SPARTAEX and its affiliates (hereinafter, ''SPARTAEX'', ''we'', ''us'' or ''our'') are committed to protecting and respecting your privacy. This Privacy Policy explains what you can expect from us and what we need from you in relation to your personal data. Please read this carefully as this Policy is legally binding when you use our SPARTAEX Services, as defined below. This Privacy Policy applies to any SPARTAEX Services, as defined below, regardless of how you access or use them, including through mobile devices. We may amend this Privacy Policy at any time by posting the amended version on this site including the effective date of the amended version. We will announce any material changes to this Privacy Policy via email.
Sparta Financial Services (SPARTAEX) is a company registered in the United Kingdom. Our registered office is at 20-22 Wenlock Road, London N1 7GU, United Kingdom, Registration No. 09414540. SPARTAEX has developed a multi-level account system with individual approach to each customer, to buy, sell, use and receive payments in Digital currencies and FIAT currencies. Worldwide coverage, multiple currency options, and 24/7 support are accompanied by time-proven platform stability that guarantees safety of assets and data.
The Sparta Financial Services company (SPARTAEX) you are contracting with is your data controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards, this Privacy Policy, as well as any applicable national laws. The SPARTAEX group companies use encryption to protect your information and store decryption keys in separate systems. Data controllers process and retain your personal information on our servers where our data centers are located, including the European Union, Japan, Singapore, the United States of America, Hong Kong, Russia and elsewhere in the world. Our Data Protection Officer is the person in charge of ensuring our company adheres to this privacy policy. This person is also the main contact for our Data Protection Supervisory Authority, the Information Commissioner’s Office (www.ico.org.uk). The Data Protection Officer may be contacted on dpo@spartaex.com.
Personal Information We Collect
We collect the Personal Data you provide directly to us or which we generate when you open a SPARTAEX Account, perform any type of transactions on the SPARTAEX System, or use other SPARTAEX Services or our website. This may include:
Personal Information you provide during the registration process may be retained, even if your registration is left incomplete or abandoned. If you are located within the EEA, this Information will not be retained without your consent.
In providing the personal data of any individual (other than yourself) to us during your use of the SPARTAEX Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data for the purposes set out in this Privacy Policy.
Information we collect about you automatically
Information we receive about you from other sources
Below in a table format we set a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Definitions for Table:
Legitimate Interest: this means an interest of ours as a business to continue to innovate and improve the SPARTAEX Services and offer the most secure experience possible. We make sure to consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Fulfilling a Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Our Legal Obligation: this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
When you use SPARTAEX Services, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit SPARTAEX Services. We use Cookies to help us recognize you as a customer, collect information about your use of SPARTAEX Services to better customize our services and content for you, and to collect information about your computer or other access devices as part to ensure our compliance with our BSA and AML obligations and ensure that your account security has not been compromised by detecting irregular or suspicious account activities. We use both session and persistent Cookies. Session Cookies expire when you log out of your account or close your browser. Persistent Cookies remain on your computer or mobile device until deleted or otherwise expire. Most web browsers are set to accept Cookies by default. If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features or our website or services, such as logging and General use of your SPARTAEX Account. Your use of our website or service with a browser that is configure to accept cookies constitutes an acceptance of our and third-party cookies.
We may disclose your Personal Data to third parties and legal and regulatory authorities, and transfer your Personal Data outside the EEA, as described below.
There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties.
Your information is held within our servers located within the European Union.
We will hold your Personal Information only for as long as it is necessary for the purposes described in this Privacy Policy and our own legal and regulatory requirements. In accordance with record keeping activities for Anti-Money Laundering (AML), Tax and Company legal obligations, we will retain Accounts and Personal Information for, at least, a period of ten years after a user closes his account with us. Data stored for regulatory purposes only will be protected from unnecessary processing and will be held only for the purpose of being able to provide information or access to relevant authorities. Your payment method information that you may use to effect or receive payments from SPARTAEX are passed on to a third-party payment processor(s) which is/are based in the EU or USA and with which SPARTAEX has a contractual agreement to safeguard your rights. Unless you create an account with us and conduct transactions, we do not retain your payment method information.
