Last updated on: September 16, 2016
Sparta Systems, Inc. (“Sparta” or “Sparta Systems”) respects individual privacy. If you have questions or concerns regarding this Policy, you should contact us by emailing firstname.lastname@example.org.
Compliance with the EU-US Privacy Shield Framework
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Sparta is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
In certain situations, Sparta may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at http://feedback-form.truste.com/watchdog/request
Under certain conditions, more fully described on the Privacy Shield website listed above, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Under the Privacy Shield Framework, you have a right to access your personal data. Sparta’s policy for accessing your personal data is described below.
Sparta has implemented internal mechanisms to verify ongoing adherence to this policy. Sparta periodically verifies that this policy remains accurate, comprehensive for its intended purpose, and is accessible in accordance with applicable law.
DATA COLLECTION AND USE
Sparta only collects personal information, including, without limitation, your name, home or business address, telephone number and/or email address when you voluntarily submit it to Sparta. For example, we may collect this information when you sign up for our Sparta Systems Blog, register for the TrackWise User Group (“TUG Portal”), or contact us using our “Contact Us” function. This information may be used by Sparta personnel to respond to or provide you with information that you have requested or additional information which Sparta believes may be of interest to you. Sparta may also use this information for performing marketing studies or internal business research or for other commercial purposes such as contacting you about other products or services available from our affiliates or partners.
If you send us personal correspondence, such as e-mails, we may keep a record of that correspondence. We also periodically ask users for feedback that we use to improve our service and products and add new features. If you respond to these requests, we may keep a record of your response.
We reserve the right to combine information from third parties to the information we collect about you or your device, for instance to research prospective clients. From time to time we may purchase marketing data from third parties and add it to our existing user database, to better target our advertising and to provide pertinent offers in which we think you would be interested. To enrich our profiles of individual customers, we may tie this information to the personal information you have provided to us.
COOKIES AND LOG FILES
Estimate the number of visitors to our Sites. Each browser that accesses Sparta Systems is given a unique cookie, which is used to calculate how many people return to our Site and evaluate customer interests and behavior to target our marketing.
Measure the traffic to various areas of the Sites. We measure the areas of the network of Web sites you visit and your visiting patterns in the aggregate. This research helps us understand the ways in which our customers are alike and the ways in which they differ. We may use this information to personalize the content and design in our Sites.
SHARING YOUR INFORMATION
Our policy is to not share the information described above with third parties or transfer or use that information outside of Sparta without your prior consent. We may, however, share the information we collect about you in limited circumstances including:
With our parent company and our subsidiaries and affiliates;
With third parties or agents who perform services on our behalf or help us in the delivery of our own products and services to you (i.e., emailing or direct mail services, marketing services, Web analytics);
With third parties who may contact you about their products or services;
We may disclose the information described above when required by law or regulation or in the good faith belief that such action is necessary in order to conform to the edicts of the law, comply with legal mandates, to prevent a crime or protect national security, to enforce our policies or agreements or terms and conditions, or to protect the rights, property, or personal safety of Sparta Systems, its employees, users and the public. Because Sparta is a US company and information collected on our Sites is stored in whole or in part in the United States, your information may become subject to U.S. law;
We may disclose and transfer your information to a third party who acquires any or all of Sparta, whether such acquisition is by way of merger, consolidation or purchase of all or a substantial portion of our assets. In addition, in the event Sparta becomes the subject of an insolvency proceeding, whether voluntary or involuntary, Sparta or its liquidator, administrator, receiver or administrative receiver may sell, license or otherwise dispose of such information in a transaction approved by the court; or
When you otherwise consent.
In each situation described above, the recipients of your data may potentially be located in any country in the world. If you are a resident Switzerland you must be aware that Swiss authorities do not generally consider that the regulations of non-Swiss countries ensure an adequate or equivalent level of protection as compared to the Swiss data protection regulations.
Sparta is responsible for the treatment processing of personal data it receives directly under the Privacy Shield Framework, and remains liable for the treatment and processing of that data in the event of subsequent transfers of that data to a third party acting as an agent on its behalf. Sparta complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
TRACKWISE USER GROUP
The TUG Portal is a knowledge community for Sparta Systems customers. The broad membership represents both technical and business users across all industries, from various size organizations, and from regions around the globe. The TUG Portal provides both existing and prospective clients with an interactive community to facilitate the exchange of ideas and user experiences, discuss common goals and objectives for TrackWise enhancements, promote best practices, and share information.
By registering on the TUG Portal, you consent for Sparta to use your information to allow you to create an account, and to create a profile for you based on information that you have provided to us. Sparta’s policy is to not share such account or profile information with third parties, unless otherwise provided herein.
