This policy explains how we collect and use personal data that we obtain about you and your rights in relation to that data. If you have any questions about this policy or want to make a complaint about how we handle your personal data, please contact StarQube at Rue de Corps-Saints 4, 1201 Geneva, Switzerland.
What information do we collect and why?
We may collect, process and disclose personal data relating to clients and counterparties and their personnel in the following circumstances:
- For the legitimate interest of the provision of products and services, or because we need to liaise with a counterparty on a matter arising from or in connection with the products or services we are providing.
- To collect our fees or expenses.
- In providing information on our products and services updates that we consider may be relevant to clients.
- Inviting clients to events.
- Identifying where we may make improvements in product and service delivery.
- In order to comply with our obligations to check the identity of clients in compliance with applicable laws, such as anti-money laundering laws.
- Where required by our insurers and other regulatory authorities.
Our general retention period for client files is 10 years, with some exceptions where files are required to be held for longer periods. If you require further information, please contact us.
Business Contacts and marketing to potential clients
We may process personal data such as name, email address, job title, telephone number, area of business, job role, jurisdiction, language, seniority and other business contact information in the administration and operation for legitimate business purposes such as:
- Making contact details available to our staff, contractors or consultants.
- Performing analytics – such as trends, business intelligence, marketing effectiveness, uptake and progress.
- Business to business marketing.
We may acquire your personal data from public sources, including data vendors for the purposes of marketing our products and services to you through your business contact details (mostly email) and we rely on a legitimate interest to do so. We always include an option in our communications so that you can opt out of receiving such information at any time.
Any personal data processed for the above purposes will be retained for no longer than is necessary for those purposes.
If a business contact requests to be forgotten their contact details will be deleted. If a business contact opts out of receiving marketing materials their details will still be retained (as we may still be in contact) but marketing materials will no longer be sent to them.
Personal data, including name, email address, telephone number and other business contact information are collected.
- To receive services from our suppliers – we will use and disclose personal data in such manner as we believe is reasonably necessary to receive and to review the provision of those services from suppliers.
- To provide services to clients – if a supplier is assisting us in delivering services to our clients, we will process personal data to manage that relationship.
- To agree payment arrangements with our suppliers, and to make payments to them.
Our legal basis for such processing is the performance of the supplier contract.
A general retention period of seven years (after the supplier relationship ends) will be applied unless there are any legal and or regulatory exceptions which require documentation to be held for longer periods. If you require further information, please contact us.
Personal data will be collected from visitors to our website such as the time and date of your visit, the pages you visit and your physical location when visiting them, and other more specific details like your IP address, the links you click and the route you take through the website, and your information if you report a problem with our website. This is in our legitimate interest to improve our website offerings and enhance your online visit to us.
Personal data will also be collected if you sign up to attend any of our events and / or to receive our marketing literature via our website. We always include an unsubscribe button in our communications, so you can opt out of receiving such information at any time.
We may share this data with our client relationship and e-marketing management system providers. They may process this data only for the purpose of providing us with their services.
Third party sub-contractors/ Consultants and business partners
Personal data, including name, email address, telephone number and other business contact information, is collected from consultants, sub-contractor, business partners and other third parties to provide services to clients. If a third party is assisting us in delivering services to our clients we will process personal data to manage that relationship. Personal data included in professional curriculum vitae (CVs) is also processed in order to provide clients with information about the individuals that we may use and their expertise. Personal data of third parties is retained for as long as the third party is providing services to us or our clients. Professional appointment (non-recruitment) CVs are retained for three years.
Personal data of our clients, including data subject to bank secrecy
We may process your personal data if you are a customer of our clients in order to deliver our services to our clients.
We will implement measures to keep your personal information, confidential information and/or information, that is subject to bank secrecy or professional secrecy, secure, including by:
- Requiring that our client designate such personal data as confidential. If you live in Switzerland the personal data shall be marked as “Confidential Information pursuant to Article 47 of the Federal Law on Banks and Savings Banks”.
- Requiring that our client provide the personal information in an encrypted form where possible and practicable.
- Training our employees, agents, directors, contractors, consultants and representatives on the applicable client internal policies and regulations.
- Requiring that our client set clear rules and guidelines as to how such information is to be handled by us (including the degree of access to be granted, the terms and conditions applicable to such information, the persons who are granted access to such confidential information etc.).
- Ensuring that our employees, agents, directors, contractors and representatives, who may have access to such information, conclude an enhanced non-disclosure agreement to ensure their compliance.
- Ensuring that the access to such information is limited on a need to know and such information is retained kept for as long as is necessary.
Personal data is collected to ascertain a candidate’s suitability for a specific role. We have a legitimate interest in recruitment new personnel.
We may use third party software to provide a platform where applications are submitted and then processed by us. We may also send a candidate emails about their application through our email service provider.
We will retain unsuccessful applications for a period of 18 months. Successful applications are retained with the individual’s HR file.
Personal data in relation to employees will be held on various internal systems and applications. A privacy notice which sets out the purposes for which personal data will be processed and contains information on data subject rights is provided to employees. Our legal basis for such processing concerns the performance of the employer / employee contractual relationship. If further information is required please contact the Human Resources Department.
Links to Third Party Websites
Our website may contain links to other websites. We are not responsible for the privacy practices or the content of such other websites. If you link to or visit another website, please review the privacy statement for that website.
Security of your Data
We use industry standard security measures to protect your information and to prevent the loss, misuse or alteration of any information in our control. All our personnel are subject to strict confidentiality obligations. However, as effective as modern security practices are, no security system is entirely secure and we cannot guarantee the security of your information.
Your rights in relation to your personal data
Under certain circumstances you may:
- Request access to copies of the personal data we hold about you and further information in relation to its processing, or else request that such information be supplemented, updated or rectified.
- Request erasure, anonymization or blocking of your personal data that is processed in breach of the law.
- Object on legitimate grounds to the processing of your personal data. In certain circumstances we may not be able to stop using your personal data; if that is the case, we’ll let you know why.
- Withdraw your consent – when personal data is processed on the basis of consent you may withdraw consent at any time. This does not affect the lawfulness of processing which took place prior to its withdrawal. In the event that you no longer want to receive any marketing material from us, please use the unsubscribe option (which is in all of our marketing emails to you), or contact us.
- To exercise such rights (other than withdrawing from marketing emails) please contact firstname.lastname@example.org.
Changes to our Privacy Statement
We may change this Privacy Statement from time to time. If we make changes, they will be posted here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it.
Each time you use our website the then current Privacy Statement will apply and you should review it each time you use the website to satisfy yourself that you are happy with it.
Rue des Corps-Saints 4
Email Address: email@example.com
Telephone: +41 22 535 39 93
This policy was last updated on 27 September 2022. It explains in general terms the way your personal data may be processed by us. This policy does not constitute a part of any contract between us. We reserve the right to amend this policy from time to time. In the event of such amendment, you will be informed in an appropriate manner depending on how we usually communicate with you, for example via the website.