Last updated: April 14, 2023

Kstar takes protection of your personal data very seriously and strictly complies with the applicable data protection laws and regulations, inparticular with the provisions of the General Data Protection Regulation(GDPR). Please find below information on how we collect and use your personal data when you use our website or are in direct contact with our staff. You may access this policy at any time on our website.

When you visit our website for the first time, if you agree toour use of cookies in accordance with the terms of this policy, it means that you are allowed to use cookies every time you visit our website there after.

Information we collect

• Information about your computer, including your IP address,geographic location, browser type and version, and operating system;

• Information about your visit and use of this website, includingtraffic sources, access time, page views and  website navigation paths;

• he information filled in when registering on our website, such as your name, region, and email address;

• he information you fill out when you subscribe to our email and/ or news information, such as your name and email address;

• The information you fill out when using the services on ourwebsite;

• Information that you post on our website and intend to post onthe Internet, including your username, profile picture, and content；

• Information generated when you use our website, includingbrowsing time, frequency and environment;

• The information you include when you communicate with us viaemail or our website, including communication content and metadata;

• Any other personal information you send to us.

Before  disclosing the personal information of others to us, you must obtain thepermission of the disclosed party in accordance with this policy in order todisclose and use the personal information of the others.

How we collect information

Inaddition to the ways described in the ‘Information we collect’ section, Kstarmay collect personal data from a variety of sources that generally fall intothese categories:

• Publicly available data / Data from third parties: Data fromautomated interactions on non-Kstar websites, or other data you may have madepublicly available, such as social media posts, or data provided by third partysources, such as marketing opt-in lists or data aggregators.

• Automated interactions: From the use of technologies such aselectronic communication protocols, cookies, embedded URLs or pixels, orwidgets, buttons and tools.

• Electronic communications protocols: Kstar may automaticallyreceive information from you as part of the communication connection itself,which consists of network routing information (where you came from), equipmentinformation (browser type or device type), your IP address (which may identifyyour general geographic location or company) and date and time.

• Kstar may also automatically receive and record informationabout your interaction with the Information Channels, such as clickstreaminformation (when each Kstar webpage was visited and how much time was spent onthe page), how often you access the Information Channel, performance data,aggregate usage or general geo-location data.

• Google and other third-party analysis tools. We use a toolcalled "Google Analytics" to collect information about the use of ourwebsite services (for example, Google Analytics collects information about howoften users visit a website, the pages they visit when they visit the website,and other websites they used before visiting the website) . Google Analyticsonly collects the IP address assigned to you on the day of access to thewebsite service, not your name or other identifying information. The informationcollected through Google Analytics will not be combined with your personalinformation. You can learn more about how Google Analytics collects andprocesses data and opt-out options by visitinghttp://www.google.com/policies/privacy/partners/. We also use other third-partyanalysis tools to collect similar information about the use of certain onlineservices.

• Like many companies, Kstar uses “cookies” and other similartracking technology (collectively "Cookies"). Kstar's server willquery your browser to see if there are Cookies previously set by our electronicInformation Channels.

Cookies：

• A cookie is a small text file which is placed on your device.Cookies help to analyze web traffic and allow web applications to respond toyou as an individual. The web application can tailor its operations to yourneeds, likes and dislikes by gathering and remembering information about yourpreferences. Certain cookies may contain Personal Data – for example, if youclick “Remember me” when logging in, a cookie may store your username. 

• Cookies may collect information, including a unique identifier, user preferences,profile information, membership information and general usage and volumestatistical information. Cookies may also be used to collect individualizedwebsite use data, provide electronic Information Channel personalization orconduct and measure the effectiveness of advertising in accordance with this Notice.

What do we use cookies for?

• We use first-party and third-party cookies for several reasons.Some cookies are required for technical reasons in order for our Information  Channels to operate, and we refer to these as "essential" or"strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our  Information Channels. Third parties serve cookies through our Information Channels  for advertising, analytics and other purposes.

• We may place cookies or similar files on your device forsecurity purposes, to tell us whether you have visited the Information Channels  before, to remember your language preferences, to determine if you are new  visitor or to otherwise facilitate site navigation, and to personalize yourexperience on our Information Channels. Cookies allow us to collect technicaland navigational information, such as browser type, time spent on our Information channels and pages visited. Cookies also allow us to select which of our advertisements or offers are most likely to appeal to you and display them to you. Cookies may enhance your online experience by saving your preferences while you are visiting a website.

