Privacy Policy
The website https://spectra-am.com/ is operated by Spectra Asset Management Limited (“we” or “us”) and we are a “data controller” for the purposes of the EU General Data Protection Regulation 2016/679. This means that we are responsible for, and control the processing of, your personal information.
This privacy policy relates to your use of our website. Please note that any other websites linked to by our website are not governed by this privacy policy.
We take your privacy very seriously and we ask that you read this privacy policy carefully as it contains important information on what personal information we collect about you, what we do with that information, and the situations in which we may share your information with other businesses.
It also explains how to contact us if you have any complaints or queries about how we use your personal information and how to exercise your rights in this respect.
We will collect your personal information for purposes set out below.
We will only process your personal information where we have a lawful basis for doing so. In general, the lawful basis will be for compliance with our legal obligations and for the purposes of pursuing our legitimate interests as a business.
We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided, unless you have asked us not to.
From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.
You can opt out of receiving emails from us at any time using the unsubscribe function contained within the communication or by emailing or writing to us using the contact details below.
Please see ‘The right to ask us to stop contacting you with direct marketing’ below for further information.
We collect personal information about you when you register with us, contact us or when you submit a response to an online questionnaire on our website.
We may collect the following personal information:
Please note that we do not collect any information in relation to your payment information, such as credit/debit card details.
We shall retain your personal information in accordance with our internal retention procedure, such procedure based on our regulatory obligations to (without limitation) the Abu Dhabi Global Market and good market practice.
If you have any concerns or queries in this respect, please contact us using the details noted below.
To protect your information, Spectra Asset Management Limited has policies and procedures in place to make sure that only authorised personnel can access the information, that information is handled and stored in a secure and sensible manner and all systems that can access the information have the necessary security measures in place. To achieve this, all employees, contractors and sub-contractors have roles and responsibilities defined in those policies and procedures.
To make sure all employees, contractors and subcontractors understand these responsibilities they are provided with the necessary training and resources they need.
In addition to these operational measures, we also use a range of technologies and security systems to reinforce the policies.
To make sure that these measures are suitable, vulnerability tests are run regularly. Audits to identify areas of weakness and non-compliance are routinely scheduled.
Additionally, all areas of the organisation are constantly monitored and measured to identify problems and issues before they arise.
In order to process any of the requests listed below, we may need to verify your identity for your security. In such cases your response will be necessary for you to exercise this right.
The right to access information we hold about you
At any point you can contact us to request that the information we hold about you as well as why we have that information, who has access to the information and where we got the information. Once we have received your request we will respond within 30 days.
The right to correct and update the information we hold about you
If the data we hold about you is out of date, incomplete or incorrect, you can inform us and we will ensure that it is updated.
The right to have your information erased
If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or tell you the reason why it cannot be deleted.
The right to object to processing of your data
You have the right to request that Spectra Asset Management Limited stops processing your data. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue. If data is no longer processed, we may continue to hold your data to comply with your other rights.
The right to ask us to stop contacting you with direct marketing
You have the right to request that we stop contacting you with direct marketing. In order to process your request we may need to verify your identity for your security.
The right to data portability
You have the right to request that we transfer your data to another controller. Once we have received your request, we will comply where it is feasible to do so.
The right to complain
You can make a complaint to us by contacting us via compliance@spectra-am.com (for the attention of Nico Van Bockstal, Compliance Officer) or to the data protection supervisory authority – in the Abu Dhabi Global Market, this is the Office of Data Protection, at data.protection@adgm.com.
Consent
In those cases where we need your consent to hold your information, we will ask you to check a box on any form requiring consent. By checking these boxes you are stating that you have been informed as to why Spectra Asset Management Limited is collecting the information, how it will be used, for how long it will be kept, who else will have access to it and what your rights are as a data subject.
Sharing your information
Where necessary to fulfil our obligations to you, Spectra Asset Management Limited may pass your details to third parties where this is necessary for the functioning of our product. These third parties include Google Analytics.
Use of cookies
A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website.
We use cookies on this website to:
In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a product or service you have requested.
Consent
If you visit our website when your browser is set to accept cookies, we will interpret this as an indication that you consent to our use of cookies and other similar technologies as described in this privacy policy. If you change your mind in the future about letting us use cookies, you can modify the settings of your browser to reject cookies or disable cookies completely.
Description of cookies
The table below provides some information on the cookies which we use on our website:
Cookie Name: cookie_notice_accepted
What it does: Collect information about how visitors use our website.
Why is it used: This enables us to personalise our content for our visitors.
How long it lasts: 14 days
How to turn off cookies
If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website.
When contacted with an enquiry, Spectra Asset Management Limited will hold the entity name and contact details only for the purposes of handling the enquiry.
The online forms are subject to the same cookies and tracking as the rest of the website (see the above section “Cookies and Tracking” for more information).
Calls made to us may be recorded to protect the interests of all parties.
If you have any queries about this privacy policy, need further information or wish to lodge a complaint you can use the details below to contact the relevant party.
Attention: Nico Van Bockstal, Compliance Officer
Email: compliance@spectra-am.com
Address: Unit 13 (A), Al Khatem Tower, Abu Dhabi Global Market Square, Al Maryah Island, Abu Dhabi, UAE
We may change this privacy policy from time to time. You should check this privacy policy occasionally to ensure that you are aware of the most recent version that will apply each time you access the website.