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Spectra Technology Privacy Policy
Qubol SA doing business as (dba) Spectra Technology respects your privacy. Spectra Technology and
its affiliates (“Spectra” or the “Company”) offer tracking, marshalling, GPS geolocation and safety
services to users of the Sirius Rally Tracker and e-Flag Racer systems (the “Systems”) and/or users of
Sirius Rally Tracker and e-Flag Racer applications and websites (the “Applications”) (collectively
referred to as the “Services”). When you use our services, you’re trusting us with your information. We
understand this is a serious responsibility and work hard to protect your information.
In this Privacy Policy, the term “personal information” means information which you provide to us
which personally identifies you, such as your name, email address, etc, andas well as your location and
race information or other data which can be reasonably linked to such information by Spectra.
By using the Systems you consent to allowing information about your device and app usage to be sent
to our servers, as well as third parties. Location information is used by us and race control officials to
monitor your position, speed and safety status while driving during an event. We do not use the
information beyond these purposes.
This Privacy Policy is meant to help you understand what information we collect, why we collect it,
and how you can update, manage, and delete your information.
Privacy concerns reports
If you have any questions about this Privacy Policy, or if you believe that your privacy has been
compromised in the course of using the Services, or if you have other requests, responses, questions
and complaints, please contact Spectra at: info@spectra-tec.com.
User Accounts & Accessing the Services
Please note that when you use our Services, Spectra will set up an account (the “Account”). Spectra
will collect and use your information, including meta-data (as described below), in accordance with this
Privacy Policy.
Spectra will link all of your information with your registered Account. This includes information
received from all devices and browsers which you have chosen to sign in; your Account and
information associated with your Account will be visible only to Spectra and the third parties (the
“institutions”) in whose events you are participating in any role (competitor, co-pilot, race official,
service person, etc); and when using the Services, your approximate location and other information you
may choose to contribute will be visible to the users associated with the institution organizing,
promoting, marshaling, servicing and/or controlling the event.
Your login details are your responsibility. You are fully accountable for any use or misuse of your
Account and personal details as a result of conveying your login details to someone else. You must
maintain your login details in absolute confidentiality and avoid disclosing them to others. If you set a
password, make sure that you change your password frequently and at least once every six months.
Information that is being collected
Spectra collects information to provide better services to all its users.
Information you provide to us
• Account Information: information required when setting up an Account, such as your name or
email address. Spectra will explicitly indicate the fields for mandatory completion. If you do not
enter the requisite data in these fields, you may not be able to register your Account.
• Your phone number. Your phone number will be used to verify your account.

Information we collect as you use our services
• We collect information about your activity in the Services, which we use to provide you with
the Services of Spectra. The activity information we collect may include detailed location and
course information. Location and course information is collected for example in the form of
GPS signals, combined with a time-stamp, and other information from sensors and receivers on
or around your device, on which the Application is installed and activated. This location and
course information is saved to a course history of all of the events run while using the
Application, which will be saved for a limited time for marshaling purposes and later deleted
once the institutions have no use for the data with regards to official decisions concerning an
event. The types of data we collect is only data relevant to official decisions for race marshals
concerning an event, such as position, speed, times, messages received and/or sent and other
details. We may collect information about your location and course also while you are using the
app in the background, in order to be able to marshal your location and course information
during an event.
Why Spectra collects data
Spectra may use information collected from or provided by you for the following purposes:
Provide our services
We use your information to deliver our services, specifically everything related to race marshaling and
for the enhancement of the competitors safety.
Maintain & improve our services
We also use your information to ensure our services are working as intended, such as tracking outages
or troubleshooting issues you report to us. And we use your information to improve the service or to
develop new features or services.
Measure performance
We use data for analytics and measurement to understand how our services are used.
Communicate with you
We also use your information to send you updates, notices, announcements, users’ requests and
additional information related to the Services (including through push notifications, email address and
SMS); we may also use your information to conduct surveys and questionnaires; and if you contact
Spectra we may keep a record of your request in order to help solve any issues you might be facing.
To protect Spectra , our users, the public and for Legal reasons
We may also use and process your information, using different technologies to the following purposes:
• To enforce the Terms of Use or Privacy Policy;
• To contact you when Spectra believes it to be necessary;
• To comply with any applicable law and assist law enforcement agencies under any applicable
law, when Spectra has a good faith belief that Spectra’s cooperation with the law enforcement
agencies is legally mandated or meets the applicable legal standards and procedures;
• To detect abuse and illegal activity; to detect and prevent fraud, misappropriation,
infringements, identity theft and other illegal activities and misuse of the Services;
• To handle breakdowns and malfunctions;
• To take any action in any case of dispute, or legal proceeding of any kind between you and the
Services, or between you and other users or third parties with respect to, or in relation with the
Services;
• For purposes provided under this Privacy Policy and Terms of Use;

