Star Gate Privacy Policy

 

1. Introduction

Welcome to Star Gate’s Privacy Policy!

At Star Gate, we believe in being transparent about how we conduct our business. In fact it is one of our core values. We, therefore, would like to be very transparent about the way we collect and use your personal data. This privacy policy (“Policy”) was developed by Star Gate Holdings Limited UK (“us” or “we” or “Star Gate”) in order for you to understand how we, our subsidiaries and affiliates collect, use, communicate, protect, disclose, and make use of personal information in connection with our website (“Site”), our blogs (“Blogs”), our mobile application (“App”) or other service (collectively “Services” and each individually as “Service”). This Policy also tells you about your rights and choices with respect to your Personal Information, defined as information relating to an identified or identifiable individual, and how you can contact us if you have any questions or concerns.

We encourage you to read the Policy carefully before you use any of our Services. This Policy applies to all of our Services that link to it, including when you interact with us in other contexts. Your continued use of our Services constitutes consent to the Policy. If you have any questions or concerns regarding this policy, please contact us at privacy@stargategroup.gr.

2. What information we collect

Category	Examples	Collected
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal Information Categories	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Yes
C. Protected classification characteristics	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes
D. Commercial information	Records of personal property, solutions purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity	Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.	Yes
G. Geo-location data	Physical location or movements.	Yes
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information	Current or past job history or performance evaluations.	Yes
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No
L. Equipment information	Information about your internet connection, the equipment you use to access our Website, and usage details.	Yes

3. How do we collect this information

We collect information mainly in three ways:

1. We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website or any User Website, register a User Account, make an inquiry or a booking of a property, when you download our App, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services, including through the use of “cookies” and other tracking technologies.
2. We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you sign in to our Services via third party services such as Facebook or Google; when you make inquiries or bookings for certain apartments; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly by any communication channel (e.g., telephone, email).

3. We also collect information from third party sources as described in Section 11 below.

Some information you provide through the Services is collected and processed by third parties on our behalf. For example, when you make an online booking through the Services, we need to collect your credit or debit card information. This information is collected and processed by third-party payment processors. In the event that a credit report is required to use a Service, you may be asked to provide your Social Security number (“SSN”). When SSNs are required, we use technology to pass that information directly to the third-party providers who need the information to process the credit or background check report.

4. How do we use this information

We use the collected information to:

• Provide you with our Services as an unregistered or registered user of the Site, process transactions and send related information such as confirmations and invoices;
• Send you technical notices, updates, security alerts and support and administrative messages;
• Respond to your comments, questions and requests and provide customer service;
• Manage and improve the performance of our products and Services;
• Communicate with you about products, services, offers, promotions, rewards and events offered by Star Gate and others, and provide news and information we think will be of interest to you;
• For audits and reporting purposes;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Star Gate, as well as that of our employees, our agents or others, and to comply with applicable law and government requests;
• Provide and deliver the Services, process transactions and send related information such as confirmations and invoices;
• Monitor and analyze trends, usage and activities in connection with our Services;
• Revise, modify, and update existing Services and develop new Services;
• Carry out any other purpose described to you at the time the information was collected.

We only collect personal information that is required for us to collect by our legal obligations or is necessary to fulfill the Services, as described here. We may retain your Personal Information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal or regulatory requirements or as otherwise disclosed to you.

5. How do we disclose this personal information

We may disclose personal information in the following circumstances and to the following parties:

• Other companies belonging to or directly affiliated to Star Gate and always in accordance with this policy. Note that sharing of Personal Information from Star Gate subsidiaries and affiliated companies in the European Union with Star Gate’s United States subsidiary, adheres to the EU-US Privacy Shield frameworks.
• Certain service providers perform a number of services on our behalf, such as web hosting, email service providers, payment processing, analytics, etc. To do so, we sometimes need to share your personal information with them for the purposes described above. These service providers are located around the world.
• Certain third-parties when required by law, and when necessary to provide, and to protect Our Services.
• Certain third-party partners, after we receive your explicit consent. We will request your consent to share personal information about you with third parties so that they may provide you with special offers, promotional materials, and other materials that may be of interest to you.
• Aggregated information that does not identify specific individuals.
• Third parties involved in a corporate transaction involving all or part of Star Gate assets.

