Star Cargo plc and its subsidiaries are committed to protecting and respecting your privacy. The current data protection regime is governed under UK law by the Data Protection Act 1998 but with effect from 25th May 2018, this was replaced by the EU General Data Protection Regulation and this will affect the way companies and other organisations keep information.
2 What is our lawful basis for using your personal data?
2.1 The GDPR only permits us to process your personal data to the extent that one of the lawful bases set out therein applies to that processing. In processing your personal data, we rely principally on the following lawful basis, namely that processing is necessary for the purposes of our legitimate interests, and those are not overridden by your interests or your fundamental rights or freedoms. When we say “legitimate interests”, we mean our (or a third party’s) interests in enabling us to provide our services to you as efficiently and securely as possibly.
2.2 In certain circumstances, we may rely on one of the following lawful bases for our processing, namely:
2.2.1 processing is necessary for the performance of a service or contract entered into between us, or to be entered into between us; or
2.2.2 processing is required for compliance with a legal obligation of ours; or
2.2.3 the data subject has given consent to the processing of his or her personal data.
2.3 We may process your personal data relying on more than one lawful basis depending on the specific purpose for which we are using your data.
3 What information do we hold about you and why?
3.1 The provision of our services often requires the processing of personal data. The processing of personal data may be necessary both prior to the conclusion of a service (e.g., in order to provide you with a quotation) and during the implementation of a service with you. Such data may include but are not limited to:
Individual and business-contact information (such as name, company name, physical address, email address, and telephone or fax number)
Information relating to the service being provided by the Star Cargo subsidiary.
Names, email addresses and telephone numbers of others to whom we are asked to send information
Payment information and financial information (such as bank account, company and VAT registration numbers)
Other personal information that may be provided to us to obtain a service.
3.2 If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
• Give consent on his/her behalf to the processing of his/her data
• Receive on his/her behalf and data protection notices
• Give consent to any transfer of his/her data.
4 Who do we share your personal information with?
We may only disclose information about you and contact details when this is required for us to provide our service to you (for example, to our suppliers). Other than this, we will not sell or pass your personal information to third parties unless you have given us permission to do so. We may also be obliged to disclose information to meet any legal or regulatory requirements.
5 Information from third parties
5.1 Occasionally, we may receive information from other sources (such as credit reference agencies), which will be added to the information already held in order for us to help supply our services and products to you.
5.2 We use credit reference agencies to make fair and informed decisions on whether to offer our products and services to you. We use them as part of our application process and ongoing monitoring on the account.
5.3 We do not perform a credit check on the individual, therefore a credit check footprint will not be left on a personal credit file.
6 Where we store your information and data security
6.1 We process data and store it on servers managed by our hosting provider. Those servers are located in the UK and our server environment is highly secure and there is very limited personnel access.
6.2 We operate secure data networks protected by industry standard firewall and password protection. We have security measures in place to attempt to protect against the loss, misuse and alteration of your user date under our control.
6.3 We try to ensure that we do not send data outside the EEA, however, this is not possible in all cases. In relation to a very small number of our suppliers or data processors, the data that we collect from you may be processed by staff operating outside the EEA who work for them. However, by submitting your personal data, you consent to this transfer, storing or processing. We will ensure that suitable safeguards are in place before personal information is transferred outside the EEA and we will ensure that your data is treated securely.
6.4 We will do our best to protect your personal data, however, the transmission of information via the internet can never be 100% secure. We cannot guarantee the security of your data transmitted to us and so any transmission is at your own risk.
7 How long do we hold your information?
We keep information for as long as we need it for the purposes for which it was collected. This will vary on the type of information. 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 requirements.
The data may be deleted in the following circumstances:
• You have withdrawn your consent to data processing.
• The original purpose for processing the data is no longer relevant or cannot be performed any more.
• The data is no longer up to date or accurate.
8 Marketing and opting out
If you have provided your consent to receive news, special offers or promotions from us, we may contact you by mail, telephone, SMS or e-mail, about our products, services or promotions that may be of interest to you. If you prefer not to receive any further direct marketing communications from us or our business partners, you can opt out at any time.
Cookies are small text files, which we may store on your computer to track your activity on our homepage. When you visit our website, information about you is collected and it is used to adjust and improve your experience. If you do not want information about you to be collected, you should delete your cookies and/or avoid visiting our website.
Cookies are stored on your computer, mobile phone or similar with the purpose of recognising it, remember settings, make statistics. Cookies cannot contain damaging content, such as virus. It is possible to delete or block cookies. If you delete or block cookies, ads maybe become less relevant to you and occur more often.
10 Google Adwords
Some of the group’s websites may use Google AdWords and, in doing so, its conversion tracking feature as well. If you come to our website by clicking on a Google ad, Google AdWords will add cookies to your computer. These cookies become invalid after 30 days and do not serve as a means of personal identification. If you visit specific pages of the AdWords customer's website and the cookie has not yet expired, both Google and we, the customer, can see that the user clicked on the advertisement and was redirected to the current page. Every AdWords customer receives a different cookie. Cookies can therefore not be tracked over AdWords customer websites.
The information collected with the help of the conversion cookies are used in the creation of conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers receive information about the total number of users that have clicked on their advertisement(s), and how many of these customers were redirected to a website with a conversion-tracking tag.
However, these AdWords customers do not receive any information which would personally identify the users. If you do not wish to participate in the tracking process, you can block the Google AdWords conversion-tracking cookie by changing your browser settings (block cookies from the www.googleadservices.com domain). Google's privacy statement on conversion tracking is available at www.google.com/intl/de/policies/privacy
11 Google Analytics
Some of the group’s websites use Google Analytics, a web-analytic service provided by Google, Inc. (www.google.com). Google Analytics uses "cookies", text files which are stored on your computer and which allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is generally transferred to a Google server in the USA and stored there. However, in the case of the activation of the IP anonymisation on this website, your IP address will be previously abridged by Google within the member states of the European Union or in other states parties to the Agreement on the European Economic Area. Only in exceptional cases, will the full IP address be transferred to a Google server in the US and abbreviated there. IP anonymisation is active on this website.
On behalf of the company, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website usage and internet usage. The IP address provided by your browser as part of Google Analytics will not be merged with other Google data. You can prevent the Google cookies from being saved by setting your browser settings accordingly.
Where users have chosen to enable Google to associate their web and app browsing history with their Google account and to use information from their Google account to personalize ads, Google will use data from its signed-in users together with your Google Analytics data to build audience lists for cross-device remarketing. In order to support this feature, two things will happen: First, for users on this site, Google Analytics will collect Google-authenticated identifiers associated with users’ Google Accounts (and therefore, personal information). Second, Google Analytics will temporarily join these identifiers to this site's Google Analytics data in order to support our audiences.
To learn more about Google Analytics, including how to opt out of it, please visit https://tools.google.com/dlpage/gaoptout
12 What are your rights?
12.1 Individuals from the European Economic Area and individuals located in the EEA have statutory rights in relation to personal data. Subject to any exemptions provided by law, you have the right to be informed, request access to information, as well as to seek to update, delete or correct this Information, alongside the right to restrict processing, to object and request the portability of the data (i.e. requesting that we move, copy or transfer your personal information to another organisation). If you wish to exercise any of these rights, please contact us.
12.2 You have the right to access personal information held about you through a subject access request made in writing.
If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the Data Protection Laws you have the right to lodge a complaint at the Information Commissioner’s Office (www.ico.org.uk)/.