• To help improve the safety and reliability of our Services. This includes detecting, preventing,
and responding to security risks, and technical issues that could harm Spectra, our users, or the
public;
• To create aggregated and/or anonymous data (where such data does not enable the identification
of a specific user). See “How does Spectra use aggregated information”, below;
We’ll ask for your consent before using your information for a purpose that isn’t covered in this
Privacy Policy.
Sharing your information
Personal information that you share
The Services are based on a group of users privately sharing information with Spectra and with other
members of that group.
In particular, users may choose to share personal information such as name, picture, their location
information, reports and other files. This information may be shared either directly to the Services and
to some institution’s users. This information may also be shared via third party services (such as
streaming services) which interact with the Services upon such institutions’ choice.
You will engage in communications through the Services. However any communication that you
choose to have is neither private nor confidential and you should expect that it may be made public and
known to others.
Communications you engage in might be posted publicly along with your user name and other personal
information. Therefore, you must exercise caution and common sense when engaging in
communications. In any event, neither your email address nor phone number will be publicly visible to
others.
We, at Spectra, take great measures to provide you with the best experience you can have while using
the Services. However, Spectra has no control over the conduct of any user and disclaims all liability in
this regard. Users are advised to carefully and thoroughly consider whether or not to make public or
available any information and carefully examine all necessary details related to any communication
with other users prior to any engagement or communication being made.
Participating in any institutions or user’s activities as a result, directly or indirectly, from using the
Services, is entirely at your own risk. Spectra is not a party to any agreement entered into between the
users in any circumstances. The user has the sole and ultimate responsibility regarding compliance with
all laws, regulations or any other duty. We do not accept any liability for any loss, damage, cost or
expense that you may suffer or incur as a result of or in connection with your participation in any
activity or event initiated, held or conducted by a user or a third party nor in connection to any
agreement between the users or third parties, including any activity or event related in any way, directly
or indirectly, the Services or the use thereof.
When Spectra shares your information
Spectra does not sell, rent or lease your personal information to third parties.
Spectra will not share your personal information with others, without your permission, except for the
following purposes and to the extent necessary in Spectra’s good-faith discretion:
• As necessary for the facilitation and operation of the Services;
• If Spectra reasonably believes that you have breached the Terms of Use or is investigating
potential breach of the Terms of Use, or believes that you abused your rights to use the Services,
or performed any act or omission that Spectra reasonably believes to be violating any applicable
law, rules, or regulations. Spectra may share your information in these cases, with law enforcement agencies and other competent authorities and with any third party as may be
required to handle any result of your wrongdoing;
• If Spectra is required, or reasonably believes that it is required by law to share or disclose your
information;
• In any case of dispute, or legal proceeding of any kind between you and Spectra, or between
you and other users with respect to, or in relation with the Services;
• In any case where Spectra reasonably believes that sharing information is necessary to protect
against harm to the rights, property or safety of Spectra, our users, or the public as required or
permitted by law, including to prevent imminent physical damage or damage to property;
• To detect, prevent, or otherwise address fraud, security, or technical issues;
• If Spectra organizes the operation of the Services within a different framework, or through
another legal structure or entity, or if Spectra is acquired by, or merged into or with another
entity, or if Spectra enters bankruptcy, provided however, that those entities agree to be bound
by the provisions of this Privacy Policy, with respective changes taken into consideration;
• To collect, store, hold and manage your personal information through cloud based or hosting
services or a third party or a party affiliated or connected to Spectra, as reasonable for business
purposes;
• Spectra may also share personal information with companies or organizations connected or
affiliated with Spectra, such as subsidiaries, sister-companies and parent companies;
• Personal information may also be shared with Spectra’s trusted partners and service providers to
process it for us, based on our instructions and in compliance with this policy and any other
appropriate confidentiality and security measures. For example, we may use service providers
to help us with customer services.
Visibility
Please note that your username and some other information will be visible to others. Note that your
username will be included along with any communications you engage in. It will therefore be visible to
others.
Controlling your personal information
You can always review and update certain information by visiting your Account & Login settings (such
as your phone, name, photo and more).
If you find that the information associated with your Account is not accurate, complete or updated, then
you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or
outdated information may prevent you from setting up an Account and impair the ability to provide you
with Services.
Deleting your information
If you would like us to delete your Account information, please send a request to info@spectra-tec.com
On receiving such a request, Spectra will use reasonable efforts to delete such information, however
please note that information may not be deleted immediately from our back-up systems. We aim to
initiate the deletion process immediately after your request. As with any deletion process, things like
routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the
processes and time frames defined in this policy. We maintain systems designed to detect and remediate
such issues.
How Spectra retains data we collect

