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Privacy Statement of Startselect BV

This policy was last modified on 17 September 2020.

When you make use of our services and visit the website startselect.com (“Website”), it is possible that your personal data will be processed.

Because the Website and services offered are managed by us, Startselect B.V. (Startselect B.V.), we are responsible for the careful handling of all personal data. In this regard we do, of course, adhere to all requirements imposed by privacy legislation, in particular the Australian Privacy Act 1988 (Cth) (Privacy Act) as well as the European General Data Protection Regulation. One of those requirements is that we have to inform you properly about how we handle your personal data. We do this by means of this privacy policy and through other notices we may provide to you at the time of collecting your personal data (where reasonably practicable to do so).

If you have any questions, you can always contact us. The contact details are included at the end of this policy.

Over time this policy may be subject to changes. It is advisable to regularly consult this policy so that you are aware of any changes.
In this privacy policy we explain:

  • what personal data we collect from you and why we need this data;
  • on what grounds we collect this data;
  • how long we retain the data for;
  • whether your data will be passed on to other parties or disclosed to recipients outside Australia;
  • what your rights are as regards your data.

In this privacy policy, references to "personal data" includes personal information as defined in the Privacy Act, which (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise.

What personal data do we collect?
The personal data we collect depends on the context in which it was collected, and may include contact details, complaint details, information from your social media account, location information and any other information we require to allow you to use our services and operate your account on our platform. We collect your personal data from you when you enter into an agreement with us or when a person discloses your personal information to us for the purposes of purchasing a gift.

Details of some of the most common scenarios where we collect your personal data, and the purpose for doing so, is outlined below in the section "When and why do we process your data?".

On what grounds do we process your data?
The personal data which you provide to us is only processed on one (or a combination) of the following legal grounds, namely:

  • if it is necessary for the performance of an agreement with you, or to deal with your request to enter into an agreement;
  • if you have given us permission to do so;
  • if we have a legitimate interest in so doing;
  • if we have a statutory duty or right to do so.

When and why do we process your data?

Registration for an account
We give you the option of creating an account. This can be done either by you yourself providing the data or by registering yourself through your social media account. In the latter case, you consent to us obtaining the necessary data from your social media account. You can always undo this link via the relevant social media platform.

The data which we obtain during registration is used solely to create and make available an account. In the first instance, this involves only your email address and a self-selected password. Your account can then be supplemented by your name (first and last names) and the country in which you live. The IP address from the device with which you visit the Website is also processed automatically for security purposes. All orders which you place from your account are also recorded in your account under order history.

We process and retain your account and the personal data linked to it as long as your account is not removed. Should you wish to remove your account, you can do this by sending a request to us via the contact details below.

The grounds for the above data processing are: the performance of an agreement for providing an account and our legitimate interest in that.

The placement and handling of an order
When you place an order with us, we use your personal data so that we are able to handle the order properly. Your email address, among other things, is then used to supply your order (the code) and/or send an order confirmation.

For this purpose, we use the data necessary for the performance of the agreement, such as your name and email address. In addition, we retain the order data for up to seven years after the order was completed.

The grounds for the above data processing are: preparatory actions for entering into an agreement and the performance thereof, compliance with a legal obligation.

Giving a gift to a third party
When you place an order with us you have the option within the ordering process to indicate that you want to give the code or voucher to a third party as a gift. The name and email address of this third party are used for the purposes of sending the gift digitally.

We use the data necessary to perform the agreement which we have with you, such as the name and email address of the third party. We retain this data up until the point at which the gift is sent to the third party.

We inform the third party to whom the gift was sent about what we do with personal data. The third party is entitled to object to the processing of their personal data after receipt of the gift.

Information for you as the third party receiving the gift:

  • We use your data from you as the recipient of the gift because a friend of yours has indicated that he or she wants to give you a gift.
  • We only use your name and e-mail address that we received from the friend to be able to send the gift digitally to you.
  • We only use this data for this purpose and after sending the gift, this data is deleted.
  • When sending the gift, we inform you who gave you the gift.
  • You have the right to object to the processing of your personal data after receiving the gift.
  • (see also below in this privacy policy “What rights do you have in relation to your data?”).

The grounds for the above data processing are: our legitimate interest in the performance of the agreement with the purchaser.

Location data
In some cases, it is necessary for us to ascertain the country from which you are visiting our Website. We do this in order to comply with agreements with our suppliers. We use only your IP address for this purpose.

The grounds for the above data processing are: our legitimate interest.

You can subscribe to our newsletter on the Website. Your email address will only be added to the list of subscribers if you have given your permission for this. You can revoke this permission at any time. Each newsletter has a link with which you can unsubscribe by simply clicking on the link. You can also do this via your account. When you unsubscribe from the newsletter, your email address is immediately removed from our mailing list. The cancellation is saved for a month after you have unsubscribed.

The grounds for the above data processing are: the permission previously provided by you.

