Privacy Policy

Your privacy is important to us at Spectrum Communications & Consulting LLC (“Spectrum”, or “we”, or “us”, or “our”). This Privacy Policy (the “Privacy Policy”) applies to any websites or mobile applications owned or operated by us, including, without limitation, this website currently located at www.spectruminc.com (collectively, the “Websites”), any newsletters subscribed to via the Websites, digital subscriptions to any service or product of Spectrum, including, without limitation, mobile applications or other digital properties, as expressly indicated by Spectrum through a link or display of this Privacy Policy (collectively with the Websites, the “Services”).

This Privacy Policy explains what information, including Personal Information, we collect from or about you on our Services, how we use or share such information, how to exercise any rights you may have with respect to your Personal Information, and the safeguards we have in place to reduce the risk of unauthorized access and use. For the purposes of this Privacy Policy, Personal Information means any information, alone or in combination, from which a natural person can be identified. Personal Information does not include data where identifiers have been removed.

User Consent to Privacy Policy

Any person accessing, browsing, or otherwise using the Services, either manually or via an automated device or program, shall be considered a “User”. All Users are bound by the terms of this Privacy Policy. Users consent to the collection, use and disclosure of personally identifiable User information (“Information”) pursuant to the terms of this Privacy Policy.

Information Collected from Users

Spectrum, or where relevant, a designated service provider, collects information that you choose to provide or we receive from other sources. This may include Personal Information or Sensitive Personal Information that you provide through the Services, on third-party websites and applications when subscribing to the Services, through requesting certain Spectrum services or products, when downloading our e-books or webinars, or by submitting the information to enter a sweepstakes, contest, or other promotion.

We may collect and we have collected, within the past 12 months, the following categories of Personal Information about consumers. Personal Information we collect about you may vary depending on the nature of your interactions with us and may not include all of the examples listed below.

In addition, we may collect, use, and disclose your Personal Information as required or permitted by applicable law. We do not treat deidentified data or aggregated consumer information as Personal Information, and we reserve the right to convert, or permit other to convert, your Personal Information into deidentified data or aggregate consumer information.

For purposes of this Privacy Policy, “Sensitive Personal Information” shall be understood to mean any information that reveals (a) consumer’s Social Security or other identification number; (b) a consumer’s account log-in, debit card or credit card, any required security or access code; (c) consumer’s geolocation; (d) consumer’s racial or ethnic origin religious or philosophical beliefs, or union membership; (e) the contents of a consumer’s mail, email, or text messages, unless the business is the intended recipient of the communications; and (f) the consumer’s genetic data.

Although it is our preference to minimize the collection of Sensitive Personal Information, it is possible that we may collect or may have collected, within the past 12 months, the categories of Sensitive Personal Information about consumers that are indicated in the chart below. The Sensitive Personal Information we collect may vary depending on the nature of your interactions with us and may not include all of the examples listed.

Sources of Personal Information

Information You Provide: Personal Information may be obtained directly from you. If you submit Personal Information to use about others, then you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

Information Collected Automatically: We may use various tools and technologies like cookies and web server logs to collect information automatically on the Services. This information may include IP addresses, device identifiers, browser characteristics, operating system details, internet service provider details, language preferences, referring URLs, time and length of visits, and pages viewed.

Information Collected from Other Parties: Personal Information may also be obtained from other parties authorized to provide the information, from activity on the Services, and from other parties with whom we work, such as service providers, business partners, advertisers, advertising technology providers, advertising servers, data analytics providers, and social network. For example, if you choose to link your social media or other third-party accounts to our Services, we may obtain your Personal Information from these sources.

Usage Data and Websites Activity

We automatically collect and analyze information in connection with the actions you take on the Websites and in connection with the Servies (“Usage Data”) to improve the Websites, Services, and user experience. This Usage Data may be associated with your username and profile. The lawful bases for processing your Personal Information in this manner include Spectrum’s legitimate interest, compliance with legal obligations, and the performance of a contractual relationship with you.

