Website Privacy and Cookie Policy
Introduction
Welcome to C-STAR Global's privacy policy.
Last Updated 3rd June 2024.
C-STAR Global respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you contact us or visit one of our websites (regardless of where you visit it from), or when you submit personal data to us pursuant to a transaction, and it tells you about your privacy rights and how the law protects you.
C-STAR Global is made up of different legal entities, details of which can be found here. This privacy policy is issued on behalf of the. C-STAR Global so when we mention “C-STAR Global Inc”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the C-STAR Global Group responsible for processing your data.
We have appointed a Data Compliance Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Data Compliance Officer at C-STAR Global Inc, 5005 W Royal Ln Ste 142 C, Irving, TX 75063, or email contact@cstarglobal.com.
1. Purpose of this privacy policy
This privacy policy aims to give you information on how we, C-STAR Global, collect and process your personal data through your use of our websites, including any data you may provide through our websites when you sign up to our newsletter, purchase services from us, or interact with us in any way.
Our websites and services are primarily intended for other businesses rather than consumers. This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other such notices and privacy policies and is not intended to override them.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal data we collect. This version was last updated on the date specified at the top of this page.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not routinely collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), unless strictly required (for example, dietary or access requirements in relation to an event). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may break the law, or we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
If it is not disproportionate or prejudicial, we’ll contact you to let you know we are processing your personal data and, if we have obtained your personal data from a third party, we will let you know where we obtained your personal data from.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Purposes for which we will use your personal data
If you have placed an order with us, we will use the Identity, Contact, Financial and Profile Data supplied to perform our obligations under our contract with you (for example, to set up individual user accounts to enable such users to access our services). You warrant that you are lawfully permitted to submit any third-party data to us.
We might also use Identity, Contact, Financial and Transaction Data to process the order where necessary for the performance of the contract (for example, to manage payments, fees and charges), or where it is necessary for our legitimate interests (for example, to recover debts owed to us, and/or to administer and protect our business).
If you access or use our services, we may use Identity, Contact, Profile, Technical, Usage, Profile and Marketing and Communications Data in order to manage our relationship with you. For example, to monitor how our services are being used, to contact you in connection with our services with advice and assistance, or to ask you to complete a review or take a survey. We will only do this where it is in our legitimate interest to do so (for example, to study how our services are being used to make improvements), or where it is necessary in connection with our performance of a contract with you.
From time to time, we might also make suggestions and recommendations to you about additional services that may be of interest to you based on the services you are using and/or to contact you in connection with potential business opportunities that may be of interest to you. We will only do this where it is necessary for our legitimate interests in order to develop our products/services and to grow our business and our relationship with you.
We may use your Identity, Contact, Profile, Usage, Marketing and Communications and Technical Data to deliver relevant website content and advertisements to you and to measure or understand the effectiveness of the advertising we serve to you. We will only do this where you have given consent, or where it is necessary for our legitimate interests (please also refer to the Cookies section below).
We may use data analytics to improve our website, products/services, marketing, customer relationships and experiences. This may involve us using Technical and Usage Data where it is necessary for our legitimate interests, for example, to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
We might also use Identity, Contact and Technical Data to administer and protect our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). We will only do this when it is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), or necessary to comply with a legal obligation.
We will use your Identity, Contact, Transaction, Profile, and Marketing and Communications Data in order to set up your account (if applicable) and to provide you with content which might be of interest to you. If you have requested specific content, the lawful basis will be your consent.
We may also use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you in order to decide which content may be relevant for you. We will do this only for corporate subscribers with a corporate e-mail address and/or contact number where it is in our legitimate interests to do so and your interests and fundamental rights do not override those interests.
If you have requested content provided by a third party, we may share your details with that third party where you have consented to us doing so, or where it is in our or that third party’s legitimate interests to do so. We will notify you if we intend to share your personal data with the relevant third-party content provider(s) at the point of collecting your personal data and you can withhold consent, or alternatively opt-out of us sharing your personal data by emailing us at contact@cstarglobal.com at that point.
From time to time we may also share your details with other carefully selected third parties who operate within your industry, and who may be able to provide additional content and services to help grow or provide value to your and/or that third party’s business. Such third parties may contact you via your corporate email address with business-to-business related correspondence, which you can opt-out of at any time. We will only share your information in accordance with the above where we have determined that it is in our or that third party’s legitimate interests to do so and your interests and fundamental rights do not override those interests, and we ensure appropriate safeguards are in place to protect your personal data.
If you wish to object to us sharing your personal data with any third parties as set out above you can do so by emailing us at contact@cstarglobal.com .
If you sign up to an event, seminar or workshop, we will collect your Identity, Contact, and Financial Data so that we can facilitate the event, provide an acceptable service, and respond to you. The lawful basis we rely upon for collecting this information is consent. If relevant for the event, we may also need information about dietary or access requirements, in which case we also need your consent as this type of information is classed as special category data.
Some events may be recorded, in which case presenters may have their image and audio captured in the recording. If you are an attendee and choose to interact with the event your comments may also form part of the recording. If an event is being recorded we will always notify you in advance. Our purpose for collecting this information is so we can facilitate the event and provide wider access to its content. The lawful basis we rely on for processing your personal data is our legitimate interests.
