Draft — pending legal review. This document is a good-faith working draft published for transparency and review by counsel. It is not yet a final or binding legal agreement and may change. For a countersigned version or questions, contact legal@CloudSpectra.Ai.

Cloud Spectra Gateway is a self-hosted networking appliance: it is deployed by you, from the AWS Marketplace or a CloudFormation template, into your own AWS account and VPC. Production network traffic, configuration, logs, and TLS keys remain inside your AWS account. Cloud Spectra LLC operates no infrastructure in the Gateway data path and receives no telemetry from deployed Gateway appliances. This shapes most of what follows: for the Gateway line, most "customer data" in the traditional SaaS sense never reaches us.

CloudSpectra VPN Twin is different, and this policy covers it too. VPN Twin is a subscription product billed by the hour, so it necessarily reports a small amount of operational data to a Cloud Spectra control plane. Section 2.3 sets out exactly what that is. We do not receive the content of your traffic in either product.

1. Who we are

Cloud Spectra LLC ("Cloud Spectra", "we", "us") is the data controller for personal data we collect through this website and our sales process. Registered address: 1957 Limewood Dr, San Jose, CA 95132, USA. Privacy contact: privacy@CloudSpectra.Ai.

2. What we collect

2.1 Website visitors

2.2 Prospects and customers

2.3 The cost scanner (savings page)

Our optional read-only cost scanner uses an IAM role you create to read AWS Cost Explorer / billing aggregates in your account. It reads cost figures, not your network payloads. Results are returned to your browser; we describe its exact permissions on the Trust Center.

2.3 CloudSpectra VPN Twin subscribers

VPN Twin is billed on measured relay uptime, so unlike the Gateway line it does report to us. What we receive is limited to the following, and never includes the content of your network traffic:

Billing itself is handled by Stripe acting as merchant of record: Stripe is the seller of record for VPN Twin subscriptions and processes your payment details directly. We do not receive or store your card details.

3. How we use it

4. Legal bases (GDPR)

Where the EU/UK GDPR applies, we rely on: legitimate interests (running and securing our site, responding to B2B enquiries), performance of a contract (delivering and supporting a subscription you purchased), consent (non-essential cookies/embeds, where required), and legal obligation (tax/records).

5. Service providers / sub-processors

A current list is maintained here and in our DPA. We will give notice of material changes to sub-processors that process customer personal data.

6. International transfers

Our providers are primarily US-based. Where personal data is transferred out of the EEA/UK, we rely on the applicable Standard Contractual Clauses / UK IDTA offered by those providers. Counsel to confirm the transfer mechanism and any supplementary measures.

7. Retention

We keep personal data only as long as needed for the purpose it was collected, then delete or anonymize it. Indicative periods by category:

8. Your rights

Depending on your location (GDPR / UK GDPR / CCPA-CPRA and similar), you may have rights to access, correct, delete, port, or restrict processing of your personal data, to object to processing, and to withdraw consent. We do not sell or "share" personal information as those terms are defined under the CCPA/CPRA. To exercise any right, email privacy@CloudSpectra.Ai; we will respond within the timeframes required by applicable law.

9. Security

We apply appropriate technical and organizational measures to the limited personal data we hold. Security questions or reports: security@CloudSpectra.Ai (see also our responsible disclosure policy).

10. Children

The website and product are intended for businesses; they are not directed to children and we do not knowingly collect data from anyone under 16.

11. Changes & contact

We may update this policy; the "last updated" date above reflects the current version. Questions: privacy@CloudSpectra.Ai or 1957 Limewood Dr, San Jose, CA 95132, USA.