This is the
Privacy Statement of STARLAPPS IT UG, Parkstr. 7e, 55545 Bad Kreuznach, DE (“STARLAPPS
a private limited liability company incorporated under the laws of Germany, registered with the Chamber of Commerce in Munich („STARLAPPS IT“).
It applies to all subsidiaries and branches of STARLAPPS IT to the extent that they process personal data.
treats personal data which it receives through its websites, portals and any
other means with due care and is dedicated to safeguarding any personal data it
receives. STARLAPPS IT is bound by the General Data Protection Regulation
(Regulation (EU) 2016/679),
the German Data Protection Act and the German Telecommunications Act.
This Privacy Statement is designed to advise you about the type of information that STARLAPPS collects and the purposes for which this information is being processed, used, maintained and disclosed.
This Privacy Statement aims to explain in a simple and transparent way what personal data we gather about you and how we process it.
We may amend this Privacy Statement to remain compliant with any changes in law and/or to reflect how our business processes personal data. This version was created on December 28th 2018. The most recent version is available at https://www.paire.app/privacypolicy_en.html
A list of external partners can be found here: ______________________
2. Personal Data
Personal data refers to any information that tells us something about you or that we can link to you.
IT processes any information we receive from you, including personal and
financial information you provide to us including when you or your business:
enquire or make an application for STARLAPPS IT’s services, register to use and/or use any of our services and when you communicate with us through e-mail, SMS, a website or portal, telephone or any other electronic means.
You share personal information with us, for example when you: visit our website, complete a(n) (online) (application) form or contact us through one of our channels.
process data about your use of our website and services ("usage data").
The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services.
The legal basis for this processing is consent or our legitimate interests, namely monitoring and improving our website and services on the base of Art. 6 Abs. 1 S. 1 lit. f GDPR
We also may
process information relating to our customer relationships, including customer
contact information ("customer relationship data").
The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you.
The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers.
The legal basis for this processing is consent or our legitimate interests, based on Art. 6 Abs. 1 S. 1 lit. f GDPR namely the proper management of our customer relationships
process information that you provide to us for the purpose of subscribing to
our email notifications and/or newsletters ("notification data").
The notification data may be processed for the purposes of sending you the
relevant notifications and/or newsletters.
The legal basis for this processing is consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
process information contained in or relating to any communication that you send
to us ("correspondence data"). The correspondence data may
include the communication content and metadata associated with the
Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users based on Art. 6 Abs. 1 S. 1 lit. a and f GDPR.
process information that you provide to us for the purpose of subscribing to
our contest, games or similar activities or in case of video-uploads ("correspondence
The correspondence data may include your name, your contact details, and information contained in communications between us and you. The source of the correspondence data in this case is you.
The correspondence data may be processed for the purposes of managing the contest, games, video-upload or similar activities. The legal basis for this processing is consent or our legitimate interests, based on Art. 6 Abs. 1 S. 1 lit. a and f GDPR.
case we will not process your personal information.
3. Sensitive data
We do not record sensitive data relating to your health, ethnicity, religious or political beliefs unless it is strictly necessary.
4. What we do with your personal data
We only use your personal data for legitimate business reasons. This includes:
• Administration. When you use our services we are legally obliged to collect personal data that verifies your identity and to assess whether we can accept you as a user/customer.
Personalised marketing. We may send you letters, emails, or text messages
offering you a product or service based on your personal circumstances, or
shows you such an offer when you log in to our website.
You may unsubscribe from such personalised offers. You have the right, not to consent or to object to personalised direct marketing or commercial activities, including profiling related to these activities.
• Improving and developing products and services: Analysing how you use our products and services helps us understand more about you and shows us where we can improve.
• we analyse the results of our marketing activities to measure their effectiveness and the relevance of our campaigns.
• We may process your personal information to protect you and your assets from fraudulent activities, for example if you are the victim of identity theft, if your personal data was disclosed or if you are hacked.
