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Privacy Policy

Last updated 09/04/2019

Starcount recognises the importance and value of your privacy, and are committed to transparency regarding what data we collect or receive about you and what we do with it.

This Privacy Notice is intended to let you know who we are, and to describe how and why we use data about you.

1. Who are we?
1.1. Starcount Insights Ltd (trading as “Starcount”) is a data science company, helping businesses & organisations around the world (our “Clients”) understand their customers better. Through a better understanding of their customers, our Clients can serve them better – giving them products, services, communication & experiences that are much more relevant to them.

1.2. Our registered office is 120 Cavendish Street, London, W1W 6XX.

1.3. Our “Services” are delivered through a variety of mechanisms; the services that are relevant to this Privacy Notice are:

• our website (www.starcount.com)
• our online insight portals: “The Observatory” and “Audiences”
• client consultancy services

2. Some general information
2.1. This Privacy Notice explains how Starcount collects, uses, discloses and processes personal data. By visiting the Starcount website or insight portal, authenticating with us or registering with us, or otherwise being provided with the opportunity to view this Privacy Notice, you accept and consent to the terms of this Privacy Notice.

2.2. This Privacy Notice applies to all of the data that we collect through our Services, regardless of the type of Service or the device on which you access the Services; it also applies to the data we receive, either from the Clients we work with or the data we license from 3rd party data suppliers.

2.3. From time to time, we may update this Privacy Statement to clarify or amend our privacy policies; if we make a material change to this Privacy Statement, we will notify you either by email or by notice on or through the Services you use. By continuing to use any of our Services, this will be treated as your acceptance of the updated Privacy Statement.

2.4. If you have any questions or concerns about anything we’ve said in this Privacy Notice, please email us at privacy@starcount.com.

3. Data we collect and receive
The personal data we hold can come from a number of sources;

• we collect personal data if you are a user or client of our Services
• we might receive personal data from the Clients we work with or in the data we license.

3.1. Data we collect – If you’re a user or client of our services

3.1.1. If you request a demo or register for online insight portals, we will ask you to provide some business-related personal information – this can include your name, a business email address, a business contact telephone number, the company you work for, your business address, a username and password and other information relevant to the Services we provide. The administrator for your Client account may provide this information on your behalf.

3.1.2. For our online insight portals, we will always request the information you submit to be your business personal information (eg. your business email address) rather your personal information (eg. your personal email address).

3.1.3. If you message us or register to receive information from Starcount (for example: newsletters, marketing material, sample reports, etc), we will ask you to provide some user-related information – this can include your name, an email address, a contact telephone number, the company you work for, a username and password and other information relevant to the Services we provide. For information requests, we do not insist on the information you provide to be your business information.

3.1.4. If you apply for a job with Starcount, along with the user-related information described in section 3.1.3 above, we may also ask for your CV.

3.1.5. We collect technical information when you use our website or online insight portals;

• your IP address
• the browser you are using
• the type of device you are using
• your operating system
• broad location (country or city)

3.1.6. The technical information we collect is generally anonymous unless you are logged in to one or more of our services, or you have provided your details to receive communication from us; when this is the case, we are able to link you to the technical information we collect.

3.1.7. We collect usage information when you use our website or online insight portals;

• the pages you visit
• requests you have made
• what links you have clicked
• how long you stay on each page

3.1.8. This usage information we collect is generally anonymous unless you are logged in to one or more of our services, or you have provided your details to receive communication from us; when this is the case, we are able to link you to the usage information we collect.

3.1.9. Based on the information you have provided or made available to us, we may infer other information to allow us to improve our service to you. This may include customising your experience of our Services or to suggest other Starcount Services you may be interested in trying.

3.1.10. As we constantly improve and expand our services, we may require the collection of new information from you. Whenever this occurs, this Privacy Notice will be updated.

3.2. Data we receive – from our clients and from reputable 3rd party data suppliers

3.2.1. In some cases, our clients send us information about their customers, prospects, subscribers, etc. Wherever possible we only seek to receive limited information about those individuals (postcode, gender, date of birth, email address)

3.2.2. In order to create our Observatory and Audiences Services, we license datasets from a number of well-known reputable data suppliers. These suppliers obtain information from people who volunteer information about themselves and / or their activities and have given these suppliers permission to share this information with other organisations for analytic and marketing purposes. The information we receive in these datasets can include postcodes, gender, dates of birth, email addresses, demographic data, lifestyle data, publicly available social data and transactional data (eg. purchases, enquiries).

3.2.3. When we receive personal data from clients, or it is contained in the data we license, we will always ensure the organisations who send it to us have the right to let us store and process it for the purposes agreed with the providers.

3.2.4. We don’t really like holding personal information so we will always limit it to the very minimum required to deliver our services; also, due to the nature of our insight services, we are able to anonymise much of the personal data we receive (for example, email addresses are scrambled using a combination of encryption and hashing, and dates of birth are converted to year of birth).

4. How we use your data
4.1. Data we collect – if you’re a user or client of our services

4.1.1. The information you provide when registering for our online insight portals (see 3.1.1) will be used to fulfil our contract with you (or your organization) to provide our service(s) to you. We will also use this information to help us understand how you use our services and, therefore, how we can improve them in the future. We will only use your contact information to communicate with you about the services we provide. We will never share this information with 3rd parties.

