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Privacy Policy

"Our Privacy Policy page provides valuable information on how we handle your personal data and ensure your privacy. Discover our commitment to safeguarding your information, the types of data we collect, how it's used, and your rights regarding your data. We're dedicated to transparency and protecting your privacy every step of the way."

Last updated 01 September 2023.

Scope

This Privacy Policy applies to the processing of personal data, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, mobile application, and other services, offerings, sales, marketing or events are collectively called “Services” StarPrice is the controller (“Controller”) for the personal data we process, unless otherwise stated. For data on how to contact us, please refer to Section 11 Contact Us below.

2

Personal Data We Collect

The categories of personal data we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect data that you provide to us, data we obtain automatically when you use our Services, and data from other sources such as third-party services and organizations, as described below.

2.1   

Personal Data You Provide to Us Directly

We may collect the following personal data that you provide to us.

  • Name and Contact Data. first and last name, email address, postal address, phone number and other similar contact data.

  • Credentials. passwords, password hints, and similar security data used for authentication and account access.

  • Preferences and interests. the preferences and interests you let us know in the course of the account registration

  • Purchase Data. data and details associated with your purchases, including payment data. Any payments made via our Services are processed by Stripe. You may find their privacy policy at https://stripe.com/privacy. We do not directly collect or store any payment card data entered through our Services, but we may receive data associated with your payment card data (e.g., your billing details).

  • Content Data you upload. photos, chat logs, general chat function content, direct messaging content

2.2

Personal Data We Collect From You

We may collect personal data when you use our Services:

  • Device Information and Identifiers. We may collect certain data when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, personal identifiers (e.g. cookies), mobile carrier, mobile advertising and other unique identifiers, browser or device data, location data (including approximate location derived from IP address), and Internet service provider.

2.3

Personal Data collected from other Sources

We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

3

How We Use Your Personal Data

We process your data for various purposes and corresponding legal basis as shown in the table below.

You are not obligated to share your personal data with us. However, if you do not share personal data with us we might not be able to offer all of our services to you.

Purposes for which personal data are processed

Categories of personal data that are processed (please see definitions in section 2 above)

Legal basis of the processing (and legitimate interests pursued, if applicable)

Manage your data and accounts (including service communication about your account, activities on our Services, and policy changes)

Name and Contact InformationPurchase DataCredentials

Necessary to fulfil our contract with you (Art. 6 (1) (b) GDPR) (our Terms of Use).

Provide access to certain areas, functionalities and features of our Services

Name and Contact Information, Credentials, Device Information and Identifiers

Necessary to fulfil our contract with you (Art. 6 (1) (b) GDPR) (our Terms of Use).

Answering requests for customer or technical support

Name and Contact Information Purchase Data Credentials

Our legitimate interests (Art. 6 (1) (f) GDPR) (to provide you with customer support).

Allowing you to communicate to other users

Name and Contact Information

Necessary to fulfil our contract with you (Art. 6 (1) (b) GDPR) (our Terms of Use).

Performing research and development

Device Information and Identifiers Analytic Data

Your consent (Art. 6 (1) (a) GDPR) where such consent is required and obtained otherwise our legitimate interests (Art. 6 (1) (f) GDPR) (to improve our services).

Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.

Device Information and IdentifiersName and Contact Details Credentials

Our legitimate interests (Art. 6 (1) (f) GDPR) (to keep our systems secure e.g. against fraud, spam, malware and other security risks) and efficient and to block unauthorized users)

Measuring interest and engagement in our Services

Analytic DataDevice Information and Identifiers

Your consent (Art. 6 (1) (a) GDPR) where such consent is required and obtained otherwise our legitimate interests (Art. 6 (1) (f) GDPR) (to improve our services)

Developing new products and Services

Analytic DataDevice Information and Identifiers Surveys Preferences and interests

Your consent (Art. 6 (1) (a) GDPR) where such consent is required and obtained otherwise our legitimate interests (Art. 6 (1) (f) GDPR) (to improve our services)

Ensuring internal quality control and safety

Device Information and Identifiers Credentials

Our legitimate interests (Art. 6 (1) (f) GDPR) (to keep our systems secure)

Debugging to identify and repair errors with our Services

Device Information and Identifiers

Our legitimate interests (Art. 6 (1) (f) GDPR) (to keep our systems secure)

Enforcing our agreements and policies

Purchase DataName and Contact Information

Our legitimate interests (Art. 6 (1) (f) GDPR) (that our agreements and policies are adhered by)

Fulfil and manage your orders, payments, returns, and exchanges made through the Services

Purchase DataName and Contact Information

Necessary to fulfil our contract with you (Art. 6 (1) (b) GDPR) (our Terms of Use).