How We Use the Information We Collect

We may use your Personal Information in the following circumstances:

• Where we need to comply with a legal obligation
• Where it is necessary for our legitimate interests (or those of a third party) and your interested and fundamental rights do not override those interests
• Where it is needed in the public interest or for official purposes
• With your consent

Disclosure of Information

This chart shows the categories of Personal Information that may have been disclosed to our service providers and contractors for commercial or business purposes.

In addition to other purposes for collection, use, and disclosure of Personal Information described in this Privacy Policy, we may collect, use, and disclose Personal Information as required by law, regulation, or court order; to respond to governmental and/or law enforcement requests; to identify, contact, or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense, or declaration in a case or before jurisdictional and/or administrative authority, arbitration, or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may disclose Personal Information to other parties in connection with the sale, assignment, merger, or reorganization.

Text Messages

If you provide your mobile phone number to us, we may ask for your consent to receive text message alerts from us containing product/service, event, or promotional information in a text or SMS message (“Text Messages”). The Text Message program allows users to receive SMS/MMS mobile messages by users affirmatively opting into the program. Your consent to receive Text Messages is not required to purchase services from us.

Cookies and Online Tracking Technologies

Spectrum may use cookies and other third-party tracking technologies to collect general and personally identifiable information about visitors to the Websites. The information collected is used to improve the experience of the Websites and Services.

Your Choices About Your Information

We strive to provide you with the appropriate choices regarding the Personal Information you provide to us. We have created the following mechanisms to provide you choices and control over your information.

• Other Uses: We will not collect, use, or disclose your Personal Information in any ways or for any purposes that are materially different from those set forth herein. However, if we do wish to do so in the future, we will provide notice and an opportunity to opt-out of such proposed collection, use, or disclosure.
• Promotional or Marketing: You can opt-out of receiving marketing or promotional communications from us or third parties by using the “Unsubscribe” feature at the bottom of each email or “STOP” in text messages.
• Cookies: You have the ability to disable or opt-out of certain cookies by going to the Cookie Preferences of your browser. Also, you can find out more information about how to change your browser cookie settings at www.allaboutcookies.org. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Websites or Services may not work if you delete or disable cookies.
• Internet-based Advertising: In some instances, you can opt-out of receiving internet-based advertising from us, third-party advertisers, and other networks. We do not control third parties’ collection or use of your information to serve internet-based advertising.
• Analytics Providers: We may use third-party web analytics services to measure the effectiveness of our advertising and determine how visitors use the website. These services providers’ tools, including cookies, allow us to collect information such as the state and zip code from which our visitors come and the IP addresses of our visitor’s computers.

Your Legal Rights

You have the right to:

• Request a copy of the Personal Information and Sensitive Personal Information we hold about you;
• Request that inaccurate information about you be corrected or deleted;
• Object to having your Personal Information and Sensitive Personal Information processed;
• Request that we delete any and all Personal Information and Sensitive Personal Information we hold about you;
• Request that we restrict processing your Personal Information and Sensitive Personal Information;
• Request that you not be subject to automated decision-making, including profiling;
• Receive your Personal Information and Sensitive Personal Information in a structured, prevailing, and machine-readable form and/or have your Personal Information and Sensitive Personal Information transferred to another controller, where technically feasible; and
• Withdraw consent provided for processing Personal Information and Sensitive Personal Information.

To exercise rights or for any other questions related to this Privacy Policy, you may contact us using the form located at www.spectruminc.com/contact-us/. State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. Users in California, Nevada, Colorado, Virginia, Connecticut, and Utah may have additional rights as described below.

We may not accommodate a request to change information if we believe that the change would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights

“Shine the Light” Law

California residents with whom Spectrum has an established relationship have the right to request certain information with respect to any Personal Information Spectrum may have shared with third parties for their direct marketing purposes. Alternatively, Spectrum may provide a cost-free means to opt-out of such sharing. Spectrum has opted to provide you with a cost-free means to opt out of such sharing. If you do not want Spectrum to disclose your Personal Information to other companies for their marketing purposes, please contact us using the form at www.spectruminc.com/contact-us/.

