Privacy Policy
Spartan Advisory Partners (us, we, our) is committed to providing quality services to you and this privacy policy outlines our on-going obligations to you in respect of how we manage your Personal Information.
We have adopted the Law of Georgia on Personal Data Protection of 28 December 2011 No. 5669, the Department of Homeland Security FIPPS at Work and some principles of the EU`s General Data Protection Regulation (GDPR) to the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
This Policy applies to our use of any and all Data collected by us in relation to your use of the Web Site and our Services and was last updated in March 2022.
What personal information do we collect?
Personal information refers to any information relating to an identified or identifiable natural person (“Personal Information”).
We may collect data or ask you to provide certain data when you use our website and services. The sources from which we collect Personal Information are:
Data collected directly from you or your device relating to an identified or identifiable natural person (“Data Subject”) and may include direct identifiers such as name, address, email address, phone number, additional billing or property addresses, booking service or related information about your service preferences. Data collected that is linked, for example if you have used our service and later choose us again, we will link your data and treat that linked data as Personal Information.
We organise collected Personal Information as Account Data and Billing Data.
Account Data is everything we need to set up your account and includes your email address and username, and information connected with our services, such as, your First and Last Name, your address and phone number.
Billing data is everything we need to set up your payment including your name, email address, masked credit card number and in certain circumstances, your billing address and your phone number if this is not already collected.
When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting it, who we will give it to and how we will use or disclose it. As described above, we link data and if we have already collected some of your data, we will only ask you for the remaining data that is necessary to carry out the service contracted for.
What are our legal grounds for using your personal information?
We use your Personal Information for the following purposes:
When you use our services:
On the basis of fulfilling our contract.
When you contact us:
On the basis of your consent.
For Tax, Accounting, Anti-money laundering requirements, or when a court asks us to:
On the basis of our legal obligations.
For communications about security, privacy and performance improvements of our services. or for establishing, exercising or defending our legal rights
On the basis of our legitimate interest and of course, before we relying on any of those legitimate interests, we will always balance our interest against your interests and make sure will not cause any unwarranted harm.
Disclosure of personal information
We will generally use or disclose your Personal Information for the primary purpose for which it was collected. We may also use or disclose your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure.
We may also share information with our secure payment gateway provider, and you may need to provide credit or debit card information in order to process payment details and authorise payment following a secure link. The information which you supply to in such cases is not within our control and is subject to the payment gateway provider’s own Privacy Notice and Terms and Conditions.
We may otherwise use or disclose your Personal Information if you have given us consent for the use or disclosure, or it is required or authorised by law.
If those purposes involve disclosing your Personal Information to a third party, we will take appropriate and reasonable steps to ensure that your Personal information is protected.
In relation to marketing activities, you may unsubscribe or ‘opt-out’ from our mailing lists and direct marketing communications at any time.
How long do we retain your data?
We will only retain your Personal Information 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.
How do we protect your personal information?
We protect your data using state of the art technical, and physical safeguards and operate a firm system of policies, confidentiality agreements, digital safeguards and procedures to ensure the highest level of administrative protection.
The data we collect from you may be stored, with appropriate technical and organisational security measures applied to it, on our server in the USA. In all cases, we follow generally high data protection standards and advanced security measures to protect the Personal Information submitted to us, both during transmission and once we receive it.
Accuracy
It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure that we can continue to provide quality services to you.
International Transfer
We do not share your data with recipients outside the United States. However, if we do then we will make sure that it is protected in the same way as if it was being processed in the United States. Some countries or territories outside the United States do not have adequate levels of data protection. In order to protect your data and to achieve an adequate level of protection for your Personal Information when we transfer it to these countries or territories, we will ensure that one or more safeguards are put in place.
Do Not Track
Do Not Track is a privacy preference you can set in most browsers. We support Do Not Track because we believe that you should have genuine control over how your info gets used and our site responds to Do Not Track requests.
Do not sell my personal information
We do not sell information that directly identifies you, like your name, address or phone records.
Policy Updates
This privacy policy may change from time to time and is available on our website. If you have any objections to the privacy policy at present or at any time in the future, you should not access or use our website and services.
Complaints and Inquiries
If you have questions or complaints regarding our privacy policy or practices, wish to make a request or believe that your privacy has been breached, please contact us and provide details of the matter so that we can investigate it.
We request that all complaints be made in writing so that we can be sure about the details of the complaint. We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and your complaint is resolved within a reasonable time.
Commercial Partners
No Personal Information can be transmitted to any Commercial Partners in any method unless the Commercial Partners has been pre-certified for the receipt of such information.
Personal Information Training
Employees in positions with regular ongoing access to Personal Information or those transferred into such positions are provided with training reinforcing this policy and procedures for the maintenance of Personal Information data and shall receive annual training regarding the security and protection of Personal Information data and company proprietary data
Data Breaches/Notification
Databases or data sets that include Personal Information may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Information may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach.
Confirmation of Confidentiality
All our employees must maintain the confidentiality of Personal Information as well as company proprietary data to which they may have access and understand that that such Personal Information is to be restricted to only those with a business need to know.
Violations of Policies and Procedures
Infractions of this policy or its procedures will result in disciplinary actions under our discipline policy and may include suspension or termination in the case of severe or repeat violations. Personal Information violations and disciplinary actions are incorporated in our onboarding and refresher training to reinforce our continuing commitment to ensuring that your data is protected by the highest standards.
If you believe that we have not complied with this policy or acted otherwise, please notify us.