How can you manage your cookies?

• You can choose to accept or decline cookies. Most web browsers  automatically accept cookies, but you can usually modify your browser settingto decline cookies if you prefer. If you would prefer not to accept cookies,most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it;(ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. However, please be aware that if you disable or reject  cookies, some features and services may not work properly because we may not beable to recognize and associate you with your Kstar Account(s). In addition,the offers we provide when you visit us may not be as relevant to you or  tailored to your interests.

How We use Your Personal Data

• We may use the information we collect in the course of providingservices to you for the following purposes: to provide services to you;

• To provide services for identification, customer service,security, fraud monitoring, archiving and Backup purposes to ensure thesecurity of the products and services we provide to you; 

• Help us design new services and improve our existing services

• Evaluate our services to provide you with more relevant ads inplace of general delivery advertising; the effectiveness and improvement of  advertising and other promotions and promotional activities;

• software certification or management software upgrades; allowingyou to participate in surveys about our products and services. In order toallow you to have a better experience, improve our services or other uses that  you agree with, in accordance with relevant laws and regulations, we may usethe information collected through a service to aggregate information or  personalize

• For our other services. For example, the information collectedwhen you use one of our services may be used to provide you with specificcontent in another service or to show you non-generalized information about you. You can also authorize us to use the information provided and stored by  the service for our other services if we provide the corresponding option inthe relevant service. How you access and control your personal information We will do everything possible to take appropriate technical measures to ensure  that you can access, update and correct your registration information or other  personal information provided when using our services. When accessing,updating, correcting, and deleting the information, we may ask you to verify your identity to protect your account.

How We share Your Personal Data

We do not share your personal information with any third parties that is outside Kstar  Ltd. unless one of the following circumstances applies:

• With our service partners: Our service partners may provide  services for us. We need to share your registered personal information with them in order to provide you services. In the case of unique applications, we need to share your personal information to the software developers/ account  manager in order to set up your account.

• With our associated enterprises and affiliates:We may provide  your personal information to our associated enterprises and affiliates, orother trusted businesses or persons to process or store your information forus.

• With third-party advertising partners. We share limited personalinformation with third parties that provide online advertising services so thatthey can display our ads to individuals who may be considered most relevant. We  share this information to satisfy our legitimate rights and interests to  effectively promote our products.

• For legal reasons
  We will share your personal information with companies, organizations orindividuals outside Kstar Ltd. if we have a belief in good faith that access,use, preservation or disclosure of your information is reasonably necessary to:

  o   meet any applicable laws, regulations, legal processes or  enforceable governmental requirements;

  o   enforce our services, including investigation of potential  violations;

  o   detect, prevent possible fraud, infringement of security ortechnical issues;

  o   protect against harm to our rights, property or data security,or other user’s/public safety .

Advertising technologies and networks

• Kstar uses third parties such as Google, Facebook, LinkedIn and  Twitter and other programmatic advertising platforms to administer Kstar  advertisements on third-party electronic channels. Personal data, such as user  community or implied or inferred interests, may be used in the selection of  advertising to make sure that it has relevance to the user. Some ads may  contain embedded pixels that may write and read cookies or return session  connection information that allows advertisers to better determine how many  individual users have interacted with the ad.

• Kstar may also use advertising technologies and participate in  advertising technology networks that collect usage information from Kstar and  non-Kstar websites, as well as from other sources, to show you Kstar-related  advertisements on Kstar’s own and third-party websites. These advertisements  may be tailored to your perceived interests using retargeting and behavioral   advertising technologies. Any retargeted or behavioral advertisements served to   your browser will contain information on or near it that informs you about the   advertising technology partner and how to opt-out of viewing such advertisements.Opting-out does not mean that you will stop receiving ads from Kstar. It meansthat you still stop receiving ads from Kstar that have been targeted to you   based on your visits and browsing activity across websites over time.

• Cookie-based tools that allow you to opt-out of Interest-Based  Advertising prevent Kstar and other participating advertising technologycompanies from serving interest-related ads to you on behalf of Kstar. They   will only work on the internet browser on which they are deposited, and theywill function only if your browser is set to accept third-party cookies. These   cookie-based opt-out tools may not be as reliable where (e.g., certain mobile   devices and operating systems) cookies are sometimes automatically disabled orremoved. If you delete cookies, change browsers, computers or use anotheroperating system, you will need to opt-out again.

