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Privacy Policy

Last updated: April 2026

SPECTRUM Scaling ("we", "us", "our") is committed to protecting your personal data. This policy explains what information we collect, how we use it, and your rights under the General Data Protection Regulation (GDPR) and applicable data protection law.

1. Who We Are

SPECTRUM Scaling operates the website at scalingspectrum.com and the associated investor portal. For data protection purposes, we are the data controller. You can reach us at hello@scalingspectrum.com.

2. What Data We Collect

We collect personal data you provide directly when you:

• Submit a report request or sign-up form: your name, email address, and company name.
• Contact us via email or our contact form: your name, email address, and the content of your message.
• Log in to the portal: your email address and authentication credentials.

We do not collect sensitive personal data (such as health information, political opinions, or financial account details).

3. How We Use Your Data

We use your personal data to:

• Provide you with access to SPECTRUM investment reports and the secure portal.
• Send you login credentials and service communications related to your account.
• Respond to enquiries you submit via the contact form or email.
• Improve the quality and relevance of our research and platform.

We process your data on the legal basis of legitimate interests (providing the service you requested) and, where applicable, your consent.

4. Data Retention

We retain your personal data for as long as your account is active or as needed to provide our services. If you request deletion, we will remove your data within 30 days unless we are required to retain it by law.

5. Cookies

Our website uses minimal cookies and browser local storage to maintain your login session and remember your preferences. We do not use advertising or tracking cookies. No third-party analytics services track your behaviour on this site.

6. Third-Party Services

We use the following services to operate our platform:

• Netlify — website hosting and form processing. Netlify may store submitted form data on servers in the United States. Netlify complies with GDPR through standard contractual clauses.
• EmailJS — transactional email delivery. Email content is processed through EmailJS servers to deliver messages to your inbox.

We do not sell, rent, or share your personal data with third parties for marketing purposes.

7. Data Security

We apply appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. Access to the portal is protected by password authentication.

8. Your Rights Under GDPR

If you are located in the European Economic Area, you have the following rights:

• Access — you can request a copy of the personal data we hold about you.
• Rectification — you can ask us to correct inaccurate or incomplete data.
• Erasure — you can ask us to delete your personal data ("right to be forgotten").
• Portability — you can request your data in a structured, machine-readable format.
• Objection — you can object to processing based on legitimate interests.
• Restriction — you can request that we limit how we use your data while a dispute is resolved.

To exercise any of these rights, contact us at hello@scalingspectrum.com. We will respond within 30 days.

You also have the right to lodge a complaint with your national data protection authority. In the Netherlands, this is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl).

9. Changes to This Policy

We may update this privacy policy from time to time. We will publish the revised version on this page with an updated date. Material changes will be communicated by email where appropriate.

10. Contact

For any questions about this privacy policy or how we handle your data, please contact us at hello@scalingspectrum.com.