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LEGAL · PRIVACY

privacy policy.

EFFECTIVE 01 · APR · 2026
VERSION 01
GOVERNING LAW England & Wales · Delaware, USA

01 · who controls your data

This Privacy Policy describes how Spectra Acquisition Ltd. (“Spectra,” “we”) processes personal data collected through spectraacquisition.com, our marketing operations, and our client engagements. For our website visitors, newsletter subscribers, and prospective clients we act as data controller. For personal data we process on behalf of a client during an active engagement we act as data processor; that processing is governed by our Data Processing Agreement.

Registered address: Kington, London, United Kingdom. US office: Dover, Delaware. Contact the privacy team at info@spectraacquisition.com.

02 · what we collect, why, and on what basis

CategoryPurposeLegal basis
Contact details (name, work email, company, role)Responding to enquiries, scheduling calls, sending briefsLegitimate interest · contract performance
Business context (revenue band, meeting volume, timeline)Qualifying fit and tailoring our responseLegitimate interest
Technical data (IP, device, referrer, pages viewed)Website analytics, security, debuggingLegitimate interest · consent (where required)
Marketing data (opens, clicks, replies on our newsletter)Measuring and improving our own outboundConsent · legitimate interest (B2B, opt-out always)

03 · cookies and similar technologies

We use a minimal set of cookies and equivalent browser storage — strictly necessary cookies for the site to function, and privacy-respecting analytics to measure traffic in aggregate. We do not run third-party advertising pixels on spectraacquisition.com. A cookie banner is shown where consent is required.

04 · how long we keep data

  • enquiry data — 24 months from last contact, then deleted unless you become a client.
  • client data (as controller) — 7 years after engagement end, in line with UK tax and accounting requirements.
  • website analytics — aggregated; raw logs retained 13 months.
  • newsletter subscribers — until you unsubscribe, plus 30-day grace period.

05 · who we share data with

We share personal data only with vetted sub-processors listed at /legal/sub-processors, and with regulators, auditors, or courts where required by law. We do not sell personal data. We do not share data with third-party advertisers.

06 · international transfers

Some of our sub-processors are located in the United States. Where personal data of UK or EEA residents is transferred, we rely on Standard Contractual Clauses and the UK International Data Transfer Addendum, together with supplementary technical measures (encryption in transit and at rest, access controls).

07 · your rights

Under UK GDPR, EU GDPR, and CCPA/CPRA you have the right to access, correct, delete, port, restrict, or object to our processing of your personal data, and to withdraw consent where it is our legal basis. To exercise any of these rights, email info@spectraacquisition.com. We will respond within 30 days. If you believe we have handled your data unlawfully, you may complain to the UK Information Commissioner's Office (ico.org.uk) or your local supervisory authority.

08 · security

We operate a defence-in-depth programme: TLS in transit, encryption at rest on managed platforms, role-based access controls, MFA on all operator accounts, least-privilege sub-processor access, and a documented incident response plan. Breaches affecting personal data are notified to affected parties and regulators within 72 hours where required by law.

09 · changes

We may update this Policy periodically. Material changes will be flagged on this page with the new effective date. Continued use of the site after the effective date constitutes acceptance of the revised Policy.

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