1Who We Are
Sparta Pewter USA, Inc. (“Sparta Pewter,” “we,” “us,” or “our”) is a Florida corporation and a U.S. manufacturer of custom promotional products, challenge coins, recognition awards, drinkware, apparel, and related goods. We have manufactured in the United States since 1983.
Postal address: 5924 Sandphil Road, Sarasota, FL 34232-6301, United States
Telephone: 888.923.2999 (toll-free) / 941.379.9696
Privacy contact: sales@spartausa.com (Attn: Privacy)
For the purposes of the EU and UK General Data Protection Regulation, Sparta Pewter USA, Inc. is the controller of the personal data described in this notice.
We operate an affiliated Canadian entity, Sparta 2002 Designs & Promotions Inc. (Montreal, Quebec). Where that affiliate is involved in producing or fulfilling your order, your information may be shared with it as described in Section 7.
2Scope of This Notice
This notice explains how we collect, use, disclose, and safeguard personal information when you:
- visit spartapewter.com or any other website we operate (the “Sites”);
- create an account, place an order, or submit a request for quote;
- upload artwork, logos, or production files to us;
- contact us by phone, email, or web form;
- subscribe to marketing communications; or
- interact with us as a business, government, or military customer.
This notice does not apply to our employment practices or to third-party websites we link to.
3Information We Collect
3.1 Information you provide directly
| Category | Examples |
|---|---|
| Identifiers & contact data | Name, job title, employer or unit/command name, billing and shipping address, email address, telephone number, account username and password |
| Commercial information | Products viewed, quote requests, order history, quantities, customization selections, purchase amounts |
| Payment information | We do not collect payment card details through the Sites. Orders are placed through our request-for-quote process, and payment is arranged with our team by invoice. Where you pay by card, payment is handled by our payment processor, and we do not store full payment card numbers on our systems. We may also collect billing details and tax-exemption certificates. |
| Customer content | Artwork, logos, insignia, text, proofs, and other files you upload or send for production, together with any personal information those files happen to contain (for example, names to be engraved on awards) |
| Communications | Emails, web-form submissions, call notes, and correspondence with our sales and art departments |
| Business/government account data | Credit-application information, purchase-order numbers, contracting officer details, and similar information supplied by business, federal, and military purchasers |
3.2 Information collected automatically
When you use the Sites we and our service providers automatically collect: IP address, approximate location derived from IP address, device and browser type, operating system, referring and exit pages, pages viewed, search terms used on the Sites, clickstream and session activity, and dates and times of access. This is collected through cookies, pixels, tags, and server logs (see Section 5).
3.3 Information from third parties
We may receive information from our payment processor, shipping carriers, advertising and analytics providers, credit-reference sources (for business net-terms accounts), and publicly available business directories.
3.4 Sensitive personal information
We do not seek to collect sensitive personal information (as defined under U.S. state privacy laws) or special-category data (as defined under the GDPR). We do not use or disclose sensitive personal information for purposes other than those permitted without a right to limit under the California Consumer Privacy Act. Please do not submit special-category or sensitive data to us in artwork files or correspondence unless it is necessary for your order.
4How and Why We Use Personal Information
The table below sets out our purposes and, for individuals in the EEA and UK, the legal basis on which we rely.
| Purpose | EEA/UK Legal Basis |
|---|---|
| Providing quotes, accepting and fulfilling orders, producing custom goods, and delivering products | Performance of a contract (Art. 6(1)(b)); legitimate interests where you act for a business (Art. 6(1)(f)) |
| Processing payments, invoicing, credit assessment, and collections | Performance of a contract (Art. 6(1)(b)); legitimate interests in managing credit risk (Art. 6(1)(f)) |
| Customer service, art proofing, and responding to enquiries | Performance of a contract (Art. 6(1)(b)); legitimate interests (Art. 6(1)(f)) |
| Account creation and administration | Performance of a contract (Art. 6(1)(b)) |
| Direct marketing, newsletters, and catalog mailings | Consent (Art. 6(1)(a)) where required; legitimate interests in B2B marketing to existing business contacts (Art. 6(1)(f)) |
| Site analytics, performance measurement, and improving the Sites | Consent for non-essential cookies (Art. 6(1)(a)); legitimate interests (Art. 6(1)(f)) |
| Targeted and cross-context advertising, including remarketing | Consent (Art. 6(1)(a)) |
| Fraud prevention, network and information security | Legitimate interests (Art. 6(1)(f)) |
| Verifying rights to use submitted artwork, trademarks, and government or military insignia | Legitimate interests in legal compliance and risk management (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) |
| Tax, accounting, export-control, and government-contracting recordkeeping | Legal obligation (Art. 6(1)(c)) |
| Establishing, exercising, or defending legal claims | Legitimate interests (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) |
Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms. You may request further information about that assessment using the contact details in Section 15.
