Privacy En

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PRIVACY POLICY
Effective May 25, 2018
This Starbit Privacy Policy (“Policy”) outlines the information that Starbit International Ltd.
(“Starbit”, “we”, “us” or “our”) gathers, how we use that information, and the options you have
to access, correct, or delete such information
STARBIT’S PROMISE
Our mission to help build a better knowledge of Blockchain and its applications (such as cryptocurrencies) is rooted
in the importance we place on establishing trust with our Customers, Website Visitors, and the Internet community
globally. To earn and maintain that trust, we commit to communicating transparently, providing security, and
protecting the privacy of data on our systems.
We keep your personal information personal and private. We will not sell, rent, share, or otherwise disclose your
personal information to anyone except as necessary to provide our services or as otherwise described in this Policy
without first providing you with notice and the opportunity to consent.

  1. POLICY APPLICATION:
    This Policy applies to Starbit’s collection, use, and disclosure of the information of the following categories of
    individuals:
    ● Attendees: Individuals who provide their information to Starbit or Starbit representatives when they attend
    or register to attend Starbit-sponsored events or other events at which Starbit participates.
    ● Website Visitors: Individuals who visit our Websites and who may opt to provide an email address to
    became member and receive communications from Starbit. For the purposes of this Policy, “Websites” shall
    refer collectively to www.starbit.com as well as any other websites Starbit owns and that link to this Policy.
    For clarity, “Websites” does not include any sites owned or operated by our Customers, including where we
    serve as Registrar.
    ● Customers: Those who register on their own or on behalf of an entity or organization to buy and use any of
    the Starbit Services (as defined below), including administrators on a Customer account. For the purposes of
    this Policy, “Services” shall refer to all services marketed for subscription at www.starbit.
    ● Promoter: Individuals who collaborates with Starbit network marketing.
    This Policy does not apply to our Promoters’ websites, which may have their own terms and privacy policies. Our
    Promoters are solely responsible for establishing policies for and ensuring compliance with all applicable laws and
    regulations, including those relating to the collection of personal information in connection with their marketing
    activity.
    Starbit’s Websites and Services are not intended for, nor designed to attract, individuals under the age of eighteen.
    Starbit does not knowingly collect personally identifiable information from any person under the age of eighteen.
  2. INFORMATION WE COLLECT
    Attendees:
    ● We may ask for and collect personal information such as your name, address, phone number and email
    address when you register for or attend a sponsored event or other events at which Starbit (and/or its
    representatives) participates.
    Website Visitors:
    ● Name, email address, and other contact information. We ask for and—at your option—collect personal
    information from you when you submit web forms on our Websites, including opportunities to sign up for
    and agree to receive email communications from us. We also may ask you to submit such personal
    information if you choose to use interactive features of the Websites, including participation in surveys,
    contests, promotions, sweepstakes, requesting customer support, or otherwise communicating with us. We  will send such communications in accordance with applicable law.
    ● Log Files. Just as when you visit and interact with most websites and services delivered via the Internet,
    when you visit our Websites, including the Starbit Community Forum, we gather certain information and store  it in log files. This information may include but is not limited to Internet Protocol (IP) addresses,
    system configuration information, URLs of referring pages, and locale and language preferences.
    ● Cookies and Other Tracking Technologies. We may use cookies and other information gathering technologies
    for a variety of purposes, such as providing us with information about how you interact with
    our Websites and assisting us in our marketing efforts. You can control how websites use cookies by
    configuring your browser’s privacy settings (please refer to your browser’s help function to learn more about cookie
    controls). Note that if you disable cookies entirely, Starbrt’s Websites may not function properly.
    We may also use cookies and similar technologies to provide you advertising on third-party sites based upon your
    browsing activities and interests. For more information about the cookies Starbit uses, please see our
    Cookie Policy.
    ● Interactive Areas. The Websites may offer publicly accessible blogs, community forums, comments sections
    , discussion forums, or other interactive features (“Interactive Areas”). If you choose to participate
    in any of these Interactive Areas, please be aware that any information that you post in an Interactive
    An area might be read, collected, and used by others who access it. If you wish to remove your personal information from
    any of our Interactive Areas, please see the section below entitled, Your Data Rights.
    Customers:
    ● Customer Account Information. When you register for a Starbit account, we collect your email address. We refer
    to this information as “Customer Account Information” for the purposes of this Policy. Customer
    Account Information is required to identify you as a Customer and permit you to access your account(s). By voluntarily
    providing us with such Customer Account Information, you represent that you are the owner of
    such personal data or otherwise have the requisite consent to provide it to us.
    ● Payment Information. You are not required to enter any payment details as we accept payment on our cryptocurrencies
    wallets, therefore we don’t collect any of your personal data of payment.
    ● Legal Basis for Processing (EEA only):
    If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using
    your personal information will depend on the personal information collected and the specific context in which we
    collect it. We normally will collect personal information from you only where: (a) we have your consent to do so,
    (b) where we need your personal information to perform a contract with you (e.g. to activate the Starbit Services you have
    requested), or (c) where the processing is in our legitimate interests. Please note that in most cases, if you do not
    provide the requested information, Starbit will not be able to provide the requested service to you.
    In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need
    the personal information to protect your vital interests or those of another person.
    Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at
    any time. Where we rely on our legitimate interests to process your personal data, you have the right to object.
