Privacy Policy

Last updated: February 26, 2025

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Spartans Sec Pty Ltd, trading as Spartans Information Security (“we”, “our”, “us”) is committed to protecting your privacy and understanding the importance of keeping personal information we may receive about you confidential and secure. This Privacy Policy outlines how we collect, use, disclose, and manage your personal information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth). Spartans Information Security may update this policy from time to time.

What is personal information?
“Personal information” means any information or opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or a reasonably identifiable individual. In general terms, this includes information or an opinion that personally identifies you either directly (e.g. your name) or indirectly.

What personal information do we collect?
The personal information we collect about you depends on the nature of your dealings with us or what you choose to share with us. The personal information we collect about you may include name, email, phone numbers, any other contact details, payment information, business address.

How do we collect your personal information?
We collect your personal information directly from you when you:
• interact with us over the phone.
• interact with us in person.
• interact with us online.
• participate in surveys or questionnaires.
• attend events organised by us, sponsored by us or participated by us.
• subscribe to our mailing list.
• fill out forms on our website.
• apply for a position with us as an employee, contractor or volunteer.
• third-party service providers, where applicable.
We may also collect your personal information from third parties as part of providing services to you.

How do we use your personal information?
We use personal information for many purposes in connection with our functions and activities, including the following purposes:
• provide you with information or services that you request from us.
• deliver to you a more personalised experience and service offering.
• improve the quality of the services we offer.
• internal administrative purposes.
• marketing and research purposes.

Disclosure of personal information to third parties
We may disclose your personal information to third parties in accordance with this Policy in circumstances where you would reasonably expect us to disclose your information. For example, we may disclose your personal information to:
• our third-party service providers (for example, IT and accounting services providers).
• our marketing providers.
• upstream service providers.
• our professional services advisors.

Transfer of personal information overseas
Some of the third-party service providers we disclose personal information to may be based in or have servers located outside of Australia. Where we disclose your personal information to third parties overseas, we will take reasonable steps to ensure that data security and appropriate privacy practices are maintained.

How do we protect your personal information?
We will take reasonable steps to ensure that the personal information that we hold about you is kept confidential and secure, including by:
• having robust physical security of our premises and databases / records.
• taking measures to restrict access to only personnel who need that personal information to effectively provide services to you.
• having technological measures in place (for example, anti-virus software, firewalls).
Despite these measures, we cannot guarantee the security of information transmitted over the internet, and you provide personal information at your own risk.

Online activity
Cookies: Our website uses cookies. A cookie is a small file of letters and numbers the website puts on your device. These cookies recognise when your device has visited our website(s) before so we can distinguish you from other users of the website. This improves your experience and our website. We may use cookies to identify you and to improve your experience on our website. If you do not wish to use the cookies, you can amend the settings on your internet browser so it will not automatically download cookies.
Website analytics: Our website uses analytics to help us better understand visitor traffic so we can improve our services. Although this data is mostly anonymous, it is possible that under certain circumstances, we may connect it to you.
Direct marketing: We may send you direct marketing communications and information about our services, opportunities, or events that we consider may be of interest to you if you have requested or consented to receive such communications. These communications may be sent in various forms, including mail, SMS, fax and email. You may opt-out of receiving marketing communications from us at any time by following the instructions to “unsubscribe'' set out in the relevant communication or contacting us using the details set out in the “How to contact us” section below.

How to access and correct your personal information
We will endeavor to keep your personal information accurate, complete and up to date. If you wish to make a request to access and / or correct the personal information we hold about you, you should make a request by contacting us using the details provided below. We will respond to your request within a reasonable time, usually within 30 days.

Links to third party sites
Our website contains links to websites operated by third parties. If you access a third-party website through our website, personal information may be collected by that third-party website. We make no representations or warranties in relation to the privacy practices of any third-party provider or website, and we are not responsible for the privacy policies or the content of any third-party provider or website. Third-party providers / websites are responsible for informing you about their own privacy practices, and we encourage you to read their privacy policies.

Inquiries and Complaints
If you believe we have breached your privacy rights, you can make a complaint by contacting us using the details provided below. We will:
• acknowledge your complaint promptly.
• investigate the matter thoroughly.
• respond to you within 30 days or as soon as practicable.
If you are dissatisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC).

How to contact us
If you have a question or concern about our handling of your personal information or this Policy, you can contact us at privacy@spartanssec.com.