5Cookies, Pixels, and Similar Technologies
We use cookies and similar technologies on the Sites. By continuing to use the Sites, you consent to our use of cookies as described in this notice. Cookies fall into the following categories:
- Strictly necessary — required to operate the Sites, maintain your session, hold cart and quote contents, and provide security. These cannot be switched off.
- Functional — remember preferences such as language and accessibility settings.
- Analytics/performance — help us understand how the Sites are used. We currently use Google Analytics 4, deployed through Google Tag Manager.
- Advertising/targeting — used to deliver and measure advertising, including remarketing. We currently use the LinkedIn Insight Tag.
Managing cookies. You can control or delete cookies at any time through your browser settings, although blocking strictly necessary cookies will impair the Sites. You can also opt out of interest-based advertising directly with our vendors: Google Ads Settings, LinkedIn advertising opt-out, and the industry tool at optout.aboutads.info.
6Sale, Sharing, and Targeted Advertising
We do not sell personal information for money. However, our use of advertising and analytics cookies may constitute a “sale” or “sharing” of personal information for cross-context behavioral advertising under the California Consumer Privacy Act, and “targeted advertising” under other U.S. state privacy laws.
The categories of personal information involved are identifiers, internet and network activity information, and inferences. The categories of recipients are advertising networks and analytics providers. We do not knowingly sell or share the personal information of consumers under 16 years of age.
You may opt out at any time through the vendor opt-out tools and browser controls described in Section 5, or by contacting us using the details in Section 15.
7How We Disclose Personal Information
We disclose personal information to the following categories of recipients, in each case only as necessary for the purposes described above:
- Affiliates — including Sparta 2002 Designs & Promotions Inc. (Canada), for production and fulfillment.
- Service providers and processors — website hosting, IT and security, payment processing, email and marketing platforms, customer-support tools, analytics providers, and cloud storage.
- Manufacturing and decoration partners — where a product or decoration method is produced outside our own facilities.
- Shipping and logistics carriers — and, for international shipments, customs authorities and customs brokers.
- Professional advisers — accountants, auditors, insurers, and legal counsel.
- Government and regulatory authorities — where required by law, including in connection with our federal government contracts, export-control obligations, and lawful requests.
- Corporate transactions — an actual or prospective buyer in connection with a merger, acquisition, financing, or sale of assets.
We do not disclose your artwork, logos, or order details to unrelated third parties for their own marketing purposes.
8International Transfers
We are based in the United States and our systems and service providers are located primarily in the United States and Canada. If you are in the EEA or UK, your personal information will be transferred outside your home jurisdiction.
Where we transfer personal information out of the EEA or UK, we rely on:
- the European Commission’s Standard Contractual Clauses (2021), and the UK International Data Transfer Agreement or UK Addendum, together with a transfer impact assessment; and/or
- the European Commission’s adequacy decision for Canada (commercial organizations) in respect of our Canadian affiliate.
You may request a copy of the safeguards we use by contacting us at the address in Section 15.
