Privacy Policy Statement

Last Updated: 3 August 2026 1. Introduction and Scope Spectrum Data Ltd ("Spectrum", "we", "us", or "our") respects your privacy and is committed to handling personal information responsibly. This Privacy Policy Statement explains how we collect, use, disclose, retain, and protect personal information when you visit https://spx-dt.com, use its language selector, or submit its contact form (collectively, the "Website"). It applies only to the Website and related communications. It does not describe information-handling practices for separate client projects, contracts, employment, or third-party websites. This policy is intended to reflect applicable Canadian private-sector privacy laws, including British Columbia's Personal Information Protection Act ("BC PIPA") and the Personal Information Protection and Electronic Documents Act ("PIPEDA") where it applies. Key points: The contact form sends the information listed in Section 3.1 to Spectrum by email so we can respond to the inquiry. Website hosting, media, email-delivery, and business-email providers process information as described in Section 6, and some processing may occur outside Canada. The Website uses one first-party language-preference cookie and does not currently use analytics or advertising cookies. You can contact us to ask about or request access to your personal information. 2. Accountability Spectrum is responsible for personal information under its control. We designate a person or role to oversee compliance with this policy and applicable privacy law. Privacy questions, access or correction requests, consent withdrawals, and complaints may be directed to the contact listed in Section 13. 3. Personal Information We Collect 3.1 Information you provide through the contact form When you submit a Website inquiry, we collect: - email address; - full name; - company or organization name; - industry; - whether your organization currently uses NetSuite ERP; and - the contents of your message. You may also choose to provide: - company website; - telephone number; - additional industry information; and - additional ERP or system information. Please do not include sensitive personal, financial, health, identity-document, account-credential, or other confidential information that is not necessary for us to respond to your inquiry. 3.2 Technical information processed when you use the Website When your browser connects to the Website or its media delivery services, our hosting and content-delivery providers may automatically process technical information needed to deliver, secure, and troubleshoot the Website. Depending on the request and provider settings, this information may include: - Internet Protocol (IP) address and approximate location derived from it; - browser, device, and operating-system information; - requested page or asset, referring page, date and time; - request identifiers, response status, performance, diagnostic, and security information; and - system configuration information associated with the request. Spectrum does not currently use this Website data to build advertising profiles or make automated decisions about visitors. 3.3 Language preference cookie If you choose a Website language, the Website stores a first-party functional cookie named spectrum-locale. It records only the selected language (en, zh-Hans, or zh-Hant), is not available to client-side scripts, and expires after one year. The Website may also set this cookie when redirecting an older language-prefixed link to the current Website route. If the cookie is missing, expired, blocked, or deleted, the Website defaults to English. See Section 7 for more information. 3.4 Analytics and advertising As of the Last Updated date, the Website does not use Google Analytics, advertising cookies, targeting cookies, session-replay tools, or cross-site behavioural tracking. We will update this policy and provide any choices required by law before introducing materially different analytics or advertising practices. 4. How We Use Personal Information We use personal information for the following purposes: - to receive, review, and respond to Website inquiries; - to understand the services or business needs described in an inquiry and communicate about them; - to deliver Website pages and media, remember a selected language, and maintain Website functionality; - to secure, monitor, troubleshoot, and improve the Website and its technical performance; - to prevent spam, fraud, abuse, security incidents, and other prohibited or unlawful activity; - to keep appropriate business records and manage any resulting business relationship; - to comply with legal obligations, enforce our rights, and respond to lawful requests; and - for another purpose that we identify when collecting the information and to which you consent, or that is otherwise permitted or required by law. We do not add contact-form information to a marketing list or use it for unrelated promotional communications unless we obtain any consent required by law. You may withdraw marketing consent at any time through the unsubscribe method in the message or by contacting us. 5. Consent and Your Choices We seek meaningful consent appropriate to the sensitivity of the information and the circumstances. When you voluntarily submit the contact form, you consent to our collection, use, and disclosure of the submitted information as reasonably necessary to respond to and manage your inquiry. Required fields are identified on the form. Optional fields may be left blank. Selecting a language asks the Website to store the functional language cookie described in Section 3.3. You can delete or block it using your browser settings, although your selected language will not persist and the Website will default to English. You may withdraw consent to future use or disclosure by contacting us, subject to reasonable notice and any legal, contractual, or operational restrictions. Withdrawal does not affect handling that occurred before the withdrawal. If information is necessary to provide a requested service, withdrawing consent may prevent us from continuing that service. 