1. Purpose and Object

This privacy policy describes how SPARTAN collects, uses, stores and protects the personal data of its customers, partners and employees, in accordance with the applicable provisions of the GDPR and other relevant legislation.

2. Field of Application

This policy applies to all departments of SPARTAN and concerns the processing of personal data that takes place in the course of business activity, whether it concerns customers, suppliers, employees or third parties.

3. Principles and Commitments of the Company

• SPARTAN is committed to the protection of personal data and the preservation of the privacy of natural persons.
• Data processing is done with transparency, lawfulness, integrity and confidentiality.
• Data collection is done only for specific and legitimate purposes, with a minimum amount of data necessary.
• The company takes technical and organizational measures to prevent unauthorized access or data leakage.

4. Roles and Responsibilities

• The Management of SPARTAN is responsible for the implementation and revision of this policy.
• Employees are informed in detail and are required to adhere to data protection procedures and to inform the Information Security Department of any breaches.
• A Data Protection Officer (DPO) monitors compliance and informs the parties involved.

5. Implementation and Compliance Measures

• The collection and processing of personal data is only done with explicit consent or legal basis.
• Logs of the edits are kept.
• The data is deleted or anonymized when the purpose of the collection ceases to exist.
• Access to data is restricted based on roles and responsibilities.
• Regular inspections and staff trainings are carried out.

6. Communication and Education

• SPARTAN regularly informs staff and partners about privacy issues through training seminars.
• There are procedures for submitting data protection requests, complaints or reports.

7. Monitoring, Review, and Revision

• This policy is reviewed at regular intervals or whenever required due to legislative changes or significant incidents.
• The findings of the audits are used to improve policy and procedures.

8. Approval and Date of Implementation

• Policy approved by the SPARTAN Management.
• Date of last revision: 30.11.2024
• Next scheduled review: 16.12.2027
• Version number: 3.0.

The policy comes into force from the above date and is mandatory for all employees, partners and third parties involved in the management of personal data.