Informazioni sulla Gestione dei Dati Personali
For all data that is obtained in connection with the conclusion, performance and termination of your contract, the controller within the meaning of Article 4, no. 7, of the EU General Data Protection Regulation (GDPR), i.e. the person or entity responsible, is STARLAB S.r.l., Via Pinturicchio 1, 20133 Milano, Italia (“STARLAB”).
Processing of your Personal Data
The personal data processed by STARLAB includes your particulars (name, gender, position, employer and comparable data), work address and contact data (telephone number, email address and comparable data) as well as information about your customer history (ordered products, points discussed in sales conversations and comparable data) and information about your product and contract interests which is deduced from that data.
Insofar as that data is necessary for the conclusion, performance and termination of the contracts, STARLAB processes it on the basis of Article 6, paragraph 1, point b, of the GDPR.
The data necessary for the performance of the contract, especially the particulars as well as the work address and contact data, are necessary for the conclusion of the contract. If the customer does not provide that data, the contract cannot be concluded. There will be no other consequences of any failure to provide the above personal data.
STARLAB also processes that personal data of customers in order to get to know its customers better and be able to offer them products and services that are suitable for them. The legal basis of this data processing is Article 6, paragraph 1, point f, of the GDPR or, if a consent has been given, Article 6, paragraph 1, point a, of the GDPR. If you have given a consent, you may revoke it at any time; however, the revocation will not affect the legality of the data processing that took place on the basis of the consent until the time of the revocation. If the processing of your personal data is based on Article 6, paragraph 1, point f, of the GDPR, our legitimate interest lies in our economic interest in the advancement of our business operations and specifically in the optimisation of our sales activities.
If you do not want us to use your personal data for the above-mentioned purposes (advertising), you may object to it at any time (Article 21 paragraph 3 of the GDPR). Please send your objection by email to email@example.com or by mail to STARLAB S.r.l., Via Pinturicchio 1, 20133 Milano, Italia. Of course, your objection will not affect your contracts with STARLAB.
Automatic decision-making pursuant to Article 22 paragraphs 1 and 4 of the GDPR does not take place at STARLAB.
Deletion of Data
Personal data will be deleted by STARLAB if they are no longer needed for the purpose of their processing and any legal retention periods have expired.
As a rule, data of accounting transactions is deleted ten years after the transaction was carried out, and all other personal data is deleted six years after the termination of all contracts of the customer with STARLAB.
Disclosure of Your Personal Data
For the performance of contracts, STARLAB cooperates closely with internal and external sales partners. To enable your STARLAB-internal sales partner to advise you adequately and support you in all matters related to your existing contracts with STARLAB, the adviser in charge of you is given access to the data described above. A disclosure of personal data to external sales partners only takes place on particular occasions and only for the data that is necessary for the performance of the contracts. This concerns, for example, disclosures to logistics service providers or to service partners. The legal basis of such disclosures of your personal data is Article 6, paragraph 1, point b, of the GDPR.
In addition, we may also transfer your data to the appropriate national company of the STARLAB Group (see also the section “Data Transfer Abroad”) if you use offers that are provided jointly by several companies of the STARLAB Group. The legal basis of such disclosures of your personal data is Article 6, paragraph 1, point b, of the GDPR.
Besides, we disclose your personal data to the appropriate national company if it is in charge of the country in which you operate. In those cases, the legal basis of the data transmission is Article 6, paragraph 1, point f, of the GDPR. Our legitimate interest in such data transmissions lies in our business's interest in the effectiveness of its sales organisation.
In addition, we may give service providers that are bound by instruction access to your data. These so-called processors within the meaning of Article 28 of the GDPR must not process the data for their own purposes but only in the manner defined by STARLAB. They are chosen carefully and are obliged, by law and by contract, to ensure a high level of data protection. For example, an IT administrator sent by an IT service provider might maintain STARLAB databases and, in the course of this work, theoretically have the possibility to access personal data of our customers. As further examples, we may assign third parties with hosting our website, operating the different functions available on the website, sending emails, analysing data, making available search results or links and supporting us with executing your orders.
For purposes other than those mentioned in this letter, we will only disclose your personal data to third parties if we are obliged to do so by law (e.g. to provide information to supervisory authorities in certain cases) or if you have given us your express consent to doing so. In addition, we may disclose your data if we are entitled to do so by law. In those cases, however, we will inform you separately (in case the disclosure is not described in this document already).
Data Transfer Abroad
STARLAB is globally active with subsidiaries within the European Economic Area (https://www.starlab.click/worldwide).
In the course of the disclosure of data described above, we may share your personal data with companies that are based also outside the European Economic Area.
If your personal data is transferred to territories outside the European Economic Area, STARLAB will adhere to the requirements of the GDPR, particularly Article 44 et seq. of the GDPR. This means that, when transferring data, STARLAB will ensure that the level of protection guaranteed by the GDPR will not be undermined.
The transfer to third countries has one of the following legal bases as regards the international data transfer:
- The adequacy decisions of the European Commission within the meaning of Article 45 paragraph 3 of the GDPR; or
- Standard data protection clauses within the meaning of Article 46 paragraph 2, point c, of the GDPR. The standard data protection clauses of the European Commission can be found here (as of 30/04/2018): https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_de.
Information, deletion and porting of your personal data
If you wish to be given detailed information about the personal data that STARLAB has stored about your person, please contact STARLAB S.r.l., Via Pinturicchio 1, 20133 Milano, Italia or firstname.lastname@example.org. On request, we can also provide you with a copy of the data that STARLAB has stored about your person.
Besides, you may receive the data which you have provided to us in a structured standard machine-readable format from us or require us to transfer that data to a third party named by you.
If you find that data stored about your person is incorrect or incomplete, you can require the immediate correction or completion of that data at any time.
Provided that the prerequisites described in Article 17 and 18 of the GDPR are fulfilled, you may require the deletion of your data or the restriction of its processing.
If you should not agree to the data processing performed by us or the information provided by us, you may file a complaint with the “Garante per la protezione dei dati personali” Piazza di Monte Citorio, 121 – 00186 Rom, Phone: +39-06-6967 71 / +39-06-6967 72917or email@example.com
If you have any questions about the processing of your personal data by STARLAB, do not hesitate to contact our Data Protection Service at the email address firstname.lastname@example.org or the postal address STARLAB S.r.l., Via Pinturicchio 1, 20133 Milano, Italia.