Information notice on the General Information Policy on the protection of personal data

1. What is this Privacy Notice about?

1.1 SPARTAN and its partners respect your privacy. We want you to know how we collect, use and disclose information that is directly or indirectly related to you as an individual (“Personal Data“) and the rights you have in this regard.

1.2 This Privacy Notice (“Privacy Notice“) describes how STRONG MND CORPORATION SRL with registered office in Suceava, STR. DEALUL CRUCII no. 64, processes your Personal Data collected in connection with:

The SPARTAN website available at (“Platform“). The Platform is a site where you can submit comments, upload photos and videos, participate in sweepstakes and contests, etc.

1.3 CCS is the data controller (within the meaning of Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC, hereinafter referred to as the “General Data Protection Regulation“) responsible for the processing of Personal Data described in the Privacy Notice.

1.4 You can contact us using the contact details in section 8 of this Privacy Policy.

2. What types of Personal Data do we collect about you?

1. The Personal Data we collect and process about you.

If you are a registered user, the Personal Data described below will be linked to the Personal Data collected and processed by the Privacy Notice at Registration.

When you use our Services, we collect and process the following Personal Data:

– Full name;

– Username and password;

– Photos and videos;

– E-mail address;

– Mailing address and delivery address;

– Country of residence;

– Phone number;

– Age;

– Sex;

– Details of your location;

– Voice recordings;

– IP address;

– Universal Coordinated Time (UTC);

– Social network profile;

– Information about hobbies, preferences and interests;

– Promo pin code;

– Consumer habits.

– Information about your use of the Services (for example, how many times and for how long you interact with the Services on our site, what videos you have watched, what sweepstakes or contests you have participated in, the site you visit, how many times you click on an item);

– Information about the device(s) you use to access and interact with the Services on our website (for example, this allows us to know whether you are using a computer, tablet or smartphone, your operating system, your Wi-Fi connection, internet browser and IP address).

– Participation Data: Personal Data related to your participation in promotions, contests and other types of promotions (e.g. type of promotion, date and time of participation in the promotion, result of participation).

2. Sensitive personal data

We do not collect or process Personal Data relating to:

– racial or ethnic origin;

– political opinions;

– religion or philosophical beliefs;

– health or medical condition;

– criminal record;

– trade union membership;

– genetic or biometric data;

– life or sexual orientation;

(hereinafter referred to as “Sensitive Personal Data“).

Please do not transmit or disclose Sensitive Personal Data through the Services on our website or otherwise.

3. How do we collect Personal Data?

We collect Personal Data as follows:

through our Services: we collect your Personal Data when you access or use the Services on our website;

using cookies and similar technologies: we collect your Personal Data when you access our Services through the use of cookies and similar technologies. The collection and processing of Personal Data through cookies and similar technologies is governed by the Cookie Policy, which you will need to read carefully. You can accept or reject cookies or similar technologies (except for Strictly Necessary Cookies as defined in the Cookie Policy) for each distinct purpose we pursue through their use.

off-line: we collect Personal Data when you are not using our services, for example when you attend SPARTAN events or contact customer service;

when you actively provide us with your Personal Data: we collect your Personal Data when you actively provide it, for example when you contact us in the contact section or we want you on our team.

To achieve the purposes described in this Privacy Policy, we collect your Personal Data that is collected through the Services, through cookies and similar technologies, when you are offline and that you voluntarily provide. We also aggregate your Personal Data with other Personal Data that we have obtained from you when you have used other SPARTAN services, websites and/or applications.

4. How do we use your Personal Data?

1. We respond to requests and demands:

To respond to requests, complaints and suggestions about the Services on our website that you have submitted through the contact service or other communication channels.

Legal basis for processing: our legitimate interests in dealing adequately and in a timely manner with customer requests, complaints and suggestions regarding the Services.

2. Promotions, special offers, loyalty programs, sweepstakes prizes and other offers/promotions:

To allow you to participate in promotions, special offers, loyalty programs, contest prizes and other offers/promotions. The Personal Data that must be provided to register for an offer/promotion usually includes your email address, user ID and password.

