(Last Updated September 22, 2020)

1. Introduction

Welcome to Ageras.com website Privacy Statement. This website and service is provided by Ageras USA Inc., with business office address at 2 Penn Center, 1500 JFK Blvd, Suite 1220, Philadelphia, PA 19102 USA. Please read this privacy statement carefully for it explains our rights to the processing of your data.

Ageras takes your privacy seriously and the use, disclosure and protection of your information is important to us. This policy covers how Ageras, collects, uses, discloses, transfers, stores and protects your personal information. We encourage you take a moment and familiarize yourself with our privacy practices and contact us at Spartacredit.com for any further clarification.

This Privacy Policy has been developed in accordance with the EU General Data Protection Regulation (GDPR) as well as in support of the EU-US Privacy Shield requirements.

I. Introduction II. Data Protection Principles III. Summary of Personal Information and Use IV. Personal Information We Collect About You (PIPEDA) V. Purposes of Data Collection VI. Data Collection Methods VII. Information Collected and Stored Automatically (Web Analytics Data) VIII. Types of Data Collected IX. Non-Personal Information X. How we use this data XI. Opt-Out XII. Google Adwords XIII. Third Party Disclosures XIV. Ageras as a Controller XV. Cookies XVI. Do Not Track XVII. Browser Information Collected on the Website XVIII. External Links XIX. Children's Privacy (COPPA) XX. Compliance with Laws XXI. Retention period XXII. Site Security XXIII. Information Security XXIV. International Transfers XXV. If you are located in California (CALOPPA) XXVI. GDPR Data Privacy Rights XXVII. Data Subject Rights XXVIII. Your Right To Withdraw Consent XXIX. Complaint Process and Independent Recourse Mechanism XXX. Jurisdiction XXXI. Terms and Conditions XXXII. Contact Us XXXIII. Changes to Privacy Policy

2. Data Protection Principles

Ageras is dedicated to ensuring the security of your personal data and adhering to compliance with applicable data protection laws. As a summary of how Ageras protects and utilizes your personal data, the organization is committed to ensuring that your personal data is:

  • used lawfully, fairly and in a transparent way;

  • collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

  • relevant to the purposes we have told you about and limited only to those purposes;

  • accurate and kept up-to-date;

  • allowed for you as the individual to request access to your personal data

  • kept only as long as necessary for the purposes we have told you about; and

  • kept securely

3. Summary of Personal Information and Use

Ageras may collect or obtain Personal Data about you, and this information may be transferred from a location outside USA to other regions through the following methods:

  • directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase);

  • when you make your Personal Information public,

  • when you visit our website; when you register to use any part of the Services;

  • when you volunteer Personal Data about yourself in public areas of the Services; when you interact with any third party content or advertising;

We may also receive Personal Information about you from third parties.

4. Personal Information We Collect About You (PIPEDA)

According to the personal information protection and electronic documents act, 2000 (PIPEDA), \"personal information\" means information about an identifiable individual. The information you provide to us is considered personally identifiable information, which may include your name, address, e-mail address, telephone number, and any other information that can identify you. If PII cannot be related to an individual, it is considered anonymous. Whenever possible, Ageras works with anonymous information. This privacy statement does not apply to anonymous information

5. Purposes of Data Collection

For data collection methods as described for Ageras as a Company the following examples of uses of this Personal Information may be used for:

  • Provision of Services to you

  • Offering and Improving the Service

  • Completing your Order

  • Surveys

  • Communication

  • Advertising

  • User Engagement

  • Marketing

  • Lead Generation

  • Legal Compliance

6. Data Collection Methods

The personal data we collect from you, and the way we collect it from you, includes the following methods when you:

  • Visit our website

  • Receive or provided communication from or to us through:

  • Use our products and services as an authorized user

  • Register for or attend Ageras events, webinars, or surveys

7. Information Collected and Stored Automatically (Web Analytics Data)

When you visit Ageras, we may store some or all of the following:

  1. The IP address from which you access Ageras.

  2. The date and time of access.

  3. The Internet address of the website from which you linked to Ageras.

  4. The browser and operating system used, and any other related information.

This information is used for our legitimate purpose of measuring the number of visitors to the various sections of our site and identifying system performance or problem areas. We also use this information to help us develop the site, analyse patterns of usage, and to make the site more useful. This information is not used for associating search terms or patterns of site navigation with individual users. Simply means that if multiple users are using one account from the same IP address Ageras will get their account banned from the site

8. Types of Data Collected

When you make a purchase on our website we acquire some Data (PII) from you such as

  • Personal Identifiable Information (PII). We Collect PII that includes, Full name, company name, job title, email address, billing information, Information relevant to the legal advice and assistance for which you wish to obtain quotes, including the contents of any Request for Quotes you submit.‚Äč and other relevant information which helps us to operate and provide you our services

  • Financial Information: we will collect billing information from you when you make a purchase using the Ageras website.

  • Sensitive PII: Information about the transactions you make on our Services, such as the names, mobile number, e-mail address, and other information about the directly connected accounts to your account, which are attracted to our service by you.

