{"id":564,"date":"2020-03-18T15:03:49","date_gmt":"2020-03-18T15:03:49","guid":{"rendered":"https:\/\/starksglobal.com\/?page_id=564"},"modified":"2021-04-23T09:26:12","modified_gmt":"2021-04-23T08:26:12","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/starksglobal.com\/privacy-policy\/","title":{"rendered":"Privacy Policy"},"content":{"rendered":"

Privacy Policy<\/h1>\n

 <\/p>\n

1) About STARKS and this Privacy Policy<\/strong><\/p>\n

SMG Italia <\/span> has its registered offices at Milano 20121 (MI), via Montebello, n. 27<\/span> (the \u201cCompany<\/strong>\u201d).\u00a0 In this Privacy Policy, we use \u201cSTARKS<\/strong>\u201d and “we<\/strong>“, “us<\/strong>” and “our<\/strong>” to refer to the Company, its parent company, its affiliated companies and clinics.<\/p>\n

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 \u201cUser(s)<\/strong>\u201d). 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 \u201cPlatform(s)<\/strong>\u201d) 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.<\/p>\n

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.<\/strong><\/p>\n

2) Updates to this Privacy Policy<\/strong><\/p>\n

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.<\/p>\n

3) Collection of Personal Data <\/strong><\/p>\n

We may collect Personal Data as described below:<\/p>\n

    \n
  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;<\/li>\n
  2. The same type of Personal Data may be collected when Users contact the STARKS contact centre using our number: 800-596-334<\/span>. Please note that calls to the STARKS contact centre may be recorded for security, training and development purposes.<\/li>\n
  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 \u201cCommercial Communications\u201d<\/a> below;<\/li>\n
  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;<\/li>\n
  5. We also collect certain information automatically about Users of our Platforms, as described in the Article headed “Cookies and other information automatically collected”<\/a> below.<\/li>\n<\/ol>\n

    <\/a>4) Purpose and legal basis of the processing<\/strong><\/p>\n

    We will use the Personal Information provided by or collect from the User:<\/p>\n

      \n
    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;<\/li>\n
    2. To Comply with our legal obligations, as required by applicable law or to communicate with and respond to the requests of authorities;<\/li>\n
    3. To protect the vital interests of the User or of another natural person, if needed;<\/li>\n
    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;<\/li>\n
    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;<\/li>\n
    6. In accordance with the User\u2019s 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 \u201cCommercial Communications\u201d<\/a>\u00a0below for further information about how you can control these purposes.<\/li>\n<\/ol>\n

      5) Nature of the provision of Personal Data<\/strong><\/p>\n

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

      If the User fails to provide Personal Data in accordance with letter a) of Article 4<\/a>, 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.<\/p>\n

      Conversely, the provision of Personal Data pursuant to letter f) of Article 4<\/a> is optional, but limited to specific purposes, such as receiving commercial communications or determining the degree of satisfaction of the Users, and the User\u2019s consent may be withdrawn at any time in accordance with the Article headed \u201cCommercial Communications\u201d<\/a> of this Privacy Policy.<\/p>\n

      6) Cookies and other information automatically collected<\/strong><\/p>\n

      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.<\/p>\n

      We may collect information about the User\u2019s 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.<\/p>\n

      The User can find out more about how we use cookies and related technologies by checking our “Cookie Policy”.<\/a><\/p>\n

      7) Special categories of Personal Data<\/strong><\/p>\n

      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.<\/p>\n

      8) Personal Data processing <\/strong><\/p>\n

      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.<\/p>\n

      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<\/a> 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.<\/p>\n

      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.<\/p>\n

      <\/a>9) Sharing Personal Data <\/strong><\/p>\n

      We will only share Personal Data with third parties under the following circumstances:<\/p>\n

        \n
      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<\/a> of this Privacy Policy;<\/li>\n
      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;<\/li>\n
      3. With any STARKS affiliated entity that directly or indirectly controls, is controlled by, or is under common control with the Company (the \u201cAffiliates<\/strong>\u201d), 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.<\/li>\n<\/ol>\n

        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 \u201cContact us\u201d<\/a> of this Privacy Policy.<\/p>\n

        10) International Transfers<\/strong><\/p>\n

        Personal Data may be transferred to, stored and processed in countries or territories located inside or outside the European Economic Area and Switzerland.<\/p>\n

        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\u2019s explicit and fully informed consent or the transfer is necessary for the conclusion or performance of a contract between us and the User.<\/p>\n

        11) Retention of Personal Data<\/strong><\/p>\n

        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.<\/p>\n

        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.<\/p>\n

        Where Personal Data is used in accordance with the User\u2019s consent for any specific purpose, as stated in letter f) of Article 4<\/a> 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 \u201cCommercial Communications\u201d<\/a> of this Privacy Policy.<\/p>\n

        With respect to Cookies, STARKS uses both ‘session cookies’ and \u2018permanent cookies\u2019, 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”.<\/a><\/p>\n

        12) Non-personal data<\/strong><\/p>\n

        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.<\/p>\n

        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.<\/p>\n

        13) Advertising<\/strong><\/p>\n

        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.\u00a0 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.\u00a0Third party ad serving enables us to target advertisements to you for products and services that you might be interested.<\/p>\n

        Third party tracking technologies are not controlled by us, even if they are associated with our Platforms or our ads.\u00a0 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.\u00a0 The relevant third party\u2019s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices.\u00a0 We make no representations regarding the policies or practices of third party advertisers or advertising networks or exchanges or related third parties.<\/p>\n

        You have choices in respect of the delivery of ads.\u00a0 You may opt-out of receiving certain types of behavioural ads by visiting the third party websites described in the “Cookie Policy”<\/a>. We are not responsible for effectiveness of or compliance with any third parties\u2019 opt-out options.<\/p>\n

        14) Protecting Personal Data <\/strong><\/p>\n

        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.<\/p>\n

        15) Users\u2019 rights <\/strong><\/p>\n

        STARKS fully recognizes the following rights of each User in accordance with applicable law:<\/p>\n

          \n
        1. Right to access the User\u2019s Personal Data;<\/li>\n
        2. Right to rectify the User\u2019s Personal Data;<\/li>\n
        3. Right to erase the User\u2019s Personal Data;<\/li>\n
        4. Right to restrict the processing of the User\u2019s Personal Data;<\/li>\n
        5. Right to portability of the User\u2019s Personal Data;<\/li>\n
        6. Right to object the processing of the User\u2019s Personal Data;<\/li>\n
        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 \u201cCommercial Communications\u201d<\/a> below.<\/li>\n
        8. Right for the User to lodge a complaint with a supervisory authority.<\/li>\n<\/ol>\n

          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 \u201cContact us\u201d<\/a> of this Privacy Policy.<\/p>\n

          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).<\/p>\n

          <\/a>16) Commercial communications: How to withdraw?<\/strong><\/p>\n

          Where the User has given consent to the processing of Personal Data for any specific purpose, as stated in letter f) of Article 4<\/a> 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.<\/p>\n

          The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.<\/p>\n

          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 \u201cContact us\u201d<\/a> below.<\/p>\n

          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 \u201cContact us\u201d<\/a> or by clicking on the \u2018unsubscribe\u2019 link in any STARKSmarketing e-mails.<\/p>\n

          <\/a>17) Contact us<\/strong><\/p>\n

          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:<\/p>\n