9Retention
We retain personal information only for as long as necessary for the purposes described in this notice, and then delete or anonymize it. Our general retention periods are:
| Category | Retention period |
|---|---|
| Order, invoice, and tax records | As required by IRS and Florida recordkeeping requirements (typically seven years) |
| Federal government contract records | As required by applicable FAR record-retention clauses |
| Customer artwork, proofs, and production files | Retained to support reorders, unless you ask us to delete them |
| Account records | Duration of the account, plus a reasonable period after closure |
| Marketing contact data | Until you unsubscribe, plus a suppression record thereafter |
| Website analytics and log data | Per our analytics retention settings (typically 14 months) |
10Security
We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction, including encryption in transit, access controls, and vendor due diligence. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
11Your U.S. State Privacy Rights
Depending on your state of residence, you may have the right to:
- Know / access the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of third parties to whom we disclose it;
- Delete personal information we hold about you;
- Correct inaccurate personal information;
- Obtain a portable copy of personal information you provided to us;
- Opt out of the sale or sharing of personal information, of targeted advertising, and of profiling that produces legal or similarly significant effects;
- Limit the use and disclosure of sensitive personal information (California);
- Appeal a decision we make on your request; and
- Be free from discrimination for exercising any of these rights.
These rights apply to residents of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, and Florida, subject to the terms and exceptions of each state’s law. Not every right is available in every state.
11.1 How to exercise your rights
Submit a request by email to sales@spartausa.com (subject line “Privacy Request”), by telephone at 888.923.2999, or by post to the address in Section 15.
We will verify your identity before responding, typically by matching the information in your request against information already in our records. If you use an authorized agent, we may require proof of the agent’s authority and may require you to verify your own identity directly.
We will respond within 45 days, and may extend once by a further 45 days where reasonably necessary, with notice to you.
11.2 Appeals
If we decline your request, you may appeal by writing to sales@spartausa.com with the subject line “Privacy Request Appeal.” We will respond in writing within 60 days with our decision and the reasons for it. If your appeal is denied, you may contact your state Attorney General to submit a complaint.
11.3 Additional California disclosures
The categories of personal information we have collected, disclosed for a business purpose, and shared in the preceding 12 months are set out in Sections 3, 6, and 7. California residents may exercise their rights through the mechanisms above, including opting out of sharing via the tools in Section 5. We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.
12Your Rights in the EEA and United Kingdom
If you are located in the EEA or UK, you have the right to request access to, rectification of, or erasure of your personal data; to request restriction of processing; to object to processing carried out on the basis of legitimate interests; to data portability; to withdraw consent at any time without affecting the lawfulness of prior processing; and not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects.
We do not carry out automated decision-making, including profiling, that produces legal or similarly significant effects concerning you.
You have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or place of the alleged infringement. In the UK, this is the Information Commissioner’s Office (ico.org.uk).
We have assessed that we are not required to appoint a Data Protection Officer, because our core activities do not consist of large-scale processing of special-category data or large-scale regular and systematic monitoring.
13Canada
If you are located in Canada, you have the right to access and request correction of your personal information under the Personal Information Protection and Electronic Documents Act and applicable provincial legislation, and you may withdraw consent subject to legal and contractual restrictions. Requests may be submitted using the contact details in Section 15.
14Children’s Privacy
The Sites are intended for business and adult purchasers. We do not knowingly collect personal information from children under 13 years of age, and we do not knowingly sell or share the personal information of anyone under 16. In the EEA and UK, we do not knowingly process the personal data of anyone under the applicable age of digital consent (13 to 16 depending on country). If you believe a child has provided us with personal information, contact us at sales@spartausa.com and we will delete it.
15Contact Us
Sparta Pewter USA, Inc.
Attn: Privacy
5924 Sandphil Road
Sarasota, FL 34232-6301
United States
Email: sales@spartausa.com
Telephone: 888.923.2999 (toll-free) / 941.379.9696
16Government, Military, and Business Customers
Where you interact with us on behalf of a business, government agency, or military unit, we process your contact and order information for the purpose of performing the resulting contract and complying with applicable procurement, export-control, and recordkeeping obligations, including those attaching to our General Services Administration contracts. Personal information supplied in that capacity is generally business-contact information rather than consumer personal information, and certain U.S. state privacy rights may not apply to it.
17Third-Party Links
The Sites may link to third-party websites and services that we do not control. This notice does not apply to them, and we are not responsible for their privacy practices. Review their notices before providing personal information.
18Changes to This Notice
We may update this notice from time to time. We will post the revised version on this page and update the “Last Updated” date. Where changes are material, we will provide additional notice, such as by email or a prominent notice on the Sites. Your continued use of the Sites after the effective date constitutes acceptance of the revised notice.