Policies

www.starborn.eu

Published Privacy policy to better serve those who

are concerned with how their ‘Personally identifiable information’ (PII) is

being used online. PII, as used in US privacy law and information

security, is information that can be used on its own or with other

information to identify, contact, or locate a single person, or to identify an

individual in context. Please read our privacy policy carefully to get a

clear understanding of how we collect, use, protect or otherwise handle

your Personally Identifiable Information in accordance with our website.

What personal information do we collect from the people that visit

our catalog and website?

When ordering or registering on our site, as appropriate, you may be

asked to enter your name, email address, mailing address, and phone

number or other details to help you with your experience and help us with

customer service assistance for your order.

When do we collect information?

We collect information from you when you place an order, subscribe to a

newsletter or enter information on our site.

How do we use your information?

We may use the information we collect from you when you register, make

a purchase, sign up for our newsletter, respond to a survey or marketing

communication, or use certain other site features in the following ways:

• To allow us to better service you in responding to your customer

service requests.

• To administer a sale, promotion, survey or other site feature.

• To quickly process your transactions.

• To send periodic emails regarding your order or other products and

services.

How do we protect visitor information?

Our website is monitored on a regular basis for security holes and known

vulnerabilities in order to make your visit to our site as safe as possible.

Your personal information is contained behind secured networks and is

only accessible by a limited number of persons who have special access

rights to such systems, and are required to keep the information

confidential. In addition, all sensitive/credit information you supply is

encrypted via Secure Socket Layer (SSL) technology and not accessible.

We implement a variety of security measures when a user places an

order enters, submits, or accesses their information to maintain the safety

of your personal information.

All transactions are processed through a gateway provider and are not

stored or processed on our servers.

Do we use ‘cookies’?

Yes. Cookies are small files that a site or its service provider transfers to

your computer’s hard drive through your Web browser (if you allow) that

enables the site’s or service provider’s systems to recognize your

browser and capture and remember certain information. For instance, we

use cookies to help us remember and process the items in your shopping

cart. They are also used to help us understand your preferences based

on previous or current site activity, which enables us to provide you with

improved services. We also use cookies to help us compile aggregate

data about site traffic and site interaction so that we can offer better site

experiences and tools in the future.

We use cookies to:

• Help hold and process the items in user’s shopping carts.

• Understand and save user’s preferences for future visits.

You can choose to have your computer warn you each time a cookie is

being sent, or you can choose to turn off all cookies. You do this through

your browser (like Internet Explorer) settings. Each browser is a little

different, so look at your browser’s Help menu to learn the correct way to

modify your cookies.

If users disable cookies in their browser:

If you disable cookies off, some features will be disabled It will turn off

some of the features that make your site experience more efficient and

some of our services will not function properly.

However, you can still place orders over the telephone by contacting

customer service.

Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your

personally identifiable information. Ever!

Third-party links

We do not include or offer third-party services on our website.

Google

Google’s advertising requirements can be summed up by Google’s

Advertising Principles. They are put in place to provide a positive

experience for users. https://support.google.com/adwordspolicy/

answer/1316548?hl=en

We have not enabled Google AdSense on our site but we may do so in

the future.

How does our site handle do not track signals?

We honor do not track signals and do not track, plant cookies, or use

advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third-party behavioral tracking?

It’s also important to note that we do not allow third-party behavioral

tracking.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy

law in the United States and the concepts they include have played a

significant role in the development of data protection laws around the

globe. Understanding the Fair Information Practice Principles and how

they should be implemented is critical to comply with the various privacy

laws that protect personal information.

In order to be in line with Fair Information Practices we will take the

following responsive action, should a data breach occur:

We will notify the users via email

• Within 7 business days

We will notify users via phone call

• Within 7 business days

We will notify the users via in-site notification

We also agree to the Individual Redress Principle, which requires that

individuals have a right to pursue legally enforceable rights against data

collectors and processors who fail to adhere to the law. This principle

requires not only that individuals have enforceable rights against data

users, but also that individuals have recourse to courts or government

agencies to investigate and/or prosecute non-compliance by data

processors.