To clarify, Star Gate may share your Personal Information in manners other than as described above, pursuant to your explicit approval, or if we are legally obligated to do so.

6. What are your rights in relation to your personal information

It is important that you have control over your Personal Information. That’s why we are taking steps to enable you to access, receive a copy of, update, amend, delete, or limit the use of your Personal Information.

Individuals located in certain jurisdictions, including the European Economic Area, California, and other US states that have enacted consumer privacy laws, have certain statutory rights in relation to their personal data. Specifically, they have the following rights:

• Right of access: you have the right to obtain confirmation that your personal data is processed, and in the case of processing, information regarding the purposes of your data processing, the retention period (and the criteria used to determine this period) of the data, the recipients to whom your personal data has been or will be disclosed, and a copy of your personal data that we maintain.
• Right to data portability: you have the right to receive your personal data that you have provided to us, in a structured, commonly used and machine-readable format.
• Right to rectification or correction: you have the right to obtain rectification of any inaccurate or incomplete personal data that we maintain about you.
• Right to erasure (right to be forgotten): you have the right, in some circumstances, to obtain the erasure of the personal data that we maintain about you. The right to be forgotten is not unreservedly guaranteed. It is limited especially when colliding with the right of freedom of expression and information. Other exceptions are if the processing of data which is subject to an erasure request is necessary to comply with legal obligations, for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes or for the defence of legal claims.
• Right to restriction of processing: you have the right, in some circumstances, to obtain restriction of processing to the personal data that we maintain about you.
• Right to object: you have the right to object to any processing of your personal data that we maintain, but there may be compelling reasons for continuing this processing from our side. In any case we will assess your request and respond to you accordingly. Marketing activities are not included in the aforementioned compelling reasons.

Before disclosing the requested records of Personal Information, we keep of you, we may ask you for additional information in order to confirm your identity and for security purposes. We reserve the right to charge a fee were permitted by law (e.g., if your request is unfounded or excessive).

Star Gate does not “sell” or “share” your Personal Information as we understand those terms are used under the California Consumer Privacy Act.

If you believe that Star Gate has failed to take appropriate action in responses to your privacy rights request, you have the right to appeal and can do so by contact us as described below. You also have the right to file a complaint with your local supervisory authority for data protection (but we still recommend that you contact us first).

In case you wish to exercise one of these rights, please contact us at privacy@stargategroup.gr. We will make all reasonable efforts to honor your request promptly (unless we require further information from you in order to fulfill your request), subject to legal and other permissible considerations.

We will not discriminate against you for exercising any of your rights described here.

7. Information security and privacy incident reporting

We implement reasonable organizational and technical measures in order to safeguard your Personal Information against accidental or unlawful destruction, loss, change or damage. Having said that, no security program is 100% foolproof and thus we cannot guarantee the absolute security of your personal or other information.

8. Interest-based advertising

We participate in interest-based advertising. This means that when you use the Services, we or third-party service providers or advertisers may use cookies (that they collect or that we provide to them) or other similar technologies to collect information about your use of the Services (including mobile applications) or your online activities over time and across different websites and devices. Collected information may include the content you view, the date and time that you view this content, and the website that referred you to the Services, and this information may be associated with your unique browser, device identifier, or Internet Protocol (IP) address. These practices help tailor advertisements that are relevant and useful to you. These tailored advertisements may appear on the Services or on other websites, applications or properties. For more information and to opt-out of most third-party cookie collection, you can visit https://optout.aboutads.info/?c=2&lang=EN or https://optout.networkadvertising.org/?c=1.