6. Disclosure and Service Providers Spectrum does not sell or rent personal information. We may disclose personal information only as reasonably necessary for the purposes described in this policy, including to: - Vercel, which hosts and delivers the Website and processes technical request and security information; - Sanity, which provides Website content management and media delivery and may process technical request information when it delivers Website assets; - Resend, which transmits contact-form submissions as email and processes the recipient address, reply address, inquiry content, and related delivery records; - our business email provider, currently Microsoft 365, which receives and stores inquiry email and related correspondence; - personnel, contractors, and professional advisers who need the information for an authorized purpose and are subject to appropriate confidentiality obligations; - a purchaser, successor, or other relevant party in connection with a proposed or completed financing, reorganization, merger, sale, or transfer of all or part of our business, subject to applicable law and appropriate safeguards; and - courts, regulators, law-enforcement bodies, government authorities, or other parties when disclosure is permitted or required by law, needed to respond to lawful process, or reasonably necessary to protect rights, security, or safety. We may also disclose information with your consent or at your direction. 7. Cookies, Media, and Third-Party Links The Website currently uses only the first-party functional language cookie described in Section 3.3. We do not currently use analytics, advertising, or targeting cookies. Most browsers let you review, block, or delete cookies. Blocking the language cookie will not prevent access to the Website, but the Website will not remember your selected language and will default to English. The Website loads some media from Sanity's content-delivery network. It may also contain links to third-party websites or social-media services. If you follow a third-party link, that party's privacy policy and terms apply. Spectrum does not control third-party websites or their information-handling practices. 8. Safeguards We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity of the information in our control. These safeguards are intended to protect against unauthorized access, use, disclosure, alteration, loss, or destruction and include secure HTTPS transmission, access restrictions, service-provider controls, and credential management where applicable. No Internet transmission or electronic storage system can be guaranteed to be completely secure. Please use caution when deciding what information to send through the Website. 9. Retention We retain personal information only for as long as reasonably necessary for the purposes described in this policy or as permitted or required by law. Contact-form inquiries, related email correspondence, and associated delivery records are retained for TBC (To be confirmed). If an inquiry results in a client or other business relationship, relevant records may be retained for the duration of that relationship and for any additional period required for contractual, tax, accounting, insurance, dispute-resolution, or legal purposes. The language cookie expires after one year unless you delete it earlier. Technical logs and provider records are retained according to the applicable service configuration, contract, security needs, and legal requirements. When personal information is no longer required, we delete, anonymize, or securely dispose of it, subject to backup cycles and legal retention requirements. 10. Processing Outside Canada The service providers identified in Section 6 operate in multiple jurisdictions. Personal information and technical information may therefore be processed or stored outside Canada, including in the United States, depending on the provider and service configuration. Information handled outside Canada may be subject to the laws of the country where it is processed, including lawful access by courts, law-enforcement bodies, or government authorities in that country. Spectrum remains responsible for personal information under its control and uses contractual and other measures appropriate to the sensitivity of the information and applicable Canadian law. You may contact us for information about our use of service providers outside Canada. 11. Access, Correction, and Privacy Complaints Subject to applicable law, you may ask us to: - confirm whether we hold personal information about you; - provide access to that information and information about how it has been used or disclosed; - correct information that is inaccurate or incomplete; - withdraw consent to future handling where consent is the legal basis; or - address a question or complaint about our privacy practices. Please submit your request in writing using the contact information in Section 13. We may need to verify your identity before responding. Applicable law may permit or require us to refuse access to some information; if so, we will explain the reason unless prohibited by law. We encourage you to contact us first so that we can try to resolve your concern. If you are not satisfied, you may contact the Office of the Information and Privacy Commissioner for British Columbia or, where applicable, the Office of the Privacy Commissioner of Canada. 12. Changes to This Policy We may update this policy when our Website, information-handling practices, service providers, or legal obligations change. The revised policy will be posted on this page with a new Last Updated date. If a change is material, we will provide additional notice or obtain new consent where required by law. 13. Contact Us Questions, requests, or complaints regarding this policy or our handling of personal information may be sent to: Spectrum Data Ltd Attention: TBC (To be confirmed) Email: info [at] spx-dt [dot] comCopy email Mailing address: TBC (To be confirmed) 14. Applicable Law and Language This policy is intended to comply with applicable Canadian privacy law, including British Columbia's Personal Information Protection Act ("BC PIPA") and PIPEDA where it applies. For matters requiring a governing-law clause, the governing law will be the laws of the Province of British Columbia and the federal laws of Canada applicable there, without regard to conflict-of-law rules, except where another law must apply. If this policy is made available in another language and there is a discrepancy, the English version will govern to the extent permitted by applicable law.