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We at Starky's Club have created this Privacy Policy to explain how we collect, use, disclose and otherwise process personal information in connection with operating our business.
This Privacy Policy describes the practices concerning the information collected through the use of our websites and mobile applications (such as Self-CEO) on which this Privacy Policy is posted by our company Starky's Club s.r.o., a Czech registered limited liability company with identification number 05301122 and its registered seat at Strančická 1084/29, 100 00, Praha 10 - Strašnice, registered in the Commercial Register of the Municipal Court in Prague, File No. C 261487. The terms "Starky's Club", "we", "us" or "our" used in this Privacy Policy refer to the above specified company Starky's Club s.r.o.
This Privacy Policy applies to our websites and mobile applications and other online services we may provide on which this Privacy Policy is posted, and our collection of information from our corresponding social media features and pages (each a "Service" and collectively, the "Services"). In addition to describing how we collect, use, disclose and otherwise process personal information, this Privacy Policy explains the rights and choices available to individuals with respect to their personal information.
We greatly respect your privacy, which is why we make every effort to provide a platform that would live to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can among others fully understand our practices in relation to Personal Data. "Personal Data" means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.
This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.
We may obtain information about you in a variety of ways, including through your use of our Services, when you call, email or otherwise communicate with us (including through social media), or when you participate in events or other promotions.
The information that we collect, whether from you directly or automatically, may be considered personal information in certain jurisdictions or personal data under the European General Data Protection Regulation (the "GDPR"). Whenever we refer to personal information in this Privacy Policy, it means personal information or personal data as defined by applicable laws in the relevant jurisdiction.
We may obtain information, including personal information from third parties and sources that we integrate into our Services either for the provision of our services or to facilitate your access to our Services such as described below.
You may be given the option to access or register for our services through the use of your third-party social media account, such as Facebook or Google. If you select this option, your social media provider may make some of your personal information available to us, such as your email address or other unique identifier or we may be asked to share certain information with such social media provider. If you choose to sign on through your third party social media provider, you authorize us to collect your information from such provider and process it in accordance with this Privacy Policy and you also authorize us to share your information with your social media provider as necessary to permit you to access our services using your social media account. We recommend that you review your social media provider's privacy policies carefully before using their service to connect to our Services.
We may collect Automated Information through the use of cookies, and other technologies. Please see our Cookies Policy for more information on cookies. In addition to cookies, such other technologies may include:
"Pixel tags" (also known as a "clear GIFs" or "web beacons") which are tiny images (in most cases, typically just one-pixel) that can be placed on a Web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you've opened one of our emails or seen one of our Web pages.
"HTML5" (the language some websites, such as mobile websites, are coded in) may be used to store information on your computer or device about your website usage activities and to help determine how our Services are being used by our visitors, how the services can be improved and to customize our Services for our users.
The above tracking technologies may be deployed by us or our service providers on our behalf. You can find more information on our third-party service providers in Section 4 of this Privacy Policy.
Automated Information includes information such as:
In addition to the purposes described above, we may use the information we collect for a variety of purposes, such as those described below.
Performing Our Services
Maintaining or servicing accounts, providing customer service, operation our website and mobile applications; processing or fulfilling orders and transactions, verifying user information, processing payments
Communicating about the products and Services we offer, and responding to requests, inquiries, comments, and suggestions
Internal Research
Understanding and evaluating how our Services and features perform with our users
Uncovering insights about usage in order to improve the Services and provide customers with enhanced features as well as inform our development of new features and products.