2019 Comprehensive Privacy Policy Integrated with GDPR

Standards

For our website visitors, we care deeply about privacy. We believe in

transparency, and we’re committed to being upfront about our privacy

practices, including how we treat your personal information. We know you

care about your privacy too, so we provide settings that allow you to

choose how certain information is used by Starborn. This policy explains

our privacy practices for starborn.com (we’ll refer to starborn.com as the

“Site”) We’ll refer to the Site and our other services as the “Services.”

1. Accepting the Privacy Policy

We need to process your personal information to run our business and

provide you with the Services. By accepting our Privacy Policy, you are

confirming that you have read and understand this policy including how

and why we use your information. If you don’t want us to collect or

process your personal information in the ways described in this policy,

you shouldn’t use the Services. We are not responsible for the content or

the privacy policies or practices of third-party websites.

Starborn’s Privacy Policy require all account owners to be at least 18

years of age. Minors under 18 years of age and at least 13 years of age

are permitted to use Starborn’s Services only if they have the appropriate

permission and direct supervision by their legal parent or guardian.

Children under age 13 are not permitted to use Starborn or the Services.

You are responsible for any and all account activity conducted by a minor

on your account.

Acknowledgement: By using the Services, you acknowledge that

Starborn will use your information in the European Union, the United

States and any other country where Starborn operates. Please be aware

that the privacy laws and standards in certain countries, including the

rights of authorities to access your personal information, may differ from

those that apply in the country in which you reside. We will transfer

personal information only to these countries to which we are permitted by

law to transfer personal information, and we will take steps to ensure that

your personal information continues to enjoy appropriate protections.

Please read on to learn more about how we protect personal information

that’s transferred outside of Europe.

2. Information Collected or Received

In the course of providing our Services, we collect or receive your

personal information in a few different ways. Often, you choose what

information to provide, but sometimes we require certain information for

you to use and for us to provide you the Services.

Registration, Account Setup, Service Usage: In order to use the

Services, you need to provide us with a valid email address, and for

Services that require registration, a name associated with your account

that you can choose and that represents your identity on Starborn. You

may review, change, or remove that name through your account settings.

You need to provide this information to enable us to provide you with the

Services. Depending on which services you choose to use, additional

information, such as your business name, billing and payment information

(including billing contact name, address, telephone number, credit card

information), a telephone number, and/or a physical postal address, may

be necessary in order for us to provide a particular service. You are not

required to provide us with this information to sign up, but we will need it

to provide certain services. For example, we need a physical postal

address if you are buying something on the Site for delivery. We may

need to store credit card information (or arrange for it to be stored) and

use it for both billing and payment purposes. Depending on your local

jurisdiction, you can also choose to allow us to save your credit card

information to facilitate the checkout process for future purchases. In

order to use certain products or services on Starborn, you may be

required to complete an application; for setting up a wholesale account. In

such cases, Starborn may require information such as your full name,

identification ID or tax ID, date of birth, bank account information, credit

card information, and/or other proof of identification in order to verify your

identity and provide this service to you and to comply with applicable law.

Information that you submit through the application processes will not be

displayed publicly and will only be used internally by Starborn, unless

otherwise specified.

Profile: You may provide your name and other personal information

(such as birthday, gender, location) in connection with your account and

activity. You can edit or remove this information through your account

settings. The name associated with your account, which you may review

and change in your account settings, is publicly displayed and connected

to your Starborn activity such as when leaving comments or reviews.

Other people may see the date you joined; ratings, reviews and related

photos for items you purchased at Starborn, as well as comments you

post in our community spaces; and information you decide to share via

social networks.

Automated Information: Starborn automatically receives and records

information from your browser or your mobile device when you visit the

Site such as your IP address or unique device identifier, cookies and data

about which pages you visit in order to allow us to operate and provide

the Services. This information is stored in log files and is collected

automatically. We may combine this information from your browser or

your mobile device with other information that we collect about you,

including across devices. This information is used to prevent fraud and to

keep the Services secure, to analyze and understand how the Services

work for members and visitors, and to provide advertising, including

across your devices, and a more personalized experience for members

and visitors.

We may also automatically collect device-specific information when you

access, or use our Services. This information may include information

such as the hardware model, operating system information, app version,

app usage and debugging information, browser information, IP address,

and device identifiers. For more information about these online tools and

how we use them, see our “Information Uses, Sharing & Disclosure”

section below.

