CCPA Privacy Notice

Please Read Carefully Prior To Using our website and other Spektra products & services including CSP Control Center, CloudLabs, CloudEvents, SaaSify & WVD Control Center. The below statement of Spektra Systems is designed to notify its customers based in California about Spektra Systems Commitment towards protecting its Californian Customers Data Privacy under the legal requirements of California Consumer Privacy Act (CCPA).

Spektra Systems LLC products and Services are not designed for children/minors below age of 13 years. Spektra Systems responds to any Lawful request from a Californian Resident if they fall under the following categories of Age limit:

• 13–16 years represented by a parent/Guardian
• 16 years & above individuals

”Shine the Light” Law

Your California Privacy Rights:

California Civil Code Section 1798.83 entitles California residents to request information concerning whether a business has disclosed Personal Information to any third parties for their direct marketing purposes. California residents may request and obtain from us once a year, free of charge, information about the personal information, if any, we disclosed to third parties for direct marketing purposes within the immediately preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information within the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to: privacy@spektrasystems.com

Data Collection & Use and Disclosure of Information

More specific information about Personal Information we collect is laid out in this notice and in our privacy policy, which we update from time to time. You can refer directly on the following sections in the Privacy Policy regarding Data Collection, Purpose, and its use:

• Data Collection
• Use and Disclosure of Information

Information for California Residents

While CCPA applies to California residents who wish to exercise their rights, our products or services including CloudLabs does not sell your personal data and CloudLabs (Spektra Systems) will not discriminate against you in any way based on our exercise of these rights. If you are a California resident and would like to make such a request, please submit your request in writing to: privacy@spektrasystems.com

Your Privacy Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. To exercise your rights under CCPA, please refer to the CONTACT INFORMATION section of this privacy notice statement. You have the following rights under the CCPA:

The Right to Request Information

The CCPA gives consumers who are residents of California the right to request the following information about the personal information that we’ve collected in the past 12 months:

1: Information about Data Collection

The categories of personal information that have been collected and the specific pieces of personal information that have been collected about you. The categories of sources from which we have collected personal information and the business purpose for which we have collected personal information.

Information about Data Disclosure

The categories of third parties with whom personal information has been shared and the categories of personal information that we have disclosed for a business purpose.

General details about data collection and disclosure are provided in our Privacy Policy. Please include in your request sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information.

You can reach us anytime to access your rights under CCPA by writing to: privacy@spektrasystems.com.

Attn: Data Protection Officer

• Right to request Spektra Systems DISCLOSE Personal Information, or Categories of Personal Information, it collects, uses, discloses, and sells (Access to Specific Information and Data Portability Rights)
• Right to request Spektra Systems DELETE Personal Information we have collected from you (Deletion Request Rights)

Right to Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you, as requested and verified.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Opt-Out and Opt-In Rights for California Customers

Our products reserve the right to compile, save, use within the scope of Our products’ activities, and analyse any and all User data (registration data, use history, etc.). Our products will use such User data for internal purposes only, including without limitation for the purposes of responding to User’s requests for information and for contacting User.

Except as otherwise described in this CCPA Privacy Notice & our Privacy Policy, User email addresses and any personal customer information will not be distributed or shared with any third parties other than Spektra Systems employees, consultants and representatives.

You have the right at any time to prevent us from contacting you for marketing purposes. You can opt-out of promotional communications by following the unsubscribe instructions unsubscribe@spektrasystems.com provided in each promotional email that we send to you. We may continue to send you administrative emails; for example, periodic updates to our Privacy Notice, even if you indicate that you no longer wish to receive promotional email from us.

We do not sell, trade or rent the personal information (PII) of consumers at any cost with third parties.

If you have any concerns about our data handling practices, we welcome you to write to us: privacy@spektrasystems.com

Alternatively, you can simply reply to an email from our products and type “REMOVE” in the subject line.

Do Not Sell Personal Information / Do Not Track Personal Information

As a Californian resident and user of our services, if you ever feel that your personal information is being tracked, shared or sold, please reach to us by writing to privacy@spektrasystems.com. We want to assure that no data of our customers is compromised, shared, sold or traded with any third parties. In the event of we doing so, this will be strictly subject to your notice and acceptance to do so.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by mailing us at: privacy@spektrasystems.com

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Any information collected for verification will not be tracked, stored, sold or used for any other purposes.

The following is our process for Verifying a Request:

• Request to Know Categories of Personal Information: We will verify your identity to a “reasonable degree of certainty” by verifying at least two data points that you previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
• Request to Know Specific Pieces of Personal Information: We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities.
• Request to Delete: We will verify your identity to a “reasonably high degree of certainty” by verifying at least three pieces of Personal Information previously provided to us and which we have determined to be reliable for the purpose of verifying identities.

Response Timing and Format

We endeavour to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Privacy Notice

Spektra Systems reserve the right to amend this privacy notice at our discretion and at any time. This privacy notice is subject to review after a period of every 12 months from the previous update. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

For additional information on Cookies and technologies engaged by Spektra Systems, please refer to https://spektrasystems.com/privacy-policy.

Contact Information

If you have any concerns about how we process your data or would like to exercise any of your California privacy rights, including those described above, you can:

• Call us: +1-844-773-5872
• Write to us @ privacy@spektrasystems.com

Spektra Systems LLC

Attn: Data Protection Officer

8201 164TH AVE NE, Suite 200 REDMOND WA 98052-7615