Privacy Policy
How we collect, use, and protect your information.
Privacy Policy
SART CREATIVE TRADING SRL · Draft — Effective date to be confirmed
Introduction
This Privacy Policy explains how SART CREATIVE TRADING SRL ("Spartan," "we," "us," or "our") collects, uses, shares, and protects information when you use the Spartan mobile application and the Spartan website (together, the "Service").
Spartan is established in Romania, a European Union Member State. Where EU data protection law, including the General Data Protection Regulation ("GDPR"), applies to our processing of your personal information, we intend to comply with it.
TO BE CONFIRMED — final confirmation from legal counsel of every data protection regime that applies to Spartan's user base (e.g., GDPR, UK GDPR, or others), and the complete rights language required for each, before this Policy is published.
This Policy should be read alongside the Terms & Conditions and the Official Spartan Handbook, which describe how Challenge Levels, Badges, Streaks, Spartan Shields, the Spartan Wallet, Prize Pools, and Contribution Weight function.
Information We Collect
Account Information
When you create a Spartan account, we collect information such as your name, email address, and password (or authentication credentials, if you sign in through a third-party provider). Because Spartan requires users to be at least 18 years old, we may also collect information necessary to confirm your age.
TO BE CONFIRMED — the exact method used to confirm a user's age at signup.
Challenge & Activity Data
To operate the Service, we collect the data generated by your use of it, including:
- Your selected Challenge Level for each month;
- Session records (start/end time, duration, steps, distance);
- Verification results for each session;
- Your streak, Badge history, Shield inventory, and Prize Pool history;
- The statistics listed in the Official Spartan Handbook (Current Challenge Level, Current Streak, Longest Streak, Current Badge, Highest Badge Achieved, Sessions Completed, Total Steps, Total Distance, Monthly Success Rate, Prize Pool History, Rewards Earned).
As described in the Handbook, these statistics represent your permanent journey within Spartan and cannot be edited or manually changed by you or by us.
Location Data
During a tracked walking or running session, we collect location data from your device. This data is used to verify that your session was completed outdoors and meets the requirements of your selected Challenge Level.
TO BE CONFIRMED — whether location data is collected only during active sessions or at any other time, and the exact retention period for raw location data versus the derived verification result.
Payment, Subscription & Wallet Data
When you subscribe to a Challenge Level, or add funds to your Wallet, your payment is processed by our payment provider, Stripe. We receive confirmation of payment, subscription status, and transaction history from Stripe, but we do not store your full card or bank account number. Approved Wallet withdrawals are paid out using the same payment method you originally used to subscribe, through Stripe.
We also maintain your Spartan Wallet balance and a complete Wallet History, covering subscription purchases, Commitment Deposit refunds, Bronze Rewards, Silver/Gold/Elite Prize Pool rewards, Shield purchases, Wallet top-ups, and withdrawals. As with your other Spartan statistics, your Wallet History is permanently recorded and remains available inside your account.
Fraud & Account Review Data
If suspicious activity is detected on your account, we collect any additional information you provide during the resulting review, including any evidence submitted in response to our request within the 14-calendar-day response window.
Device & Technical Information
We may collect technical information such as device type, operating system version, app version, and crash or diagnostic logs, to operate and improve the Service.
TO BE CONFIRMED — specific diagnostic/analytics tools in use.
Communications
If you contact our support team, we collect the content of your communications and any information you choose to provide to resolve your inquiry.
Website Cookies
The Spartan website may use cookies and similar technologies. See the Cookie Policy for details.
How We Use Your Information
We use the information described above to:
- Create and maintain your account, and confirm you meet the minimum age requirement;
- Manage Monthly Enrollment and verify your sessions against your selected Challenge Level's requirements;
- Calculate your streak, Badge, Shield inventory, Contribution Weight, and Prize Pool eligibility and rewards;
- Process your subscription, Platform Fee, Commitment Deposit, and Wallet balance, including refunds, forfeitures, top-ups, and withdrawal requests, via Stripe and Spartan's own systems;
- Perform Monthly Settlement;
- Send you service-related communications and, where permitted, push notifications;
- Provide customer support;
- Detect and review suspicious activity and prevent fraud, cheating, or misuse of the Service;
- Comply with legal obligations;
- Improve and develop the Service.
TO BE CONFIRMED — whether any aggregated or anonymized data is used for marketing or shared with partners. Spartan does not use your Challenge, activity, or location data to sell targeted advertising to third parties.
GPS and Location Permissions
The Spartan app requests access to your device's location services so that it can verify that a walking or running session was genuinely completed outdoors, in line with the Session Requirements described in the Official Spartan Handbook. You can decline or revoke this permission at any time through your device settings, but doing so will prevent you from completing a verifiable session.
The precise technical mechanism used to verify sessions using location data is part of Spartan's internal verification system and is intentionally not detailed publicly.
TO BE CONFIRMED — confirm with engineering the exact scope of location collection (e.g., whether it is limited strictly to the duration of an active session) before publishing this section.
Data Retention
We retain your account and activity data for as long as your account is active, and for a further period afterward as necessary to comply with legal, accounting, or dispute-resolution obligations.
As documented in the Official Spartan Handbook, your historical statistics (streak history, Badge history, Prize Pool history, and rewards earned) and your complete Wallet History (subscription purchases, Commitment Deposit refunds, Bronze Rewards, Prize Pool rewards, Shield purchases, Wallet top-ups, and withdrawals) are retained permanently as a record of your journey, even after an account is cancelled, and cannot be edited or deleted on request in the same way other personal data can.
TO BE CONFIRMED — specific retention periods for other categories of data (raw location data, fraud review records, support communications, device logs).
Your Rights
Depending on your jurisdiction, you may have rights to access, correct, delete, restrict, or port your personal information, and to object to certain processing. Where applicable law grants these rights, you may exercise them by contacting us at support@spartanroutine.com.
Please note that your permanent Spartan statistics and Wallet History (see Data Retention) are retained as an accurate historical record even where other personal data associated with your account is deleted, to the extent permitted by applicable law.
TO BE CONFIRMED — the complete rights language required once the applicable data protection regimes referenced in the Introduction are confirmed.
International Data Transfers
Your information may be processed in a country other than the one in which you reside, including by Stripe and any hosting or infrastructure providers we use.
TO BE CONFIRMED — the countries in which Spartan and its providers process data, and the safeguards used for any cross-border transfer.
Data Security
We use reasonable technical and organizational measures designed to protect your information from unauthorized access, loss, or misuse. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
Spartan does not claim any specific compliance certification (e.g., ISO 27001, SOC 2) unless and until it has actually been obtained.
Push Notifications
The Spartan app may send you push notifications relating to your monthly challenge, sessions, streaks, Badges, Prize Pools, or Wallet activity. You can manage or disable push notifications at any time through your device's notification settings.
Minimum Age
The Service is only available to users who are at least 18 years old, as described in the Official Spartan Handbook. We do not knowingly collect personal information from anyone under 18. If you believe a person under 18 has created a Spartan account or provided us with personal information, please contact us at support@spartanroutine.com.
Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will provide notice through the app, the website, or email before the changes take effect.
Contact Us
Questions about this Privacy Policy, or requests relating to your personal information, can be sent to support@spartanroutine.com.