Privacy Policy for Spectrum Nodes
Effective Date: April 25, 2025.

1. Introduction
Simply VC Limited (“we”, “our”, or “us”) is committed to protecting your personal data and respecting your privacy rights in accordance with the General Data Protection Regulation (GDPR) and applicable data protection laws.
This Privacy Policy explains how we collect, use, store, and share your personal information when you visit our website https://spectrumnodes.com or interact with our services. It also explains your rights and how you can exercise them.
2. Who We Are
- Data Controller: Simply VC Limited
- Registered Address: Triq Dragunara, Aragon House, St. Julians, Malta
- Website: https://spectrumnodes.com
- Contact Email: [email protected]
- Support Form: https://spectrumnodes.com/support
3. What Personal Data We Collect
We collect personal data under two categories:
a. Voluntarily Provided Information
- Name, email address, phone number
- Billing address or postal address (e.g., for invoicing or contract delivery)
- Social media handles if you interact with us publicly
b. Automatically Collected Information
- IP address, browser type, device type, operating system
- Pages visited, time spent, referring URLs, and error logs
- Location data (if shared by your device/browser)
c. Cookies and Tracking Technologies
We use cookies and similar technologies to enhance your experience. You can view our full Cookie Policy on our website.
4. Legal Basis for Processing
We only process your personal data where legally permitted:
- Consent: For email marketing, cookies, and optional services. You may withdraw consent at any time by contacting us at [email protected] or via the unsubscribe link in our communications.
- Contract: To respond to inquiries or provide services you've requested. For example, we may require your name, contact details, and billing address to issue legally valid invoices or provide agreed services.
- Legitimate Interests: For analytics, fraud prevention, business development.
- Legal Obligation: To comply with applicable laws or authorities.
5. How We Use Your Personal Data
We process your data for purposes including:
- Providing and managing access to our website and services
- Responding to queries and user support requests
- Sending newsletters and marketing communications (only with consent)
- Issuing invoices and fulfilling our financial and contractual obligations
- Analytics, optimization, and website improvement
- Legal and compliance purposes
6. How We Store and Protect Your Data
Your data is stored securely using modern technical and organizational measures to prevent unauthorized access, disclosure, alteration, or destruction. While we strive for maximum protection, no method is 100% secure.
We retain personal data only as long as necessary to fulfill the purposes outlined or as required by law. Data is deleted or anonymized when no longer needed.
7. Your Rights Under GDPR
You have the right to:
- Access: Request a copy of the data we hold about you.
- Rectification: Correct inaccurate or outdated data.
- Erasure: Request deletion of your personal data.
- Restriction: Request limited processing of your data.
- Portability: Request transfer of your data in a readable format.
- Objection: Object to processing based on legitimate interests.
- Withdraw Consent: At any time, for any processing based on consent.
To exercise your rights, contact: [email protected].
8. Children's Privacy
Our services are not directed at children under 13. We do not knowingly collect data from anyone under 13 years of age. If we discover we have collected such data, we will delete it immediately.
9. Third-Party Services and International Transfers
We share data only with trusted third-party service providers for necessary operations. This may include international transfers to countries outside the EEA, which are safeguarded by Standard Contractual Clauses (SCCs) or equivalent mechanisms.
We ensure all third-party relationships are governed by Data Processing Agreements (DPAs) as required by Article 28 of the GDPR.
Key Third-Party Processors & DPAs
Provider | Purpose | DPA Link |
---|---|---|
Google Analytics | Web analytics | Google Analytics DPA (as per provider) |
Google Ads | Advertising | Google Ads DPA (as per provider) |
Facebook (Meta) | Retargeting / Social | Facebook DPA (as per provider) |
Twitter (X) | Advertising | Twitter/X DPA (as per provider) |
SendGrid | Transactional emails | SendGrid DPA (as per provider) |
Note: For actual DPA documents or links, please refer to each provider’s official site or request them via their support channels.
10. Automated Decision-Making and Profiling
We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.
11. Cookies
We use cookies and similar technologies for session management, analytics, and personalization. For full details and to manage your preferences, visit our Cookie Policy and cookie banner on our site.
12. Data Breaches
In the event of a personal data breach, we will notify affected individuals and the relevant supervisory authority within 72 hours, in accordance with Articles 33 and 34 of the GDPR.
13. Your Supervisory Authority
If you're not satisfied with how we handle your request or data, you have the right to lodge a complaint with your local Data Protection Authority. If you're located in Malta:
- Office of the Information and Data Protection Commissioner
- Website: https://idpc.org.mt
- Email: [email protected]
- Phone: +356 2328 7100
14. Business Transfers
If we undergo a business transaction (merger, acquisition, etc.), your personal data may be transferred as part of that deal, and this Privacy Policy will continue to apply to your data.
15. Updates to This Policy
We may update this Privacy Policy as needed to reflect changes in law or practices. Updates will be posted at this URL and dated accordingly. If legally required, we will seek your consent before applying changes that affect your rights.
16. Contact Us
If you have questions or requests related to this policy or your data:
- Data Protection Officer: Lewis Clifford
- Email: [email protected]
- Support: https://spectrumnodes.com/support