PRIVACY AND COOKIES POLICY

POLICY GOVERNING THE PROCESSING OF PERSONAL DATA PURSUANT TO REGULATION EU 2016/679
(GDPR – General Data Protection Regulation)

1. WHO WE ARE? STARKEM S.R.L. is a single-member company subject to the direction and coordination of Quadragono S.r.l. and is the Data Controller responsible processing and protecting your personal data.

2. FOR WHAT PURPOSES WE USE YOUR DATA. We will use your data, among other things, to answer your queries and to evaluate your application to become part of our staff.

3. WHY WE USE YOUR DATA. In some cases, the legal basis for processing your personal data includes complying with law and contract requirements and obligations. We need to process your data to ensure proper performance of the agreement entered into with you when you purchase our products or use our services. Other legal bases for processing may include our interest in answering your queries.

4. WHO WE SHARE YOUR DATA WITH. We will share your data with the service providers who help us or support us in the pursuit of the aforesaid purposes, such as independent contractors with whom we have executed a specific agreement and who may be established within or outside the territory of the European Union. Compliance with privacy regulations will, however, be ensured at any time.

5. YOUR RIGHTS. You have the right to access, rectify or erase your personal data and lodge a complaint with the Supervisory Authority governing the protection of personal data at any time. You may also exercise other rights such as the right to object to the processing of your data by us or the right to portability, as explained in further detail below.

You are kindly requested to review our full Privacy and cookies policy below so that you may gain a better understanding of (i) how we use your personal data and (ii) your rights in respect of your personal data. In this Privacy and cookies policy you will find all the relevant information covering our use of the personal data of our customers, regardless of the channel or means (online or in person) you use to interact with us.

1. THE DATA PROCESSOR OF YOUR DATA

The Data Processor of your personal data is:
STARKEM S.R.L. – A single-member company subject to management and coordination of Quadragono S.r.l., with registered office in Vittorio Veneto, via Donatori del Sangue n. 32, share capital € 50,000.00, Tax ID. No. 03491050260, registered with the Treviso-Belluno Companies’ Register under the same number, in the person of its pro tempore legal representative.

2. WHY WE PROCESS YOUR PERSONAL DATA

Depending on the services you plan to use from time to time, as stated above, we will process certain data rather than others. Generally, and chiefly, we will only process:
(a) Your identity data (e.g. first name, last name, language and country from which you interact with us, agreement details, etc.);
(b) Commercial information (e.g. if you have subscribed to our newsletter);
(c) Connection, geolocalisation and navigation data (e.g. if you interact with us using your cellular phone);
Please bear in mind that when we ask you to provide your personal data to us to allow you to use some of our services, some fields will be marked as required because we need these data to deliver the service you requested. Therefore, these data are needed to ensure that we fully meet our obligations arising from the agreement we entered into with you or to comply with our obligations pursuant to the provisions under the applicable laws or regulations. Failure to provide such data may prevent you from receiving such services.
Depending on the services, products or functions you request, your personal data will be processed for the following purposes.

PURPOSES OF PROCESSING DESCRIPTION
1. Fulfilling your requests about our products or through customer support service channels. We will only process the data strictly necessary to handle or fulfil your request.
2. Marketing purposes This purpose requires your data to be processed as shown below:

  • If you subscribe to our Newsletter and give your consent for marketing purposes, we will process your personal data to manage your newsletter subscription and send you customised information about our products or services by using different means of communication, including email or SMS.
    • You may cancel your subscription to our Newsletter at any time at no cost by accessing the “Newsletter” section of our website as well as by following the instructions given in each communication.
  • To launch promotional actions (for example, to send you special discounts).
3. Quality and usage analysis to improve our services If you access our website, please be aware that your navigation data will be processed for analytical and statistical purposes, i.e. to understand how users interact with our website and to enable us to improve it.

3. WHAT ARE THE LEGAL BASES FOR PROCESSING YOUR DATA?

The legal basis for processing your personal data will also depend on the purpose of the specific processing procedure, as outlined in the table below.