Information you post in public areas of the TUG Portal visible to other members may be accessed, used, and stored by members, including others members in countries that might not have legislation that guarantees adequate protection of personal information as defined by your country of residence. If you provide information in the areas of TUG visible to other members, other members may use your personal information to contact you for networking or other purposes. Sparta does not control these third parties and we are not responsible for their use of information you post or otherwise make publicly available in the TUG Portal. Accordingly, we recommend that you not provide personal information on these public areas of the TUG Portal, particularly sensitive information. Please note that while we attempt to limit access to our TUG Portal to legitimate users (existing and potential TrackWise customers), we cannot guarantee that other parties will not gain access to this Portal.
You may have access to, review, correct, update, change or delete your account TUG profile information at any time. Simply log into your account, go to your profile, and make the necessary changes. Before providing you with a copy of your personal information or correcting, updating or deleting such information, we reserve the right to verify and authenticate your identity and the personal information to which you have requested access. Access to or correction, updating or deletion of your personal information may be denied or limited by Sparta if it would violate another person’s rights and/or as otherwise permitted by applicable law. We will use commercially reasonable efforts to respond to information access requests within 30 days of receipt. If we require additional time to provide access to your information, we will acknowledge receipt of your request within 30 days and supplement our response within the time period required by applicable law.
If you wish to delete or close your account or account profile information altogether, please email email@example.com to contact us. An email will be sent to you to confirm that your personal information has been deleted (save for an archival copy which is not accessible by you or third parties on the Internet). The archival copy is retained only for as long as Sparta reasonably considers necessary for audit and record purposes. We will also retain logs, demographic, indirect, and statistical information that may relate to you but do not identify you personally. If your personal information was previously accessed by others using our Sites, we are not able to delete the information or copies thereof from their systems.
If you do not log into your account for a significant period of time, it will expire and be scheduled for deletion. Our current expiration and deletion period is 36 months; we may extend or reduce this period. Deletion of expired accounts occurs on a periodic basis and includes the deletion of all applicable account data including contact information.
If you previously opted to receive newsletters, commercial e-mails or other communications from Sparta or third parties, but subsequently change your mind, you may opt-out by editing your account profile as described above. If you previously opted not to receive such communications, you may later opt-in by editing your account profile.
SOLUTIONS SUPPORT PORTAL
Sparta’s Solutions Support Portal allows TrackWise support and maintenance customers to request product support via the Site. By registering on the Solutions Support Portal, you consent for Sparta to use such information to allow you to create an account and to create a profile for you based on information that you have provided to us. Sparta will not voluntarily share such account or profile information but will use such information (along with support request information) within Sparta to provide product support and resolution of issues relating to TrackWise.
From time to time we send our visitors e-mail messages with announcements, enhancements, maintenance information and general updates. If you no longer wish to receive these promotional communications, you may opt-out of receiving them by following the instructions included in each communication or you may contact us at firstname.lastname@example.org. You may also request access to personal data about you that Sparta holds and you may have the opportunity to request a correction or amendment to your personal data.
To make changes or to delete your TUG Portal profile, please see the Section “TRACKWISE USER GROUP” above.
Sparta has implemented commercially reasonable technical and organizational measures to protect your information collected through the Sites, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however, and we cannot guarantee its absolute security.
You are responsible for ensuring that your log-in credentials (your username and password) to the TUG Portal and/or the Solutions Support Portal are kept confidential.
If you have any questions about security on our Site, you can email us at email@example.com.
U.S.-E.U. AND U.S-SWISS SAFE HARBOR
Sparta Systems is committed to complying with the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding its handling of personal information from Switzerland. Sparta Systems has certified that it adheres to the Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access, and Enforcement. You may view Sparta Systems’ Safe Harbor Certification at http://safeharbor.export.gov/swisslist.aspx. For more information about the Safe Harbor Principles, please visit the U.S. Department of Commerce’s website at http://2016.export.gov/safeharbor/swiss/index.asp.
YOUR CALIFORNIA RIGHTS
A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California customer”) is entitled to request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed.
Sparta Systems does not share, sell, trade, or rent your personal information to third parties for their direct marketing purposes unless you affirmatively agree to such disclosure.
California customers may request further information about our compliance with this law by e-mailing firstname.lastname@example.org. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this e-mail address.
In addition, under California law, website operators are required to disclose how they respond to Web browser “do not track” signals or other similar mechanisms. Currently, Sparta’s practice is to continue to track users after a consumer has enabled a “do not track” signal. This law also requires website operators to disclose whether third parties may collect personally identifiable information about their users’ online activities over time and across different Sites when the users use the operator’s website. Sparta does not knowingly permit third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different Web sites when a consumer uses our Sites.
CHANGES TO THIS POLICY
LINKS TO OTHER SITES
Sparta Systems does not knowingly collect information from children under the age of 13 and Sparta Systems does not target its Sites or its products to children under the age of 13. If you are under 13 years of age, you may not use our Sites.
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