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Privacy Policy


1) About STARKS and this Privacy Policy

SMG Italia has its registered offices at Milano 20121 (MI), via Montebello, n. 27 (the “Company”).  In this Privacy Policy, we use “STARKS” and “we“, “us” and “our” to refer to the Company, its parent company, its affiliated companies and clinics.

This Privacy Policy provides natural persons with useful information so that they give a specific, unambiguous, informed, free and informed consent to the collection and processing of their Personal Data when they use our Platforms (the “User(s)”). Please take a moment to read the following policy which explains how we collect, use, disclose and transfer the Personal Data that Users provide to us or that we collect on our websites, mobile applications, when the Users contact the STARKS contact centre by telephone (the “Platform(s)”) or interact with us over social media. It also explains how we collect information through the use of cookies and related technologies when using our Platforms. By using any of the Platforms, you agree to be bound by this Privacy Policy.

The Platforms are not directed at collecting or processing any Personal Data on any User who is under the age of 16. If the User is below the age of 16 years, the consent to such processing shall be given or authorised by the holder of the parental responsibility over the User.

2) Updates to this Privacy Policy

From time to time, we may update this Privacy Policy. The latest version of this Privacy Policy will always be available on the Platform. We will inform the User of any substantial changes to this Privacy Policy on the Platforms or by contacting you through other channels, such as email. Any new version of this Privacy Policy shall take effect upon the date of information or posting on the Platforms. By continuing to use any of the Platforms, you agree to be bound by the terms of these updates and amendments.

3) Collection of Personal Data

We may collect Personal Data as described below:

  1. To correspond with STARKS, to enquire about our products or services, or to book an online appointment, the User will need to submit Personal Data (including name and address, date of birth, e-mail address, telephone number and messages). Where the User is required to register on our Platforms, Personal Data will also include login and password. If online purchases are enabled, the User will also need to submit delivery, payment and invoicing information for STARKS to process the order. By providing Personal Data, the User enables STARKS to provide the products or perform the services selected. Where Users contact us on the Platforms we will keep track of the correspondence to follow-up on their requests;
  2. The same type of Personal Data may be collected when Users contact the STARKS contact centre using our number: 800-596-334. Please note that calls to the STARKS contact centre may be recorded for security, training and development purposes.
  3. To receive marketing updates and commercial information, if this option has been accepted by the User, she or he will need to submit Personal Data (including at least e-mail address). The User can decide not to receive commercial communications at any time in accordance with the Article headed “Commercial Communications” below;
  4. To interact with STARKS via a social media platforms or other third party services, we will collect Personal Data provided to us by the User through that platform and in accordance with their applicable policies;
  5. We also collect certain information automatically about Users of our Platforms, as described in the Article headed “Cookies and other information automatically collected” below.

4) Purpose and legal basis of the processing

We will use the Personal Information provided by or collect from the User:

  1. To perform the services or sales contract between us and the User, as well as at the request of the User to take the steps prior to entering into a contract, such as for example following-up on specific enquiries about our products and services or acquiring preliminary information necessary to the conclusion of the contract, and after the contract is formed to send contract related communications, including without limitation messages such as order confirmation, and to provide the products or perform the services agreed upon with the User;
  2. To Comply with our legal obligations, as required by applicable law or to communicate with and respond to the requests of authorities;
  3. To protect the vital interests of the User or of another natural person, if needed;
  4. To perform an action of public interest in some cases, to carry out or defend ourselves in legal actions, or when the processing involves Personal Data that is clearly in the public domain;
  5. To protect our legitimate interests, for example to understand how our Platform is used so that we can to continuously improve it or to limit the risks of fraud and other prohibited or illegal activities, since those interests do not conflict with the fundamental rights and freedoms of the User which require the protection of Personal Data;
  6. In accordance with the User’s consent for any other specific purpose, for example to promote STARKS or third party products and services by sending advertising material, to contact by telephone or any other form of electronic communication, such as e-mails, SMS, MMS, social networks, or to conduct market research, directly or through the services of specialized companies, via interviews, questionnaires, investigations, so that we can continuously improve the content and services we provide to the Users. Please see the article headed “Commercial Communications” below for further information about how you can control these purposes.

5) Nature of the provision of Personal Data

Please note that the provision of Personal Data pursuant to letters a), b), c), d), e) of Article 4 above is a mandatory legal or contractual requirement.

If the User fails to provide Personal Data in accordance with letter a) of Article 4, she or he may not be able to use the Platform, receive information requested about our products and services, or conclude a contract with us.