Development of customized or personalized experiences of our Services, such as remembering your information, so you do not have to re-enter it each time you use one of our Services
Auditing Interactions with Consumers
measuring usage of our websites and mobile applications
measuring our advertising and marketing activity (e.g., measuring how a user was acquired)
Security
To provide you with a secure experience and to take measures to protect our website and mobile applications from cyber risks
Protecting against, identifying, investigating, preventing, and responding to fraud, illegal activity (such as incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities, including by enforcing the terms and conditions that govern the Services we provide
Debugging/Repair
identification and repair of impairments to intended, existing functionality of our Services
Marketing
Understanding our customer in order to more effectively market our Services
Quality and Safety Maintenance and Verification
activities related to improving the quality of the Services we provide, including upgrade or enhancement of the Services
verification or maintenance of the quality or safety of Services
Tracking and responding to quality and safety matters
Protecting our rights and property
Other purposes that may be described at the time you choose to provide personal information to us
To perform the above functions, we may match information collected from you through different means or at different times, including both personal information and Automated Information, and use such information along with information obtained from other sources. We may also aggregate and/or de-identify any information that we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis and business planning – without restriction.
In this section, we identify the legal grounds on which we rely to process personal information.
If we rely on consent for the processing of your personal information, we will seek such consent at the time we collect your personal information.
We may share information about you for the purposes described in this Privacy Policy or pursuant to a specific "in-time" privacy notice we may provide at the time we collect the information.
We may share information about you with the following categories of third-party providers for a variety of business purposes:
Customer Communications and Insights Platforms. We may share phone number, email, app usage and interactions with our third-party customer communications platform provider for the following business purposes: performing services that allow us to communicate with you and administer your account as well as track your usage for our internal analytics.
Internal Business Insights Platforms. Our third-party internal business analytics platform provides us with the tools to help us understand app usage and interactions and uncover insights that allow us to improve our product and features. We may share or make available unique user identifiers, IDFA, deviceID, IP address and app usage and events (such as when you subscribed to our services) with these providers for the following business purposes: performing services that allow us to (i) monitor and understand usage in order to enhance existing Services or develop new products and features and (ii) better understand our customers in order to market our products more effectively.
Customer Support. When you contact us through our one of our support emails indicated in the "How to Contact Us" section at the bottom of this Privacy Policy, your email may be directed through our third party customer support platform which will have access to your personal information, the content of your email as well as date and time your request came into our system. We use this provider to allow us to communicate with you about your account and to receive reports from users about the quality or safety of our products.
Measurement and Attribution. These service providers offer tools that allow us to measure and attribute the source of new subscription sign ups and that allow us to uncover insights about usage and app events. We may use unique user identifiers made available to us from these third-party providers to help us measure the effectiveness of our ads (e.g., where and how a user is acquired) and to uncover information about how our customers are using our apps in order to improve their quality and safety. We may also share and/or store unique user identifiers, deviceIDs, IDFA or IP addresses with these providers for the same purpose.
Other technology providers necessary to provide our services (including cloud storage and web hosting providers). We may make certain Automated Information and/or aggregate or non-personally identifiable information available for various purposes including monitoring network traffic to detect malicious actors and to protect against malware, fraud or other unlawful uses or activity.
Marketing providers. We, or the third-party service providers we use to assist us with marketing our own products to you, may use the information we collect from you to provide advertisements and offers for our other products. Additionally, we may share certain information with Facebook that allows us to create Custom or Lookalike Audiences. You may learn more about Facebook Lookalike Audiences click here and about your off-Facebook activity and how to opt out of having such activity sent to Facebook click here. We encourage you to review Facebook's Privacy Policy here. Additionally, if we obtain your information in connection with a contest, sweepstakes, event, offering or other promotional activity that is jointly offered by us and any third parties. By entering such contest or sweepstakes, you authorize and direct us to share your information with our co-sponsor. We may also share your information with a third-party service provider who administers the promotion, contest and/or sweepstakes. We may also share aggregate information to third party providers and platforms that help us understand our user demographic, including user demographic interests, habits and usage patterns for certain of our Services so that we may market our products more effectively.
We may share information about you in connection with (including during the evaluation or negotiation of) a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind-down of a business (each a "Corporate Transaction"). Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we engage in any Corporate Transaction (including, selling or transferring all or a portion of our business or assets). If we engage in such a sale or transfer, we will, where feasible - direct the recipient to use the information in a manner that is consistent with this Privacy Policy. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.
