INTRODUCTION

This Privacy & Cookies Policy (the “Privacy Policy” or the “Policy”) explains how STARMOVE SERVICES LTD (the “Company”, “we”, “our”) collects, uses, stores, and protects personal information obtained through the use of this website (the “Website”) and any communications you may have with us.

This Policy outlines the types of information that may be collected through the Website, the purposes for which such information may be used, and the measures implemented by the Company to safeguard it.

Users may choose to contact the Company through the Website or by other means. Please refrain from sending confidential or sensitive information unless and until we have confirmed in writing that we represent or act for you or your organisation. Unsolicited communications from non-clients do not create any professional or client relationship and may not be treated as confidential or privileged.

This Privacy Policy is intended to help you understand how personal information may be processed by the Company and to assist you in making informed decisions when accessing or using our Website.

COLLECTION OF PERSONAL INFORMATION

The Company may collect and process personal information relating to individuals who access the Website, communicate with the Company, or otherwise interact with the Company in the course of its business activities.

For the purposes of this Privacy Policy, “Personal Information” refers to any information that identifies, or may reasonably be used to identify, an individual.

Personal information may be collected directly from individuals when they:

• Submit information through forms available on the Website;
• Communicate with the Company by email or other means;
• Request information or services from the Company; or
• Otherwise interact with the Company in the course of its activities.

In certain circumstances, Personal Information may also be obtained through third parties or publicly available sources where permitted by applicable law.

CATEGORIES OF PERSONAL INFORMATION

Depending on the nature of the interaction with the Company, the categories of personal information collected may include:

• Identification information, such as name, date of birth, or place of birth;
• Contact details, including address, telephone number, and email address;
• Professional or business information, such as occupation, employer, or line of business;
• Identification or verification information, including passport or identification details where required;
• Financial or billing information, including bank account details or payment-related information where necessary;
• Information provided in correspondence or communications with the Company;
• Information contained in documents submitted to the Company.

Where information is combined with other data that does not independently identify an individual, such combined information will be treated as personal information for as long as its remains associated with identifiable individuals.

INFORMATION COLLECTED AUTOMATICALLY

When users access or interact with the Website, certain technical and usage-related information may be collected automatically. Such information may include:

• IP Address;
• Browser type and device information;
• Operating system;
• Pages visited and navigation paths;
• Dates and times of website access; and
• General usage data relating to interaction with the Website.

This information helps the Company understand how the Website is used, maintain its functionality, and improve user experience.

TRACKING TECHNOLOGIES

The Website may use cookies, pixels, event tags, and other similar technologies (“Tracking Technologies”) to collect information about user activity and device interaction with the Website.

These technologies may be used to:

• Facilitate the operation and functionality of the Website;
• Enhance user navigation and experience;
• Analyze website performance and usage patterns; and
• Support internal analytics and service improvements.

In some cases, the Company may combine information collected through Tracking Technologies with other information obtained from users or from other sources. When such information is combined with identifiable data, it will be treated as personal information.

Further information about the use of cookies and similar technologies is provided in the Cookies section of this Policy.

PURPOSES OF PROCESSING PERSONAL INFORMATION

Personal Information may be collected and used for a variety of legitimate business purposes, including:

• Verifying the identity of individuals where necessary;
• Responding to inquiries, requests, or communications;
• Providing services or information requested by users;
• Managing relationships with individuals who interact with the Company;
• Maintaining and improving the functionality and security of the Website;
• Investigating or resolving inquiries, complaints, or disputes;
• Complying with applicable legal, regulatory, or compliance obligations; and
• Protecting the rights, property, or safety of the Company, its personnel, or third parties.

Personal information may also be processed where otherwise permitted or required by applicable law.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

Where required by applicable laws or regulations, the Company may process personal information on the basis of one or more lawful grounds, including:

• The consent of the individual;
• The performance of contractual obligations or steps taken prior to entering into a contract;
• Compliance with legal or regulatory obligations;
• The establishment, exercise, or defence of legal claims; or
• The legitimate business interests of the Company or a third party, provided that such interests are not overridden by the rights or interests of the individual.

USE OF PERSONAL INFORMATION

The Company may use personal information collected through the Website or through communication with individual for a variety of legitimate business purposes, including the following.

1. Provision and Improvement of Services
Personal information may be used to provide, manage, and improve the Company’s services and to respond to requests, inquiries, or communications submitted by users.

This may include verifying identity where necessary, facilitating interactions with the Company, maintaining records of communications, and ensuring the effective operation and delivery of services.

2. Communication and Marketing
Where permitted, the Company may use contact details such as email address or telephone number to send updates, newsletters, announcements, or other information relating to the Company’s activities, services, or events that may be of interest.