Attendee Contact Data may be shared with event sponsors, with other attendees, and with third parties who run similar events which may be of interest to you. We will only do this where you have given us consent to share your Contact Data, or where it is in our legitimate interests to do. If you wish to object to us sharing your personal data with any third parties as set out above you can do so by emailing us at contact@cstarglobal.com.
We may use your Identity, Contact, Profile, Usage, Marketing and Communications Data if you have signed up to participate in a prize draw or competition, or if you have completed a survey. We will only use your data to the extent necessary to perform our obligations under a contract with you, or where it is necessary for our legitimate interests (for example, to study how customers use our products/services, to develop them and grow our business).
If you contact us to make an enquiry or complaint, we may collect information, including your personal data, so that we can respond to the enquiry/complaint (as the case may be). We need enough information from you to answer your enquiry or respond to the complaint. If you contact our helpline, we may make an audio recording of the conversation, but will inform you of this at the time. This is so we have an accurate account of the request/complaint so that we can ensure that we are taking appropriate action.
The lawful basis we rely on to process your personal data is our legitimate interests to respond to the enquiry/complaint and to improve our services.
From time to time, personal data may be captured within one of our Information Centres made available to paying clients. This will typically be publicly available corporate contact information linked to a particular project or business venture. If personal data may be captured, we will undertake a Data Protection Impact Assessment to ensure the personal data is captured and processed lawfully and that appropriate steps are taken to minimise any impact.
If you become a shareholder we may collect your Identity, Contact, and Financial Data to comply with our regulatory and legal obligations in relation to shareholders, to communicate with you and to facilitate the payment of dividends. The lawful basis we rely upon to process your personal data is: (i) necessary to comply with a legal obligation; (ii) performance of a contract with you; and (iii) our legitimate interests (to effectively run our business and keep you informed of developments and provide notice about C-STAR Global's etc.).
If you apply for a job with us, we may use you Identity and Contact Data and information contained within your CV and application form to consider you for the vacancy. The lawful basis we rely upon to process your personal data is your consent and our legitimate interest (for running and improving our business). Further information is contained within our candidate privacy policy, which is provided to candidates.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We do not intend to market to non-corporate subscribers and ask that you provide your corporate subscriber information when submitting your information to us. As above, we refer to a corporate subscriber as an individual within an organisation that possesses a corporate email address and/or contact telephone number.
Opting out
If you are receiving any marketing messages from us, you can ask us to stop sending you marketing messages or ask us to stop sharing your personal data with any third parties for marketing purposes at any time by emailing us at contact@cstarglobal.com or by following the opt-out links on any marketing message sent to you. We will process your request as promptly as practical, however you may receive communications for a transitional period whilst we update your records.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
If you are receiving marketing messages from any third party in respect of whom we have shared your personal data, that third party will be the controller in respect of your personal data and you will need to contact that third party in order to unsubscribe to their marketing messages.
Cookies
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies :
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Service | Description | Privacy Policy |
---|---|---|
Google Analytics (Google LLC) | We use the data collected by Google Analytics to track and examine the use of this application and to prepare reports on user activities. | Privacy Policy |
Permutive (Permutive Inc) | We use data collected by Permutive to track and analyze customer interactions with our website. User’s IP addresses are received and processed but raw IP’s are not stored. | Privacy Policy |
Facebook (Facebook Inc) | This Cookie is placed by Facebook. It enables us to measure, optimise and build audiences for advertising campaigns served on Facebook. | Privacy Policy |
CloudFlare | We use Cloudflare to resolve a company name from your IP address when possible. | Privacy Policy |
Intercom | We use data collected by Intercom to track and analyze customer interactions with our services. We may also use Intercom as (1) a medium for communications, either through email, or through messages within our product(s); and (2) to provide help information to our customers. | Privacy Policy |
Hubspot | We use a cookie from HubSpot to track and analyze customer interactions with our services. We also use HubSpot as a communications platform to send messages to our users, including over email. | Privacy Policy |
Content Square | We use a cookie from Content Square to track and analyze customer interactions with our websites. | Privacy Policy |
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Except for essential cookies, we will only place cookies where you have given us consent to do so.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
C-STAR Global engages different types of processors to perform various functions in connection with the services we provide to you as explained below. With regard to all third parties with whom C-STAR Global shares personal data, we have undertaken a commercially reasonable selection process to evaluate the security, privacy and confidentiality practices of those processors to ensure the integrity, confidentiality and availability of our data (including any personal data). Processors are required to enter into an agreement with us which includes the personal data processing provisions stipulated under Article 28 of the UK GDPR. Additional safeguards, such as Standard Contractual Clauses and additional due diligence, is also undertaken if the processor is located in a country which does not have an ‘adequacy’ decision (i.e. the country does not have the benefit of a decision from the EU that is has an ‘essentially equivalent’ level of data protection to that which exists within the EU), but in any event we carry out the required Data Transfer Risk Assessments prior to making a restricted transfer.