For California residents under the age of 18 and registered users of the Websites and Services, California law provides that you can request the removal of content or information you posted on Websites. Any such request should be sent to us using the form at www.spectruminc.com/contact-us/ along with a description of the posted content or other information to be removed. Be advised, however, that applicable law may not permit us to completely or comprehensively remove your deleted content or for other reasons as set forth in this California law.

California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)

Under CCPA and CPRA, California residents variously may be able to exercise additional rights listed below in accordance with the laws of the State of California: Right to Correct, Right to Know, Right to Delete and Right to Opt Out.

Right to Correct. If you believe that Personal Information or Sensitive Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.

Right to Know. You have the right to request that we disclose the following information for the 12-month period prior to the request date. Consumer requests of this nature may be made no more than twice in a 12-month period. You have the right to know what Personal Information we have collected about you, which includes:

The categories of Personal Information we have collected about you, including:

• The categories of sources from which the Personal Information was collected
• Our business or commercial purposes for collecting, sharing, or disclosing Personal Information
• The categories of recipients to which we disclose Personal Information
• The categories of Personal Information that we shared, and for each category identified, the categories of third parties to which we shared that particular category of Personal Information
• The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.

Where required by law, we will provide this information in a portable and, if technically feasible, readily usable format.

Right to Delete Your Personal Information. You have the right to request that we delete Personal Information and Sensitive Personal Information we collected from you, subject to certain exceptions. Under the CCPA and CPRA, we may decline to delete your Personal Information under certain circumstances, for example, if we need the Personal Information to complete transactions or provide services you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes (including maintaining business records), to comply with law, or to exercise or defend legal claims. Note also that we are not required to delete your Personal Information that we did not collect directly from you.

Right to Opt Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale of your Personal Information and Sensitive Personal Information, and to request that we do not share your Personal Information and Sensitive Personal Information for cross-context behavioral advertising. To opt-out, please contact us using our form at www.spectruminc.com/contact-us/. Please note that opting-out of the sale of your information for interest-based advertising purposes does not mean you will stop seeing ads, including interest-based ads, and your information that was collected and sold prior to 90 days before your opt-out request may be further used and sold for interest-based advertising purposes

Alternatively, to submit a request to exercise any of your California privacy rights, please contact us using our contact form at www.spectruminc.com/contact-us/.

Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA and CPRA.

Rights Related to Automated Decision-Making. You have the right to opt out of automated decision-making, including profiling, that we use to evaluate certain personal aspects relating to your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA and CPRA, you also have the right not to receive discriminatory treatment by us.

You may use an authorized agent to submit requests. We do not discriminate against a user if they exercise any of the rights available under the CCPA or CPRA. However, we may charge a different price or rate, or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable data and permitted under the law. In addition, we may offer you financial incentives for the collection, sale and retention and use of your Personal Information and Sensitive Personal Information as permitted by the CCPA and CPRA that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional. You will have to affirmatively opt-in to the program and you can opt-out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs and/or their terms by posting notice on the program descriptions and terms linked to above so check them regularly. We will not fulfill a request pursuant to CCPA or CPRA unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected Personal Information and/or Sensitive Personal Information. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome.

We do not sell the Personal Information and Sensitive Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information or Sensitive Personal Information sales may opt-out of future sales at any time.

Please note that while CCPA and CPRA rights do apply to Personal Information collected from job applicants and employees, this policy only covers those individuals in their capacity as users of our website. Separate privacy disclosures will be made to these parties during their application and onboarding processes.

Your Nevada Privacy Rights

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to www.spectruminc.com/contact-us/.

Your Colorado, Connecticut, and Utah Privacy Rights

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

• Confirm whether we process their Personal Information.
• Access and delete certain Personal Information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their Personal Information, taking into account the information's nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights please submit a request to www.spectruminc.com/contact-us/. To appeal a decision regarding a consumer rights request previously denied by us which you believe we denied in error, you may appeal for reconsideration of your request using our email at legal@spectruminc.com.