Location Information: We may collect information about your use of the

Services for advertising, analytics, to serve content and to protect the

Services, including your IP address, browser information (including

referrers), device information (such as iOS IDFA, IDFV for limited non-

advertising purposes, Android AAID, and, when enabled by you, location

information provided by your device). When you use the Service, you

may choose to share your geo-location details with Starborn in order to

use functions like our local marketplace, maps, and for in-person sales

(although you don’t need to share these details).

We may obtain location information you provide in your profile or your IP

address. With your consent, we may also determine location by using

other information from your device, such as precise location information

from GPS or information about wireless networks or cell towers near your

mobile device. We may use and store information about your location to

provide features and to improve and customize the Services, for example,

for Starborn’s internal analytics and performance monitoring; localization,

regional requirements, and policies for the Services; for local content,

search results, and recommendations; for mapping services; and (using

non-precise location information) marketing. If you have consented to

share your precise device location details but would no longer like to

continue sharing that information with us, you may revoke your consent to the sharing of that information through the settings on the Apps or on your

mobile device. Certain non-precise location services, such as for security

and localized policies based on your IP address or submitted address,

are critical for the site to function. We will only share your geo-location

details with third parties (like mapping and payments) in order to provide

you with the Services. You may also choose to enable the Apps to access

your mobile device’s camera to upload photographs to Starborn.

Information from Third Parties: Some members or visitors may choose

to connect to Starborn.eu or register an Starborn.eu account using an

external third-party application, such as Facebook, or an app developed

using the Starborn API. Starborn may receive information from those

connected third-party applications. Connecting your Starborn account to

third-party applications or services is optional. If you choose to connect

your account to a third-party application, Starborn may receive

information from that application. We may also collect public information

in order to connect with you. We may use that information as part of

providing the Services to you. You can also choose to share some of your

activity on Starborn on certain social media networks which are

connected to your Starborn account, and you can revoke your permission

anytime in your account settings.

Non-Member Information: Starborn may receive or obtain information

(for example, an email address or IP address) about a person who is not

yet a registered Starborn customer or member (a “non-member”) in

connection with certain Starborn features, such as when a non-member

chooses to subscribe to an Starborn newsletter, a member invites a non-

member to visit the Site, a member uploads non-member information

using the contact uploader feature, a non-member engages in a

transaction, or a member sends a gift card code to a non-member, or a

non-member uses the Guest Checkout feature when making a purchase

through one of the Services. Non-member information is used only for the

purposes disclosed when it was submitted to Starborn or to facilitate

action authorized by the non-member.

Pattern by Starborn: We collect certain information from both members

and non-members who visit our website. This information may include

your IP address or unique device identifier, and cookies and data from the

pages you visit.

3. Cookies & Similar Technologies Policy

We think it’s important for you to understand how cookies and other

similar technologies are used by Starborn. These technologies help

Starborn function, allow us to understand how you use the Services, and

have a number of purposes that you can read about in this policy. In this

policy, we’ll refer to cookies and similar technologies collectively as

“Cookie Technologies.”

Types of Cookie Technologies

Cookies

Cookies are small data files sent from a server to your web browser. They

are stored in your browser’s cache and allow a website or a third party to

recognize your browser. There are three primary types of cookies:

Session cookies are specific to a particular visit and carry

information as you view different pages so you don’t have to

re-enter information every time you change pages or attempt

to checkout. Session cookies expire and delete themselves

automatically in a short period of time like after you leave the

Site or when you close your web browser.

Persistent cookies remember certain information about your

preferences for viewing the site, and allow Starborn to

recognize you each time you return. Persistent cookies are

stored on your browser cache or mobile device until you

choose to delete them, and otherwise typically delete

themselves at expiration.

Third-party cookies are placed by someone other than

Starborn, and may gather browsing activity across multiple

websites and across multiple sessions. They are usually a type

of persistent cookie and are stored until you delete them or

they expire based on the time period set in each third-party

cookie.

Cookies store data about your use, but they are helpful because they

allow us to help Starborn function and customize your experience. You

can configure your desktop or mobile browser’s settings to reflect your

preference to accept or reject cookies, including how to handle third-party

cookies.