    If you have any questions about or need further information concerning the legal basis on which we collect and use
    your personal information, please contact us at [email protected]
  3. HOW WE USE INFORMATION WE COLLECT
    Starbit only processes personal information in a way that is compatible with and relevant for the purpose for which it
    was collected or authorized. As a general matter, for all categories of data we collect, we may use the information we
    collect (including personal information, to the extent applicable) to:
    ● provide, operate, maintain, improve, and promote the Website and Services;
    ● enable you to access and use the Website and Services;
    ● process and complete transactions, and send you related information, including purchase confirmations and
    invoices;
    ● send transactional messages, including responses to your comments, questions, and requests; provide
    customer service and support; and send you technical notices, updates, security alerts, and support and
    administrative messages;
    ● send commercial communications, in accordance with your communication preferences, such as providing
    you with information about products and services, features, surveys, newsletters, offers, promotions,
    contests, and events about us and our partners; and send other news or information about us and our
    partners. See Section 8 below for information on managing your communication preferences.
    ● process and deliver contest or sweepstakes entries and rewards;
    ● monitor and analyze trends, usage, and activities in connection with the Websites and Services and for
    marketing or advertising purposes;
    ● comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized
    access to the Services, and other illegal activities;
    ● personalize the Websites and Services, including by providing features or content that match your interests
    and preferences; and
    ● process for other purposes for which we obtain your consent.
  4. INFORMATION SHARING
    We work with other companies who help us run our business (“Service Providers”). These companies provide
    services to help us deliver customer support, process credit card payments, manage and contact our existing
    Customers as well as sales leads, provide marketing support, and otherwise operate and improve our Services. These
    Service Providers may only process personal information pursuant to our instructions and in compliance both with this
    Privacy Policy and other applicable confidentiality and security measures and regulations, including our
    obligations under the EU-US and Swiss-US Privacy Shield frameworks described in Section 6, below.
    Specifically, we do not permit our Service Providers to use any personal information we share with them for their
    own marketing purposes or for any other purpose than in connection with the services they provide to us.
    In addition to sharing with Service Providers as described above, we may also share your information with others in
    the following circumstances:
    ● Within Starbit (defined for the purposes of this Policy as Starbit International Ltd. (Dubai));
    ● With our promoters who may help us distribute the Services to Customers;
    ● In the event of a merger, sale, change in control, or reorganization of all our part of our business;
    ● When we are required to disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims);
    ● Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding
    illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person,
    violations of our Service Agreement, or as otherwise required to comply with our legal obligations; or
    ● As you may otherwise consent from time to time.
    We do not sell, rent, or share personal information with third parties for their direct marketing purposes, including as
    defined under Dubai Civil Code.
  5. DATA AGGREGATION
    Starbit may aggregate data we acquire about our Customers and their End Users, including the Log Data described above
    . For example, we may assemble data to determine how Web crawlers index the Internet and whether they are engaged
    in a malicious activity or to compile web traffic reports and statistics. Non-personally identifiable, aggregated data
    may be shared with third parties.
  6. INTERNATIONAL INFORMATION TRANSFERS
    Starbit is a Dubai global company. We primarily store your information in Canada and the European Economic
    Area (the “EEA”). To facilitate our global operations, we may transfer and access such information from around the world,
    including from other countries in which the Starbit has operations for the purposes described in this Policy.
    Whenever Starbit shares personal information originating in the EEA with a Starbit entity outside the EEA, it will do
    so on the basis of the EU standard contractual clauses or the Privacy Shield Frameworks detailed in this section.
    If you are accessing or using our Websites or Services or otherwise providing information to us, you are agreeing to
    the transfer of your personal information to Canada and other jurisdictions in which we operate.
  7. DATA SUBJECT RIGHTS
    Attendees, Website Visitors, and Customers: You have the right to access, correct, update, export, or delete your personal
    information. You may email us at [email protected] with any such subject access requests, and we will
    respond within thirty (30) days. Customers also can access, correct, export, or update their Account Information by
    editing their profile or organization record at starbit.com.
    End Users: Starbit hasa direct relationship with End Users. If an End User requests that we access, correct, update, or
    delete their information, he may email us at [email protected] with any such subject access requests, and we will
    respond within thirty (30) days.
    Promoters: Starbit has direct relationship with Promoters. If a promoter requests that we access, correct, update, or
    delete their information, he may email us at [email protected] with any such subject access requests, and we will
    respond within thirty (30) days.
    For any SAR, we will need to verify a requestor is inquiring about their own information before we can assist. Where
    a SAR may implicate the personal data of another individual, we must balance the request against the risk of
    violating another person’s privacy rights.
  8. COMMUNICATION PREFERENCES
    You may manage your receipt of commercial communications by clicking on the “unsubscribe” link located on the
    bottom of such emails, through your account settings if you have a Starbit account, or you may send a request to
    [email protected]
  9. DATA SECURITY, DATA INTEGRITY, AND ACCESS:
    We take all reasonable steps to protect information we receive from you from loss, misuse or unauthorized access,
    disclosure, alteration, and/or destruction. We have put in place appropriate physical, technical, and administrative
    measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as
    encryption. If you have any questions about the security of your personal information, you can contact us at
    [email protected]
  10. NOTIFICATION OF CHANGES
    If we make changes to this Policy that we believe materially impact the privacy of your personal data, we will
    promptly provide notice of any such changes (and, where necessary, obtain consent), as well as post the updated
    Policy on this website noting the effective date of any changes.
  11. BUSINESS TRANSACTIONS
    We may assign or transfer this Policy, as well as information covered by this Policy, in the event of a merger, sale,
    change in control, or reorganization of all or part of our business.
  12. ENGLISH LANGUAGE CONTROLS
    Any non-English translations of this Privacy Policy are provided for convenience only. In the event of any ambiguity or
    conflict between translations, the English version is authoritative and controls.
  13. CONTACT INFORMATION
    Starbit International Ltd.
    Office 2905 29th floor
    Jumeirah Business Center 3
    Cluster Jumeirah Lake Towers
    Dubai P.O. Box 474288
    UAE
    Attention: Giovanni Lionetti
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