IDENTITY & CONTACT DETAILS OF THE CONTROLLER & PRIVACY OFFICERSpartan Global Services Ltd T/A Spartan Outlet (“Spartan Outlet”, “Spartan”, “us”,“we”) are committed to protecting and respecting your privacy whilst remaining compliant with The General Data Protection Regulation (EU GDPR) and the Data Protection Act (DPA). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. For us to drive compliance, we have an Information Governance Framework embedded within the organisation, which is compliant with The General Data Protection Regulation.
Spartan, are the Data Controller and have a Privacy Officer whom can be contacted via email: firstname.lastname@example.org
You can also contact Spartan, via post at: Unit 36 Rumer Hill Business Estate, Rumer Hill Road, Cannock, Staffordshire, WS11 0ET, United Kingdom
PURPOSE OF THE PROCESSING AND THE LEGAL BASIS FOR THE PROCESSING
Spartan, collects and creates personal data for several different purposes:
- Business Development
- Provision of services to our customers; and
- Procurement of services
The legal basis for processing personal data for the purpose of business development is the pursuit of our legitimate interest in developing our business and undertaking sales and marketing activities. We acquire personal data directly from data subjects when they contact us via our website www.spartanoutlet.com or our ebay account SpartanOutlet and/or they purchase items from these sites.
We will retain personal information we collect through our sales processes for as long as we believe our products and services may be of interest to prospects, customers and former customers.
Provision of services to our customers
The legal basis for processing personal data for the purpose of providing services to our customers is via an agreement (a contract) between Spartan and a customer, either to fulfil our contractual obligations with customers and by the pursuit of related legitimate interests including maintaining accurate records relating to accounting and finance, monitoring the quality of our services and in order to facilitate the delivery of products to our customers. We will retain personal information we collect through our service delivery processes for as long as such information is relevant to our service delivery model or defined in below under Retention of Records
Procurement of services
The legal basis for processing personal data for the purpose of procurement is the pursuit of our legitimate interest in maintaining efficient and effective procurement processes. Personal data we collect from suppliers and prospective suppliers is usually supplied directly by data subject or their employer. We will retain personal information we collect through our procurement processes for as long as we need to comply with accounting and taxation rules, policies and conventions.
We obtain consent from individuals in order to send them electronic marketing messages. We retain evidence of the details of consent which has been provided by our customers to process their information in this manner. Where the processing of information about you is based on consent you may withdraw your consent at any time and will be provided with instructions on how to do that.
LEGITIMATE INTERESTS OF SPARTAN
Spartan, may use your information for other specific legitimate purposes such as:
- To ensure that content from our site is presented in the most effective manner for you and for your computer.
- To provide you with information, products or services that you request from us or which we feel may interest you, where you have either consented to or we believe you have a legitimate interest in.
- To carry out our obligations arising from any contracts entered between you and us.
- To allow you to participate in interactive features of our service, when you choose to do so.
- To notify you about changes to our service.
We do not sell, rent or lease customer lists to third parties. However, we may share personal information with companies in our Spartan Group where we feel that there is a genuine possibility of your interest in their services. The lawful basis for this data sharing is the legitimate interest of the third party in developing and growing their business.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Information that you provide by filling in forms on our site (www.spartanoutlet.com) or by corresponding with us by phone, email or otherwise. The information you give us may include:
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of your visits to our web site and the resources that you access.
In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with .
RECIPIENTS OF THE PERSONAL DATA
Spartan are required to transfer the personal information provided by its customers to third parties in order to fulfil contractual obligations. The following are categories of recipients that customer information could be transferred to:
- Customer relationship management (CRM)
- Data Centres
- Accountancy Services
- Logistic Companies
All information you provide to us is stored on our secure servers. However, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We may disclose your personal information to any member of our group (Spartan Group), which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We will not disclose your information to any of the relevant third parties listed above for marketing purposes.
Our Privacy Officer can provide you with contact details of our third parties upon request if required. You can do this by emailing email@example.com
DETAILS OF TRANSFERS TO THIRD COUNTRIES & SAFEGUARDS
Spartan store personal data on information systems that require transfer to third countries as follows:
- Klaviyo USA/Canada
- Shopify USA/Canada
- Ebay USA
- Klarna Sweden
e.g. USA, controls are in place to ensure that the level of protection is not undermined and that security controls are at a level to commensurate with the type of information being transferred. This is applicable to Klaviyo, Shopify and Ebay. Further information is available on the privacy shield website:
Aside from this, we ensure that all other personally identifiable information held on our customers and employees remains within the EEA or Countries where there is a recognised and adequate level of data privacy protection. Those countries are currently:
Canada (commercial organisations),
Isle of Man,
Spartan securely retain all customer information for 5 Years after they last interacted with us unless:
a) you ask us to remove it
b) we believe that you are no longer interested in our business
c) we no longer need it for the purposes it was collected.
Where there has been a period of 5 years and there has been no interaction between the organisation and the customer, their information is erased and securely disposed of.
More detailed information is available from our Data Protection Officer via our Data Retention Policy, this is available via the contact details at the the start this Privacy Notice.
RIGHTS OF DATA SUBJECTS
As a Data Subject (individual) which Spartan process information on behalf of, you have the right to request access to, and the rectification or erasure of personal data that we hold about you, as well as a right to object to and to a restriction of our processing of your personal data at any given time. You can do this through the contact details provided above in this policy. You can exercise the right at any time by contacting us at firstname.lastname@example.org.
You also have a right to lodge a complaint with the Supervisory Authority (Information Commissioner's Office (ICO) in the UK - at www.ico.org.uk), should you feel that we have not handled your information in line with legislative and regulatory requirements.
You have the right to make a Data Subject Access Request to Spartan’s Privacy Officer if you wish to determine what information we hold on you. We welcome these requests and aim to respond within 1 month of receipt.
AUTOMATED DECISION MAKING, INCLUDING PROFILING & INFORMATION ABOUT HOW DECISIONS ARE MADE -THE SIGNIFICANCE OF THE CONSEQUENCES
We use email monitoring services to monitor the emails which we send to users. In doing this, we obtain information such as but not limited to:
- Time of receipt.
- Time of opening.
- Device user to open.
- Location it was opened in.
- Which parts of the email you interacted with.
We use systems that enable us to link your social media accounts to your account if registered with the same email address. This enables us to tailor our promotions and products as best as possible.
We may collect information about your computer, including where available your IP address, geographic location (if you allow when prompted by your browser), operating system and browser type, for system administration when you access our website or our DataWise platform. We use this information, for this is statistical data about our users' browsing actions and patterns when they access our website – logging IP addresses is used as a security feature of our services.
In the event that you wish to you alter your Privacy settings or opt-out, you are able to do this by emailing our Data Protection Officer at email@example.com. Our Data Protection Officer shall provide you with contact details of our third parties upon request if required.
We may send out email communication such as our newsletter to keep you up to date with all the latest offers from Spartan. If you wish to unsubscribe from these emails you can do so at any time by simply clicking either of the links in the header or footer and you will be removed from all promotional emails.
Please note that even if you decide not to subscribe to, or to unsubscribe, from promotional email messages, we may still need to contact you with important transactional information related to your account and your purchases. For example, even if you have unsubscribed from our promotional email messages, we will still send you confirmations when you confirm services from our site.