Data that we process for any other reason is anonymised or we remove as much of the personal information as possible
5. Providing your personal data to others
Whenever we share personal data internally or with third parties in other countries, we ensure the necessary safeguards are in place to protect it.
For this, STARLAPPS IT relies on:
• EU Model clauses, which are standardised contractual clauses used in agreements with service providers to ensure personal data transferred outside of the European Economic Area complies with EU data protection law
• Privacy Shield framework that protects personal data transferred to the United States.
To be able to offer you the best possible services and remain competitive in our business, we share certain data both internally as well as outside of the STARLAPPS IT Group. This includes:
IT entities: We transfer data across STARLAPPS IT businesses and branches for
operational, regulatory or reporting purposes, for example to comply with
certain laws, secure IT systems or provide certain services.
We may also transfer data to centralised storage systems or to process it globally for more efficiency.
· Service Provider.
some cases, we are obliged by law to share your data with external parties,
including: - public authorities, regulators and supervisory bodies such
as fraud protection agencies and the central banks of the countries where we
- judicial/investigative authorities such as the police, public prosecutors, - courts and arbitration/mediation bodies on their express and legal request;
· With your permission: Your information may also be used for other purposes for which you give your specific permission, or when required by law or where permitted under the terms of the laws of the relevant jurisdiction.
6. Your rights
Section 6, we have summarized the rights that you have under data protection
Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
the right to confirmation as to whether or not we process your personal data
and, where we do, access to the personal data, together with certain additional
That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.
Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
circumstances you have the right to the erasure of your personal data without
Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing;
you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure.
The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims
circumstances you have the right to restrict the processing of your personal
Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment,
exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data.
However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
the right to object to our processing of your personal data on grounds relating
to your particular situation, but only to the extent that the legal basis for
the processing is that the processing is necessary for:
the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
the processing is necessary for the performance of a contract to which you are
party or in order to take steps at your request prior to entering into a
contract, and such processing is carried out by automated means,
you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection.
You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
extent that the legal basis for our processing of your personal information is
consent, you have the right to withdraw that consent at any time.
Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us.
1. Session cookies:
These cookies may store your browser name, the type of computer and technical
information about your means of connection to this website, such as the
operating system and the Internet Service Providers utilized and other similar
This information is used to technically facilitate the navigation and use of this website. In addition, functional cookies may be used to store personal settings, such as language, or to remember your information for next visits if so requested.
Analytics cookies: This website also uses analytics cookies to measure
the number of visits and the parts of the website that are the most popular
among our website visitors as well as for benchmarking purposes.
This information is used to provide aggregated and statistical information on the use of this website and is used to improve the contents of this website to enhance your user experience.
Third-party/social media cookies: This website contains cookies from
third-party websites, mainly social media cookies. When placed on your
computer, they automatically activate handy extras..
These cookies inform our website whether you are logged into such social media and they also enable you to share parts of this website on social media.
Do you object to cookies?
generally process your IP-address but they do not save your personal
information like e-mail address or phone number.
If you do not want to have cookies stored on your computer or want to remove cookies that have already been stored, you can arrange this via your browser settings.
8. How we protect your personal data
We apply an
internal framework of policies and minimum standards to keep your data safe.
These policies and standards are periodically updated to keep them up to date
with regulations and market developments.
More specifically and in accordance with the law, we take appropriate technical and organisational measures (policies and procedures, IT security etc.) to ensure the confidentiality and integrity of your personal data and the way it’s processed.
In addition, STARLAPPS IT employees are subject to confidentiality and may not disclose your personal data unlawfully or unnecessarily.
9. What you can do to help us keep your data safe
the transmission of information via the internet in general is not always
completely secure. Although we will do our best to protect your personal
information, we cannot guarantee the security of your information transmitted
to our site; any transmission is at your own risk.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We do our utmost to protect your data, but there are certain things you can do too:
• install anti-virus software, anti-spyware software and a firewall on your computer and keep them updated;
• do not leave verification tokens or your credit card) unattended;
• keep your passwords strictly confidential and use strong passwords, i.e. avoid obvious combinations of letters and figures; and • be alert online and learn how to spot unusual activity, such as a new website address or phishing emails requesting personal information.
