Privacy Policy

Last updated on:  August 21, 2020

Sparta Systems, Inc. and its subsidiary, 123Compliance Corporation (collectively “Sparta”, “Sparta Systems”, “we”, “our” or “us”) respect individual privacy. If you have questions or concerns regarding this Policy, you should contact us by emailing privacy@spartasystems.com, or write to us at 2000 Waterview Drive, Suite 300, Hamilton NJ 08691.
 
This Privacy Policy sets forth Sparta’s practices regarding the collection, use and disclosure of information that you may provide through the sites www.spartasystems.com and https://www.spartasystems.com/learning/community-portal (the “Sites”). Please read this Privacy Policy before using the Sites or submitting information to Sparta through the Sites.  By personal data, we mean any information which enables us to identify you, or which is capable of being associated with you, directly or indirectly, and includes any identifier, such as name, identification number, location data, IP address or online identifier.  It does not include data which has been de-identified (anonymous data).

For the purposes of Regulation (EU) 2016/679 (“GDPR”), Sparta is the controller of your personal data. 
 

COMPLIANCE WITH THE EU-US AND SWISS-US PRIVACY SHIELD FRAMEWORK

Sparta and 123Compliance Corporation comply with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and the United Kingdom and from Switzerland.  Sparta has certified that it and 123Compliance adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  We are committed to applying those Principles to any and all personal data received from the EU and Switzerland.  If there is any conflict between this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Sparta commits to resolve complaints about our collection or use of your personal information.  EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Sparta at:
 
privacy@spartasystems.com
 
Sparta has further committed to refer unresolved Privacy Shield complaints to TrustArc (TRUSTe), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint.  The services of TrustArc (TRUSTe) are provided at no cost to you.

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.  Our policy for accessing your personal data is described below.

VERIFICATION

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

We will use your personal data in the following circumstances:

  • where we need to, to perform the contract we are about to enter into or have entered into with you; or

  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or

  • where we need to comply with a legal or regulatory obligation.

Categories of Personal Data We Collect
We may collect, use, store and transfer different kinds of personal data, as follows:

Information you provide to us. Sparta collects the following information (identity and contact data) when you voluntarily submit it to us:

  • Identifiers. We collect identifiers, such as your name, home or business address, telephone number and/or email address. We collect this information when you sign up for our Sparta Systems Blog, register for the Sparta Systems Community Portal (“Community Portal”) (see “SPARTA SYSTEMS COMMUNITY PORTAL” below), or contact us using the details in our “CONTACT US” section below. 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 (where you have opted in to receive such information) to contact you about other products or services available from our affiliates or partners.

  • Communications. 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. In each case, we will retain that correspondence and feedback in accordance with our current Records Retention Policy and Records Retention Schedule (please see “RETENTION” below for additional details). 

Information we collect from automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies (see “COOKIES AND LOG FILES” below for further details) and other similar technologies.
 
Information we collect from third parties. 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 data you have provided to us.

COOKIES AND LOG FILES

Our Sites use “cookies” and “log files” so that we can recognize revisits to our Sites and provide a more personalized experience. Cookies are sent to your browser from our Sites and stored on your computer or device. Sparta uses cookies to track certain information about your usage and devices, such as host domain, IP address, pages accessed, clickstreams, time spent on our Sites and general browser statistics. Sparta Systems uses this information to, among other things, identify broad demographic trends that may be used to provide information tailored to your interests. We also monitor customer traffic patterns and Site usage to help us refine and improve the design and layout of our Sites and the overall user experience. We may link the information we store in cookies to personal information you submit while on our Sites.

More specifically, Sparta Systems may use cookies to:

  • 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.

  • Track our promotions, contests, and sales. When a Sparta Systems-hosted promotion uses cookies, the information written to the cookie tracks progress through the promotion (for example, entries, submissions, and registrations). 

  • 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. 

We may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) on our Sites. Google Analytics uses cookies, to help us analyze how users use the Sites. The information generated by the cookie about your use of the Site will be transmitted to and stored by Google on servers in the United States. Google uses this information to help us evaluate usage patterns on the Sites and providing other services to Sparta relating to Site activity and internet usage. You may delete or reject cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of the Sites. By using the Sites, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
 
For users in the EEA. You can visit www.aboutcookies.org or www.youronlinechoices.eu for comprehensive information on how to manage cookies.

SHARING YOUR PERSONAL DATA

We do not sell personal data to third parties.
 
We may share the information we collect about you in the following circumstances:

  • With our parent company and our subsidiaries and affiliates;

  • With service providers 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);

  • If you attend a webinar or other event we co-host with one of our non-affiliated partners, both we and our co-hosting partners may collect the information you provide through the event. These partners may contact you about their products or services if you have opted in to receiving marketing communications;

  • 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.

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 and all applicable data protection laws, for all onward transfers of personal data from the EU or Switzerland, including the onward transfer liability provisions.

SPARTA SYSTEMS COMMUNITY PORTAL

The Community 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 Community Portal provides existing clients with an interactive community to facilitate the exchange of ideas and user experiences, discuss common goals and objectives for Sparta Systems’ Product Suite enhancements, promote best practices, and share information.

We collect and store the information you provide to us when you register on the Community Portal, and use such information 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 Community Portal may be visible to other members and may be accessed, used, and stored by members, including other 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 Community Portal visible to other members, other members may use your personal data 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 Community Portal. Accordingly, we recommend that you not provide personal data on these public areas of the Community Portal, particularly sensitive personal data.