Other Technologies

In addition to cookies, there are other similar technologies used by

Starborn and elsewhere on the web or in mobile ecosystems.

Web beacons: These are tiny graphics (sometimes called

“clear GIFs” or “web pixels”) with a unique identifier that are

used to understand browsing activity. In contrast to cookies,

which are stored on a user’s computer hard drive, web

beacons are rendered invisibly on web pages when you open

a page.

Social widgets: These are buttons or icons provided by third-

party social media providers that allow you to interact with

those social media services when you view a web page or a

mobile app screen. These social widgets may collect browsing

data, which may be received by the third party that provided

the widget, and are controlled by the third parties.

UTM codes: These are strings that can appear in a URL (the

“Uniform Resource Locator,” which is typically the http or https

address entered to go to a web page) when a user moves from

one web page or website to another, where the string can

represent information about browsing, such as which

advertisement, page, or publisher sent the user to the

receiving website.

Application SDKs: These are mobile application third-party

software development kits that are embedded in the Apps (and

are used in many mobile applications). These app SDKs

permit the collection of information about the app itself, activity

in the app, and the device the application is running on.

Local Storage Objects: These (sometimes called flash

cookies) are sets of data that can be stored on your browser

by a site or app. They can be used to maintain preferences,

maintain a history of usage, or even maintain the state or

settings of an app.

Purposes

Starborn.eu uses Cookie Technologies to recognize your logged-in state

on Starborn.eu, to understand what purchases members and visitors are

interested in, to make Starborn’s Sites function for you, and to help your

browsing experience and use of the Site, Services, and Apps feel more

customized. More generally, Starborn.eu uses Cookie Technologies for

the following.

Security and Authentication (Strictly Necessary)

Some cookie and similar technology functions are necessary and vital to

ensuring that Starborn works properly for visitors and members, such as

maintaining the security, safety, and integrity of the Site, authentication

and logging into Starborn.eu (including remembering permissions and

consents you have granted), and ensuring the ability to securely complete

transactions.

Account and User Preferences

Some technologies are used to remember your account and preferences

over time, such as remembering your account or keeping yourself logged

in when returning to Starborn.eu, maintaining your choices on Starborn.eu

features and how you want Starborn.eu to appear, including keeping track of

your preferred language and country, and customizing content based on

on how you use Starborn.eu.

Social Networks

Some technologies help you to interact with social networks you are

signed into while using the Services, such as sharing content with the

social network, logging in with the social network, and other features you

employ with the social network, or that are allowed in the social network’s

privacy policy. These may be set and controlled by the social networks,

and your preferences with those social networks. Social networks may

also work with Starborn.eu or with you for analytics or for marketing

purposes, as discussed below. You may be able to manage your privacy

preferences for these social networks and their tools and widgets via your

account with the social network.

Performance and Analytics

Some technologies help provide performance data on how the Services

are functioning in order to improve Starborn.eu and the Services,

including, for example, data on site and app functionality and speed to

help us optimize Starborn.eu, how the Services are used to help us

improve your experience on Starborn.eu, and detecting and gathering

reporting on bugs to help make Starborn.eu work better. The Site also

employs Google Analytics to help understand how Starborn.eu is used by

its community. For some of the advertising features listed below, like

retargeting, data from Google Analytics may be combined with Starborn’s

first-party data and third-party cookies (like Google’s advertising cookies).

To see how to opt-out of Google Analytics Advertising Features, see the

Opt-Out section at the bottom of this policy.

You can find more information on how Google Analytics works in

this Google guide.

Marketing Services

Starborn.eu partners with third-party service providers that may use

various Cookie Technologies to permit us and them to learn about what

ads you see and click when you visit Starborn, the Apps, and affiliated

sites or to show you ads on and off Starborn. These may include things

such as:

Frequency capping, which limits the number of times a user’s

browser or mobile device displays the same ad;

Attribution tracking, which estimates what advertising or

marketing source brought someone to Starborn, or determines

what marketing source led to actions like a visit or a purchase;

Remarketing, which shows relevant ads to an audience based

on prior shopping and browsing patterns on Starborn;

Audience targeting, which refers to targeting advertisements

to a large audience based on the audience’s known or inferred

demographics; and

Cross-device recognition, which recognizes actions across

multiple devices or browsers.

