Starcks
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Privacy policy

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1. Privacy Notice pursuant to European Regulation No. 679/16 – G.D.P.R.

This policy describes the information and personal data that we process.
Pursuant to the applicable legislation, the following definitions apply:

  • Personal data: any information relating to a natural person, legal person, entity, or association, identified or identifiable, even indirectly, by reference to any other information;
  • Processing of personal data: any operation or set of operations, carried out with or without the use of electronic tools, concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, restriction, communication, dissemination, deletion, and destruction of data, even if not recorded in a database;
  • Data controller: the entity (natural or legal person, public authority, or any other body, association, or organization) that determines the purposes, methods, and means used for processing personal data, including those related to security;
  • Data processor: the entity (natural or legal person, public authority, or any other body, association, or organization) appointed by the data controller to process personal data;
  • Authorized person for processing: a natural person authorized by the data controller or data processor to carry out personal data processing operations;
  • Data subject: the natural person, legal person, entity, or association to whom the personal data refers.

2. Purpose of the Processing

Having stated the above, we inform you that our company, Starcks S.r.l., with registered office in Rome at Via Bachelet 12, processes your personal data, as Data Controller, for the following purposes:

1. to provide you with information about the services offered by the Company and the possibility of purchasing the tokens known as Star Token ($STK);
2. to allow you to purchase Star Tokens and Star Player Tokens under the terms proposed and accepted by you, based on the exchange values available on the platform, and to hold them in a dedicated wallet;
3. to enable you to obtain “star perks”, i.e., goods and services that can be purchased using Tokens directly on the platform;
4. to comply with legal obligations relating to user identification (KYC – Know Your Customer) and anti-money laundering (AML);

3. Types of Data Processed

In order to provide the service, we may process, directly or through legally authorized third-party partners, the following data, which fall within the scope of personal data pursuant to Article 6 of the GDPR:

  • personal details (first name, last name, email address, tax identification number, place of residence, date of birth);
  • a copy of the identity document provided during the KYC & AML verification process;
  • one or more photographs taken for the purpose of secure user identification;
  • contact information (phone number);
  • banking information relating to your bank account and/or credit card.

4. Legal Basis for the Processing

The personal data you provide is processed in accordance with the following legal bases:

  • Article 6(b) GDPR: processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract;
  • Article 6(c) GDPR: processing is necessary for compliance with a legal obligation to which the data controller is subject;
  • Article 6(f) GDPR: processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party.

5. Methods of Processing

Your data will be processed, including by electronic or automated means, in accordance with the safeguards set out by European Regulation No. 679/16 (GDPR) and, more generally, in a manner that protects your rights, fundamental freedoms, and dignity, with particular reference to confidentiality and personal identity. The processing will be carried out for no longer than is strictly necessary to achieve the purposes described above.

We have already implemented the minimum security measures required for the processing of your personal data under applicable privacy laws. We also undertake to update such measures in accordance with any subsequent legislative amendments, as well as in line with technological developments and industry best practices.

In order to comply with legal obligations, we may transfer your data to Partners who meet all legal requirements and are duly authorized, specialized in user identification and anti-money laundering (AML) monitoring procedures, such as Sum and Substance Ltd., based in London. Their privacy policy and full information on data processing—compliant with the GDPR—are available at the following link: https://sumsub.com/privacy-notice.

Payments required for the purchase of tokens will be handled by external platforms of proven reliability and internationally recognized for their high security standards, such as Stripe Inc., whose privacy policy is available at: https://stripe.com/gb/privacy.

Please note that if you refuse to consent to such processing, Starcks’ services may not function properly.

6. Rights of the Data Subject

The applicable European data protection regulations (General Data Protection Regulation – GDPR) grant the following rights to data subjects:

Right of access: the data subject has the right to obtain information regarding the type of processing actually carried out on their data, any third parties to whom the data has been disclosed, and the methods of storage. You may also request a copy of your data, for which you may be required to reimburse any costs incurred.

Right to rectification: the data subject has the right to request and obtain the correction of their data where it has been recorded inaccurately or incompletely.

Right to erasure: the data subject has the right to request and obtain the deletion of the personal data provided.

Right to restriction of processing: the data subject has the right to request and obtain the restriction and/or partial deletion of the data being processed.

Right to data portability: the data subject has the right to receive their personal data in a commonly used format suitable for automated transmission, in order to transfer it to another party without prior notice to Starcks.

Right to object to processing: the data subject has the right to object at any time to the processing of their personal data and to request that such processing be discontinued. Where processing is no longer necessary or the data subject has legitimate grounds to object, we will promptly comply with the request at no cost.

7. Methods for Exercising Your Rights

You may exercise your rights, within the limits described above, by contacting us at the following email address: support@starcks.io.

Upon receipt of your request, Starcks undertakes to respond promptly, within 36 hours, to the extent technically feasible.

The right to erasure (“right to be forgotten”) may be limited only in the following cases:

  • to ensure the exercise of freedom of expression or the right of defense in legal proceedings;
  • to protect a public interest or to comply with a legal obligation;
  • where the data, once anonymized, is necessary for historical research or for statistical or scientific purposes.

8. Further Information and Complaints – What to Do in Case of a Complaint

The Data Controller may be contacted at the following details:

Starcks S.r.l.
Via Bachelet, 12
00185 Rome, Italy
Email: support@starcks.io

If the data subject believes that the processing of their personal data by Starcks does not comply with the GDPR or this privacy notice, they may contact the Data Controller or lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), available at the following website: https://www.garanteprivacy.it.

9. Data Controller

We hereby inform you that the Data Controller, i.e. the legal entity responsible for determining the purposes and means of processing your personal data, is Starcks S.r.l., represented by its legal representative, with registered office in Via Bachelet 12, 00185 Rome, Italy.

Last updated: October 26, 2022