You may have access to, review, and update your account Community Portal 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 updating such information, we reserve the right to verify and authenticate your identity and the personal information to which you have requested access. Access to reviewing and updating 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 are based within the EEA, you may have additional rights, as set out below (see Your Rights (EEA Only)).
 
If you wish to delete or close your account or account profile information altogether, please email spartacare@spartasystems.com to contact us. An email will be sent to you to confirm that your personal data 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 or other legitimate 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 data 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 deactivation. Our current expiration and deactivation period is 12 months; we may extend or reduce this period. Deactivation of expired accounts occurs on a periodic basis and includes the deactivation 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.

YOUR CHOICES

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 marketing@spartasystems.com. 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. If you are based within the EEA, you may have additional rights, as set out below (see Your Rights (EEA Only)).

To make changes, deactivate, or to delete your Community Portal profile, please see the Section “Sparta Systems Community Portal” above.

YOUR RIGHTS (EEA ONLY)

If you are located in the EEA, you have a number of rights in relation to how we process your personal data. These include:

  • the right to access the personal data that we may hold about you;

  • the right to rectify any inaccurate personal data that we may hold about you;

  • the right to have your personal data erased in certain circumstances, for example, where it is no longer necessary for us to process your personal data to fulfil our processing purposes; where you object to your data being processed on certain grounds (for example, for marketing purposes) or where your personal data is being unlawfully processed;

  • the right to object to our processing of your personal data where we are relying on a legitimate interest and your interests override those interests;

  • the right to restrict the processing of your personal data under limited circumstances; and

  • the right to have your data ported to a new service provider if you no longer wish to use the Sites or our services. 

Should you wish to exercise any of these rights, please contact us at privacy@spartasystems.com.
 
What we may need from you.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to safeguard against your personal data being disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.

The Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third party sites.

RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
 
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
 
For further information on retention periods, please contact us using the details provided at the end of this Policy.

SECURITY

Sparta has implemented appropriate technical and organizational measures to protect your information collected through the Sites, both during transmission and once we receive it. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know the same. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however, and we cannot guarantee its absolute security.   In the event a data security incident does occur, Sparta has adopted a Data Security Incident Response Policy.  

You are responsible for ensuring that your log-in credentials (your username and password) to the Community Portal are kept confidential.

If you have any questions about security on our Site or our Data Security Incident Response Policy, you can email us at privacy@spartasystems.com.

YOUR CALIFORNIA RIGHTS

Rights of Data Access and Data Portability. You have the right, subject to certain exceptions defined in the California Consumer Protection Act “CCPA” and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your “personal information” (as that term is defined in the CCPA) over the past 12 months. This right of access includes information about:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting that personal information.

  • The categories of third parties with whom we share that personal information.

  • The categories of personal information that each recipient received.

  • The specific pieces of personal information we collected about you.

Right of Deletion. You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your personal information that it has collected from you and retained, subject to certain exceptions.

How to Exercise Your Data Access, Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, California residents may submit a verifiable consumer request to us by either:

  • Contacting us by email at privacy@spartasystems.com

  • Calling us toll-free at 800-910-8305.

The verifiable consumer request must:

  • Provide sufficient information that allows us to verify, to a reasonably high degree of certainty, that you are the person about whom we collected personal information. This may include requesting that you provide us with two or more pieces of personal information to match against our records for verifications purposes.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

Right to Opt Out of the Sale of Personal Information. You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that companies stop selling your personal information and refrain from doing so in the future. Sparta does not sell personal information (as defined by the CCPA), nor does Sparta intend to sell personal information in the future. However, if you would like to submit such a request, please send your request to privacy@spartasystems.com.

Authorized Agents. Only you, or a person you have designated in writing as your authorized agent, or who is registered with the California Secretary of State to act on your behalf, or to whom you have provided power of attorney pursuant to California Probate Code sections 4000 to 4465, (“Authorized Agent”), may make a verifiable consumer request or do not sell request related to your personal information.

If you wish to have an Authorized Agent make a request on your behalf, he or she will need to provide us with sufficient written proof that you have designated them as your Authorized Agent. We will also require you to provide sufficient information to allow us to reasonably verify that you are the person about whom we collected personal information.

Right of Non-Discrimination. You have the right not to be discriminated against for exercising the above CCPA rights.

Other California Privacy Rights. If you are a California resident, California Civil Code Section 1798.83 permits you to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain personally identifiable information for direct marketing purposes. We do not share personal information about consumers with third parties for their own marketing purposes and will not do so without consent. We are only required to respond to a customer request once during any calendar year. To make such a request you should send a letter to Sparta Systems, Inc., 2000 Waterview Drive, Suite 300, Hamilton NJ 08691. Please be aware that not all information sharing is covered by this Code section; only information sharing that is covered will be included in our response.

User-enabled global privacy controls, including “do not track.” At this time, we do not track our users’ personal information over time and across third-party websites, and we not respond to browser Do Not Track signals.

CHANGES TO THIS POLICY

If we make material changes to our Privacy Policy, we will, where required, contact you via the email address that you have submitted to us. We may also post those changes through a prominent notice on the www.spartansystems.com so that you will always know what information we gather, how we might use that information, and to whom we will disclose it.

LINKS TO OTHER SITES

Our Sites may contain links to other sites. Please be aware that we do not endorse and are not responsible for the privacy practices of such other sites. The Privacy Policy presented here does not apply to such sites. You should contact these sites directly for information on their privacy policies and data collection/distribution procedures.

CHILDREN'S PRIVACY

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.
 

CONTACT US

If you have questions or concerns regarding this Policy, you should contact us by emailing privacy@spartasystems.com, or write to us at 2000 Waterview Drive, Suite 300, Hamilton NJ 08691.

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