Some data you can delete whenever you like, some data is deleted automatically, and some data we
retain for longer periods of time when necessary.
• Information retained until you remove it - such as name, email address and other account
related information. We’ll keep this data in your Spectra Account until you choose to remove it
and/or update it.
• Data that expires after a specific period of time - in some cases, you don’t need to actively
delete your information as we set retention timeframes based on the reason for the data’s
collection, such as course information after particular events.
• Information retained until your Account is deleted - we may keep some data for the life of your
Account if it’s useful for helping us understand how users interact with our features and how we
can improve our services.
• Information retained for extended time periods for limited purposes - sometimes business and
legal requirements oblige us to retain certain information, for specific purposes, for an extended
period of time. Reasons we might retain some data for extended periods of time include:
security, fraud & abuse prevention, financial record-keeping, complying with legal or regulatory
requirements, ensuring the continuity of our services, communications with Spectra.
How does Spectra use aggregated information?
Spectra may use anonymous, statistical or aggregated information (including anonymous location
information), in a form that does not enable the identification of a specific user, to properly operate the
Services, to improve the quality of the Services, to enhance your experience, to create new services and
features, including customized services, to change or cancel existing content or service, and for further
internal, commercial and statistical purposes.
Spectra may also use anonymous, statistical or aggregated information collected on the Services, in a
form that does not enable the identification of a specific user, by posting, disseminating, transmitting or
otherwise communicating or making available such information to users of the Services, to the
Services’ providers, partners and any other third party.
Cookies
Spectra may use cookies and similar technologies on the Services. Cookies are packets of information
sent by the Website’s servers to your web browser and then sent back by the browser each time it
accesses the Website’s servers.
Spectra may use cookies for various purposes, such as to save you the need to re-enter your username
and password each time you log in, to facilitate the use of the Website, to collect statistical information,
to verify information, and to customize the Website to your personal preferences and for information
security purposes.
Some of the cookies may expire when the session ends and you exit your browser. Other cookies are
saved on your computer’s hard drive. If you wish to block the Website’s cookies, then please use the
help button in your browser and follow the necessary instructions. However, bear in mind that disabling
cookies may complicate or even prevent your use of the Website, or certain features thereof.
Information security
Spectra considers information security to be a top priority. Spectra services are built with strong
security features that continuously protect your information. Spectra implements systems, applications
and procedures to secure your personal information, to minimize the risk of theft, damage, loss of
information, or unauthorized access or use of information. In addition, we restrict access to personal
information to Spectra employees, contractors, and agents who need that information in order to
process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be
disciplined or terminated if they fail to meet these obligations.
However, these measures are unable to provide absolute assurance. Therefore, although Spectra takes
great efforts to protect your personal information, Spectra cannot guarantee and you cannot reasonably
expect that Spectra’s databases will be immune from any wrongdoings, malfunctions, unlawful
interceptions or access, or other kinds of abuse and misuse.
Compliance & cooperation with regulators
We regularly review this Privacy Policy and make sure that we process your information in ways that
comply with it.
Data transfers
We store data on servers located around the world and your information may be processed on servers
located outside of the country where you live. Data protection laws vary among countries, with some
providing more protection than others. Regardless of where your information is processed, we apply
the same protections described in this policy.
When we receive formal written complaints, we respond by contacting the person who made the
complaint. We work with the appropriate regulatory authorities, including local data protection
authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with
you directly.
European requirements
If European Union (EU) or United Kingdom (UK) data protection law applies to the processing of your
information, we provide the controls described in this policy so you can exercise your right to request
access to, update, remove, delete, and restrict the processing of your information.
You also have the right to object to the processing of your information. We process your information
for the purposes described in this policy, based on the following legal grounds:
With your consent
We ask for your agreement to process your information for specific purposes and you have the right to
withdraw your consent at any time.
When we’re pursuing legitimate interests
We process your information for our legitimate interests and those of third parties while applying
appropriate safeguards that protect your privacy. This means that we process your information for
things like:
• Providing, maintaining, and improving our services to meet the needs of our users
• Developing new services and features that are useful for our users