In addition, if you have provided your email address to us, we may use a scrambled, unreadable form (a hash) of your email address to deliver tailored advertisements to you on the Services or on other websites. We do not access or collect any of the contents of your email messages in providing interest-based advertising. Our use of information received from Gmail APIs will adhere to Google’s Limited Use Requirements.

9. Communication from Star Gate

We may use your Personal Information to send you promotional content and messages by email, text messages, direct text messages, marketing calls and similar forms of communication. If you do not wish to receive such promotional messages or calls, you may notify us at any time or follow the “unsubscribe” link. We take steps to limit the promotional content we send you to a reasonable and proportionate level, and to send you information which we believe may be of interest or relevance to you, based on your information.

Also, we may contact you with important information regarding our Services, or your use thereof. For example, we may send you billing information; replies to your support ticket or email; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; or notify you of material changes in our Services.

It is important that you are always able to receive such messages. For this reason, you are not able to opt-out of receiving such Service and Billing Messages unless you are no longer a Star Gate Visitor or User.

10. Star Gate job applications

Star Gate welcomes all qualified Applicants to apply to any of the open positions published on https://boards.greenhouse.io/StarGate, by sending us their contact details and CV (“Applicants’ Information”) via email or through any other means.

We understand that privacy and discreteness are crucial to our Applicants, and are committed to keep Applicants’ Information private and use it solely for Star Gate’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).

Please note that Star Gate may retain Applicants’ Information submitted to it for no longer than two years after the applied position has been filled or closed. This is done so we can re-consider Applicants for other positions and opportunities at Star Gate; so we can use their Applicants Information as a reference for future applications submitted by them; and if the Applicant is hired, for additional employment and business purposes related to his/her work at Star Gate.

If you previously submitted your Applicants’ Information to Star Gate, and now wish to access it, update it or have it deleted from Star Gate’s systems, please contact us at privacy@stargategroup.gr.

11. Opting out of collection of information by third parties

Star Gate’s third-party ad servers, ad network providers, third-party advertisers may provide you with advertisements that you may see on the Services or on other affiliated websites. To improve the relevancy and help measure the effectiveness of such advertisements, the Star Gate Ad Providers may use cookies, web beacons, clear gifs or similar technologies. These are used to record users’ activity, such as the pages visited, and to learn what types of information are of most interest to the users. As noted above, you can learn more and opt-out, by visiting https://optout.aboutads.info/?c=2&lang=EN or https://optout.networkadvertising.org/?c=1.

12. Third-party links and websites

Throughout the Services, we may link to the websites of other companies and/or individuals. These third-party websites may collect information about users on those websites, and Star Gate’s privacy policy does not extend to these external websites and third parties. Please refer directly to these third parties and websites regarding their privacy policies.

13. Children’s privacy

Our Services are addressed to individuals, who are at least 18 years old, unless we specify otherwise. For individuals under 18, we do not knowingly collect personal data, without prior parental consent. If you find out that your child has provided us with any personal data, without your prior consent, please inform us, in order to delete this information and terminate any account that your child may have created with us.

14. Visitors from outside the United States — Cross-Border Transfer

The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and law applicable in such jurisdictions. By using the Services and/or providing Personal Information to us, you consent to transfer of your information to our facilities as described in this Privacy Policy.

15. Updates to this policy

This Star Gate Site Privacy Policy may be changed or updated occasionally to meet legal, technological or operational requirements and standards. You are encouraged to frequently visit this policy to stay updated about changes. In case of critical changes, these will be circulated to you prior to their implementation. Modifications will be effective on the day they are published.

16. How to contact us

If you have any questions about this Privacy Policy or wish to exercise any of your rights, you may contact us at privacy@stargategroup.gr. We will attempt to resolve any complaints regarding the use of your Personal Information in accordance with this Privacy Policy.

Our EU head office by mail at Voukourestion 18, Athens, Greece.