By using SPARTAEX Services, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. In all such transfers, we will protect your personal information as described in this Privacy Policy and in a manner consistent with the principles of the EU-US and Swiss-US Privacy Shield framework.
Once we do not have any obligation to providing you with a service you requested, nor an obligation to hold Personal Information for regulatory or legal purpose, we will anonymise or dispose of your Personal Information in line with acceptable industry and security standards so that this cannot be subsequently retrieved and associated to you. Where we cannot directly remove such records, such as in archived backups, we will retain a log of which Personal Information should be removed if ever the backup data is restored.
We may use Automated Decision Making in order to improve your experience, or to help fight financial crime. For example, so that we can provide you with a fast and efficient service, we may use Automated Decision Making to verify your identity documents, or to confirm the accuracy of the information you have provided to us. None of our Automated Decision Making processes have a legal effect on you.
You have certain rights concerning your Personal Data under Law as mentioned below, and can exercise them by contacting us at dpo@spartaex.com.
Right of Access – Upon your written request at dpo@spartaex.com, we will inform you of the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information. We will also give you a copy of the Personal Information we have retained. There may be a charge for providing you additional copies of your Personal Information to cover administrative costs.
Right of Erasure – You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which SPARTAEX is subject to.
Correction – you are entitled to request that any incomplete or inaccurate personal data we hold about you is corrected.
Transfer – You may have the right to transfer certain of your personal data between data controllers, for example, to move your account details from one online platform to another.
Right of Rectification – You have the right to correct any personal information We hold on you that is inaccurate, incorrect, or out of date.
To ensure the confidentiality, integrity and availability of your information to yourself, we may request you to confirm your identity by providing identification documentation and/or other methods prior to assisting you in exercising any of your rights.
If you refuse to prove your identity, we may decline to take actions in respect of your data, save restricting processing, until we can ensure that such actions are the true wish of the data subject.
In the carrying out of our services we may use automated processing and profiling to reduce the risks of fraud, money laundering and abuse of our services. Through this automated processing, we carry out an analysis of your identification, transactional and behavioural patterns.
We may not able to provide you with some or all our services if you do not wish this automated processing to be carried out.
We have implemented technical and organisational security measures to ensure the confidentiality of your Personal Information and to protect your Personal Information from loss, misuse, alteration or destruction.
All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorised SPARTAEX personnel are permitted access to your Personal Data, and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments. Where you have consented to, or we are obliged to pass on Personal Information to third parties to provide you with a requested service or in the carrying out of a regulatory or legal obligation, we will request that the same levels of technical and organisational security measure be applied through contractual arrangements, where possible. Technical and organisational security measures in place will, from time to time, be reviewed in line with legal and technical developments. In the event of a personal data breach or the failure of the measures of protection of such information we will immediately notify you without undue delay. You are responsible for keeping your account passcode, passwords, membership numbers, Digital Currency Addresses, codes and pin numbers safe and secure. Do not share those with anyone. If there is an unauthorised use or any other breach of security involving your information, you must notify us below as soon as possible. We do not ask for financial or payment information, such as your credit card number, passcode, passwords, Digital Currency Addresses, Digital Currency codes, account number or pin number, in an e-mail, text or any other communication that we send to you. Please always check that any website on which you are asked for financial or payment information in relation to our reservations or services is operated by SPARTAEX. If you do receive a suspicious request, do not provide your information and report it by contacting one our member service representatives as set in this Privacy Policy.
Your funding of Bitcoin and other Digital Currencies, may be recorded on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Because blockchains are decentralized or third-party networks which are not controlled or operated by SPARTAEX or its affiliates, we are not able to erase, modify, or alter personal data from such networks. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data.
There may be links from our Site to other sites and resources provided by third parties. This Privacy Policy applies only to our Site. Accessing those third-party sites or sources requires you to leave our Site. We do not control those third party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.
Any questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo@spartaex.com.
If you feel that we have not addressed your questions or concerns adequately, you may contact our data controller.
The Information Commissioner’s Office
Wycliffe House, Water Ln
Wilmslow SK9 5AF, UK