Legal basis for processing: the processing of your Personal Data for this purpose is based on the fulfilment of the terms and conditions of the relevant promotions.

3. Data analysis to obtain trends and improve SPARTAN products and services:

We collect Personal Data to evaluate your interaction with the Services offered by Spartan Romania and to see what trends and consumption patterns result from this analysis. This will help us to better understand the users of the Services offered by Spartan and tailor them to your preferences.

4. Technical functionality of the Services

We collect and use Personal Data for the technical administration of the services and to ensure that they function properly. In particular, we collect information about the status of the device when the application crashes in order to identify the cause of the incident and to do what is necessary to prevent it from happening again.

5. To whom is your Personal Data disclosed?

Your Personal Data is disclosed to the following recipients:

STRONG MND CORPORATION SRL, which will assist us in managing our websites and in connection with our communications to you.

Competent authorities: we may disclose your Personal Data within the strict limits legally required by the competent authorities.

6. What about other websites, apps, platforms and the like?

When you use the Services provided by Spartan, you may find links to other sites, applications or platforms that are not provided by us, but by other companies. We are not responsible for such sites, applications or platforms and this Privacy Notice does not apply to them. You should read the policies and rules that these companies have posted on their sites, apps or platforms to understand how they protect your privacy.

7. Third Party Service Providers

The Services give you access to a third-party functionality that allows you to upload content from the Services to your social media account(s). For example, if you like a video on the Platform, you can click the “Like” button on Facebook and show it to your social media friends.

Any information you provide through the use of this feature will be subject to the third party Privacy Notice and not this Spartan Privacy Notice. We have no control over, and are not responsible for, any use of the information by third parties that you provide through this feature.

We are also not responsible for the policies and practices (including data security practices) regarding collection, use and disclosure by other organizations, [such as Facebook, Twitter, Instagram, Pinterest, Apple, Google, Microsoft, RIM or any other application developer, application provider, social networking provider, operating system provider, wireless service provider or device manufacturer, including any Personal Data you disclose to other organizations through or in connection with the Services offered by them].

8. What are your rights regarding the processing of Personal Data, how can you exercise them and how can you contact us?

1. Your rights regarding the processing of Personal Data

With respect to the processing of Personal Data described in this Privacy Notice, you have the right, in certain circumstances:

– To receive a copy of the Personal Data we hold about you and to receive information about the processing of Personal Data;

– Ask us to update or correct any inaccurate Personal Data or complete any incomplete data;

– To request to stop processing Personal Data (i) for the purpose of personalising notifications (ii) for the purpose of performing data analysis to determine trends and patterns of consumer behaviour and to improve SPARTAN Services and products.

You also have the right in certain situations:

– To object to the processing of your Personal Data;

– Ask us to delete your Personal Data;

– Restrict the processing of your Personal Data;

– To ask us to transmit certain Personal Data to you or to transfer it to another authorised person.

2. Contacting us to exercise your rights

If you wish to exercise any of the above rights, you can contact us at:

Please specify clearly what types of information you want us to provide to you, analyze, modify, stop processing or delete.

You can also contact us with any questions or queries regarding the processing of Personal Data using the contact options above.

3. The right to lodge a complaint with the competent data protection authority

You have the right to lodge a complaint with the competent supervisory authority (in particular in the Member State where you normally reside, where you have your place of work or where the alleged breach occurred) if you believe that any of your personal data is being processed in a way that breaches the EU General Data Protection Regulation No 2016/679 of 27 April 2016.

9. Retention periods of your Personal Data

We intend to keep your Personal Data up to date.

We retain the personal data we use for the purposes described in this Privacy Notice for a maximum period of 2 years, unless legal requirements apply that require us to retain your personal data for longer or shorter periods.

We keep the cookies we use on the device from which you logged into the Services for a maximum of 13 months, except for session cookies which are only kept for the duration of the session in which you are logged into the Services and are then deleted.

Thank you for reviewing this information and taking the time to learn how we protect your personal data.