Privacy Policy

Last updated September 2020

Whitespectre and its subsidiaries and affiliates (collectively referred to as “Whitespectre”, “WS”, “we”, “us”, “our”) are committed to protecting and respecting your privacy. This Privacy Policy (hereinafter, “Policy”) provides you with the details of how any personally identifiable information (hereinafter, “Personal Data”) will be used and processed. We can be contacted via email at hello@whitespectre.com.

We undertake to provide the best level of protection to your Personal Data when using our website, our services, or interact with us, in accordance with our legal responsibilities as the ‘Data Controller’ under applicable data protection laws such as the US Data Protection Act (‘DPA’) and the EU General Data Protection Regulation (the ‘GDPR’).

We encourage you to read the present statement before using our website. Your use of this website signifies that you understand and agree with all terms of this Policy including, but not limited, to the way we may collect, use and share your Personal Data.

This Policy addresses data subjects whose Personal Data we may receive from our users in our websites located at https://www.whitespectre.com, https://www.paragoncommerce.com (the “Website(s)”).

2. Collection, use, retention and disclosure of collected Personal Data

We do not require visitors to register or provide information to view our Website. We may collect and process the following aspects of data about you:

We use the information held about you in the following ways:

We will retain your Personal Data as long as necessary to fulfil the purposes for which it was collected, or as required by applicable laws or regulations.

3. Sharing Personal Data with Third Parties

We may share your Personal Data with our subsidiaries and affiliates, as well as with our service providers (collectively, “Third Parties”), who process Personal Data on behalf of Whitespectre, and who agree to use the Personal Data only to assist us in providing our services or as required by law. Our service providers include those providing:

Such Third Parties may be located outside the European Union or the European Economic Area. In any case, we are responsible for ensuring that these Third Party companies have an ‘adequate level of protection’ under the GDPR and have put in place a strict data protection policy and contractual clauses to protect any Personal Data we share with them.

We require all Third Party services to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our Third Party services to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

4. Data subject rights

All users of our Websites have a right to access, rectify, request for the portability, oppose for legitimate reasons the processing of their personal information, delete their Personal Data or lodge a complaint with a supervisory authority.

Those rights can be exercised by sending an email to hello@whitespectre.com enclosing a copy of your ID or passport.

5. Security of your Personal Data

We have adopted the measures necessary in order to keep the required security level, according to the nature of the Personal Data processed and the circumstances of the processing, with the aim of avoiding, in the measure possible and always according to the state of the technology, its unauthorized alteration, loss, treatment or access.

6. Cookies

Cookies are small text files that can be used by Websites to make a user’s experience more efficient. Cookies help us to provide you with a good experience when you browse this Website and allow you to make full use of the features available on this Website.

We use cookies on our Website for one purpose, and that is to collect statistical information about how visitors use our website, so we can improve the way this website works and measure our success. By recording such statistics as browser usage, visitor location, operating system etc. we can measure and improve on how we manage and maintain our site, in order to give you an ultimately better visitor experience.

Most web browsers automatically accept cookies. Unless you have adjusted your browser settings so that it will refuse cookies, cookies will be set when you access our Website. By continuing to use and browse this Website, you agree and consent to our use of cookies. If you do not consent, please understand that certain features of our Website may not function as intended.

If you would like to manage your use of cookies then you can find out how to do so by visiting www.allaboutcookies.org

7. Privacy Policy Updates

Whitespectre reserves the right to modify this Policy at any time in order to adapt it to new legislation as well as to strategic corporate decisions with effect from the date of publication of this change on the Website.