Privacy Statement of Startselect BV

This policy was last modified on 25 August 2021.      

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

At Startselect B.V. (Startselect), we are committed to protecting your privacy by complying with applicable Canadian laws and regulations.  This Privacy Statement applies to any personal information we collect about you in relation to our Canadian operations, including when you use our services, visit the website startselect.com (“Website”), or otherwise communicate with us.

The purpose of this Privacy Statement is to inform you about the types of personal information we collect, use and disclose. It explains how we collect, use and disclose that information, the choices you have regarding such use and disclosure, and how you may access and correct that information.

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

Over time this Privacy Statement may be subject to changes. It is advisable to regularly consult this Privacy Statement so that you are aware of any changes.

In this Privacy Statement, references to "personal information" means information about an identified individual or an individual who is reasonably identifiable.  However, personal information does not generally encompass business contact information, where used to communicate for purposes related to the recipient’s business or profession. 

What personal information do we collect?
The personal information 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. This may include your location, IP address, , website account login credentials, and payment information. We collect your personal information 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 information, and the purpose for doing so, is outlined below in the section "When and why do we process your data?".

When and why do we process your data?
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your personal information for any purpose. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations you might have in the circumstances.

Where feasible or required by applicable law, we will generally accommodate requests to withdraw consent – subject to legal or contractual restrictions.  However, this may mean that you are no longer eligible for certain goods or services, or to participate in certain programs – or otherwise limit our ability to fully meet your needs.

Generally, we identify the purposes for which we use your personal information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your personal information for the following purposes.

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 (including your name and email address) 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 information 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 placement and handling of an order
When you place an order with us, we use your personal information 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.

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 assume that you have the permission of the third party to provide us with their personal information for this purpose – and it is your responsibility to obtain any necessary consent from that third party.

We retain personal information about the recipient up until the point at which the gift is sent to the third party.

If you are 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, and we rely on him or her to have obtained your permission.
  • 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 personal information for this purpose and after sending the gift, this data is deleted.
  • When sending the gift, we inform you who gave you the gift.
  • If object to receive the gift, please contact us.
  • (also, see the heading below, “What rights do you have in relation to your data?”).

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.

Newsletter
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.

Customer service and feedback
For questions about our products and services, 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 may ask you for additional information such as your name, address and contact details, where necessary to respond to 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.

Statistics and improvement of our service provision
We keep visitor and usage statistics on the use of our Website. With these statistics, we improve our Website so as to only show relevant information as an example. Also, if necessary, we may use this data to investigate complaints or quality control issues for product purchases.  The data which we may process for this purpose is your IP address and click behaviour on the Website.

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 anonymized first.

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 in an effort to prevent the loss, theft or unauthorized access, use or disclosure to personal information. The measures we have taken include:

  • user access to personal information 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 information is stored;
  • we use secure connections (TLS) that protect all information between you and our Website when you enter personal information;
  • we log retrievals of personal information.

Like most companies, we cannot guarantee that our safeguards will always be effective.  A breach of security safeguards can result in such risks as phishing and identity theft. In such cases, we act promptly to mitigate the risks and to inform you where there is a real risk of significant harm, or as otherwise required by law.

We may also require you to assist us to safeguard your personal information.  For instance, in relation to a Website account, you should use unique and strong passwords, not share your passwords with others, and promptly alert us if you believe your password has been compromised.

Which third parties process your data?
We make use of the services of various suppliers. In the case where these parties process your personal information, they do so under instruction from us. Thus, they are not allowed to use your personal information 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.

Where do we store your personal information?
Startselect B.V, and many of our suppliers, related entities and agents, are based outside Canada, and so your personal information is likely to be transferred outside Canada, 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.   In that case, the personal information may subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.  If you would like more information about our policies and practices regarding processing of personal information outside of Canada, please contact us (see contact details below).

What rights do you have in relation to your data?
You have the right to request access to personal information that we have collected, used or disclosed, and to request that we correct your personal information in our records if it is inaccurate or incomplete. 

For questions about this Privacy Statement or our privacy practices or to request access to, or to request changes to (or correction of), your personal information, please contact us .

Also, if you believe that we are not handling your data properly (including if you believe we have breached applicable Canadian privacy laws, then please contact us 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.

Contact details
All questions, requests, concerns or complaints regarding your personal information or our privacy practices should be forwarded to our Privacy Officer as follows:

Startselect B.V.
Attention: Privacy Officer
Hoevenweg 19
5652 AW Eindhoven
Email address: privacy@startselect.com

 

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