Politique de confidentialité

Retour aux Termes et conditions

Valid from: 2025-08-18

Privacy Policy (for non-EU)

General Provisions
1. The virtual currency exchange platform SpectroCoin, available on the website www.spectrocoin.com, our mobile apps or application programming interfaces ("API") ("SpectroCoin", the "Platform", the “Website”) offers a range of services, provided according to the Platform Terms and Conditions and all documents incorporated therein (the "Services"). The Services on the Platform may be provided by Spectro Finance Limited (a limited liability company, company number 2022454, registered at Craigmuir Chambers, Road Town, Tortola, VG1110, British Virgin Islands ("BVI"), Spectro Finance Systems LLC (a limited liability company, company number 2904 LLC 2023, registered at Euro House, Richmond Hill Road, Kingstown, Saint Vincent and the Grenadines) or Spectro Finance Systems Inc. (a limited liability company, company number 155770356, registered at Advanced Tower Building, Ricardo Arias street, Panama City, Republic of Panama) (any of the aforementioned companies further may be referred to as the "Company", "we" or "us") depending on the country you access the Platform or use the Services from and subject you conclude the agreement with when accepting General Terms and Conditions and other related documents of the Platform.
  Kindly be advised that this Privacy Policy (the "Policy") is applicable only if you are not a citizen of the European Union (the "EU") and you do not reside there.
2. In order to provide Services through the Platform, we may process personal data of our customers, their clients or representatives, other related persons, such as family members, beneficial owners, transaction senders, etc. (all together hereinafter referred to as "Customer" or "you"). Any personal data we gather, use or share about you is processed in accordance with applicable laws of Saint Vincent and the Grenadines, Republic of Panama or the British Virgin Islands (including the Virgins Islands Data Protection Act 2021) depending on the country you access the Platform or use the Services. The Company takes all the necessary measures to protect your personal data against unauthorized or unlawful processing and against accidental loss, destruction, or damage. This includes legal, organizational, technical, and physical security measures.
3. This Policy applies if you use of the Platform and any of the Services, available through it and indicates how your personal data is being processed by the Company, which in such a case, acts as a personal data controller and your Service provider. The Policy explains how we process your personal data through any relationship we have, whether it would be a call through the phone, use of the Services on the Platform, a message via email or any other possible mean. In case you provide information about other natural persons to the Company, you undertake to make this Policy known to them before the disclosure of such information to the Company.
4. By using this Platform and the Services you confirm you have read, understood and agree with this Policy. The Company reserves the right to make changes to this Policy. An up-to-date version of the Policy is posted on the Website.
Personal Data Management Principles
1. The Company undertakes to ensure your personal data is:
  1. processed lawfully, fairly, and in a transparent manner in relation to you;
  2. collected for specified, explicit and legitimate purposes (e.g. prevention of money laundering and terrorist financing, performance of Services, etc.), and not further processed in a manner that is incompatible with those purposes;
  3. adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. accurate and, where necessary, kept up to date;
  5. kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed;
  6. processed in a manner that ensures appropriate security of your personal data.
2. The Company follows the above indicated principles strictly during the processing of your personal data and requests the same from the data processors which it may use to process personal data on behalf of the Company.
Lawfulness of Personal Data Processing
1. Your personal data will be processed if:
  1. you have given consent to the processing of your personal data for one or more specific purposes; and/or
  2. processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract; and/or
  3. processing is necessary for compliance with a legal obligation to which we are subject; and/or
  4. processing is necessary for the purposes of legitimate interests pursued by us or relevant third parties; and/or
  5. processing is necessary for the execution of tasks carried out in the public interest or in the exercise of official authority vested in us.
2. The Company may make decisions regarding its Customers based solely on automated processing, including profiling, only if it is necessary for the conclusion of a contract with the Customer, the provision of Services under such contract, authorized by the law, or explicitly consented to by the Customer.
Purposes for Which Your Personal Data Is Being Processed
1. Your personal data is being processed for the purposes of:
  1. account establishment;
  2. performance of the Services (such as transactions of sale and purchase, withdrawal, deposit, exchange);
  3. prevention of money laundering and terrorist financing (implementation of the principle "Know Your Customer");
  4. crime prevention;
  5. implementation of international sanctions;
  6. Services support;
  7. quality assurance;
  8. adding you on the waiting list for the provision of the Services;
  9. direct marketing;
  10. call recording;
  11. use of the Company's social networks accounts;
  12. proper and secure operation of the Platform.