Some third-party service providers may provide information like

demographics, cross-device information, or interest categories from a

combination of sources that, while not identifying you personally, permit

us to provide you with more relevant and useful advertising. In some

cases, this information may have non-marketing performance analytics

uses as well.

These technologies allow a partner to recognize your computer or mobile

device each time you visit Starborn or other websites and mobile

applications based on data like a cookie, your IP address, or device ID,

but do not allow access to other personal information from Starborn.

However, these technologies may allow us or a third party to recognize

you, either from a single device or across devices, over time. These third

parties are required to follow applicable laws, self-regulatory programs,

and Starborn’s data protection rules where applicable. However,

starborn.eu does not have control over these third parties, who each have

their own privacy policies and privacy practices. Starborn.eu adheres to

the Digital Advertising Alliance‘s Self-Regulatory Principles for Online

Behavioral Advertising.

Consent, Contract, and Legitimate Interests in Processing

Certain Cookie Technologies are employed to make the Site function for

its intended purpose, and are provided based on contractual necessity

based on your agreement with Starborn.eu to perform the services you

have requested. These include the functions strictly necessary to the

service noted above.

By choosing to use our Services after having been notified of our use of

Cookie Technologies in the ways described in this Policy, and, in

applicable jurisdictions, through notice and unambiguous

acknowledgement of your consent, you agree to such use.

Opt-in and Opt-out on Browsers

In addition, when you use Starborn via a browser, you can change your

web browser’s settings to reflect your cookie preferences for cookies

directly from the site you are on or for third-party cookies. Each browser

is a little different, but usually these settings are under the “options” or

“preferences” menu.

Opt-out of Third-Party Networks

If you do not wish to have this information used for the purpose of serving

you interest-based advertisements, you may decline to receive interest

based ads through TrustE/TrustArc’spreferences manager (or if you are

located in the European Union click here). Please note this does not stop

you from being served advertisements. You will continue to receive

generic advertisements. Please note that if you reject or block all cookies

in your browser settings, you will not be able to take advantage of

Starborn’s Services as some cookies are necessary for the Site to

function properly.

You can learn more about managing your preferences for ads online,

particularly for many third-party advertising networks, through resources

made available by the Digital Advertising Alliance at https://

www.aboutads.info or the Network Advertising Initiative athttps://

optout.networkadvertising.org.

Google Analytics Opt-out

For Google Analytics Advertising Features, you can opt-

out through Google Ads Settings, Ad Settings for mobile apps, or any

other available means (for example, the NAI’s consumer opt-out listed

above). Google also provides a Google Analytics opt-out plug-in for the

web.

Third-Party Tools

Various third parties provide browser plug-ins and apps that can help

provide you information on, and limit or block, third-party cookies, web

beacons, and some Javascript-based technologies. Starborn.eu cannot

vouch for the efficacy of a particular third-party product, but popular

products that provide these privacy enhancements

include Ghostery and AdBlock Plus.

Mobile Opt-out

If you access Starborn.eu through the Apps, you may also control

interest-based advertising on an iOS or Android device by selecting the

“Limit Ad Tracking” option in the privacy section of the Settings App on

iOS or via advertising preferences on Android-based devices (usually in

the Google Settings app). This will not prevent you from seeing

advertisements, but will limit the use of device advertising identifiers to

personalize ads based on your interests.

4. Choice & Control

We know that members of our community value having control over their

own information, so Starborn.eu gives you the choice of providing, editing

or removing certain information, as well as choices about how we contact

you. You may change or update your Starborn.eu account information

through your account settings. You may also remove certain optional

information that you no longer wish to be publicly visible through the

Services, such as your name. You can also request the deletion of the

personal information in your account.

Depending on your location, you may also have certain additional rights

with respect to your information, such as: (i) data access and portability

(including the right to obtain a copy of your personal data you provided to

Starborn.eu, via your settings); (ii) data correction (including the ability to

update your personal data, in many cases via settings); (iii) data deletion

(including the right to have Starborn.eu delete your personal information,

except information we are required to retain, by contacting us); and (iv)

withdrawal of consent or objection to processing (including, in limited

circumstances, the right to ask Starborn.eu to stop processing your

personal data, with some exceptions, by contacting us).