We may transfer your personal information to countries other than the country in which the data was originally collected for the purposes described in this Privacy Notice. For example, if you are located outside of the United States, we may transfer your personal information to the United States. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information. When we transfer personal information across borders, we consider a variety of requirements that may apply to such transfers.
Specifically, we may transfer personal information from the European Economic Area to:
In addition, we may disclose and/or share your information to comply with legal or regulatory requirements (including to comply with a court order, judicial subpoena or other subpoena or warrant), industry standards, judicial process, and our company policies, as well as to protect against, identify, investigate, prevent and respond to fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), adverse event reporting, and claims and other liabilities.
We also reserve the right to disclose your information (i) when we believe in good faith that disclosure is appropriate or necessary to take precautions against liability, (ii) to protect our rights or property or the legal and property rights of others and (iii) investigate and defend third party claims or allegations against us.
In addition, we may collect, use and disclose your personal information as required or permitted by applicable law, or as directed by you, in accordance with this Privacy Policy.
We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information. Also, we cannot and do not guarantee that information will be absolutely safe from interception or intrusion during transmission or while stored on our system, or otherwise, and you provide information to us at your own risk.
If you correspond with us by email, text message or using Web forms like a "contact us" feature available through our Services, you should be aware that your transmission might not be secure from access by unauthorized parties. We have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission. If you create an account as part of using our Services, you are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account. Please notify us of any unauthorized use of your password or account.
If we believe that the security of your personal information in our care may have been compromised, we may seek to notify you. If we have your email address, we may notify you by email to the most recent email address you have provided us. Please keep your email address up to date. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your email account using your computer or mobile device and email application software. We may also post a conspicuous notice on our site or notify you through the mobile application. You consent to our use of email, text message and/or notification through the app as a means of such notification. If you prefer for us to use the postal service to notify you in this situation, please let us know by submitting your request here. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this email address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your personal information.
We do not retain your personal data longer than is necessary. Generally, except as provided below, we may retain your personal information for the longer of three (3) years after we become aware that you have ceased using our services or for so long as necessary to fulfil any contractual obligation governing the information or our legal and regulatory obligations. However, we may not know if you have stopped using our services, so we encourage you to contact us at the appropriate support email in the "How to Contact Us" section of this Privacy Policy if you are no longer using the services. We may retain other information that is not personally identifiable for backups, archiving, prevention of fraud and abuse, analytics, or where we otherwise reasonably believe that we have a legitimate reason to do so.
Please note that under applicable laws, we may be required to retain the data for a longer or a shorter period.
In some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
The following rights (which may be subject to certain exemptions or derogations), shall apply to certain individuals (some of which only apply to individuals protected by the GDPR in certain circumstances):
You can exercise your rights by contacting us at Self-CEO@starkysclub.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
If you are an individual subject to the GDPR, you can read more about your rights here: https://ec.europa.eu/info/law/law-topic/data-protection_en
We do not knowingly collect information from children under the age of 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws). If you are not over 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws) then DO NOT DOWNLOAD OR USE THE SERVICES. If you believe that we may have personal information from or about a child under the age of 16 years old, please contact us here. Note that we'll attempt to delete the account of any child under the age of 16 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account.
We reserve the right to update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will update the date of this Privacy Policy. Continued use of the Services after such date constitutes acceptance of such updates. When required by applicable law, we may inform you by additional means, such as through a notification on the website or in our mobile applications if we make material changes to how your personal information is collected, accessed or otherwise used as a result of your use of the Services or if your rights under this Privacy Policy are materially impacted by changes to our privacy practices. We recommend that you check this page from time to time to inform yourself of any changes in this Privacy Policy.
We do not knowingly collect information from children under the age of 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws). If you are not over 16 years old (or older if required in an applicable jurisdiction to comply with applicable laws) then DO NOT DOWNLOAD OR USE THE SERVICES. If you believe that we may have personal information from or about a child under the age of 16 years old, please contact us here. Note that we'll attempt to delete the account of any child under the age of 16 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account.
This Privacy Policy becomes effective as of 28 July 2020