2. The processing of your personal data is necessary for the implementation of the above indicated purpose(s), therefore, if you fail to provide the requested data, the Company may not be able to provide your requested Services.
Methods of How Your Personal Data Is Being Collected
1. The Company collects your personal data directly from you or from the third parties when:
  1. you use or view the Platform;
  2. you register to the Platform;
  3. you use our Services;
  4. you request Services support;
  5. we execute Customer’s due diligence or ongoing due diligence;
  6. we monitor your transactions;
  7. we check whether you are not related to fraudulent activities;
  8. your personal data has been provided by the authorized third party;
  9. we receive requests, orders, decisions or etc. from the third parties regarding you;
  10. you consent to the call being recorded.
2. The Company may also collect your personal data from other SpectroCoin companies, as they are defined in General Terms and Conditions of the Platform, upon the change of the SpectroCoin company as your service provider.
3. In order to ensure smooth delivery of the requested Services, effective prevention of money laundering and terrorist financing or keep you updated about our news, the Company may also collect your personal data and renew personal data related to Customer’s profile based on the up-to-date information received from the data controllers and / or respectable third parties wherein you have already initiated or have an account, partners that process your personal data or public registers, sources.
Categories of the Processed Personal Data
1. The scope of the Customer's personal data indicated below which could be requested by the Company and further processed in order to provide the Services for the purposes indicated in article 4 of this Policy may vary depending on the type of Services chosen particularly by the Customer and Company's applied verification procedures to execute it, as well as legal requirements applied for such provision of Services in order to prevent possible risks and various crimes.
2. In order to provide the Services, we may process your personal data categories, such as (including but not limited):
  1. General identification data: first name, middle name, former name, aliases, surname, gender, date of birth, residential address, email, phone number, selfie (with the identity document), real-time video;
  2. Identity document data: ID Type (Passport/Identity Card/Residence permit), its copy, MRZ, document number, date of issue, date of expiry;
  3. Other Customer's profile information: profile type, member ID, referral code, login status, email confirmed status, phone confirmed status, secret questions information;
  4. Social network data: social sign in type, social network profile photo, name, surname, your comments, emotions and other actions expressed via our social network account, other your social network profile information provided by you;
  5. Information about Customer's occupation and income sources: specific occupation, main sectors of Customer's occupation, source of wealth and funds in Customer's account, source of fixed income, information on the percentage of turnover in aforementioned Customer's activity handled in cash;
  6. Account opening information:
    1. the purpose of the account opening;
    2. explanation of the business for which the account is being opened;
    3. Services which the client plans to use;
    4. size and volume of the business for which the account is being opened;
    5. expected nature and level of the transaction sought;
    6. countries from which the funds will be received and transferred;
  7. Information about Politically Exposed Person ("PEP"):
    1. Information whether the Customer is PEP itself or has an immediate relationship with PEP;
    2. General PEP's identification data: relation, name, surname, country, PEP's position;
  8. Information about Beneficial Owner ("UBO"):
    1. Information whether the Customer is the UBO of the account and the funds in the account or acts as a representative;
  9. Financial data:
    1. information about linked or pre-paid card(s) if such services are available;
    2. accounts, wallets related to the Customer's accounts on the Platform (used for receiving/sending funds);
    3. information about other Customer's cryptocurrencies accounts and all operational information within;
    4. information about used SpectroCoin merchant services;
    5. information concerning transactions: transaction ID, method, type (credit, deposit, withdrawal, exchange), status, sender’s (Customer’s) full name and account (wallet) address, recipient’s full name and account (wallet) address or another unique identifier assigned to the beneficiary of the transaction, QR code/wallet address, time and date register, order ID, amount, currency (code), coupon code;
  10. Data obtained and/or created while performing legal obligation: inquiries, requests, notifications, orders, courts decisions or other data related to the specific Customer(s) which may be received by or provided to the police, courts, investigative bodies, notaries, tax administrator, courts, bailiffs and other institutions;
  11. Communication data: date, time, correspondence, video and voice calls, chats;
  12. Information related to electronic devices: IP address(es); time zone; log-in and log-out register; browser information; electronic device‘s operational system information; location data (country (code), city); internet service provider (ISP); selected language; information regarding Customer‘s actions within Website;
  13. History data: Customer's experience using the Website, the register of all Customer's actions performed on the Platform (i.e. operations, such as funds transactions, linking cards, log-in and log-out register, register of reset passwords, separately expressed Customer's consents for personal data processing (i.e. for direct marketing);
  14. Call recording data: the record of the call, including the representation of the agent and the caller, as well as, all information discussed during the call, data and time of the call, caller’s telephone number, agent number;
  15. Other data which may be requested or gathered by the Company or provided by the Customer herself/himself or any third party.