Your Virginia Privacy Rights

This section provides information specific to Virginia consumers, including how to exercise their rights under the Virginia Consumer Data Protection Act (“CDPA”). Terms defined in the CDPA that are used in this section shall have the same meaning as in the CDPA.

Additional Disclosures of Personal Data

Targeted Advertising. We may process your Personal Data for targeted advertising (as the term is defined in the CDPA). To opt out, please contact us at www.spectruminc.com/contact-us/.

Sales of Personal Data. We do not sell (as the term is defined in the CDPA) your Personal Data.

Your Virginia Privacy Rights

Right to Access and Data Portability. You have the right to confirm whether we are processing your Personal Data, to access your Personal Data, and to obtain a copy of Personal Data you provided to us in a portable format.

Right to Correct. You have the right to request that we correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and our purposes for processing it.

Right to Delete. You have the right to request that we delete your Personal Data.

Right to Opt Out. You have the right to opt out of the following uses of your Personal Data: (a) targeted advertising; (b) the sale of Personal Data; and (c) profiling in furtherance of decisions that produce legal or similarly significant effects.

Right to Appeal. Sometimes we are unable to process requests relating to your Personal Data, in which case, your request will be denied. If you are a resident of Virginia whose privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request using our email at legal@spectruminc.com.

Please note that if you make a privacy rights request, we will retain the Personal Data submitted in connection with your request for recordkeeping purposes.

Transfer of Information to the United States

The Websites are owned and operated by Spectrum in the United States. If you are located outside the United States, please be aware that information we collect, including Personal Information and Sensitive Personal Information, may be transferred to, processed, and stored in the United States. By using the Websites or Services, or providing us with any information, you consent to the transfer to and the processing, and storage of your information in the United States. Please be aware that the United States and jurisdictions other than the one in which you are located may not provide the same level of data protection as considered adequate in your country. Note also that your Personal Information and Sensitive Personal Information may be available to the US Government or its agencies under legal process in the United States.

Children’s Privacy

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any Personal Information or Sensitive Personal Information to the Websites. We do not knowingly collect Personal Information or Sensitive Personal Information from children under 13 on the Websites. If you are under 13, do not use or provide any information on the Websites or through any of its features, register on the Websites, make any purchases through the Websites, use any of the interactive or public comment features of this Websites, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name, social media nametag, or username you may use. If we learn we have collected or received Personal Information or Sensitive Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us using our online form at www.spectruminc.com/contact-us/.

You must be 18 years of age or older to purchase any content, product, or service offered by us through the Services. We do not otherwise knowingly collect Personal Information and Sensitive Personal Information from anyone under the age of 18 without permission. California residents under 16 years of age may have additional rights regarding the collection and sale of their Personal Information or Sensitive Personal Information. For more information, please see the “Your California Privacy Rights” Section above.

Links to Third Party Materials

The Websites or Services may include links to websites or other online properties that are not under our control. Spectrum shall have no responsibility or liability for the content or privacy practices of any such linked website or any link or linking program at any time. If you click on a link on our Website and link to a third party’s website, then this Privacy Policy will not apply to your Personal Information and Sensitive Personal Information collected on that third party’s website and you must read the privacy policy on that website to see how your information will be handled.

Social media widgets or tools may appear on our Websites or Services. Your interaction with and use of these widgets or tools will be governed by the terms of use and privacy policy of the applicable social media provider (e.g., Facebook).

Changes to Our Privacy Policy

We may update this Privacy Policy to reflect changes in our privacy practices. We will provide notice of any such changes (including when they will take effect) in accordance with applicable law. The changes will go into effect on the Effective Date shown in the revised Privacy Policy. Your continued use of our Websites or Services constitutes your consent to the revised Privacy Policy, so please check the Privacy Policy periodically for updates. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, you can contact us as follows:

Spectrum Communications & Consulting LLC.
120 E Palmetto Park Road
Suite 205
Boca Raton, FL 33432
Email: legal@spectruminc.com