9. Non-Personal Information

Non-personal information refers to information that, by itself, does not identify you as a specific individual (e.g., demographic information or web site visitations). Ageras may collect non-personal information through any of the methods discussed above, as well as automatically through the use of industry-standard technologies described further below.

10. How we use this data

This information is used in order to take steps to conclude a contract with you, or to provide our services to you, as well as to enable you to use them. We may also use these personal data for our legitimate purpose of contacting you with newsletters, marketing or promotional materials and other information concerning our activities that may be of interest to you.

11. Opt-Out

You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us. You as an individual retain the right to withhold in part or in full your personal information in order to limit our use and availably of this data. Please note that refusal to provide Personal Information may result in our inability to provide the Services to you, to manage our relationship with you, or to improve the Services provided to you.

12. Google Adwords

Google AdWords enables Google, through the use of cookies, to identify the fact that you have visited the website, to identify aspects of your usage of the site, and combine that with what it knows about your usage of another website in the Google ad network.

We use these services to advertise to visitors of Google ad network Apps who have previously visited our website or who Google deems to have shared interests with visitors to our website. The Google privacy policy covers Google\'s collection and use of your personal data. You can set preferences for how Google advertises to you using the Google Ad Preferences page.

13. Third Party Disclosures

As a standard practice Ageras does not disclose personal information to any third party or unauthorized party for any reason. Should Ageras be required to disclose any personal data to third parties it will not do so unless fully authorized by the client agreement or in accordance with support of the agreement, or applicable law.

14. Ageras as a Controller

Ageras direct methods of personal data collection include through our website, marketing, sales outreach, and third party provided information. This information is used solely to contact individuals and or organizations about sales, adverting or marketing prospects of Ageras products. Any discloser of personal information to a third party is relegated to only be used on behalf of Ageras and at Ageras' direction, and not for any other purpose.

15. Cookies

When you visit some websites, their web servers generate pieces of information known as cookies. Cookies are commonly used to recognize your computer in the future. Ageras also uses session cookies for its legitimate interest of pursuing technical purposes, such as providing seamless navigation through our site, allow you to carry information across pages of our site and avoid having to re-enter information. These cookies do not permanently record data and they are stored on your computer browser. If you don't want cookies to be stored on your computer you can simply go to your browser settings and clear your cookies cache or refuse cookies. For more information please visit our Cookies policy page

16. Do Not Track

Do Not Track (\"DNT\") is a privacy preference that users can set in specific web browsers and devices. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honour DNT signals or similar mechanisms transmitted by web browsers.

17. Browser Information Collected on the Website

Various elements of data sets may be collected to track the usefulness of certain actions and to ultimately improve the value of Ageras.com. Please note that Ageras does not gather, request, record, require, collect or track any type of Internet users' personal data (as listed above) through these processes.

18. External Links

Ageras may contain links to websites created and maintained by other public and/or private organizations. Ageras therefore provides these links as a service to our users, and when users click on a link to an external website, they are leaving Ageras and are thus subject to the privacy and security policies/related terms and conditions of these external websites.

19. Children's Privacy (COPPA)

Ageras complies both with the Children's Online Privacy Protection Act of 1998 (COPPA) and, with regard to EU data subjects, with GDPR. While children under the age of (18) may use the Site only with the consent of his or her parent or legal guardian, please be advised that this Site is not directed or otherwise promoted for use by children under the age of (18). By using the Service, you represent that you are at least (18) years of age. If you are between (18) and twenty one (21) years of age, you will need to have parental consent to use the Service. If you are below eighteen years of age, you should stop using the Site and Service immediately. Personal data from children under 18 is not knowingly collected, nor are children under 18 knowingly contacted by Ageras. To be clear, Ageras does not intend to solicit information of any kind from children under 18.

20. Compliance with Laws

Except for authorized law enforcement investigations by local, state, and/or federal agencies, no other attempts are made by Ageras to identify individual users and/or their usage habits on Ageras.

  • Ageras as required by local, state, country or federal law will disclose your personal information where required to do so by law or subpoena or if we believe that such action is necessary to pursue our legitimate interest of complying with the law and the reasonable requests of law enforcement or of protecting the security or integrity of our services.

21. Retention period

We will keep your personal data only for as long as necessary to fulfil the purposes for which we are processing it, unless the law permits or requires longer. For example, we might need to keep your personal data for quality assurance of the service we have provided, or we might need to keep it to defend future legal claims or to comply with a legal obligation.

22. Site Security

For site security purposes and to ensure that this service remains available to all users, the platform for which Ageras resides on -- commonly known as a "production environment", utilizes a wide-range of software tools and programs to for the ultimate goal of ensuring its confidentiality, integrity, and availability (CIA) -- a concept known as the CIA triad of information security. Tools which are currently in use, or are to be deployed if necessary for the security of Ageras are to include, but are not limited to, the following:

  • Network Security and Network Monitoring: Tools that assist in securing the network for which Ageras resides on. Such tools include network and perimeter firewalls, web application firewalls, routers, switches, intrusion detection systems, and other related tools.

  • Network Performance: Tools that assist in monitoring all aspects of Ageras, such as performance monitoring for website uptime, etc.