• Understanding how people use our services to ensure and improve the performance of our
services
• Customizing our services to provide you with a better user experience
• Marketing to inform users about our services
• Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with
our services
• Protecting against harm to the rights, property or safety of Spectra, our users, or the public as
required or permitted by law, including disclosing information to government authorities
• Performing research that improves our services for our users and benefits the public
• Fulfilling obligations to our partners like developers and rights holders
• Enforcing legal claims, including investigation of potential violations of applicable Terms of
Service
When we’re providing a service
We process your data to provide a service you’ve asked for under a contract (including our terms of
use).
When we’re complying with legal obligations
We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to
legal process or an enforceable governmental request.
If you have questions, you can contact Spectra at: info@spectra-tec.com. And you can contact your
local data protection authority if you have concerns regarding your rights under local law.
Brazilian requirements
If Brazilian data protection law applies to the processing of your information, we provide the controls
described in this policy so you can exercise your right to:
• Obtain confirmation on whether we process your information
• Request access to, update, review, anonymise, and remove your information
• Object to or restrict the processing of your information
• Export your information to another service
We process your information for the purposes described in this policy, based on the following legal
grounds:
With your consent
Where we ask for your consent to process your information for specific purposes, you do not have to
provide your consent but where you choose to do so, you have the right to withdraw your consent at
any time. You also have the right to obtain information about the effects of not providing your consent
to processing for specific purposes.
When we’re pursuing legitimate interests
We process your information for our legitimate interests and those of third parties while applying
appropriate safeguards that protect your privacy. This means that we process your information for
things like:
• Providing, maintaining, and improving our services to meet the needs of our users
• Developing new services and features that are useful for our users
• Understanding how people use our services to ensure and improve the performance of our
services
• Customizing our services to provide you with a better user experience
• Marketing to inform users about our services
• Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with
our services
• Protecting against harm to the rights, property or safety of Spectra, our users, or the public as
required or permitted by law, including disclosing information to government authorities
• Performing research that improves our services for our users and benefits the public
• Fulfilling obligations to our partners like developers and rights holders
• Enforcing legal claims, including investigation of potential violations of applicable Terms of
Service
When we’re providing a service
We process your data to provide a service you’ve asked for under a contract (including our terms of
use).
When we’re complying with legal obligations
We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to
legal process or an enforceable governmental request. If you have questions, you can contact Spectra
at: info@spectra-tec.com.And you can contact your local data protection authority if you have concerns
regarding your rights under Brazilian law.
U.S. State Law requirements
Some U.S. state privacy laws like the California Consumer Privacy Act (CCPA) and Virginia Consumer
Data Protection Act (VCDPA) require specific disclosures for state residents. This Privacy Policy is
designed to help you understand how Spectra handles your information:
• We explain the categories of information Spectra collects and the sources of that information in
Information That is Being Collected.
• We explain how Spectra uses information in Why Spectra Collects Data.
• We explain when Spectra may disclose information in Sharing Your Information. Spectra does
not sell your personal information. Spectra also does not “share” your personal information as
that term is defined in the CCPA.
• We explain how Spectra retains information in How Spectra Retains Data We Collect. You can
also learn more about How does Spectra Use Aggregated Information. When Spectra
anonymizes data to protect your privacy, we maintain policies and technical measures to avoid
re-identifying that information.
State laws like the CCPA and VCDPA also provide the right to request information about how Spectra
collects, uses, and discloses your information. And they give you the right to access and correct your
information and request that Spectra delete that information. The VCDPA also provides the right to opt
out of certain forms of profiling and targeted advertising. Finally, the CCPA and VCDPA provide the
right to not be discriminated against for exercising these privacy rights.
We describe the choices you have to manage your privacy and data in Controlling your personal
information section. These controls allow you to access, review, update and delete your information. If
you have questions or requests related to your rights under the CCPA or VCDPA, you (or your
authorized agent) can also contact Spectra at info@spectra-tec.com. And if you disagree with the
decision on your request, you can ask Spectra to reconsider it by responding to the support team’s
email.
The CCPA requires a description of data practices using specific categories. The following table uses
these categories to organize the information in this Privacy Policy:

Categories of information we
collect
Business purposes for which
information may be used or
disclosed
Parties with whom information
may be disclosed
Identifiers and similar
information such as your name,
password, phone number and
email address, as well as unique
identifiers tied to the browser,
application, or device you’re
using.
Demographic information, such
as your blood type.
Internet, network, and other
activity information such as
locations; information about the
interaction of your apps,
browsers, and devices with our
services.
Geolocation data, such as may be
determined by GPS, IP address,
and other data from sensors or
receivers on or around your
device, depending in part on
your device and account settings.
Depending on these settings, this
may include precise location
data. For more information see
Information we collect as you
use our services.
Communications data, if you use
our services to send and receive
messages (learn more at
Information you create or
provide to us).
Inferences drawn from the
above.
Protecting against security
threats, abuse, and illegal
activity: Spectra uses and may
disclose information to detect,
prevent and respond to security
incidents, and for protecting
against other malicious,
deceptive, fraudulent, or illegal
activity.
Auditing and measurement:
Spectra uses information for
analytics and measurement to
understand how our services are
used, as well as to fulfill
obligations to our partners like
developers, or rights holders.
Maintaining our services:
Spectra uses information to
ensure our services are working
as intended, such as tracking
outages or troubleshooting bugs
and other issues that you report
to us.
Research and development:
Spectra uses information to
improve our services and to
develop new products, features
and technologies that benefit our
users and the public.
Use of service providers: Spectra
shares information with service
providers to perform services on
our behalf, in compliance with
our Privacy Policy and other
appropriate confidentiality and
security measures. For example,
we may rely on service providers
to help provide customer
support.
Legal reasons: Spectra also uses
information to satisfy applicable
laws or regulations, and
discloses information in response
to legal process or enforceable
government requests, including
to law enforcement.


Other people and or institutions
with whom you choose to share
your information.
Service providers, trusted
businesses, affiliates or persons
that process information on
Spectra’s behalf, based on our
instructions and in compliance
with our Privacy Policy and any
other appropriate confidentiality
and security measures.
Law enforcement or other third
parties, for the legal reasons
described in “Sharing your
information”.

 

Changes to this Privacy Policy
Spectra may from time to time change the terms of this Privacy Policy. Substantial changes will take
effect 30 days after Spectra has posted a System message to users notifying them of changes to the
Privacy Policy.
Other changes will take effect 7 days after their initial posting on the System. However, if Spectra
amends this Privacy Policy to comply with legal requirements, the amendments will become effective
immediately upon their initial posting, or as required.
You agree to be bound by any of the changes made in the terms of this Privacy Policy. Continuing to
use the Services will indicate your acceptance of the amended terms. If you do not agree with any of
the amended terms, you must avoid any further use of the Services.
Last modified: November 6, 2023

 
     
     
 
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