Personal Data Recipients
1. Your personal data indicated in article 6 of this Policy may be provided by the Company itself or upon respective request to the below indicated categories of personal data recipients:
  1. Virtual currency services providers;
  2. Payment service providers, as well as intermediary services providers if relative Services are available and offered and such Services are related with these service providers;
  3. credit, financial, payment and (or) electronic money institutions if relative Services are available and offered and any of the Services are related with these service providers;
  4. authorities (i.e. supervising institutions, law enforcement institutions, courts);
  5. auditors, legal and financial consultants;
  6. IT providers;
  7. marketing services providers;
  8. telecommunication and call recording service providers;
  9. fraud detection services providers;
  10. data processors;
  11. other SpectroCoin companies, as they are defined in General Terms and Conditions of the Platform, in order to ensure smooth provision of the Services on the Platform upon change of the SpectroCoin company as your Service provider;
  12. other partners of SpectroCoin, as they are defined in annexes of General Terms and Conditions of the Platform, in order to ensure smooth and easy delivery of the Services;
  13. related business partners with whom you have established or intend to establish a business relationship concerning services available on UAB “Pervesk” or its intermediaries’ banking systems (including ib.pervesk.lt, ib.bankera.com or other);
  14. other service providers which services may include, or which are engaged in personal data processing executed by the Company.
2. Personal data may also be provided to other recipients if:
  1. the Company has to comply with a legal obligation to which it is a subject; or
  2. you have consented to the provision of the applicable personal data; or
  3. such requested personal data is necessary for the particular data recipient to carry out a particular inquiry in the general interest; or
  4. the data requesting party has a legitimate interest to request such information.
3. The Company maintains strong cooperation with local and international authorities and institutions, therefore, upon request of such party substantiated under article 7.2. of this Policy, your personal data may be provided to the requested party without permission to notify you.
Personal Data Storage
1. The Company processes personal data so that it could achieve the purposes indicated in article 4 of this Policy.
2. In order to set the below indicated data retention periods, the Company has referred to the legal acts and public recommendations such as compliance with legit limitation periods, as well as a current business practice.
3. Depending on the category of personal data and the purpose for which it is being processed, your data retention period applied within the Company, as it is required by the law or business practice to ensure smooth delivery of the Services, is:
  1. for the purposes indicated in articles 4.1.1. - 4.1.5. of this Policy, we process your personal data throughout the term of our contractual relationship and store it for 5 (five) years after this relationship ends or until it is no longer necessary for us to keep it for the indicated purposes (for example, due to the nature of our business, it may be necessary to store such data for 8 (eight) years after the business relationship termination, especially in cases where a competent authority conducts an investigation and further data processing is necessary to execute it, or if the Company sees the necessity to retain the data for a longer period, especially in cases where such necessity rises from the nature of the business relationship). In case you sign up to the SpectroCoin platform without entering into contractual relationship and where the contractual relationship was not established due to reasons not related with prevention of money laundering and terrorist financing (for example, you have started the identity verification procedure but decided not to finish it), your personal data will be processed for a period of 3 (three) to 5 (five) years since you created an account on the Platform or the last contact/action within or concerning the Platform from your side;
  2. for the purposes indicated in articles 4.1.6. - 4.1.7. we process your personal data collected via correspondence with you throughout the term of our contractual relationship and store it after this relationship ends until it is no longer necessary for us to keep it for the indicated purposes (for example, due to the nature of our business it may be necessary to store such data for additional 5 (five) years after the relationship ends). The same storage principle applies to your personal data processed for the aforementioned purposes and collected during the communication before establishing a contractual relationship or after the contractual relationship has been terminated. Due to the nature of our business, it may be necessary to store such data for 3 (three) to 5 (five) years since the day of last contact. The personal data processing for such periods is based on the necessity to keep records of communication;
  3. for the purpose indicated in article 4.1.8., your personal data may be processed for 5 (five) years since the registration credentials have been entered for the purpose of account opening at the Platform. This time limit may be additionally extended if a competent authority conducts an investigation and further data processing is necessary to execute it or if the Company sees the necessity to retain the data for a longer period, especially in cases where such necessity arises from the nature of its business or business relationship. Personal data may be retained as means to inform you once the Services become available in your country of residence so that you can continue with signing up on the Platform and proceed with using the Services as initially intended, if your application could not be completed due to the fact that the Company is not authorized to provide services in the jurisdiction of your residency;