You may also control the receipt of certain types of communications from

Starborn.eu in your account settings. Starborn.eu may send you messages

about the Services or your activity. Some of these messages are

required, service-related messages for members (such as transactional

messages or legal notices). Other messages are not required, such as

newsletters. You can control which optional messages you choose to

receive by changing your account settings, and you can learn more in the

“Messages from Starborn” section of this policy.

We partner with third parties to manage our advertising on other sites.

Our third-party partners may use cookies or similar technologies in order

to provide you with advertising based upon your browsing activities and

interests. If you have chosen to connect your account to an external third-

party application, such as Facebook, or an app developed using the API,

you can change your settings and remove permission for the app by

changing your account settings.

If you no longer wish to use the Services or receive service-related

messages (except for legally required notices), then you may email us a

request to close your account.

5. Messages from Starborn.eu

On occasion, Starborn.eu may need to contact you. Primarily, these

messages are delivered by email or by push notifications, and every

account is required to keep a valid email address on file to receive

messages. Starborn may also contact you by telephone to provide

member support or for transaction-related purposes if you request that we

call you. Additionally, and with your consent, Starborn may send you an

SMS (or similar) message or physical mail in order to provide you with

customer support or to provide you with information about products and

features that you may find of interest. You may update your contact

preferences in your account settings.

Some messages from Starborn.eu are service-related and necessary for

members and Guest Checkout users. You agree that Starborn can send

you non-marketing emails or messages, such as those related to

transactions, your account, security, or product changes. Examples of

service-related messages include an email address confirmation/

welcome email when you register your account, notification of an order,

service availability, modification of key features or functions, relaying

conversations with buyers, and correspondence with Starborn’s support

team.

When you register for an account, subscribe to a newsletter, or provide us

with your email address or phone number such as for a Guest Checkout

purchase, you receive notice of and agree (in some jurisdictions and

situations, by an additional unambiguous consent) to receive marketing

emails and messages from us. You can unsubscribe at any time from

marketing emails through the opt-out link included in marketing emails or

messages. Members may also control some marketing emails or

messages through their account settings as well as through the opt-out

link included in marketing emails or messages.

6. Information Uses, Sharing & Disclosure

When you access or use the Services, we collect, use, share, and

otherwise process your personal information as described in this policy.

We rely on a number of legal bases to use your information in these

ways. These legal bases include where:

•necessary to perform the contractual obligations in our Terms of Use and

in order to provide the Services to you;

•you have consented to the processing, which you can revoke at any

time;

•necessary to comply with a legal obligation, a court order, or to exercise

or defend legal claims;

•necessary for the purposes of our or a third party’s legitimate interests,

such as those of visitors, members, or partners;

•you have expressly made the information public;

•necessary in the public interest; and

•occasionally necessary to protect your vital interests, or those of others.

Note that we principally rely on consent (i) to send marketing messages,

(ii) for third-party data sharing related to advertising, and, to the extent

applicable, (iii) for the use of location data for advertising purposes.

Where we process your information on the basis of legitimate

interests, we do so as follows:

Providing and improving our Services: We may use your information to

improve and customize our Services, and we do so as it is necessary to

pursue our legitimate interests of improving our Services for our users.

This is also necessary to enable us to pursue our legitimate interests in

understanding how our Services are being used, and to explore and

unlock ways to develop and grow our business. It is also necessary to

allow us to pursue our legitimate interests in improving our Services,

efficiency, interest in Services for users and obtaining insights into usage

patterns of our Services.

Keeping our Services safe and secure: We may also use your

information for safety and security purposes, including sharing of your

information for such purposes, and we do so because it is necessary to

pursue our legitimate interests in ensuring the security of our Services,

including enhancing protection of our community against spam,

harassment, intellectual property infringement, crime, and security risks of

all kind.