C-STAR Global owns or controls access to the infrastructure that C-STAR Global uses to host and process client personal data. The relevant infrastructure is located in the UK, US, and European Union. C-STAR Global uses the processors listed below for hosting and infrastructure services. C-STAR Global may also use additional services provided by these processors to process data as needed for C-STAR Global to provide its services:
Processor | Jurisdiction | Purpose |
---|---|---|
Google | USA, European Union | Customer Service / Infrastructure & Hosting |
Ensono | United Kingdom | Infrastructure & Hosting |
Amazon Web Services | European Union | Infrastructure & Hosting |
Amazon Web Services | USA | Infrastructure & Hosting |
New Relic | USA | Infrastructure & Hosting |
C-STAR Global works with a number of third parties to provide specific functionality within the services we provide. The relevant processors’ use of personal data is limited to the services indicated below. Please note this list is not exhaustive and C-STAR Global may engage additional third parties from time to time to improve the services provided by C-STAR Global .
C-STAR Global works with a number of third parties to provide specific functionality within the services we provide. The relevant processors’ use of personal data is limited to the services indicated below. Please note this list is not exhaustive and C-STAR Global may engage additional third parties from time to time to improve the services provided by C-STAR Global .
Processor | Jurisdiction | Purpose |
---|---|---|
Intercom | USA | Customer service and communications |
Salesforce | European Union | Customer services and relationship management |
Freshworks | European Union | Customer service |
Permutive | USA | Advertising customer service |
New Relic | USA | Infrastructure analytics |
Cybereason | USA | Security |
Gong | USA | Customer service and product development |
Zoom | USA | Customer service (video conferencing) |
C-STAR Global may share personal data internally with other group companies to assist with the provision of the services (for example, to assist with responding to an IT request) in which case such group company will be acting as a processor. We will only do this where it is in our legitimate interests to do so, or where it is necessary for the performance of a contract.
In addition, if you have requested information or services from a group company, personal data may be shared internally with that group company in order for that group company to respond to the request. In such a scenario, the relevant group company will be operating as a separate controller.
Some of our group companies are located outside of the UK. We have implemented appropriate protections to meet the requirements of transferring personal data to third countries in accordance with applicable data protection laws.
We may also share your personal data with external third parties such as :
As detailed above, if you sign up to an event, or if you sign up to receive a report, marketing, or updates on a particular topic, we may share relevant corporate subscriber information with third party organisations linked to that event or third-party organisations operating on our platform that can provide information that may be of interest to you. Such third parties will be independent controllers of your data. We will only do this when: (i) it is required for the operation of the event; or (ii) we have your consent; or (iii) when it is in our, or the third party’s legitimate interests. If we intend to share your personal data with third party controllers, we will communicate this to you at the point at which we collect your personal data so that you can withhold consent or object to receiving such communications (if applicable).
6. International Transfers
We share your personal data within the C-STAR Global Group as set out above. This will involve transferring your data outside the UK. C-STAR Global has a global workforce with employees located throughout the world. Employees of C-STAR Global Group may be located in territories outside of the US and may have remote access to personal data from third countries. This does not qualify as a restricted transfer as such employees are not separate controllers, but employees, and thus an integral part of C-STAR Global Group. Therefore, the disclosure is carried out within the same controller. The processing, including the remote access and the processing activities carried out by such employees after the access, are performed by C-STAR Global Group, i.e., a controller in a country subject to the US GDPR and with an adequacy decision.
Many of our external third parties are based outside the US so their processing of your personal data will involve a transfer of data outside the US.
Whenever we transfer your personal data out of the US, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented. For example, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, where we have adopted standard contractual clauses approved for use in the UK to safeguard the data, or where a derogation applies (for example, if you have given consent to the transfer).
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. For example, sensitive and private data exchange between the website and its users happens over an SSL secured communication channel and is encrypted and protected with digital signatures. Our websites are also in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for users. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data Retentiion
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. For further information, please contact our Data Compliance Officer using the contact details set out above.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
If you have given us consent for processing your personal data, you can withdraw your consent at any time. 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.
In addition, under certain circumstances, you have the following rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out above, please contact the Data Compliance Officer at C-STAR Global ,, or email contact@cstarglobal.com.
You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk) if you have a complaint about the way in which we have handled your personal data. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
CCPA Privacy Policy for California Residents
California Consumer Privacy Act (CCPA)
This Privacy Policy for California Residents supplements the information contained in C-STAR Global 's Privacy Policy and applies solely to all users of our service and products who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.
The CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements. As C-STAR Global will only process B2B personal information, this means that it is currently exempt from a number of the CCPA requirements.
C-STAR Global will not typically process any personal data regarding California Residents unless transacting with an entity which is located in California. In such circumstances, details regarding the personal data we collect, where from, how we process personal data, who we share it with, and your rights (as required under CCPA) are included above within C-STAR Global ’s Privacy Policy.
If you are a California Resident, the CCPA prohibits us from reselling your personal information unless you have received explicit notice and an opportunity to opt-out of further sales. You also have the right to direct us to not sell your personal information at any time (the “right to opt-out”). To opt-out, you just need to email us at contact@cstarglobal.com.
We will not discriminate against you for exercising any of your CCPA rights.