  4. for the purpose indicated in article 4.1.9 we may process your personal data throughout the term you are registered to use the Services and/or have contractual relationship with us, or throughout the term your consent is valid (up to 3 (three) years, if not renewed)), except in cases when you have objected to such processing, terminated the contractual relationship, requested erasure of your personal data or other provisions for data erasure have been applied. After the day of termination of a contractual relationship or expiration date/revocation of the consent we store it for an additional period of time due to possible claims (it may be necessary to store such data for additional 3 (three) years) although newsletters will not be sent during this period;
  5. for the purpose indicated in article 4.1.10. your personal data will be processed for 6 (six) months since the date the record of the call has been made;
  6. for the purposes indicated in article 4.1.11 we process your personal data until your social network account or Company’s social network account is deleted – whichever comes first;
  7. for the purposes indicated in article 4.1.12. we process your personal data throughout the term we support the Platform.
4. Upon the end of the retention period indicated above your personal data will be erased or anonymized irreversibly.
Direct Marketing
1. In order to provide you generic or personalized up-to-date news about SpectroCoin products, Services and proposals and/or ask your opinion about the Services, your email address and/or telephone number might be processed by the Company for direct marketing purposes.
2. We process your personal data for direct marketing purpose based on your explicitly expressed consent. We may also send personalized direct marketing material based on Company’s legitimate interest according to the applicable laws and regulations and categorization of your profile information (such as customer’s type, last login, last transaction time, Services being ordered/used, channel used for accessing the Services, customer’s verification status, country of residence, transaction information (amount, transaction ID, etc.), use of referral code/link) to inform you about the news that may be interesting and relevant to you and/or ask your opinion about the specific Services.
3. In order to send you the direct marketing material we may use third party services and share your email address and/or telephone number with the third party providing the direct marketing services.
4. Your contact details, indicated in article 9.1. will be processed for the period indicated in article 8.3.4. of this Policy. Together with your email address and/or telephone number your personal data, such as IP address and the date when you gave a consent and or you have renewed it (as well as the day of termination of contract, cessation of provision of particular Services, or expiration/revocation date of the consent), will be processed for the aforementioned period.
5. You shall have a right to object at any time to processing of your personal data for the purpose of direct marketing, which includes profiling to the extent that is related to such direct marketing, by changing the settings in your profile, clicking on the withdrawal link provided in the received newsletters, or by sending us a request at the contacts provided in the Platform.
Information Security
1. The Company uses various technologies and procedures in order to ensure proper protection of your personal data against unauthorized or unlawful processing, accidental loss, misuse, unauthorized access, illegal usage, destruction, disclosure, damage, etc. This includes legal, organizational, technical, and physical security measures, such as the latest security systems, passwords, ability to detect cyber security attacks and other threats to the integrity of the Platform, working only with trustworthy service providers, etc. However, no transmission of information via email or other telecommunication channels or your access to the Platform or the Services through the internet could be fully secured. Therefore, you should take due care when you are accessing the Platform, using the Services via the internet, or sharing confidential information via email or other telecommunication channels.
Cookies
1. Cookies are small information files found in the Platform you visit and stored on your computer or mobile device. In order to get to know more about cookies, please read the Cookie Policy on the Platform.
Your Rights Regarding the Processing of Your Personal Data
1. You have certain legal rights in relation to the processing of your personal data, including:
  1. the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the information regarding its processing;
  2. the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you and, taking into account the purpose of the processing, the right to have incomplete personal information completed;
  3. the right to obtain from us the erasure of personal data concerning you without undue delay if it is possible;
  4. the right to obtain from us restriction of processing if it is possible;
  5. the right to data portability if it is possible;
  6. the right to object at any time to processing of your personal data if it is possible;
  7. the right not to be subject to an automated individual decision-making, including profiling if it is possible.
