Information note 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 a person (“Personal Data”) and your rights in this regard.

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

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

1.3 CCS is the data controller (within the meaning of EU Regulation 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, 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 no. 8 of this Privacy Policy.

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

1. The Personal Data that we collect and process in connection with you.
If you are a registered user, the Personal Data described below will be correlated with those collected and processed through the Registration Privacy Notice.

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

Name and surname;
Username and password;
Photos and videos;
Email Address;
Postal address and shipping address;
Country of Residence;
Phone number;
Data about your location;
Voice recordings;
IP address;
Universal Coordinated Time (UTC);
Social network profile;
Information about hobbies, preferences and interests;
Promotional pin code;
Consumption habits.
Information about your use of the Services (for example, how often and for how long you interact with the Services on our site, what videos you watched, what raffles or contests you participated in, the site you access, each time you clicked on an item);
Information about the device (s) you use to access and interact with the Services on our site (for example, this allows us to know if you are using a computer, tablet or smartphone, your system operation, your Wi-Fi connection, internet browser and IP address).
Participation data: Personal data related to your participation in the promotion, contests and other types of promotions (eg 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 related to:

racial or ethnic origin;
Political Views;
religion or philosophical beliefs;
health or medical condition;
criminal record;
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 site 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 site;
using cookies and similar technologies: we collect your Personal Data when you access our Services, by using cookies and similar technologies. The collection and processing of Personal Data through cookies and similar technologies are governed by the Cookies Policy, which you will need to read carefully. You may accept or reject cookies or similar technologies (except for Strictly Required Cookies as defined in the Cookie Policy) for each distinct purpose we pursue by using them. off-line: we collect Personal Data when you do not use our services, for example when you participate in 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 as a team.
In order to achieve the purposes described in this Privacy Policy, we collect your Personal Data which is collected through the Services, cookies and similar technologies, when you are offline and which you provide voluntarily. We also collect 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 requirements and requests:
In order to respond to requests, complaints and suggestions regarding the Services on our site, which you have sent through the contact service or through other communication channels.

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

2. Promotions, special offers, loyalty programs, raffle 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 in order to register for an offer / promotion usually includes your e-mail address, user ID and password.
Legal basis for processing: The processing of your Personal Data for this purpose is based on the fulfillment of the terms and conditions of the relevant promotions.

3. Data analysis to track 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 get to know the users of the Spartan Services better and adapt 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 it works properly. In particular, we collect information about the status of the device when the application crashes to identify the cause of the incident and to achieve 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 help us in the management of our sites and in connection with our communications to you.
Competent Authorities: we will be able to disclose your Personal Data within the limits strictly legally imposed by the competent authorities.

6. What is related to other sites, applications, 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 need to read the policies and rules that these companies have posted on their websites, applications, or platforms to understand how they protect your privacy.

7. Third Party Service Providers

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

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

We are also not responsible for policies and practices (including data security practices) regarding the collection, use and disclosure by other organizations, [such as Facebook, Twitter, Instagram, Pinterest, Apple, Google, Microsoft, RIM or any other another application developer, application provider, social networking provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Data that you disclose to other organizations through or in connection with the Services provided of 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 regard to the processing of Personal Data described in this Privacy Notice, you have the right to, in certain circumstances:

To send you a copy of the Personal Data we hold about you and to receive information regarding the processing of Personal Data;
Ask us to update or correct any inaccurate Personal Data or to fill in any incomplete data;
Request the cessation of the processing of Personal Data (i) for the personalization of notifications (ii) in order to perform data analysis to determine trends and patterns of consumer behavior and to improve SPARTAN Services and services and products.
You are also entitled as 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;
Ask us to send you certain Personal Data or to transfer it to another authorized person.

2. Contact us to exercise your rights
If you wish to exercise any of your rights above, you can contact us at the e-mail address:

Please clearly specify what types of information you wish to provide, analyze, modify, discontinue or delete.

You can also contact us for any questions or requirements 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 in which you normally reside, where you work or where the alleged infringement has taken place), if you believe that any personal data are processed in a manner that infringes the general EU Data Protection Regulation no. 2016/679 dated April 27, 2016.

9. Periods of retention 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 the legal requirements that require the retention of your personal data for a longer or shorter period of time apply.

We retain the cookies we use on the device from which you have connected to the Services for a maximum of 13 months, except for session cookies which are kept only during the session in which you are connected to the Services and which are then deleted. .

Thank you for reading this information and for taking the time to find out how we protect your personal data.