Conversely, the provision of Personal Data pursuant to letter f) of Article 4 is optional, but limited to specific purposes, such as receiving commercial communications or determining the degree of satisfaction of the Users, and the User’s consent may be withdrawn at any time in accordance with the Article headed “Commercial Communications” of this Privacy Policy.

6) Cookies and other information automatically collected

Like most websites or platforms, STARKS logs IP addresses and uses cookies and similar technologies that allow us to recognise the User, to customize the online experience, and to provide us with information about the way Users access our Platform.

We may collect information about the User’s computer or mobile device, including where available the IP address, operating system, log in times and browser type. We use this information to better understand how Users use our Platform and for internal reporting purposes. We may anonymise and then share this information with advertisers, sponsors or other businesses.

The User can find out more about how we use cookies and related technologies by checking our “Cookie Policy”.

7) Special categories of Personal Data

We do not process special categories of data such as genetic data, biometric data for the purpose of uniquely identifying a natural person, or data concerning health, unless the User has given explicit consent and entered into a contract with STARKS for the processing of those Personal Data in relation to one or more specified purposes agreed with the User.

8) Personal Data processing

Personal data will be processed in a manual or digitized form, then transmitted and inserted in the relevant databases that will be accessible to STARKS employees and external collaborators in charge of data processing, in connection with the tasks assigned to each of them and in accordance with this Privacy Policy. We limit access to Personal Data to employees and external collaborators who reasonably need access to it, to provide the products, to perform the services or in order to do their jobs.

Data processing may also be carried out by third parties that provide specific processing, administrative or instrumental tasks necessary to achieve any of the purposes mentioned in Article 4 above. For example, suppliers, agents or contractors that provide services on our behalf such as website or data hosting, online content, marketing communication, payment gateway, credit card processing, credit checks handling or fraud prevention.

Any data processing by third parties is subject to the signature of a data processing agreement with STARKS that requires data processors to comply with security, integrity, and confidentiality obligations.

9) Sharing Personal Data

We will only share Personal Data with third parties under the following circumstances:

  1. Withtechnical providers and their technicians and consultants,banksand entities operating in the financial sector, notaries, tax or accounting advisors, insurance companies, website operators and other third parties, to achieve any of the purposes mentioned in Article 4 of this Privacy Policy;
  2. With law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party;
  3. With any STARKS affiliated entity that directly or indirectly controls, is controlled by, or is under common control with the Company (the “Affiliates”), as well as any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable commercial efforts to ensure that the entity to which we transfer Personal Data uses it in a manner that is consistent with this Privacy Policy.

To know out at any time the companies to which Personal Data may be communicated, simply ask for the updated list in accordance with the Article headed “Contact us” of this Privacy Policy.

10) International Transfers

Personal Data may be transferred to, stored and processed in countries or territories located inside or outside the European Economic Area and Switzerland.

In case we have to transfer Personal Data outside the European Economic Area and Switzerland, we shall ensure that such transfer is based on an adequacy decision from the European Commission, or appropriate safeguards such as standard data protection clauses adopted by the European Commission or a Supervisory Authority, unless we obtain the User’s explicit and fully informed consent or the transfer is necessary for the conclusion or performance of a contract between us and the User.

11) Retention of Personal Data

STARKS will keep Personal Data in a form which permits identification of Users for no longer than is necessary for the purposes for which the Personal Data are processed.

The exact period of storage of depends on the purpose and legal basis according to which the Personal Data is processed and on the systems or solutions used for the processing of such Personal Data. It is not possible at the outset to detail the various time periods for which Personal Data will be stored. The criteria used to determine the period of storage include whether it is requested by applicable laws or regulations, necessary to carry out the purpose, or required for the performance of the contractual relationship with the User, and whether the User has consented or not.

Where Personal Data is used in accordance with the User’s consent for any specific purpose, as stated in letter f) of Article 4 above, for example to receive commercial communications or to take part into market research to improve our products or services, the User may withdraw her or his consent at any time in accordance with the Article headed “Commercial Communications” of this Privacy Policy.

With respect to Cookies, STARKS uses both ‘session cookies’ and ‘permanent cookies’, which can remain on Users computers or mobile devices for different periods of time. The User can enable or delete cookies at any time as explained in our “Cookie Policy”.

12) Non-personal data

For avoidance of doubt, STARKS may freely use, retain and share with third parties, data that are not personal by nature, or data that are personal subject to anonymisation or pseudonymisation.

Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific User without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the Personal Data are not attributed to an identified or identifiable natural person.

