Information pursuant to European regulation no. 679/16 – G.D.P.R.


This regulation describes the information and personal data that we process.


Pursuant to current 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 even without the aid of electronic tools, concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction of data, even if not recorded in a database;
  • data controller, the person (natural or legal person, public administration or other body, association or organization) who decides the purposes and methods and tools used, including the security profile, for the processing of personal data;
  • data processor, the person (natural or legal person, public administration or other body, association or organization) who is appointed by the data controller to process personal data;
  • data processor, the natural person who is authorized by the data controller or the data controller to carry out personal data processing operations.
  • interested party, the natural person, legal person, body or association to which the personal data refers.



Purpose of processing


  • That said, we inform you that our company Starcks S.r.l., with registered office in Rome at Via Bachelet 12, processes, as data controller, your personal data in order to:
  • (i) send you information on the services offered by the Company and on the possibility of purchasing Tokens called Star Token ($STK);
  • (ii) allow you to purchase the Star Token and the Star Player Tokens under the conditions proposed and accepted by you according to the exchange values available on the platform and to hold them in a dedicated wallet;
  • (iii) obtain the star perks, i.e. goods and services that can be purchased with the Tokens directly on the platform;
  • (iv) comply with legislative obligations regarding user identification (KYC) and anti-money laundering (AML);


Type of data processed


To provide you with the service, we may process directly or through third-party partners legally authorized to do so, the following data, attributable to the scope of personal data pursuant to art. 6 GDPR:
  • personal information (name, surname, email, Tax Code, Residence, Date of Birth);
  • copy of the identity document provided at the time of the KYC & AML process;
  • one or more of your photographs taken for the certain identification of the user;
  • contact information (telephone number);
  • banking information relating to your current account and/or credit card.


Legal basis for processing


The personal data you provide us are processed in accordance with the following legal bases for processing:


  • Art. 6 GDPR point b) processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures adopted at the request of the same;
  • Art. 6 GDPR point c), processing is necessary to comply with a legal obligation to which the data controller is subject;
  • Art. 6 GDPR point f) processing is necessary for the pursuit of the legitimate interest of the data controller or third parties.


Processing methods

The processing of your data will take place, also with the aid of electronic or automated means, in compliance with the methods that European regulation no. 679/16 (GDPR) provides for your guarantee and, in general, protecting your rights, fundamental freedoms and dignity, with particular reference to confidentiality and personal identity. The processing will take place for a period of time not exceeding that strictly necessary for the fulfillment of the purposes described above.


We have already implemented the minimum security measures for the processing of your personal data as required by the Privacy Code. We are also committed to adapting the aforementioned measures in accordance with the provisions of subsequent legislative amendments, as well as in relation to the technical evolution of the sector and the experience gained.


To comply with legal obligations, we may transmit your data to Partners, in possession of all the legal requirements and specifically authorized, specialized in user identification and monitoring procedures for Anti-Money Laundering such as Sum and substance LTD, which is based in London whose privacy policy and all information on data processing – compliant with the GDPR – are available at the following link https://sumsub.com/privacy-notice/


The payment of the amounts necessary to purchase the token will be managed by external platforms of proven authority and internationally recognized with high security protocols such as Stripe INC whose information on data processing is available at the following address: https://stripe.com/it/privacy.


We inform you that, in the event that you refuse to accept such processing, Starcks services may not function correctly.


Rights of the interested party


The current European regulations on privacy (General Data Protection Regulation) recognize the following rights for interested parties:


right of access: the interested party has the right to obtain information from us regarding the type of processing actually carried out on your data; any third parties to whom they have been communicated and the methods of storage of the same. You can also ask and request a copy for which you may have to reimburse any costs incurred by us.


right to rectification: the interested party has the right to request and obtain the rectification of your data if they have been transcribed or reported inaccurately or incompletely.


right to erasure of data: the interested party has the right to request and obtain the erasure of personal data that he/she has provided to us.


right to limit the processing of data: the interested party has the right to request and obtain the partial limitation and/or partial erasure of the data being processed.


right to portability: the interested party has the right to receive personal data in a format commonly used for automated transmission in order to be able to send them to another subject without prior notice to Starcks.


right to object to processing: the interested party has the right to object at any time to the processing of personal data and request its cessation. If the processing is no longer necessary or the interested party can legitimately object to the same, we will promptly process the request without charging any cost.


How to exercise

You can exercise your rights, within the limits described, by contacting us at support@starcks.io


Once the request has been received, Starcks undertakes to process such request promptly, within 36 hours, to the extent technically possible.


The right to be forgotten may be limited only in the following cases:


  • to guarantee the exercise of freedom of expression or the right to defense in court;
  • to protect a general interest or the execution of a legal obligation;
  • when the data, rendered anonymous, are necessary for historical research or for statistical or scientific purposes.


More information and complaint What to do in case of complaint


The data controller can be contacted at the following addresses:

Starcks S.r.l., Via Bachelet, 12, 00185 – Rome

mail: support@starcks.io


If the interested party believes that the processing of personal data by Starcks does not comply with the GDPR or this information, he/she can contact the data controller or lodge a complaint with the Personal Data Protection Authority reachable at the following web address: https://www.garanteprivacy.it.


Data Controller


Finally, we inform you that the data controller and processor, that is, the legal entity responsible for decisions regarding the purposes and methods of processing your personal data, is Starcks Srl, in the person of its legal representative, with registered office in Rome, Via Bachelet 12, 00185 – Rome.


Last update: October 26, 2022