PURPOSES OF PROCESSING LEGAL BASIS
1. Fulfilling commercial and customer support requests We believe we have a legitimate interest in responding to your enquiries and requests for advice using the different contact methods available. We feel you will also benefit from the processing of such data insofar as it allows us to provide you with appropriate support and to answer your questions appropriately.
If you contact us, specifically for matters regarding the product you purchased, then processing will be required for the purposes of sales agreement performance.
If your request relates to the exercise of the rights as shown below or complaints pertaining to our products, then the legal basis for the processing will arise from the need to comply with the obligations we are required to meet under applicable law provisions.
If your request is based on commercial purposes, then the legal basis for the processing will be the consent you give us when filling out the form on our website.
2. Marketing The legal basis for processing your data for marketing purposes lies in the consent given by you, such as when you accept to receive commercial information or when you give your consent to participating in promotional activities.
If you give your consent for marketing purposes, we will be able to send you customised promotional communications.
3. Usage and quality analysis Subject to your consent, we may analyse website usage and the level of user satisfaction. This processing procedure will also prove to your own advantage as it aims at improving user experience and delivering a better quality service.

4. HOW LONG WE WILL RETAIN YOUR DATA

The retention period of your data will depend on the purpose of the underlying processing, as shown below:

PURPOSES OF PROCESSING RETENTION PERIOD
1. Customer support Your data will be processed to the extent as necessary to fulfil your request.
2. Marketing Your data will be processed until you unsubscribe from our newsletter.
3. Usage and quality analysis Your data will be processed on an occasional basis during a certain action or survey on quality or until your navigation data are de-identified.

5. WHO WE SHARE YOUR DATA WITH

In order to achieve the purposes as listed under this Privacy and cookies policy we need to allow your personal data to be accessed by the companies belonging to our corporate group as well as third parties who help us deliver the services we provide to you, namely:

  • a) Financial institutions.
  • b) Technological service providers
  • c) Logistic, transportation and delivery providers and partners
  • d) Customer support service providers.
  • e) Marketing and advertising providers and partners

To ensure service efficiency, some of the aforesaid providers are based outside the European Economic Area in countries that do not provide the same level of data protection as the one provided by the European Union. In such cases, your data is in any case transferred with dequate guarantees and always respecting the security of the same.

Your personal data may also be accessed for processing purposes by our duly authorised personal. The relevant authorisation is issued based on the actual need to access your data for the discharge of the required tasks.

6. YOUR RIGHTS TO THE DATA YOU PROVIDE

We will keep your personal data confidential and ensure that you will be allowed to exercise your rights. You may exercise your rights entirely free of charge by sending us an email to info@starkem.com, simply stating the reason of your request and the right you intend to exercise. If proof of your identity is deemed as necessary, we may ask you to produce a copy of a document certifying your identity.
More specifically, regardless of the purposes or legal bases under which we process your data, you are entitled to the following rights:

  • a) Obtain access to your personal data held by us and seek rectification, erasure, limitation of and objection to their processing if such processing is carried out in an automated manner based on consent or for contract performance;
  • b) Withdraw your consent to the processing of your data at any time without affecting the lawfulness of the processing based on the consent given prior to any such withdrawal;
  • c) Lodge a complaint with the Supervisory Authority governing the protection of personal data.

7. CHANGES TO THE PRIVACY POLICY AND COOKIES

To the extent as deemed appropriate, we may change the information contained in this Privacy and cookies policy. In this case, we will notify you of such changes using different methods through our websites or by sending you an email if the changes have a significant impact on your privacy, so that you may review them, make your own considerations and, if appropriate, object to or cancel any services or functions. In any event, we encourage you to review this Privacy and cookies policy from time to time to see if any minor changes or improvements have been made, since the Privacy is available on our website at all times.

8. INFORMATION ABOUT COOKIES

No personal user data are intentionally collected through the website.
Cookies are not used for the transmission of personal information, nor are systems used for user tracking and identification purposes.
The use of cookies is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) required to ensure the safe and efficient exploration of the website. Cookies are used for statistical purposes to detect website visitors.
You can delete cookies from your browser using the functions of your browser.
View our full cookies policy.