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Privacy Policy
Introduction
Spectra Management Consultancy (“Company”, “we”, “our”, or “us”) operates the Ethical View (“Platform”). We are committed to protecting personal data and ensuring lawful, fair, and transparent processing in accordance with the Digital Personal Data Protection Act, 2023 (“DPDP Act”). This Privacy Policy outlines how we collect, use, process, store, and safeguard personal data when users interact with our Platform and website.
Company Information
Legal Name: Spectra Management Consultancy Registered Address: 510, Tower-2, World Trade Center, Fountain Road, near EON Free Zone, Kharadi, Pune, Maharashtra 411014, India
Website: www.Spectra.Ltd
Contact Email: Grievance@EthicalView.com
Scope of the Policy
This Privacy Policy applies to all individuals interacting with the Platform, including employees of client organizations, external whistleblowers, investigators (internal and external), case managers, administrators, and website visitors.
Description of Services
The Ethical View is a digital platform designed to facilitate ethics and compliance reporting and case management. The Platform is offered under three service tiers:
Tier 1 – Platform Only: Clients independently manage case intake, investigation, and closure.
Tier 2 – Platform with Managed Services: The Company validates complaints before forwarding relevant cases to the client.
Tier 3 – Platform with Managed and Forensic Services: The Company provides end-to-end case management including investigation and closure.
Categories of Personal Data Collected
We may collect and process the following categories of personal data: • Identity and Contact Data (optional): Name, email address, and phone number.
Complaint and Case Data: Details of allegations, individuals involved, and case notes.
Supporting Evidence: Documents, images, audio, or other files uploaded by users.
Anonymous Reporting: Users may submit complaints without disclosing identity.
We collect only such personal data as is necessary for the purposes defined in this Policy.
Failure to provide certain personal data may limit the ability to submit complaints or enable effective investigation and resolution of cases.
Use of Third-Party Communication Channels
The Platform may facilitate the submission of complaints and communication through third-party messaging platforms such as WhatsApp.
Where such channels are used, communications are handled exclusively by authorized ethics officers or designated personnel and not by any automated or unauthorized individuals.
Users are informed that messages exchanged via WhatsApp may be stored on the platform and on associated systems, and may not be subject to automatic deletion or “disappearing message” features.
While the Company implements appropriate safeguards to protect confidentiality, the use of third-party platforms is subject to the respective platform provider’s terms, privacy practices, and data handling mechanisms.
Users are advised not to share information beyond what is necessary while using such communication channels.
Purpose of Processing
Managing complaint intake and case lifecycle.
Conducting investigations and resolution.
Ensuring compliance with applicable laws.
Risk monitoring and analytics.
Enhancing platform performance and security.
Legal Basis for Processing
Personal data is processed only upon obtaining free, specific, informed, and unambiguous consent from the Data Principal through a clear affirmative action, unless processing is permitted under legitimate uses as defined under applicable law.
Roles and Responsibilities
Client organizations act as Data Fiduciaries determining the purpose and means of processing. Spectra Management Consultancy primarily acts as a Data Processor, processing personal data on behalf of the client organization in accordance with contractual obligations. However, depending on the nature of services availed (including managed services and forensic services), the Company may act as a Data Fiduciary or Joint Data Fiduciary, as defined under the Digital Personal Data Protection Act, 2023 and in accordance with applicable contractual arrangements.
Data Processing Lifecycle
Personal data follows a structured lifecycle: Submission → Storage → Validation (where applicable) → Assignment → Investigation → Closure. Automation and AI tools may be used for triaging and analytics. Any use of AI or automated processing does not result in solely automated decision-making that produces legal or similarly significant effects on individuals.
Data Storage and Security
Data is hosted within India.
Encryption is implemented for data at rest and in transit.
Role-based access controls are enforced.
Audit logs and monitoring mechanisms are maintained.
Secure multi-tenant architecture is implemented.
Data Access and Sharing
Access is restricted to authorized personnel of the client organization. The Company may access data only when necessary and with client authorization. Personal data is not shared with third parties, partners, or vendors and is not sold. Notwithstanding the above, personal data may be disclosed where required under applicable law, regulatory obligations, or pursuant to lawful orders of competent authorities.
Cross-Border Data Transfers
Currently, personal data is not transferred outside India. Any future transfers will comply with applicable legal requirements.
Data Retention
Retention periods are defined by client organizations. Data is retained only as long as necessary and is securely deleted or anonymized thereafter.
Rights of Data Principals
Right to access personal data.
Right to correction and updating.
Right to erasure.
Right to withdraw consent.
Right to grievance redressal.
Data Principals may withdraw consent by contacting the Company or the respective client organization, subject to applicable legal and contractual restrictions.
Data Principals have the right to nominate another individual who shall exercise rights on their behalf in the event of death or incapacity.
Anonymity and Confidentiality
The Platform supports anonymous reporting and ensures confidentiality throughout the case lifecycle. Identity will not be disclosed unless required by law or with explicit consent.
Cookies and Website Usage
Cookies or similar technologies may be used to enhance user experience and analyze website performance. Such use shall be in accordance with applicable laws, and where required, user consent shall be obtained.
Grievance Redressal
Grievance Officer: Name: Dhara Mehta
Email: Grievance@EthicalView.com
Response Timeline: As per applicable law
Updates to this Policy
This Privacy Policy may be updated periodically. Updated versions will be published on the website.
Contact Information
Email: Grievance@EthicalView.com
Website: www.Spectra.Ltd
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