Respect for Your Privacy. Starborn.eu will not disclose your name,

email address or other personal information to third parties without your

consent, except as specified in this policy. We use your information to

provide and improve the Services and our products, for billing and

payments, for identification and authentication, and for general research

and aggregate reporting. For example, in accordance with our existing

case resolution process, we may use information you provide to resolve

disputes with Starborn.eu

Legal and Safety: Starborn.eu may also retain, preserve, or release your

personal information to a third party in the following limited

circumstances: in response to lawful requests by public authorities,

including to meet legitimate national security or law enforcement

requirements; to protect, establish, or exercise our legal rights or defend

against legal claims, including to collect a debt; to comply with a

subpoena, court order, legal process, or other legal requirement; or when

we believe in good faith that such disclosure is reasonably necessary to

comply with the law, prevent imminent physical harm or financial loss, or

investigate, prevent, or take action regarding illegal activities, suspected

fraud, threats to our property, or other violations. In these cases, our use

of your information may be necessary for the purposes of our or a third

party’s legitimate interest in keeping our Services secure, preventing

harm or crime, enforcing or defending legal rights, or preventing damage.

Such use may also be necessary to comply with a legal obligation, a

court order, or to exercise or defend legal claims. It may also be

necessary in the public interest (such as to prevent crime) or to protect

vital interests (in rare cases where we may need to share information to

prevent loss of life or personal injury).

If Starborn.eu receives a lawful, verified request for a member’s records

or information in one of the limited circumstances described in the

previous paragraph, Starborn.eu may disclose personal information,

which may include, but may not be limited to, a member’s name, address,

phone number, email address, and company name.

Aggregated Information: Starborn.eu may share demographic

information with business partners, but it will be aggregated and de-

personalized, so that personal information is not revealed.

Service Providers: Starborn.eu also needs to engage third-party

companies and individuals (such as payment processors, research

companies, hosting providers, and analytics and security providers) to

help us operate, provide, and market the Services. These third parties

have only limited access to your information, may use your information

only to perform these tasks on our behalf, and are obligated to Starborn

not to disclose or use your information for any other purposes. Our

engagement of service providers is often necessary for us to provide the

Services to you, particularly where such companies play important roles

like processing payments and shipments and helping us keep our Service

operating and secure.

Business Reorganization: In some cases, Starborn.eu may choose to

buy or sell assets. Such transactions may be necessary and in our

legitimate interests, particularly our interest in making decisions that

enable our business to develop over the long term. In these types of

transactions (such as a sale, merger, liquidation, receivership, or transfer

of all or substantially all of Starborn’s assets), member information is

typically one of the business assets that is transferred. If Starborn intends

to transfer information about you, Starborn.eu will notify you by email or

by putting a prominent notice on the Site and the App, and you will be

afforded an opportunity to opt out before information about you becomes

subject to a different privacy policy.

Third Parties: Third-party plug-ins also may collect information about

your use of the Site. For example, when you load a page on Starborn.eu

that has a social plug-in from a third-party site or service, such as a “Like”

or “Send” button, you are also loading content from that third-party site.

That site may request cookies directly from your browser. These

interactions are subject to the privacy policy of the third-party site. In

addition, certain cookies and other similar technologies on the Site are

used by third parties for targeted online marketing and other purposes.

These technologies allow a partner to recognize your computer or mobile

device each time you use the Services. Please be aware that when you

use third-party sites or services, their own terms and privacy policies will

govern your use of those sites or services. Starborn chooses and

manages these third-party technologies placed on its Sites and Apps.

However, these are third-party technologies, and they are subject to that

third party’s privacy policy.

We can speak only for ourselves; this policy does not apply to the

practices of third parties that Starborn.eu does not own or control or

individuals that Starborn.eu does not employ or manage. If you provide

your information to others, different practices may apply to the use or

disclosure of the information that you provide to them. Starborn.eu does

not control the privacy policies of third parties, including other members

who sell using the Services. Starborn.eu is not responsible for the privacy

or security practices of these sellers or other websites on the Internet,

even those linked to or from the Services. We encourage you to read the

privacy policies and ask questions of third parties before you disclose

your personal information to them. For the purposes of European law,

these third parties are independent controllers of data, which means that

they are responsible for providing and complying with their own policies

relating to any personal information they obtain in connection with the

Services.

8. Privacy Shield

Starborn Creations Vigo Christophersen e.K. does not participate in

Privacy Shield at this time. However, Starborn may rely on the EU-US

Privacy Shield to transfer personal information to some of our third party

service providers in the United States, where they are certified to receive

such information under the Privacy Shield Program.