2. This Policy does not deprive you of any other legal rights you may enforce under the applicable law.
3. The Customer may exercise his/her rights only after the Company has successfully identified him/her. If the Company is not sure about the identity of the person sending data request, the Company may not provide the requested information to him/her, unless the Customer's identity is confirmed. Therefore, if you like to address a request towards the Company regarding the execution of your rights, we suggest you to do it through Live Chat once you are logged in to your account on the Platform (so that we could identify you). In case you decide to use other communication channels, such as sending a request via email, we kindly ask you to indicate in the email your name, surname, your date of birth and the last four digits of your identity document number which you used when entering into a business relationship with the Company (if you have provided it before). In addition, the Company keeps the right to decide if the other or additional legitimate mean of identification proof should be requested, such as a selfie with your ID document, a certified copy of your ID document, video or voice call, or any other additional document or method which could let to determine your identity.
4. The Customer will typically be provided with information related to the exercise of his/her rights free of charge. However, the Company may charge a fee where this is permitted by law and the Company will provide further details of such fee in the event that a request is made. The Customer's request for the exercise of the rights may be rejected if data protection law allows or prevents the Company from complying with the request, including, for example, where the Company is unable to identify you, is unable to locate the personal data which is being sought, or if the Company will contravene applicable law in complying with the request.
5. The Company shall provide the Customer with information on the actions taken upon receipt of the Customer's request for the exercise of his rights or the reasons for the inaction no later than within thirty days from the receipt of the access request. The period for submitting the requested information may be extended, if necessary, for thirty more days or by such period of time as is reasonable, depending on the complexity and number of requests. When the Customer submits the request by electronic means, the information shall also be provided by electronic means.
6. If the Customer considers that his/her personal data is being processed in violation of his/her rights and legitimate interests in accordance with the applicable law, the Customer shall have the right to file a complaint against the processing of personal data to the respective authority in the British Virgin Islands (the Office of the Information Commissioner), Saint Vincent and the Grenadines or Republic of Panama (depending on which Company provides the Services).
Your Responsibilities
1. You confirm that you have provided correct data about yourself in every required form and that afterwards, when changing or adding any data at the Platform, you will enter only correct data. The Company will not tolerate invalid, false or otherwise incorrect data and will pursue actions in accordance with its legal obligations. You shall bear any losses that occur with regard to the submission of invalid, false or otherwise incorrect data.
2. You are responsible for maintaining adequate security and control of every identification number, password, and/or any other code that you use to access the Platform. If you have not complied with this obligation and/or could, but have not prevented it and/or performed it on purpose or due to own negligence, you assume the losses and undertake to reimburse the losses of other persons incurred as a result of your (in)action.
3. In the event of loss of any password by yourself or if the password(s) are disclosed not due to your or the Company‘s fault, or in case of a real threat that has occurred or may occur to your account, you undertake to change the password(s) immediately or, if you do not have a possibility to do that, not later than within 1 calendar day notify the Company. The Company shall not be liable for consequences that have originated due to the notification failure.
4. After the Company receives the notification from you as indicated above, the Company shall immediately suspend access to your account and provision of the Company's Services until a new password is provided/created for you.
5. The Company draws your attention to the fact that an email address and any other contact information you have chosen to link to your account are used for your identification and communication. You undertake the responsibility to protect these instruments and logins to them. You are responsible for password disclosure and for all operations performed after you use the password for a relevant account. We recommend memorizing your passwords and not to write them down or enter anywhere where they may be seen by other persons.
Contact Details
1. If you have any questions regarding this Policy or your personal data protection or if you want to withdraw your consent, or execute your rights you may contact us via [email protected].
Final Provisions
1. This Policy shall be viewed and applied in accordance with the laws of the British Virgin Islands, the laws of Saint Vincent and the Grenadines or the laws of Republic of Panama (depending on which Company provides the Services). The Company may change, amend, delete any of the provisions contained in this Privacy Policy at any time and in its sole discretion. Any such changes will be effective upon the posting of the revised Policy on the Platform and you are solely responsible for reviewing it. Your continued use of the Platform and Services following any such revisions to the Policy will constitute your acceptance of such changes. If you do not agree to any such of such changes, do not continue to use our Services.
2. The Platform and Services may contain links to our partners or other third-party websites. If you use the services of our partners or other third-parties, their own privacy policies apply, and you will be covered by such respective policies.