4.1.2. If you message us or register to receive information from Starcount (See 3.1.3) we will use your contact details to provide you the information you requested. We may also contact you regarding other Starcount services you may be interested in. We will never share this information with 3rd parties.

4.1.3. If you contacted us regarding a job application (see 3.1.4), we will use the information provided to evaluate your suitability for the role applied for, and to contact you regarding the position. We will never share this information with 3rd parties.

4.1.4. Technical and usage data can be used in the following ways:

• To ensure that content within our Services is presented in the most effective manner for you and for your computer.
• To provide you with information, products or services that you request from us or which we feel may interest you. By registering with any of our Services you consent to this communication. For the avoidance of doubt we will not send any messages to you unless they are about our services or are messages from our Partners or Partner Websites.
• You may opt out of such messages at any time through the unsubscribe option on these messages.
• To carry out our obligations arising from any contracts entered into between you and us.
• To allow you to participate in interactive features of our Services, when you choose to do so.
• To notify you about relevant changes to Starcount Services.

4.1.5. We will never use, nor share your information for the purposes of bulk, unsolicited mail by parties unconnected to Starcount or its partners.

4.2. Data we receive – from our clients and from reputable 3rd party data suppliers

4.2.1. We provide a wide range of insight services to clients, typically using the data they have sent us. We might also use the data we license from reputable 3rd party data suppliers to enrich the data they send us.

4.2.2. All work we undertake for clients is done at their instruction and is founded on the rights they have obtained or established to use your information.

4.2.3. The data we receive and process from each client is used solely in helping that specific client.

4.2.4. The results of our analysis and recommendations are shared solely with the client for which they were performed.

4.2.5. The data we licence is used to create descriptive lifestyle, interest & purchase categories for different groups of people; groups may be split in a number of ways, including:

• by geography – creating descriptive categories for people living in the same geographic area
• by purchase behaviour – creating descriptive categories for people purchasing the same products

4.2.6. We never create these categories at an individual level – data from each individual will be aggregated along with data from other people to create a category that describes the group of people with similar characteristics.

5. Disclosure of your information
5.1. In connection with the uses made of information above for the data we collect, we may disclose or transfer personal information to any member of our company, or related holding company/subsidiaries; these may be located outside the EU.

5.2. For the data we collect about you, we may also disclose or transfer your personal information to third parties for the following purposes:

• In the event that we sell or buy any business or assets, in which case we may disclose data to the prospective seller or buyer of such business or assets.
• If our Site is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal or business obligation, or in order to enforce or apply our terms of use and other agreement.

5.3. For data we receive about you, unless permitted or instructed formally (by our client or data licensor) we never disclose the personal information.

6. Accuracy, Retention & Security
6.1. For the data we collect about you, we will retain personal information for as long as is reasonably necessary for us to provide our Services.

6.2. For the data we receive about you from clients or in our licensed data, we will retain personal information for as long as our client contract or license is active.

6.3. We are continuously implementing and updating our technical and organizational measures & controls to help protect personal data against unauthorised access, loss, destruction, or alteration. Some of the safeguards we use to protect your Personal Data are firewalls, data encryption & hashing, and data access controls (IP address restrictions, multi-factor authentication, time-limited access credentials).

7. General Data Protection Regulation (GDPR)
7.1. The GDPR, introduced in May 2018, gives you much more control over your personal data. Individuals in the EU may exercise any of the rights described in this section by contacting us directly at privacy@starcount.com. If you reside outside of the European Union, you may have similar rights under your local laws.

7.2. You have the right to access & control the information we hold about you; this includes:

• Obtaining a copy of the data we hold about you
• Requesting a correction to the data we hold about you
• Requesting information regarding our sources of the data we hold about you
• Objecting to us processing your personal data
• Requesting the deletion of the data we hold about you

7.3. To exercise these rights (this is commonly known as a ‘Subject Access Request’), please email us at privacy@starcount.com or write to us at the address listed at the beginning of this document.

7.4. For data we receive from clients or that we license, the suppliers of this data (our Clients or the licensors of the data) notify us of any Subject Access Requests made directly to them. These requests will be fulfilled by us via the data supplier, not directly with you.

7.5. The GDPR seeks to ensure that organisations can formally justify the reasons for collecting, storing and processing personal data – this is known as the “Legal Basis”. For Starcount, our Legal Basis for collecting, storing and processing your information depends on the source of this data:

7.5.1. If we collected your data (as a user or client of our services, or have requested information through our website) we will have your Consent to process your data (through the acknowledgement of our Terms & Conditions and of this Privacy Notice)

7.5.2. If we collected your data (as a user or client of our services) we will have a Contractual obligation to collect and process your data in order to provide you the service.

7.5.3. If we received your data from one of our Clients, we act as the Data Processor in this scenario and the Legal Basis for us to receive, store & process your data will be inherited from the Client from which it was received.

7.5.4. If we received your data in any of the datasets we license, we will have a Legitimate Business Interest to use the data in order to: trade as an insights business, deliver innovative services to help organisations understand their customers better, deliver these services with the intention of benefiting individuals.

8. External Links
8.1. Our Services may, from time to time, contain links to and from websites of our Partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

9. Contact
9.1. Questions, comments and requests regarding this privacy notice are welcomed. Please contact us at privacy@starcount.com

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