10. Web Analytics
may use Google Analytics. Google Analytics is a web analytics service provided
by Google, Inc., of Mountain View, CA 94043, U.S.A. („Google“). Google
The information generated by the cookie about your use of our website (such as when you visited the website, the referrer URL, details on the configuration of your operating system, your browser and your access provider) are generally transmitted to,
and stored on, a server of Google located in the U.S.A. As we are using Google Analytics’ "_anonymizeIp()" function, your IP address will be shortened when you access our site from a member state of the European Union or from other states of the European Economic Area.
It is only in exceptional circumstances that your IP address is transmitted to the U.S.A. and shortened there.
Google will use the information on our behalf to analyse your use of the website, to compile reports on website activity, and to provide us with additional services related to the use of the website as well as Internet use.
The IP address collected within the framework of Google Analytics will not be combined with other Google data.
We will use the Information gathered by cookies deployed by Google Analytics to analyse your use of our website, to generate reports on website activities and to perform other website related services to you.
basis for this processing is Art. 6 sec. 1 sent. 1 lit. f GDPR and represents
our legitimate interest to analyse our website’s traffic to improve the user’s
experience and to optimize the website in general.
explained above, you can use your browser settings to prevent the acceptance
and storage of new cookies.
Should you disagree with the analysis of your use of our website you can also deactivate Google Analytics and thus declare your objection to the collection and processing of the respective data.
To do this, please download and install the browser plugin that Google provides for this purpose. The plugin is available here.
Once the plugin has been installed, it will prevent the recollection of the data related to your use of our website that has been generated by the cookie (including your IP address).
11. Social Media Plugins
webpages of our website we may implement so-called social media plugins, in
particular Facebook, Inc.’s “like” button, Twitter, Inc.’s Twitter buttons,
Instagram, Pinterest and YouTube.
When you visit a page that displays one or more of such buttons your browser will establish a direct connection to the respective Facebook, Twitter, Instagram, Pinterest or YouTube server and load the button from there.
At the same time Facebook, Twitter, Instagram, Pinterest or YouTube will know that the respective page on our website has been visited.
This processing is based on Article 6 sec. 1 sent. 1 lit. f GDPR and represents our legitimate interest to improve your website experience and to optimize our services.
We have no
influence on the data that Facebook, Twitter, Instagram, Pinterest or YouTube collect
on the basis of the buttons.
According to the available information, however, if you do not click on the respective buttons no personal data will be collected and stored unless you have logged onto to your Facebook, Twitter, Instagram, Pinterest or YouTube account.
In that case certain user data (including your IP address at the time) may be collected and linked to the account information already present at Facebook, Twitter, Instagram, Pinterest or YouTube, respectively.
If you wish to prevent this, please log out of your social media accounts before visiting our website.
addition, clicking a button may also lead to a collection of certain data, such
as the user’s IP address. Facebook, Twitter, Instagram, Pinterest or YouTube may
set cookies as well,
unless you have disabled the acceptance and storage of cookies in your browser settings (see above).
no information from Facebook, Twitter, Instagram, Pinterest or YouTube about
which social media buttons you may have clicked or seen on our website,
but, if at all, we may receive a summarized, non-person-related statistical report on the use of the buttons.
If you wish to obtain more information on the subject go to:
· Additional Information on Facebook’s Social Plugins here
· Twitter http://twitter.com/privacy.
· YouTube https://policies.google.com/privacy
12. How long we keep your personal data
Once you are no longer a customer, we will retain your personal information for a reasonable period, or as otherwise allowed or required by law.
13. Contact us
If you want to know more about STARLAPPS IT’s data policies and how we use your personal data, you can send us an e-mail to our data protection Officer: firstname.lastname@example.org or
STARLAPPS IT UG
55545 Bad Kreuznach, DE