  • Other: Additionally, a variety of physical, electronic and procedural safeguards are implemented for helping ensure the safety and security of Ageras.

23. Information Security

All information accessed through Ageras website or App is in compliance with the required information security mandates of Article 32 of the GDPR. Specifically, Article 32 mandates the following:

  • Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk:

  • Encryption of personal data

  • The ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services.

  • The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.

  • A process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

24. International Transfers

Your Personal Information, may be transferred to, and maintained on, systems located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside USA and choose to provide information to us, please note that we transfer the information, including Personal Information, to the U.S and process it here. If you are in the EU, in transferring your Personal Information to countries outside of the EU, we will take appropriate steps to ensure that such recipients act in accordance with applicable laws. To the extent that we transfer the personal data to recipients who are located outside the European Union or the European Economic Area, we will provide an adequate level of protection of your personal data, including appropriate technical and organizational security measures and through the implementation of appropriate contractual measures to secure such transfer, in compliance with applicable law. See our Privacy Shield disclosure, below, for further information about our self-certification under the EU-U.S. Privacy Shield Framework.

25. If you are located in California (CALOPPA)

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for direct marketing purposes by such third party and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. Please see our California Policy Page

26. GDPR Data Privacy Rights

If you are an EU resident and Ageras is processing, and/or transmitting your personal data, then you - as an "EU data subject" -- benefit from the following rights and privileges under the General Data Protection Regulation (GDPR):

  • Right of Access: you have the right to obtain from us, as controllers, confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the following personal data and information:
  1. the purposes of the processing;

  2. the categories of personal data concerned; i.e name, email, phone number etc

  3. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations';

  4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

  5. the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing; (f) the right to lodge a complaint with a supervisory authority (for a list of supervisory authorities, see [https://edpb.europa.eu/about-edpb/board/members_en]);

  6. where the personal data are not collected from you, any available information as to their source;

  7. The existence of automated decision-making, including profiling, along the lines indicated by Article 22(1) and (4) GDPR, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

  • Right to Rectification: you have the right to obtain from us without undue delay the rectification of inaccurate personal data concerned, provided during registration by him or her. Taking into account the purposes of the processing, the user have the right to have request his incomplete personal data be completed, including by means of providing a supplementary statement.

  • Right to Erasure ("Right to be Forgotten): you have the right to obtain from us the erasure of your personal data without undue delay, and we have the obligation to erase personal data without undue delay when: a) your data are no longer necessary for the purposes for which they were collected; b) you had consented to the processing; c) you have objected to the processing, as per below; d) your persona data had been unlawfully collected; e) your personal data need to be erased as a matter of compliance with a legal obligation.

  • Right to Restriction of Processing: you have the right to obtain from us the restriction of processing if you: a) contest the accuracy of the personal data, until this is verified; b) the processing is unlawful but you don't want erasure; c) we no longer need the personal data, but you require them to establish, exercise to defend a legal claim; d) you have objected to processing but there is a need to verify whether our legitimate grounds override your rights to object.

  • Right to Data Portability: where your personal data have been provided on the basis of your consent or for the performance of a contract, and their processing occurs in an automated way, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data-- or have directly transmitted - to another controller.

  • Right to Object: you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data based on a legitimate ground point (e) or (f) of Article 6(1), including profiling based on those provisions. In this case, we can no longer process your personal data unless we show that there is a compelling legitimate ground for the processing which override your interests, rights and freedoms or for our establishment, exercise or defense of legal claims.

27. Data Subject Rights

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals, have the right to obtain our confirmation of whether we maintain personal information relating to you in the U.S. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the Canada under Privacy Shield, should direct their query to US\@Ageras.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to Spartacredit.com. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Ageras's accountability for personal data that it receives in the U.S under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Ageras remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Ageras proves that it is not responsible for the event giving rise to the damage.

28. Your Right To Withdraw Consent

You have the right to withdraw your consent without detriment at any time by contacting us. You can also change your marketing preferences. If we do not satisfactorily resolve your request or concern, you may contact our data protection officer; US\@Ageras.com

29. Complaint Process and Independent Recourse Mechanism

You as the data subject in the EU or Switzerland have the right to bring a complaint directly to Ageras as the Privacy Shield participant and receive a response within 45 days of receipt of the complaint. This complaint as provisioned by the Privacy Shield framework is of no cost to you.

In compliance with the Privacy Shield Principles, Ageras commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the Canada pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact Ageras at: US\@Ageras.com

30. Jurisdiction

Ageras privacy policy and services is governed by the United States of America Laws.

31. Terms and Conditions

To learn more about our terms and conditions, please visit our Terms and Conditions page establishing the use, disclaimers, and limitations of liability governing the use of our website

32. Contact Us

For any questions or requests concerning this Privacy Policy, GDPR, or Privacy Shield, please contact us at: US\@Ageras.com

33. Changes to this Policy

Ageras privacy policy is to be revised and updated as necessary for ensuring its adequacy and sufficiency. You are encouraged to visit this page often for the latest information and the effective date of any changes to such policy. If changes are made to this policy, a new Ageras policy will be prominently posted on our site please make sure you read the updated policy from time to time.