Privacy Policy

Effective Date: May 30, 2025
Last Updated: May 30, 2025

This Privacy Policy describes how HORIZENEX LTD, a company incorporated under the laws of the Republic of Cyprus with its registered office at 1065 Nicosia, Cyprus, Kranidioti & Pargas 9, Floor 1/Office 102. operating the website SpectraCams ("we", "our", "us", or the "Company"), collects, uses, discloses, and protects your personal data when you access and use the https://spectracams.com/ (the "Website").

This Privacy Policy applies to:

• Visitors to the Website ("Browsers");
• Registered users ("Members");

NOTE: The SpectraCams platform does not allow user-generated content uploads or model registrations. All content is delivered via a third-party API and moderated in accordance with applicable legal requirements and best practices.

1. Who We Are

HORIZENEX LTD is a limited liability company registered under Cypriot law. If you have any questions about this policy, contact us at: info@spectracams.com

2. How We Collect Personal Data

We collect personal data directly when you:

• Visit or browse the Website;
• Create an account;
• Contact us via email or support forms;
• Interact with Website features such as purchasing tokens, subscribing, or chatting with performers.

We also collect data automatically via cookies and similar technologies. See our Cookie Policy for details.

3. Consequences of Not Providing Personal Data

If you do not provide required personal data (e.g., email for registration or billing information for purchases), we may not be able to provide access to the Website or process transactions.

4. Categories of Personal Data We Process

From Browsers:

• Technical data: IP address, browser type, time zone, device details;
• Usage data: page visits, clicks, search activity, session times;
• Cookies and tracking data;
• Communication preferences and metadata.

From Members:

• All data above;
• Account information: username, password, email address;
• Purchase and transaction data: tokens bought, subscriptions, payment method (via third-party processor);
• Support inquiries and chat messages.

5. Special Categories of Data

We do not intentionally collect special categories of data (e.g., ethnicity, religion, sexual orientation). However, inferred preferences may result from usage data. Such data is only processed if explicitly consented.

6. Automated Data Collection

We use cookies and similar technologies to collect technical and behavioral data. Some of this data may be shared with analytics providers. For full details, refer to our Cookie Policy.

7. Purposes and Legal Basis for Processing

We process your data for the following purposes:

• To provide the Website and services (Contractual Necessity);
• To prevent fraud and abuse (Legitimate Interest);
• To comply with legal obligations (e.g., anti-money laundering);
• To send marketing with your consent (Consent).

8. Sharing Your Data

We may share data with:

• Our payment processors (e.g., SegPay, CentroBill);
• Technical infrastructure and analytics providers (e.g., Hotjar);
• Law enforcement or regulatory authorities as required;
• Legal and professional advisors.

We do not sell your personal data.

9. Financial Information

All financial data is processed through secure third-party providers. We do not store full payment card data on our servers. Transactions are encrypted and secured under PCI DSS standards.

10. Member and Performer Profiles

Users of SpectraCams must understand that any information submitted in their profiles may be publicly visible to other users on the platform. We discourage disclosing personal data that may reveal your offline identity. Users are solely responsible for the content they post on their profiles.

11. User Content

The SpectraCams platform does not allow users to upload or publish multimedia content such as videos, images, or audio files. Users are only permitted to:

• Select an avatar from a predefined set of system-generated icons (both free and paid);
• Provide limited personal information within their profile (e.g., gender identity: male, female, or other);

We do not offer any functionality for uploading custom images, videos, or documents.

Any text or data shared voluntarily by users in chats (public or private) is considered user-generated content and remains the sole responsibility of the individual who submitted it. While we do not actively monitor real-time conversations, we reserve the right to review and moderate content where necessary for compliance or safety purposes.

Important Notice: Users are advised to avoid disclosing personal information or sensitive data in any chat setting. We cannot control or reverse the sharing of such data once submitted in chat, and users assume full responsibility for any such disclosures.

12. Security of Your Personal Data

We take appropriate physical, electronic, and administrative measures to protect your personal data. These include encryption, secure transmission, and access controls. However, no system is 100% secure. You are responsible for keeping your account credentials confidential.

13. International Data Transfers

SpectraCams, operated by HORIZENEX LTD (Cyprus), may transfer personal data outside the European Economic Area (EEA), including to the U.S. All transfers comply with GDPR using Standard Contractual Clauses or other approved mechanisms.

14. Marketing Communications

We may send you marketing content if you have consented or where permitted by law. You can opt out at any time via the unsubscribe link or by emailing dpo@spectracams.com.

15. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by law. Upon expiry, we delete or anonymize the data unless further retention is required for legal or technical reasons.

16. Your Rights

You have the right to:

• Access your personal data
• Rectify inaccurate data
• Request deletion ("right to be forgotten")
• Restrict processing
• Object to processing (including for marketing)
• Data portability
• Withdraw consent at any time

To exercise your rights, email us at privacy@spectracams.com. We will respond in accordance with applicable data protection laws.

17. Profile Controls

You may control your profile visibility and media preferences through your account settings. Account deletion requests can also be submitted to our support team.

18. Your Choices

You may choose not to provide certain data; however, this may limit your access to some features. You can also control cookie collection via your browser settings. See our Cookie Policy for details.

19. Contacting Us

For questions about this Privacy Policy, contact us at:

• Email: dpo@spectracams.com

20. Complaints

If you believe your data has been mishandled, you can file a complaint with your local data protection authority. We encourage users to contact us first to resolve issues directly.

21. Minors

SpectraCams is not intended for individuals under 18 years of age or below the age of majority in their jurisdiction. We do not knowingly collect personal data from minors. Accounts found to belong to minors will be deleted immediately.

22. Third-Party Links

SpectraCams may contain links to third-party websites. We are not responsible for their privacy practices. Please review their privacy policies before providing any data.

23. Third-Party Login Options

Users may log in using third-party services (e.g., Google, Apple). We only access the data you authorize through these services and handle it in line with this policy.

24. California Consumer Privacy Act (CCPA)

California residents have rights under the CCPA, including:

• Right to know what personal data we collect
• Right to delete personal data
• Right to opt out of data sale (we do not sell personal data)
• Right to non-discrimination

To exercise these rights, contact dpo@spectracams.com.

25. Changes to This Policy

We may update this Privacy Policy. Updates will be posted on this page with the revision date. We encourage you to review it regularly.

26. Cookies

We use cookies to enhance user experience. Details are available in our Cookie Policy.

27. Disclaimer of Error-Free Performance

We strive to uphold this Privacy Policy but do not guarantee error-free performance. If we become aware of any policy breaches, we will promptly address them. We disclaim liability for incidental or indirect damages related to this policy.