13) Advertising

The Platforms may use third parties such as network advertisers and ad exchanges to serve you ads on third party platforms after you leave our Platforms, and we may use third party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Platforms and viewing of ads and of our content.  Network advertisers are third parties that display advertisements, which may be based on your visits to the Platforms and other apps and sites you have visited. Third party ad serving enables us to target advertisements to you for products and services that you might be interested.

Third party tracking technologies are not controlled by us, even if they are associated with our Platforms or our ads.  Statements regarding our practices do not apply to the methods for collecting information used by these third parties and others or the use of the information that such third parties collect.  The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices.  We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties.

You have choices in respect of the delivery of ads.  You may opt-out of receiving certain types of behavioural ads by visiting the third party websites described in the “Cookie Policy”. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.

14) Protecting Personal Data

We want Users to feel confident about using our Platform, and we are committed to make all reasonable commercial efforts to protect Personal Data we receive or collect through our Platforms. We have put in place technical and organisational physical, electronic, and procedural measures to protect Personal Data against unauthorised or unlawful processing and against accidental loss, damage or destruction. However, where the User is asked to choose a login and password in order to access certain parts of our Platforms, the User is responsible for selecting a secure password and keeping that password confidential. The User should not share the login and password with anyone else.

15) Users’ rights

STARKS fully recognizes the following rights of each User in accordance with applicable law:

  1. Right to access the User’s Personal Data;
  2. Right to rectify the User’s Personal Data;
  3. Right to erase the User’s Personal Data;
  4. Right to restrict the processing of the User’s Personal Data;
  5. Right to portability of the User’s Personal Data;
  6. Right to object the processing of the User’s Personal Data;
  7. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing, in accordance with the Article headed “Commercial Communications” below.
  8. Right for the User to lodge a complaint with a supervisory authority.

As we care about the confidentiality of information you provided us, your rights may be assert by addressing an appropriate written request to the STARKS representative in charge of the processing, including proof of your identity, at the address mentioned in the Article headed “Contact us” of this Privacy Policy.

Please note that if we process Sensitive Data in accordance with the contract and purposes agreed between STARKS and the User, we will take special care to protect the confidentiality of such data. In this context, sensitive data, such as health-related information, will only be released in our clinics to the User upon specific written request and check of identity (please bring your passport or identity card).

16) Commercial communications: How to withdraw?

Where the User has given consent to the processing of Personal Data for any specific purpose, as stated in letter f) of Article 4 above, for example to receive commercial communications or to take part into market research to improve our products or services, the User may withdraw consent at any time.

The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

If you wish to withdraw consent to the processing of Personal Data for any specific purpose, please send us a written request at the address specified in the Article headed “Contact us” below.

You may also unsubscribe from e-mail marketing communications sent by STARKS at any time by sending a message to the email address mentioned in the Article headed “Contact us” or by clicking on the ‘unsubscribe’ link in any STARKSmarketing e-mails.

17) Contact us

If you have any questions or comments about this Privacy Policy, or privacy matters generally, please contact us at the address provided below. You can also use this address if you wish to request access to the Personal Data we hold about you or to unsubscribe from any further e-mail marketing communications:

  • Controller: SMG Italy
  • Representative of the controller: : Dell’Antonio Giacomo
  • Postal address Via Montebello, n. 27 20121 Milano (MI)
  • Telephone number: 02 / 82 959 964
  • Email address:

18) Cookie Policy

Please find below some more information about how the Platform uses cookies:

a. What is a cookie?
Cookies are text files containing small amounts of information which are downloaded to the Users’ computer or mobile devices when they visit a website or mobile application. Cookies are widely used in order to make platforms work, or to work more efficiently, as well as to provide information to the owners of the platform. Cookies are used to:

  • Recognise when the User returns to a website or mobile application previously visited.
  • Allow Users to navigate efficiently from one page to another on the Platforms;
  • Store the username and Users’ preferences, for example by remembering language and/or product preferences;
  • Allow Users to avoid entering the same information (such as username and password) several times during the visit;
  • Measure the use of services by Users, to optimize the browsing experience and the services themselves;
  • Help to ensure that adverts Users see online are more relevant to their interests.

We use cookies to enhance the online experience of our Users and to better understand how our Platform is used. Cookies may tell us, for example, whether the User has visited our Platform before or whether we have a new User.

