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Privacy policy

1. INTRODUCTION

This privacy policy provides you with details on how we collect and process your personal data through our site www.thegoldenspartan.com as well as information you provide through our site when you purchase any of our products.
Providing us with your data means you confirm that you are over 13 years of age.
Credicom International Ltd (brand owner of The Golden Spartan) is the data controller and is responsible for your personal data provided through our site (referred to as “we”, “us” or “our” in this privacy policy).
Contact Details
Full name of company: Credicom International Ltd.
Email address: info@thegoldenspartan.com
Postal address: Bulevar despota Stefana 95, 11108 Belgrade, Republic of Serbia.
If you have a complaint, we will be thankful if you contact us first, so that we can try to resolve it promptly and to your satisfaction.
It is important that your information, that we have about you is accurate and up to date. For updating your personal information please email us at info@thegoldenspartan.com

2. WHAT DATA DO WE COLLECT ABOUT YOU

Personal data is any information capable of identifying an individual. It does not include anonymous data.
We may process certain types of personal data about you as follows:
Identity Data may include your first name, last name, username, title, date of birth and gender.
Contact Data may include your billing and delivery address, email address and contact number.
Transaction Data may include details about payments between us and other details of purchases made by you.
Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
Profile Data may include your username, password, purchaser, orders, interests, preferences, feedback, survey responses.
Usage Data may include information about how you use our website, products and services.
Marketing and Communications Data may include your preferences for receiving marketing communications and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
order our products;
create an account on our site;
request resources or marketing be sent to you;
enter a competition, prize draw, promotion or survey; or
give us feedback.
Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. Please see our Cookie Policy for further details.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as stated below:
Analytics providers such as Google based outside the EU;
Advertising networks such as Facebook Ads & Instagram Ads based outside the EU;
Contact, Financial and Transaction Data from providers of technical, payment services such as PayPal, all of which are based outside the EU.

4. HOW WE USE YOUR PERSONAL DATA

We only use your personal data when legally permitted. The most common uses of your personal data are:
When we need to carry out the contract between us.
When it is essential for our legitimate interests (or those of a third party) and when your interests and basic rights do not supersede those interests.
When we need to comply with a legal or regulatory obligation.
Normally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to remove your consent to marketing at any time by emailing us at info@thegoldenspartan.com
Purposes for processing your personal data
Defined below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are.
Please email us at info@thegoldenspartan.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Legal basis for processing

To register you as a new customer
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order including:
(a) Managing payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to learn how customers use our products
To enable you to partake in a prize draw, competition or complete a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to learn how customers use our products and grow our business
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud
(b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests to learn how customers use our products, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products, marketing, customer relationships and experiences
(a) Technical
(b) Usage
Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests to develop our products and grow our business

Marketing communications

You will receive marketing communications from us if you have:
1. requested information from us or
2. purchased/ordered goods from us
3. in each case, you have not opted out of receiving that marketing.
We will never share your personal data with a third party for marketing purposes.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we need to use it for another reason and that reason is similar with the original purpose. If you wish to find out more about how the processing for the new purpose is similar with the original purpose, email us at info@thegoldenspartan.com
If we need to use your personal data for a purpose not related to the purpose for which we collected the data, we will inform you and we will clarify the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers and auditors who provide consultancy, banking, legal and accounting services.
Revenue & Customs and other authorities based in the Republic of Serbia and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

6. DATA SECURITY  

We have established security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, changed or disclosed. Also, we limit access to your personal data to only employees, agents, contractors and other third parties who must know such data. They will only process your personal data with our instructions and they are subject to discretion.
We have established procedures to deal with any suspected breach of personal data and will inform you and the appropriate regulator of a breach where we are legally required to.

7. DATA RETENTION

We retain your personal data only as long as necessary to fulfill the purposes we collected it for, such as: satisfying legal, accounting, or reporting requirements.
In determining the proper retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the possible risk of harm from unauthorized use or disclosure of this data, the purposes for which we process your personal data and if we can accomplish those purposes through other means and the appropriate legal requirements.
By law we have to retain basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In certain circumstances you can request that your data be deleted: see below for more information.
In some circumstances we may make your personal data anonymous for research/statistical purposes in which case we may use this information indefinitely.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data.
Request correction of your personal data.
Request deletion of your personal data.
Opose processing of your personal data.
Request limitation of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of these rights, please email us at info@thegoldenspartan.com
You will not have to pay a fee to access your personal. However, we may charge a realistic fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information concerning your request.
We try to respond to all lawful requests within 20 business days. Rarely, if your request is very complex it may take us longer.

9. THIRD-PARTY LINKS

This site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

10. COOKIES

You can set your browser to decline all or some browser cookies. If you disable or decline cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please our Cookie Policy.