Individuals may choose to opt out of receiving marketing or promotional communications at any time by following the unsubscribe instructions included in such communications or by contacting the Company directly. Even where an individual opts out of marketing communications, the Company may continue to send non-promotional communications necessary for administrative or service-related purposes.

3. Website Operation and Analytics
Information may be used to operate, maintain, and improve the functionality, performance, and security of the Website. This may include analyzing usage patterns, evaluating user interactions with the Website, conducting surveys or research, and developing new features or improvements.

4. Protection of Rights and Security
Personal Information may be used where necessary to protect the security and integrity of the Website, investigate potential misuse or fraudulent activity, and safeguard the rights, property, or safety of the Company, its personnel, users, or third parties.

This may include investigating claims, responding to complaints, or defending against legal or regulatory matters.

5. Enforcement of Policies and Agreements
Personal Information may be used to enforce the Company’s policies, contractual arrangements, or other terms governing the use of the Website or interactions with the Company.

6. Compliance with Legal and Regulatory Obligations
The Company may process Personal Information where necessary to comply with applicable legal or regulatory requirements, including responding to lawful requests from authorities, complying with legal processes, or fulfilling obligations imposed by applicable laws or regulations.

Where relevant, Personal Information may also be used for purposes such as due diligence, fraud prevention, or compliance with applicable financial or regulatory obligations.

SHARING OF PERSONAL INFORMATION

The Company may disclose Personal Information to third parties where reasonably necessary for operational, legal, or business purposes. Such recipients may include:

• Internal personnel of the Company who require access to the information in order to perform their duties;
• Service Providers and business partners, such as hosting, storage, IT support, analytics, or administrative service providers assisting the Company in operating the Website or its activities;
• Professional advisors or agents, including legal advisors or consultants acting on behalf of the Company or the individual;
• Regulatory authorities, courts, or law enforcement agencies, where disclosure is required or permitted by law or legal process; and
• Third parties involved in corporate transactions, such as mergers, acquisitions, reorganizations, or the sale of assets.

Where Personal Information is shared with third-party service providers, the Company takes reasonable steps to ensure that such parties use the information only for the purposes for which it was disclosed and maintain appropriate safeguards to protect it.

SECURITY OF PERSONAL INFORMATION

The Company implements reasonable administrative, technical, and physical safeguards designed to protect Personal Information from unauthorized access, loss, misuse, or disclosure. Access to Personal Information is restricted to authorized personnel or service providers who require such access for legitimate operational purposes.
Despite these measures, no method of transmission over the internet or electronic storage can be guaranteed to be completely secure. While the Company takes reasonable steps to protect Personal Information, it cannot ensure or guarantee the absolute security of information transmitted through the Website, and any such transmission is undertaken at the user’s own risk.
Users are encouraged to take appropriate precautions to protect their Personal Information, including safeguarding account credentials and avoiding the transmission of sensitive information through unsecured communication channels. The Company is not responsible for unauthorized access resulting from the circumvention of security measures or from the improper handling of personal information by users.\

HOW LONG DO WE KEEP YOUR PERSONAL IFORMATION?

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for your Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

COOKIE DISCLOSURE

Cookies are small text files that are placed on your computer by websites that you visit.
They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The Company uses cookies to personalize content and ads, to provide social media features and to analyze our traffic. The Company also shares information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services.
The table below explains the cookies we use and why:

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit allaboutcookies.org.

Find out How to Manage Cookies on Popular Browsers

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

YOUR RIGHTS

You have certain rights in respect of the information we hold relating to you:

• Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
• Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your Personal Information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Information which override your rights and freedoms.
• Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your Personal Information but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

HOW YOU CAN EXERCISE YOUR RIGHTS

In order to exercise these rights, to request a Subject Access Request or if you have any concerns about our use of your personal information, please contact us at [email protected].

LINKS TO THIRD PARTY WEBSITES

Our Website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others. The Personal Information that you provide through these websites is not subject to this privacy notice and the treatment of your Personal Information by such websites is not our responsibility.

If you follow a link to any other websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites.

CHILDREN

We do not knowingly collect information from children or other persons who are under 18 years old. If you are under 18 years old, you may not submit any Personal Information to us.

CHANGES TO THIS POLICY

This Policy is subject to changes from time to time, at our sole discretion. The most current version will always be posted on our website. You are advised to check for updates regularly. By continuing to access or use our services after any revisions become effective, you agree to be bound by the updated Policy.

HOW TO CONTACT US

If you decide to terminate our engagement, you may do so by emailing us via email at [email protected]. Please be aware that Personal Information that you have provided us may still be maintained for legal and regulatory reasons (as described above).