Legal basis for processing personal data

• Our legal basis for collecting and using the Personal Datadescribed above will depend on the Personal Data concerned and the specific contextin which we collect it. 

• We will normally collect Personal Data from you only (i) wherewe have your consent to do so (ii) where we need the Personal Data to perform acontract with you, or (iii) where the processing is in our legitimate interestsand not over ridden by your data protection interests or fundamental rights and  freedoms. In some cases, we may also have a legal obligation to collect  Personal Data from you or may otherwise need the Personal Data to protect your  vital interests or those of another person.

• If we ask you to provide Personal Data to comply with a legal  requirement or to perform a contract with you, we will make this clear at the  relevant time and advise you whether the provision of your Personal Data is   mandatory or not (as well as of the possible consequences if you do not provideyour Personal Data).

Limitation of liability for external links

• This Privacy Notice does not address, and we are not responsible  for, the privacy, information or other practices of any third parties,including any third party operating any website or service to which the Kstar   Pages link. The inclusion of a link on the Kstar Pages does not imply   endorsement of the linked site or service by us or by our affiliates or   subsidiaries.

• In addition, we are not responsible for the information   collection, use, disclosure or security policies or practices of other  organizations, such as Facebook, Apple, Google, or any other app developer, appprovider, social media platform provider, operating system provider, wireless   service provider or device manufacturer, including with respect to any Personal  Data you disclose to other organizations through or in connection with the Ksatr   Pages. These other organizations may have their own privacy notices, statementsor policies. We strongly suggest that you review them to understand how your   Personal Data may be processed by those other organizations.

How do we secure your personal data?

We use appropriate technical and organizational measures toprotect the Personal Data that we collect and process. The measures we use aredesigned to provide a level of security appropriate to the risk of processing   your Personal Data. Unfortunately, no data transmission or storage system canbe guaranteed to be 100% secure.  

How long will personal data be kept?

• Kstar will retain your Personal Data for as long as needed to  provide you products or services; as needed for the purposes outlined in thisNotice or at the time of collection; as necessary to comply with our legal   obligations (e.g., to honor opt-outs), resolve disputes and enforce our   agreements; or to the extent permitted by law.
  

• At the end of the retention period or when we have no ongoing   legitimate business need to process your Personal Data, Kstar will delete or   anonymize your Personal Data in a manner designed to ensure that it cannot be   reconstructed or read. If this is not possible, then we will securely storeyour Personal Data and isolate it from any further processing until deletion ispossible.

Your rights

• You may at any time request information about the data which wehold about you as well as about their origin, recipients or categories ofrecipients to which such data is forwarded and about the retention purpose.

• You may request an immediate correction of incorrect personal    data related to you or a restriction of processing. Taking into account the   processing purposes, you are also entitled to request a completion of incomplete personal data - also by means of a supplementary declaration.

• You are entitled to receive the respective personal data   provided to us in a structured, common and machine-readable format and you areentitled to transmit such data to other data controllers without restriction ifthe processing was based on your consent or if the data was processed by meansof automated procedures.

• You may request that personal data about you is immediatelyerased. We are, inter alia, obliged to erase such data if it is no longer   required for the purpose for which it was collected or otherwise processed orif you withdraw your consent.

• You may withdraw your consent to the use of your data at anytime.

• You have the right to object to the process.

Updates to our Data Protection and Privacy Notice

• This Notice and other policies may be updated periodically andwithout prior notice to you, and any changes will be effective immediately uponthe posting of the revised Notice on the Information Channels.

• However, we will use your Personal Data in a manner consistentwith the Notice in effect at the time you submitted the Personal Data, unlessyou consent to the new or revised Notice. We will post a prominent notice onthe Information Channels to notify you of any significant changes and indicateat the top of the Notice when it was most recently updated.
  
  

We will obtain your consent to any material Notice changes if and where this isrequired by applicable data protection laws.

If you have any questions or comments about this Notice, concerns about ourprocessing of your Personal Data or any other question related to dataprotection and privacy please contact us by emailing sales@kstar.com.