Privacy Policy


Privacy Policy Spectre

Who are we?

Spectre Technologies Ltd (STL), a Prepaid Financial Services (PFS) Limited Company, is a Malta based software development company.

The middleware solutions developed by STL and in use by PFS encompass a collection of core integrated technology modules for provisioning prepaid card services from front-end to back-office with integrations to a multitude of Issuers, issuing processors, card programme managers, card programs and acquirers, cash top-up networks and service providers.

What, Why?

It is important that you know exactly what we do with the personal information you and others make available to us, why we collect it and what it means for you. This document outlines the PFS approach to Data Privacy to fulfil our obligations under the EU General Data Protection Regulation (GDPR) 2018, as implemented on the 25th of May 2018. We were delighted to welcome the advent of GDPR, as it provided Spectre with a further an opportunity to reassure our customers of the importance we place on keeping your personal data secure, and of the strict guidelines we apply to its use.

The personal data we would like to collect from you is:

  • First Name and Surname (with title);
  • Date of birth;
  • Email;
  • Telephone number;
  • CCTV footage where you visit our offices.

The personal data we collect will be used for the following purposes:

  • Contacting you regarding our service to you; and
  • Where requested by law enforcement for investigation of crime.

Our legal basis for processing the personal data:

  • receipt of your consent;
  • performance of a contract where you are a party;
  • legal obligations that Spectre is required to meet; and
  • national law.


By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified above. Consent is required for Spectre to process personal data, but it must be explicitly given. Where we are asking you for sensitive personal data, we will always tell you why and how the information will be used.

Consent for Children Under 16

If you are giving consent on behalf of a child under sixteen (16) years of age then please be aware that Children need specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned, and also of their rights in relation to the processing of personal data for the purposes of using these services. By consenting to this privacy notice, on behalf of a minor, you are giving permission for their data to be used for the purposes described above.

Withdrawal of Consent Conditions

You may withdraw consent from direct marketing at any time by contacting our Data Protection Officer. Please note, where you have consented to your data being used for carrying out financial transactions, then the right to withdraw consent does not exist.

International Data Transfers & Third-Party Disclosures

In limited situations where Spectre stores or transfers personal information outside the EEA or the EU, robust procedures and safeguarding measures apply to secure, encrypt and maintain the integrity of the data. Spectre will complete continual reviews of the countries with sufficient adequacy decisions, such as the Privacy Shield in the US, and provisions for binding corporate rules, standard data protection clauses or approved codes of conduct. Spectre will further perform due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information. Spectre undertakes that it shall not transfer Personal Data outside of the EEA or the EU in full compliance with Article 46 of the GDPR, and shall not transfer data outside of the EEA or EU unless the following conditions are fulfilled:  

  • The data subject has enforceable rights and effective legal remedies;
  • PFS shall comply with its obligations under the Data Protection Legislation by providing an adequate level of protection to any Personal Data that is transferred (or, if it is not so bound, uses its best endeavours to assist the Customer in meeting its obligations);
  • PFS complies with any reasonable instructions notified to it in advance with respect to the processing of the Personal Data; and
  • Upon written direction shall delete or return Personal Data (and any copies of it) unless Spectre is required by Law to retain the Personal Data.

Where Spectre is required to transfer Personal Data to the United States of America, Spectre shall only send such Personal Data to third-party sub-contractors that meet the minimum requirements contained under the Privacy Shield, or in the standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament. 

In the event that the Privacy Shield is repealed at any future date, for whatever reason, Spectre shall only contract with third-party sub-contractors that satisfy the requirements contained in the standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Customer.

Retention Period

Spectre will process personal data for the duration of the contract for services and will store the personal data for six (6) years after that date of termination of the contract.

Your Rights as a Data Subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you;
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete;
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. Your data relating to financial transactions, accounts or cards cannot be deleted due to national law associated with the prevention of fraud, money laundering, counter terrorist financing or misuse of services for crime;
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing;
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation;
  • Right to object – you have the right to object to certain types of processing such as direct marketing;
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling; and
  • Right to judicial review, in the event that Spectre refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined below.

All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data. You will find a copy of our Subject Access Request Form here: Choose your favourite Text editor:

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