Processing your financial information and other payment methods for products or Services purchased

Purchase DataName and Contact Information

Necessary to fulfil our contract with you (Art. 6 (1) (b) GDPR) (our Terms of Use).

Auditing relating to interactions, transactions and other compliance activities

Purchase DataName and Contact Information Credentials

For compliance with our legal obligations (Art. 6 (1) (c) GDPR).

Complying with any further legal obligations, such as cooperating with law enforcement or tax authorities

Purchase DataName and Contact Information

For compliance with our legal obligations (Art. 6 (1) (c) GDPR).

Processing your personal data we collected on conferences, tradeshows and other events to reach out to you as a business contact

Name and Contact Information

Our legitimate interests (Art. 6 (1) (f) GDPR) (to increase our business contacts)

Sending you newsletters and personalized and relevant marketing communications e-mail, push notification, in-app message or similar, including through cross device tracking,

Name and Contact Information Analytic DataPreferences and interests Device Information and Identifiers

Your consent (Art. 6 (1) (a) GDPR) where such consent is required and obtained otherwise our legitimate interests (Art. 6 (1) (f) GDPR) (to provide you with direct marketing materials our services)

To provide you with relevant marketing communications via phone calls

Name and Contact Information

Your consent (Art. 6 (1) (a) GDPR)

Carrying out surveys

Name and Contact Information Device Information and Identifiers

Your consent (Art. 6 (1) (a) GDPR) where such consent is required and obtained otherwise our legitimate interests (Art. 6 (1) (f) GDPR) (to collect feedback on our services so we can improve them)

Providing interactive features (e.g., messaging and chat features, commenting functionalities, written reviews, forums, blogs, invite a friend tools and social media pages)

Name and Contact Information Information you decide to provide through these featuresContent Data you upload

Your consent (Art. 6 (1) (a) GDPR) where such consent is required and obtained otherwise the nNecessityary to fulfil our contract with you (Art. 6 (1) (b) GDPR) (our Terms of Use).

Fulfilling our legal obligations in connection with sweepstakes or contests

Name and Contact Information

For compliance with our legal obligations (Art. 6 (1) (c) GDPR).

Anonymizing your personal data for statistic evaluation

Name and Contact Information Credentials Purchase HistoryDevice Information and Identifiers

Our legitimate interests (Art. 6 (1) (f) GDPR) (to evaluate your anonymized data for statistic purposes)

3.1

Share Content with Friends or Colleagues.

Our Services may offer various tools and functionalities. For example, we may allow you to provide data about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact data of people with whom you have a relationship (e.g., relative, friend neighbour, or co-worker) and if they have said they are happy to receive referrals from us.

4

How We Disclose You Personal Data

We disclose your data to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

4.1

Disclosures to Provide our Services

The categories of third parties with whom we may share your data are described below.

  • Service Providers. We may share your personal data with our third-party service providers who use that data to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.

  • Business Partners. We may share your personal data with business partners to provide you with a product or service you have requested. We may also share your personal data to business partners with whom we jointly offer products or services.

  • Affiliates. We may share your personal data with our company affiliates for our administrative purposes, including activities such as IT management, for them to provide services to you or support and supplement the Services we provide. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

  • Other Users/Website Visitors. As described above in “Personal Data We Collect,” our Services allow you to share your profile and/or User Content with other Users/publicly, including to those who do not use our Services.

  • Advertising Partners. With your consent, we may share your personal data with third-party advertising partners. These third-party advertising partners may set cookies and other tracking technologies on our Services to collect data regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this data (and similar data collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”

  • APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in Section 11 Contact Us below.

4.2

Disclosures to Protect Us or Others

We may access, preserve, and disclose any data we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

4.3

Disclosure in the Event of Merger, Sale, or Other Asset Transfers

In the event of a business transfer, such as a merger, acquisition, insolvency, restructuring or sale of all or part of our assets, or due diligence procedures in connection with a potential transfer of all or part of the business, the data we collect and process may be disclosed (inter alia to professional advisors involved), co-sold or transferred as part of that transaction based on our legitimate interest to transfer our business (Art. 6 (1) (f) GDPR). If such a transfer is subject to additional restrictions under applicable law, we will comply with those restrictions.

