We recognize the importance of your privacy and of transparency in our processing of your personal data.
We only process your personal data if we have a valid legal ground to do so.
1.1 We will only process your personal data if we have valid legal ground to do so, for instance in any of the following situations:
- we have obtained your prior unambiguous consent;
- the processing is necessary to comply with our legal or regulatory obligations; or
- the processing is necessary for our legitimate interests except where they are overridden by your interests or fundamental rights and freedoms. Relevant ‘legitimate interests’ include: (i) to benefit from cost-effective services (e.g. we may opt to use certain Sites offered by suppliers); (ii) to protect the security of our IT systems, architecture and networks; (iii) to perform our contractual obligations towards you, if any, and (iv) to meet our corporate and social responsibility objectives.
2. How and Where We Collect Your Personal Data
We collect the personal data which you provide.
2.1 We collect, directly or indirectly via our Partners, the personal data you provide in your correspondence with us and/or our Partners, or in your use of the Site, for example, when you contact us via our contact email address: firstname.lastname@example.org (the Contact Info).
2.2 Such information may include your name, address, email, telephone numbers, job title, business name, business address, industry, interests and any other information which you may choose to provide in that context.
3. Purposes of Data Processing
We process your personal data to operate the Site and to provide you with requested information.
Your personal data is collected so that we may operate the Site and provide the services connected therewith, providing you with requested information or in the manner expressly indicated when the personal data concerned are collected.
4. How long do we store your Personal Data?
5. Communication to Third Parties
We may disclose your personal data to third parties in case this is necessary for the proper operation of the Site.
5.1 We may communicate your personal data to third parties as part of operating the Site, and to subcontractors such as IT systems providers or cloud service providers.
We may also disclose your personal data to third parties when we have a legitimate interest to do so.
We may also disclose your personal data when we have a legitimate interest to do so, for instance to (i) any third party (including shareholders, owners, consultants, advisors and/or other members of the North Star Group) to whom we assign or transfer any of our rights or obligations or to whom we provide information on our activities; (ii) to competent courts or supervisory or regulatory bodies, when we must compellingly disclose your personal data, pursuant to any applicable law, regulation or order.
6. International Transfers
Your personal data may be disclosed outside of your country of residence, including to countries that do not guarantee the same level of data protection and privacy as Switzerland and the European Union.
6.1 The personal data that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside your country of residence, including, in respect of residents of a country within the European Economic Area (the “EEA”) or Switzerland, in a country outside the EEA or Switzerland, including without limitation the U.S. and/or India, or any other country which do not necessarily offer an adequate level of data protection as recognized by the European Commission or Switzerland. Your personal data may also be processed by staff operating inside or outside your country of residence, including staff located outside of the EEA or Switzerland, who work for us or our service providers.
6.2 Where we transfer your Personal Data outside the EEA or Switzerland, we will ensure that suitable safeguards are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Data, for instance by relying on the EU-U.S. Privacy Shield Framework, the Swiss-U.S. Privacy Shield Framework, or on standard contractual clauses adopted by the European Commission.
6.3 You may request additional information in this respect and obtain a copy of the relevant safeguards upon request through sending a request to the contact indicated section 10
We maintain physical, technical and procedural safeguards to keep secure your personal data.
7.2 Although we take appropriate steps to protect your personal data, no website is completely secure. Therefore, we cannot guarantee that data you provide to us is safe and protected from all unauthorized third-party access and theft. We waive any liability in this respect.
7.4 If we have reasonable reasons to believe that your personal data have been acquired by an unauthorized person, and applicable law requires notification, we will promptly notify you of the breach by email (if we have it) and/or by any other channel of communication (including by posting a notice on the Site).
8. Your Rights
You have the right to access your personal data processed by us and may request without limitation that they be removed, updated, or rectified.
8.1 Except as otherwise required by law, you are entitled at all times to know if we are processing personal data concerning you. You may contact us to know the content of such personal data, verify their accuracy and request that they be supplemented, removed, updated, or rectified. You also have the right to ask us to cease processing any personal data that may have been obtained in breach of applicable law, and to object to the processing of your personal data for any other legitimate reason.
8.2 Where we rely on your consent to process your personal data, we will seek your freely given and specific consent by providing you with informed and unambiguous indications relating to your personal data. You may revoke at any time such consent.
8.3 You have also the right to request your personal data’s portability, i.e. that the personal data you have provided to you be returned to you or transferred to the person of your choice, in a structured, commonly used and machine-readable format without hinderance from us and subject to our confidentiality obligations.
You have the right to lodge a complaint.
8.4 If you are not satisfied with how we process your personal data, you may file a complaint with the competent supervisory authority, in addition to your rights outlined above.
If you believe your personal data has been used in a way that is not consistent with this policy, or if you have any questions or a request in relation to the processing of your personal data by us, please contact us at the following email address: email@example.com.
Date last updated: May 29, 2020