United Kingdom, or with your local supervisory authority within the European Economic Area

Contact

SpecTec is committed to upholding this Privacy Policy. We have policies and procedures in place to educate and assist our employees and contractors in fulfilling their obligations under this Privacy Policy. Our policies and procedures will be reviewed on a regular basis and the results of such review will be presented to our personnel responsible for overseeing privacy matters.

We are committed to treating you with the greatest respect and consideration.  Should you want to advise us of any questions or concerns regarding this Privacy Policy, confirm the accuracy of applicable Personal Data, believe that the privacy of Personal Data has not been respected, or would like to update or delete incorrect Personal Data, please contact us by emailing privacy@spectec.net or write to the attention of Privacy Policy Manager, First floor, 163 Leontiou Street, Clerimos Building, 3022 Limassol, Cyprus ,

The appropriate Privacy Policy Manager will acknowledge the query and will respond within thirty (30) business days. If we need to extend the timing to respond, or have to refuse your request, we will advise you accordingly, subject to any legal restrictions.

Age

SpecTec is committed to protecting the safety of children. We will not knowingly request or use Personal Data from children under the age of sixteenwithout parental consent.  Our services are not directed at children and we do not knowingly collect Personal Data from anyone under the age of 16 (or the age applicable in your country of residence if different). If we become aware that we have collected Personal Data from a child below the applicable minimum age without appropriate parental consent, we will take steps to delete that information.

Updates

SpecTec may from time to time update this Privacy Policy, with the updated policy to be posted on our Web Site. The use of Personal Data provided to us prior to the update will continue to be governed by the policy in effect at the time the information was provided. We recommend that you revisit this Privacy Policy on a regular basis.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

Consent

Where we rely on your consent to process personal data, we will request it in a clear and specific manner for each relevant purpose. You are not required to provide consent, and if you choose not to, this will not affect your access to our services where the processing is based on another lawful basis (such as contract or legitimate interests).

Governing Law and Venue

This Privacy Policy is governed by the laws of Cyprus. SpecTec complies with the requirements of the EU General Data Protection Regulation (GDPR) and the UK GDPR, as applicable.

We will disclose Personal Data without your permission when required by law, or in good faith belief that such action is necessary to investigate or protect against harmful activities to our company, associates, or property (including this website), or to others.

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