5

International Transfer of Your Personal Data

We may transfer personal data that we collect from you to third parties located in countries that are outside of the UK and the European Economic Area ("EEA") (including to the United States) or to members of our group of companies in connection with the above purposes. Please be aware that countries which are outside the UK and the EEA may not offer the same level of data protection as the UK and the EEA, although our collection, storage and use of your personal data will continue to be governed by this Privacy Notice.

When transferring personal data outside the UK and the EEA, we will:

  • include the standard contractual data protection clauses or addendum approved by the UK Government or the European Commission (as applicable) for transferring personal data outside the UK and the EEA into our contracts with those third parties (these are the clauses approved under Article 46 (2) GDPR)

  • ensure that the country in which your personal data will be handled has been deemed "adequate" by the UK Government or the European Commission (as applicable) under Article 45 of the GDPR and the UK version of it.

You can find out further information about the rules on data transfers outside the UK and the EEA, including the mechanisms that we rely upon, on the European Commission website.

6

Your right to withdraw consent

Consent-Based Processing the following categories of processing are performed based on your consent, which you can withdraw at any time (Art. 7 (3) GDPR). Please see below how you can withdraw such consent. If you ask to withdraw your consent to us processing your personal data, this will not affect any processing which has already taken place at that time.

  • Email.

    You can withdraw your consent by using the unsubscribe link found at the bottom of the email to opt out of receiving future emails or by otherwise contacting us under Contact us.

  • Text Messages.

    You can withdraw your consent by using updating your preferences in your account or by otherwise contacting us under in Contact us.

  • Push Notifications on Mobile Devices.

    You can withdraw your consent by using by changing the settings on your mobile device.

Note that the above does not apply to non-promotional emails, such as communications regarding our Services, any transactions you enter into via our Services, or updates to our Terms or this Privacy Policy.

  • Cookies and Interest-Based Advertising.

    You may stop or restrict the placement of technologies on your device by adjusting your preferences regarding cookies and similar tracking technologies in our Consent Management Tool or by adjusting your preferences as your browser or device permits.

  • Other processing activities based on consent

    You can withdraw your consent by contacting us.

“Do Not Track.”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honour DNT signals or similar mechanisms transmitted by web browsers.

6.1

Your Privacy Rights.

In accordance with applicable law, you have the right to: in particular object to the processing of your personal data by us:

  • in certain circumstances, if we process your data on the basis of Article 6 (1) (e) or (f) GDPR (including profiling) (Art. 21 (1) GDPR), or

  • if we process your data for direct marketing purposes (Art. 21 (2) GDPR).

generally to:

  • Access Personal Data about you, including: (i) confirming whether we are processing your personal data; (ii) obtaining access to or a copy of your personal data (Art. 15 GDPR);

  • Request Correction of your personal data where it is inaccurate, incomplete or outdated. In some cases, we may provide self-service tools that enable you to update your personal data (Art. 16 GDPR);

  • Request Deletion, Anonymization or Blocking of your personal data when processing is based on your consent or when processing is unnecessary, excessive or noncompliant (Art. 17 GDPR);

  • Request Restriction our processing of your personal data under certain circumstances (Art. 18 GDPR);

  • Request data portability and receive an electronic copy of personal data that you have provided to us (Art. 20 GDPR);

  • Request the review of decisions taken exclusively based on automated processingif that could affect data subject rights.

Additionally, if you are based in France, you also the right to:

  • set guidelines regarding the use of your personal data after your death (Art. 85 French Data Protection Act),

  • register on the Bloctel list of objection to cold calling, this is a free service (Art. 223-1 French Consumer Code).

If you would like to exercise any of these rights, please contact us as set forth in 11 Contact Us below. We will process such requests in accordance with applicable laws.

Also you have the right to lodge a complaint to the Irish Data Protection Commission here or an EU data protection authority where you live, work or where you believe a breach may have occurred, see the contact details of the EU Data Protection Authorities.

7

Security of Your Personal Data

We take steps to ensure that your data is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any data you provide to us. We have taken appropriate safeguards to require that your personal data will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

8

Retention of Personal Data

We store the personal data we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfil the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9

Other Provisions

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal data to third-party websites or applications is at your own risk.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after we have notified you of the new Privacy Policy.

10

Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please email us at baris.starprice@gmail.com.

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