Introduction  

We appreciate your confidence in our Company in relation tothe handling of voluntarily provided data. Therefore, we perceive it as our duty to handle and store your data carefully in the safest and professional waypossible. We strive to use the collectedinformation only where applicable to achieve our legitimate business interests.

SPECTRUM Talent Delivery, Inc. – Datenschutz (“Company”,“we”,“our”,or “us”)respect your privacy and is committed to protecting it through our compliance with this policy (“Privacy Notice”).

This Privacy Notice describes the types of information we may collect from you or that you may provide when you visit the website www.spectrum-ag.com(our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Notice Applies To Information We Collect

• onthis Website.
• inemail, text, and other electronic messages between you and this Website.

This Privacy Notice Does Not Apply To Information Collected By

• us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Notice. This Privacy Notice may change from time to time. Your continued use of this Website after we make changes isdeemed to be acceptance of those changes, so please check the Privacy Notice periodicallyfor updates.

These Terms were last updated on May 8, 2018.

Information We Collect About You and How We Collect It  

We collect several types of information from and about users of our Website, including information:

• by which you may be personally identified, such as name, e-mail address, telephone number or any other identifier by which you may be contactedonline or offline (“personal information”);
• about your internet connection, the equipment you use to access our Website and usage details.

We Collect This Information

• directly from you when you provide it to us.
• automaticallyas you navigate through the site. Information collected automatically may include usage details, IP addresses or other tracking technologies.

Information You Provide to Us

The information we collect on or through our Website may include:

• informationthat you provide by filling in forms on our Website. Thisincludes information provided at the time of contacting us on our Website.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certaininformation about your equipment, browsing actions, and patterns, including:

• details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• informationabout your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• estimate our audience size and usage patterns.
• Storeinformation about your preferences, allowing us to customize our Website according to your individualinterests.
• speedup your searches.
• recognizeyou when you return to our Website.

The technologies we use for this automatic data collection may include:

• cookies(or browser cookies); a cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this settingyou may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• flashcookies; certainfeatures of our Website may use localstored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managedby the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• web beacons; pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information  

We use information that we collect about you or that you provide to us, including any personal information:

• to respond to your inquiry
• to notify you about changes to our Website or any products or services we offer or provide.

Disclosure Of Your Information  

We do not share, lease, sell or otherwise reveal data, which has been collectedthrough visiting our websites, to third parties, except as,described in applicable laws.

Under certain circumstances, user data may be passed on to legal or supervisory authorities or may be made available to them by order. Furthermore, data might be passed on to our professional advisors under dutyof professional secrecy or within the scope of mandatory national provisions of law, by decisionof a court or administrative authority.

Under certain circumstances, we may use your personalinformation to the extent necessary to promote our marketing, for use in customer management and fortraining purposes. Furthermore, we may use data to ensure the protection of our data.

We may disclose personal information that we collect oryou provide as described in this Privacy Notice:

• to our subsidiaries and affiliates.
• tocontractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

We do not intend to send your data to third parties; however, the Company reserves the right to exchange data with subsidiaries, associated companies, contractors and temporary employees.

The Company reserves the right to pass on customer data to other legal entities within the context of business transactions, such as spin-offs, takeovers, mergers, restructuring and/orliquidations. With your permission, yourpersonalinformation can be exchangedwith specialbusiness partners.

We May Also Disclose Your Personal Information

• To comply with any court order, law, or legal process, including responding to any government or regulatory request.
• To enforce or apply our Website’s terms of use and other agreements, including for billing and collection purposes.

Choices About How We Use and Disclose Your Information

We strive to provide you with choicesregarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising

You can set your browser to refuse all or some browser cookies,or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

You may also send us an email at info@spectrum-ag.comrequest access to, correct or delete any personal information that you have provided to us. We cannot deleteyour personal information except by alsodeletingyour user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the informationto be incorrect.

Your California Privacy Rights  

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certaininformation regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@spectrum-ag.comor write us at: SPECTRUM Talent Delivery, Inc. – 5 Water St., Unit A, Newburyport, MA 01950.

Our websites may contain links to websitesof other providers. External websites linked herein are not covered by the above-mentioned data protection declarations.

Third-party use of contact information or similar information published by the Company, such as emails, addresses, telephone or fax numbers, is prohibited if express permission is not granted. We reserve the right to take legal action against anyone sending spam emails.

Notification Of Changes

We will inform you by email requesting yourpermission,if we plan to use your personalinformation in different ways than stated at the point of collection or if we are legally obliged.

In addition, we herebyinform you that any substantial changes of our data protection provisions, which do not affect personalinformation already stored in our database, will be published as a notification on our website.

In the event thata notificationof change is sent by mail, users who have declared that they would like to be informed about such developments will also receive a corresponding email notification. The email notification will provide you with information about changes made regarding our data protection provisions.

Collecting And Processing Personal Information

With the exception ofthe IP address, personal information is only saved if you have voluntarily provided us with this information, e.g.,through registration, a survey, or to implement a contract.

Deleting Personal Information

Personal information will immediately be deletedonce legal or business process-related retention periods have expired,unless there is a legitimate interest that justifies continued storage.

Security

The Company deploys technical and organizational security measures to protect your data against all attacks, losses, manipulations, destructions and against being accessed by unauthorized persons.

Right To Information

Upon request, the Company will inform you in writing, as soon as possible and in accordance withapplicable law, if we have saved any of your personalinformation. If you are registeredas a user, we also offer the option of viewing the data yourself and if applicable, to delete or amend it. If any incorrect information is saved, despite our best efforts to ensure that data is up-to-date and accurate, we will correct the data upon your request.

Children Under the Age of 13  

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features, provideany information about yourself to us, including your name, telephone number, or email address. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@spectrum-ag.com.

Contact Information  

To ask questions or comment about this Privacy Notice and our privacy practices, contact us at:

SPECTRUM Talent Delivery, Inc. – Data Protection
5 Water St., Unit A
Newburyport, MA 01950
info@spectrum-ag.com
(833) SPCTRUM | (833) 772-8786