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Spectorn Global Privacy Notice

Pre-publication draft — not yet in force. Public registration and payment are disabled until the contracting operator, launch countries, subprocessors and effective date are approved. This draft does not create a service contract.

Last reviewed: 3 November 2026

1. Scope and roles

This notice describes the intended processing for the Global Spectorn product contour. The contracting legal entity and its registered address have not yet been approved; that missing information is a release blocker, not an omitted legal detail.

For account administration, billing, security of the service and direct support, the future Spectorn operator will generally act as controller. For tenant prompts, responses, policies and security events processed on a business customer's documented instructions, Spectorn is intended to act as processor; the customer remains controller unless the facts require a different allocation. A data processing agreement will control where it applies.

2. Data intended to be processed

  • Account data: name, email address, credential verifier, organisation, role and account-security settings. If sign-in with GitHub, Google or Microsoft is enabled and used, Spectorn receives from that provider the account identifier, email address and name, and the provider processes the sign-in under its own terms. External sign-in is not part of the initial Global release.
  • Commercial data: plan, invoice and payment status, tax and receipt metadata. Spectorn must not store full payment-card credentials.
  • Technical data: IP address, user agent, session identifiers, request timing, service and security logs. For Global Free registration this also includes the user's eligibility declaration, a coarse RU network match / no match signal, classifier source date and bounded decision/reason. Spectorn does not send the client IP to DB-IP for this check: the licensed Country Lite data is downloaded periodically and evaluated locally. IP geolocation data by DB-IP.
  • Tenant content: prompts, model responses, policies and security findings only when a customer sends them to the service or explicitly enables payload logging. Raw payload logging is intended to be off by default.
  • Support data: correspondence and files deliberately supplied to support.

Special-category, highly sensitive, regulated or children's data must not be submitted unless a signed enterprise arrangement expressly authorises the data, route, controls and legal basis.

Account data and, for Global Free, the eligibility declaration are needed to open and secure an account and to provide the service; without them an account cannot be opened. Support data and optional settings are voluntary.

The intended purposes are to create and secure accounts; assess documented Global Free eligibility; provide, meter and support the service; route requests selected by the customer; detect abuse and security incidents; meet accounting and legal duties; and improve reliability using minimised operational data.

Where EU or UK data protection law applies, the expected bases are performance of a contract, legitimate interests in service security and fraud prevention, compliance with law, and consent only for genuinely optional processing. Processor activity is performed on the controller's documented instructions.

4. Model providers and subprocessors

When a tenant enables a model route, the request and response may be disclosed to the selected upstream model provider. That provider may apply its own terms where it acts as an independent controller. The product must show the provider and route before activation; selecting a route is not permission to send data that the customer has no right to disclose.

Security findings may also be delivered to a destination a business customer configures, such as its own SIEM, on that customer's instruction.

The production release must publish an accurate subprocessor register covering hosting, model, email, payment, support and monitoring providers, their purpose and processing location. Material changes require the notice promised in the applicable data processing agreement. The register is not approved yet, so public registration remains closed.

5. International transfers

Global processing may involve more than one country. Where the EU GDPR or UK GDPR restricts a transfer, the initiating party must use an applicable adequacy decision, approved contractual safeguards such as EU Standard Contractual Clauses or the UK Addendum/IDTA, and any required transfer assessment and supplementary measures. A statement of user consent is not used as a blanket replacement for those safeguards.

6. Retention

Account, commercial, security, eligibility and tenant-content retention must follow the approved production retention schedule and customer configuration. Data is kept only for the period necessary for the stated purpose, legal obligations and documented dispute/security needs. Backup expiry, deletion from active systems and any lawful hold must be stated in the final schedule before registration is opened.

7. Security and observability

Intended controls include transport encryption, least-privilege access, credential hashing, tenant isolation, audit events, rate limits, regular backups and incident response. The separate monitoring contour receives technical metrics and health signals; it must not receive raw prompts, responses or tenant identifiers. No security control makes a service immune from every incident.

8. Individual rights

Depending on applicable law, individuals may request access, correction, deletion, restriction, portability or objection, and may complain to a competent supervisory authority. Where processing relies on consent, the consent may be withdrawn at any time without affecting processing before the withdrawal. Identity must be verified proportionately. Requests about tenant content may need to be handled by the business customer as controller; Spectorn will assist as required by the processing agreement and law.

The Global Free eligibility decision is made automatically from the applicant's declaration and the coarse network signal described in section 2. Its effect is limited to access to the free service and its quota. An applicant may request human review, explain their situation and contest the decision. The reviewer must consider the possibility of travel, corporate networks, carrier routing and geolocation error and must not treat a coarse network match as proof of residence, nationality or deliberate evasion.

California disclosures and rights will be enabled if the final operator meets CCPA/CPRA applicability thresholds. Spectorn does not intend to sell personal information or share it for cross-context behavioural advertising; that claim must be revalidated against the final analytics, advertising and subprocessor configuration before publication.

9. Cookies and communications

Strictly necessary cookies may maintain sessions, security and preferences. Non-essential analytics or marketing cookies require the controls mandated in the launch country. Transactional security/service messages are separate from marketing; marketing requires a valid opt-in or other lawful basis and an effective unsubscribe mechanism.

10. Children

The service is intended for people aged 18 or older and is not directed to children. Accounts or content known to involve children require a separately approved legal and safety design.

11. Contact and changes

Until a monitored spectorn.ai legal mailbox is approved, pre-release privacy questions may be sent to security@spectorn.ai. The final notice must identify the contracting operator, effective date, privacy contact and any required EU/UK representative before registration opens.

Spectorn has not appointed a data protection officer: it does not systematically monitor individuals on a large scale, and processing special categories of data is not its core activity. If the operator is not established in the EU or the UK, its representatives there are named in this section before the service opens to users in the EU or the UK.

Material changes will be versioned and notified as required. Continued use will not be treated as consent where applicable law requires a different mechanism.