9. Performance of the contract between Starborn and its members

Starborn.eu provides a voluntary service; you can choose whether or not

you want to use the Services. However, if you visit our Site or use the

Services, you have agreed to our Privacy Policy by doing so, which

initiates this contract between Starborn.eu and its visitors and users. As

we offer the Services in countries worldwide (including in the US) and use

technical infrastructure in the US to deliver the Services to you.

10. Security

The security of your personal information is important to us. We follow

generally accepted standards to protect the personal information

submitted to us, both during transmission and after it is received. Your

account information is protected by a password. It is important that you

protect against unauthorized access to your account and information by

choosing your password carefully and by keeping your password and

computer secure, such as by signing out after using the Services. If you

have any questions about the security of your personal information, you

can contact us at info@starborn.eu.

Starborn.eu encrypts all data transferred to and from our Site. All

information (such as credit card numbers) are transferred using secure

socket layer technology (SSL). Starborn.eu follows generally accepted

industry standards to protect the personal information submitted to us,

both during transmission and after it is received. Unfortunately, no

method of transmission over the internet or method of electronic storage

is 100% secure. Therefore, while we strive to protect your personal

information, we cannot guarantee its absolute security.

11. Retention

Starborn.eu will retain your information only for as long as is necessary

for the purposes set out in this policy, for as long as your account is active

(i.e., for the lifetime of your Starborn.eu member account), as described

in this policy, or as needed to provide the Services to you. If you no

longer want Starborn.eu to use your information to provide the Services

to you, you may close your account. Starborn.ei will retain and use your

information to the extent necessary to comply with our legal obligations

(for example, if we are required to retain your information to comply with

applicable tax/revenue laws), resolve disputes, enforce our agreements,

and as otherwise described in this policy. In addition, Starborn.eu sellers

may also be required to retain and use your information in order to

comply with their legal obligations. Please note that closing your account

may not free up your email address or username for reuse on a new

account. We also retain log files for internal analysis purposes. These log

files are generally retained for a brief period of time, except in cases

where they are used for site safety and security, to improve site

functionality, or we are legally obligated to retain them for longer time

periods.

12. Your Rights

You may benefit from a number of rights in relation to your information

that we process. Some rights apply only in certain limited cases,

depending on your location. If you would like to manage, change, limit, or

delete your personal information, you can do so via your starborn.eu

account settings or by contacting us. Upon request, Starborn.eu will

provide you with information about whether we hold any of your personal

information. By visiting your account settings, you can access, correct,

change, and delete certain personal information associated with your

account. In certain cases where we process your information, you may

also have a right to restrict or limit the ways in which we use your

personal information. In certain circumstances, you also have the right to

request the deletion of your personal information, and to obtain a copy of

your personal information in an easily accessible format. Please ensure

you’ve read the options you have under the “Choice & Control” section

above. If you need further assistance, you can contact Starborn through

one of the channels listed below under “Contact.” We will respond to your

request within a reasonable timeframe.

If we process your information based on our legitimate interests as

explained above, or in the public interest, you can object to this

processing in certain circumstances. In such cases, we will cease

processing your information unless we have compelling legitimate

grounds to continue processing or where it is needed for legal reasons.

Where we use your data for direct marketing purposes, you can always

object using the unsubscribe link in such communications or changing

your account settings.

13. Withdrawing Consent

Where you have provided your consent, you have the right to withdraw

your consent to our processing of your information and your use of the

Services. For example, you can withdraw your consent to email

marketing by using the unsubscribe link in such communications or by

changing your account settings. You can choose to withdraw your

consent to our processing of your information and your use of the

Services at any time by closing your account through your account

settings and then emailing info@starborn.eu to request that your personal

information be deleted, except for information that we are required to

retain. This deletion is permanent and your account cannot be reinstated.

14. Privacy Policy Changes

We may amend or update this policy from time to time. If we believe that

the changes are material, we’ll let you know by doing one (or more) of the

following: (i) posting the changes on or through the Services, (ii) sending

you an email or message about the changes, or (iii) posting an update in

the version notes on the Apps’ platform. We encourage you to check back

regularly and review any updates.

15. Contact

If you have any questions:

Contact Starborn’s Support team:

Send an email to Starborn’s account manager at info@starborn.eu