Cookies can remain on your computer or mobile device for different periods of time. STARKS uses both ‘session cookies’ and ‘permanent cookies’. Session cookies exist only while your browser is open and are deleted automatically once you close your browser. Permanent cookies survive after your browser is closed, and can be used to recognise your computer or mobile device when you open your browser and browse the internet again. Please see below how you can enable, disable or delete Cookies.

b. Categories of cookies
There are two broad categories of cookies:

  • First party cookies, served directly by STARKS to your computer or mobile device. They may be used by STARKS to recognise your computer or mobile device when it reconnects to our Platform.First party profiling cookies may be used to track profiles and to personalize the display of the Platforms and linked communications, to make them more suitable for the User.
  • Third party cookies, which are served by a third party service provider on our Platform, and can be used to integrate third party functionality on the Platforms (for example comment forms or social network icons that allow Users to share the Platform’s content) or to recognise computers or mobile devices when they connect to other platforms. Third party cookies are commonly used for platform analytics or advertising purposes. Since the installation of cookies and other tracking systems operated by third parties cannot be technically controlled by STARKS, any specific reference is to be considered indicative. Once third-party cookies have been installed, STARKS cannot in any way delete them directly. For complete information, see the privacy policy of any third party service listed below. The User must access the information page on the privacy policy of each third party site to remove the related cookies. These privacy policies may be different from the one adopted by STARKS, and STARKS is not liable for third party activity.

c. What cookies are used on the Platform?
The Platform serves only the following types of cookies to your computer or mobile device:

Type of Cookie Purpose
Cookies necessary for essential purposes These cookies are essential to provide the User with services available through this Platform and to use some of its features, such as access to secure areas.  Without these cookies, services the User asked for, like transactional pages and secure login accounts, would not be possible.
Functionality Cookies These cookies serve a variety of purposes related to the presentation, performance and functionality of this Platform.  Their overall purpose, however, is to enhance Users’ experience and enjoyment of this Platform.

For example, some of these cookies enable visitors to specify language, product or other platform preferences.

Analytics Cookies These cookies are used to collect information about how Users use our Platform.

This type of cookie collects anonymous information about User activity on the site and how they arrived at the site and the pages visited. The information gathered does not identify any individual User and is aggregated.  It includes the number of Users to our Platform, the platforms that referred them to our Platform and the pages that they visited on our Platform.

We use this information to help run our Platform more efficiently, to gather broad demographic information and to monitor the level of activity on our Platform.

Cookies in this category are sent from the Platform or from third-party domains. Below is a list of third-party services activated on the Platform:

Google Analytics (Google Inc.) has been set up to anonymize IPs, so we can only see aggregated and non-specific information about the User. It is used for counting visits to our Platform and for statistics on how it is used. It serves to improve the service offered.

Privacy Policy-Opt out

Advertising Cookies When the User visits our Platform or click on advertisements or promotional areas on the Platform these cookies are used to deliver adverts more relevant to the User and her or his interests.  They are also used to limit the number of times the User sees an advertisement as well as help to evaluate the effectiveness of advertising and promotion.

They are usually placed by advertising networks with our permission. They remember that the User has visited a platform and this information is shared with other organisations such as advertisers.

Content sharing and social networking cookies These cookies enable users to share pages and content through third party social networking and other platforms. The companies that serve these cookies may also use your information to serve targeted advertising on other platforms. Below is a list of third-party services that may be activated on part or all of the Platforms:


·       +1 button and Google+ social widgets (Google Inc.)

·       Like button and Facebook social widgets (Facebook, Inc.)

·       Tweet button and Twitter social widgets (Twitter, Inc.)

·       Sharethis: plugin for sharing content on major social media.

·       Remarketing with Google Analytics for display advertising:

·       Youtube, videos and links to channels (Google Inc.):

·       Google AdSense and display network (Google Inc.)


·       Facebook: Remarketing with Facebook and campaign conversion
It is used to make statistics on the campaigns we promote on Facebook.


For complete information, see the privacy policy of any third party services listed.


d. How to enable or delete cookies?
Users have the right to choose whether or not to accept cookies and we explain how they can exercise this right below. However, please note that if the User chooses to refuse cookies she or he may not be able to use the full functionality of our Platforms.

To avoid cookies on a computer, the User must set cookie preferences on each browser (Internet Explorer, Google Chrome, Mozilla Firefox or Safari). There are several ways to manage cookies, for example: enable or disable cookies completely; delete specific cookies that have already been stored in the browser; block the storage of cookies on your computer by specific websites; or block third-party cookies (when, while browsing a website, cookies are stored on your computer by another website).

In the event that you have doubts or concerns about the use of cookies, you can always change the privacy settings in your browser in order to block certain types.

To manage cookies on major browsers, visit the following links:

For further information about cookies in Europe, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit and We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.


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