Customer service and feedback
For questions, please contact our customer service via email or the contact form. You can also provide us with suggestions as to how our services and Website could be improved. So that we can help you properly, we could ask you for additional data such as your name, address and contact details. We do this only in so far as we need this data to deal with your question or process your feedback.

We keep this information until we are certain you are satisfied with our response and for six months thereafter. In this way we can easily access the information in case of follow-up questions. We can also use it to train our customer service teams to be even better.

The grounds for the above data processing are: the permission previously provided by you and/or performance of the agreement and/or our legitimate interest in that.

Statistics and improvement of our service provision
We keep visitor and usage statistics on the use of our Website, in which we can also view individual data. With these statistics, we improve our Website so as to only show relevant information as an example. The data which we may process for this purpose is your IP address and click behaviour on the Website. We can combine your personal data to learn more about you. Of course, we will respect your privacy at all times. If you do not want this to happen, you can always inform us accordingly.

Your data will not be stored any longer than is necessary for the above-mentioned purposes. If we nevertheless decide to keep data for longer, this data will be anonymised first.

The grounds for the above data processing are: our legitimate interest or by permission previously provided by you.

Use of cookies on our Website
We use cookies and similar techniques on our Website. Cookies are small information files which can be stored automatically on, or read from, the visitor’s device (e.g. PC, tablet or smartphone) when a website is visited. This takes place via the web browser on the device.

On our Website we use cookies:

  • which are necessary to allow the Website to function or to be able to offer functionalities you request (technical and functional cookies);
  • to analyse usage of the Website and thereby improve the Website (analytical cookies);
  • to improve your online advertisement provision outside of our website and to give us insight into our campaign performance (advertising cookies).

Essential cookies. For strictly necessary cookies (technical and functional cookies) we do not have to request permission - these include cookies which are strictly necessary to provide requested functionalities and services, e.g. the facilities made possible by cookies to save the content of your shopping basket or choice of language.

Analytical cookies. We do not ask for permission for analytical cookies if the service for which they are being used has been set up in a privacy-friendly way. In that case, the data processing occurs on the basis of our legitimate interest in the specific data processing.=

Other cookies. We ask prior permission for all other cookies. We do this by means of a cookie banner on the Website.

We ask permission for all cookies that are not necessary, which includes the analytical cookies not considered to be privacy friendly. In addition, we naturally ask permission for the use of cookies for advertising and targeting or re-targeting purposes. These types of cookies enable the advertisement provision on other websites (including social media platforms) which you visit or use to be adapted based on your browsing behaviour on our website. For this purpose, we use the services of third parties. These parties are listed in the cookie table included underneath this statement.

How is your data protected?

We take security measures to limit misuse of and unauthorised access to personal data. The measures we have taken include:

  • access to personal data is protected with a username and password or login token;
  • the data is stored after receipt in a separate, protected system;
  • we employ physical measures such as locks and safes to protect access to the systems in which personal data is stored;
  • we use secure connections (TLS) that protect all information between you and our Website when you enter personal data;
  • we maintain logs of all retrievals of personal data.

Which third parties process your data?

We make use of the services of various suppliers. In the case where these parties process your personal data, they do so under instruction from us. Thus, they are not allowed to use your personal data for their own purposes. We have concluded processing agreements with these parties. Our suppliers fall into the following categories:

  • IT service providers;
  • Marketing parties;
  • Email service providers;
  • Analytical and anti-fraud parties.

Startselect B.V, and many of our suppliers, related entities and agents, are based outside Australia, and so your personal data is likely to be transferred outside Australia, including to recipients located in the European Union (including but not limited to The Netherlands, Germany, Ireland), Great Britain, Switzerland, The United States of America.   

What rights do you have in relation to your data?

For questions about our privacy policy or questions regarding obtaining access or inspection of, or to request changes to (or correction of) your personal data, you can always get in touch with us (see contact details below).

In addition, you may have the right (in most cases) to:

  • inspect what data we process and why;
  • have your data changed when it is not, or no longer, correct;
  • have outdated data removed;
  • object to a particular use of your data;
  • withdraw previously given consent;
  • retrieve your data and get it transferred.

If you believe that we are not handling your data properly (including if you believe we have breached the Privacy Act, including the Australian Privacy Principles in relation to your personal data) or not assisting you properly, then please contact us (see our contact details below) and provide as much information as possible regarding your complaint or concern as possible.   We take all complaints seriously, and will respond to your complaint within a reasonable period. If you are dissatisfied with the handling of your complaint, you can submit a complaint to the national regulator.  In Australia, this is the Office of the Australian Information Commissioner, who can be contacted at: GPO Box 5218, Sydney  NSW  2001; Telephone: 1300 363 992 Email: enquiries@oaic.gov.au.  In the Netherlands, this is the Dutch Data Protection Authority. You can find a list of all regulators here.

Contact details

Startselect B.V.
Hoevenweg 19
5652 AW Eindhoven
Email address: support@startselect.com

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