1.DEFINITIONS AND INTERPRETATION
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Sites;
“Cookie” means a small text file placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in section 16, below;
“Personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Sites. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)
“We/Us/Our” We Are Star Digital Ltd. a limited company registered in England under company number 06795098, whose registered address is Mappin House, 4 Winsley Street, London, England, W1W 8HF
2. INFORMATION ABOUT US
2.1 Our Sites is owned and operated by We Are Star Digital Ltd. a limited company registered in England under company number 06795098, whose registered address is Mappin House, 4 Winsley Street, London, England, W1W 8HF
2.2 Our Data Protection Officer can be contacted by email at email@example.com, by telephone on 0208 088 7827, or by post at FAO Data Protection Officer, We Are Star Digital Ltd., Mappin House, 4 Winsley Street, London, England, W1W 8HF.
3. WHAT IS OUR LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
We are processing your Personal Data on the following lawful basis:
- Consent of the data subject; in order to use Our Sites you will be required to read and agree to the processing of your personal information via a signed written contract, tick box or confirmation button depending on the service.
- Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract.
- Processing necessary for compliance with a legal obligation.
4. YOUR RIGHTS
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data we hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please Contact Us using the details provided in section 2 and We will do our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. WHAT DATA DO WE COLLECT?
Depending upon your use of Our Sites, We may collect some or all of the following personal data:
5.2 Date of birth
5.4 Business/company name
5.5 Job title
5.6 Contact information such as email addresses and telephone numbers
5.7 Demographic information such as post code, preferences and interests
5.8 Financial information such as credit / debit card numbers
5.9 IP address
5.10 Web browser type and version
5.11 Operating system
6. HOW DO WE USE YOUR DATA?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your Account
6.2.2 Providing and managing your access to Our Sites
6.2.3 Personalising and tailoring your experience on Our Sites
6.2.4 Supplying Our products and services to you
6.2.5 Personalising and tailoring Our products for you
6.2.6 Replying to emails from you
6.2.7 Supplying you with emails about our products and services with regards to
our legitimate business interests (you may unsubscribe or opt-out at any time
6.2.8 Market research
6.2.9 Analysing your use of Our Sites to enable Us to continually improve Our Sites and your user experience
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email telephone, text message or post with information, news and offers on Our products. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and as required by applicable law. This may include keeping your Other Information after you have deactivated your account for the period of time needed for We Are Star to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
7. HOW AND WHERE DO WE STORE YOUR DATA?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Sites.
8. DO WE SHARE YOUR DATA?
8.1 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3 We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
In the course of providing Our services, We will analyse your information to build individual profiles. These profiles will be used to predict future interests and display targeted marketing. The aim is to provide you with We Are Star offers that are relevant and interesting for you. The profiling is based on your (surfing) behaviour on the internet which includes the viewing of articles and opening/engagement with our emails. You have the right to withdraw your consent at any time, by sending an email to: firstname.lastname@example.org and we will discontinue the processing of your information upon receipt of your withdrawal. However, this may result in you no longer being able to access some of Our services.
10. FURTHER PROCESSING
11. WHAT HAPPENS IF OUR BUSINESS CHANGES HANDS?
11.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
12. HOW CAN YOU CONTROL YOUR DATA?
12.1 In addition to your rights under the GDPR, set out in section 3, When you submit personal data via Our Sites, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.
13. YOUR RIGHT TO WITHHOLD INFORMATION
You may access Our Sites without providing any data at all. However, to use all features and functions available on some of Our Sites you may be required to submit or allow for the collection of certain data.
14. How CAN YOU ACCESS YOUR DATA?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com for the process for subject data access requests.
15. OUR USE OF ANALYTICS
15.1 Our Sites use analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Sites are used. This, in turn, enables Us to improve Our Sites and the products offered through it. You do not have to allow Us to use Our Sites Analytics, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Sites, it does enable Us to continually improve Our Sites, making it a better and more useful experience for you.
15.2 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
16.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
16.3 We use the following cookies: a) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. c) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).d) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
16.4 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.
16.5 Except for essential cookies, all cookies have a pre-designated lifespan after which they will expire.
17. CONTACTING US