Privacy Policy

General data privacy notice

Legal framework for protecting your personal data

This data privacy notice is written to comply with the European Union General Data Protection Regulation (GDPR). GDPR gives control to citizens and residents over their personal data.

Star (“Star”) values and respects the privacy of our users, members, and others who visit and use cms.star.global and its associated products and services (the “Star Service”) (collectively or individually “Users”) and are committed to protecting your personal data.

The purpose of this Policy is to provide you with information about how and why Star collects and processes your personal data when you visit this website and/or when you sign up to our newsletters, fill out contact forms to download any of our published reports and insights, inquire about our services, take part in a survey or otherwise interact with us through this website.

Please note that this website is not intended for children, and Star does not knowingly collect data relating to children. If you are younger than 16, you may not register with or use this website. If you think that we may have unintentionally collected data relating to a child, please write to us at hello@star.global

Contact details

Our full details:
Full name of legal entity: Star
Name data protection officer: Marty McFarland, CFO Star
Email address: hello@star.global

Postal address of data protection officer: Star, 1250 Borregas Avenue, Sunnyvale, CA 94089, USA

If you are a European Union citizen you have the right to make a complaint at any time to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement.

Information Star collects

Personal data, means any data or information about an individual from which that person can be identified. It does not include anonymous data where your identity has been removed

We may collect, use, store, and transfer different types of data about you as follows:

Contact data which includes your email address(es) and telephone numbers.
Identity Data which includes your first name, last name, and job title.
Marketing and communications data which includes your preferences in receiving marketing from us, and your communication preferences.
Profile Data includes your username and password, preferences, feedback and survey responses.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website.

You will receive marketing communications from us if you have requested information from us, or if you have provided us with your details when you entered a survey or registered for an event and when you have not opted out of receiving that marketing.

You can tell us not to contact you with marketing communications either at the point such information is collected or by following the unsubscribe instructions in any communication sent to you. You can also exercise this right at any time by contacting us using the contact details at the end of this Privacy Policy. Please note that where you opt out of receiving marketing messages, this will not delete other personal data we hold on you.

We do not collect personal data about you other than the information which you voluntarily provide to us through this site to fulfill the purpose of your request such as to request a full report or whitepaper. We do not collect any Special Categories of Personal Data about you (such as ethnicity, sexual orientation, political opinions, religious beliefs, organization membership, health, genetic or biometric information or any information about criminal convictions and offences). Please note that we will get your express opt-in consent before we share your personal data with any company outside of Star for marketing purposes.

How we collect your personal data

Direct interactions

This is where you give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you

fill in a form on this website (such as the ones on our ‘get in touch’ or ‘contact’ forms);
create an account on our website (such as on our ‘careers’ page);
subscribe to any publications;
request marketing to be sent to you
give us some feedback.

Automated interactions

As you browse our website, we may automatically collect data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. Please note that when you disable or refuse cookies, some parts of this site may become inaccessible or may not function properly.

Third-party analytics

We receive technical data (standard internet log information and details of visitor behavior) from Google Analytics about visitors to this website. This information does not identify anyone. To opt out of being tracked by Google Analytics across all websites visit: https://tools.google.com/dlpage/gaoptout.

How we use your personal data

We will only use your personal data when the law allows us to in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at hello@star.global.

Disclosures of your personal data

We may have to share your personal data with third parties such as:

Internal third parties such as our lead generation/sales/contracting departments.
External third parties, to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, inappropriately used, accessed, altered or disclosed. In addition, we limit access to your personal data to those employees, and third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

How long we retain your personal data for

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Storage and deletion

All personal data is deleted, when it is no longer necessary for the purposes for which they were processed. Generally, we delete all personal data no later than 24 months after it has been collected.

We delete the information that we collect using cookies containing personal data no later than 24 months after it has been registered by us.

Your legal rights

Data protection law gives you a range of rights in connection with our processing of your personal data. In this regard you have the right to request access to the personal data concerning you that we process. Further, you may request that we rectify or delete the personal data or restrict the processing of your personal data, if you think they are inaccurate. Furthermore, you have the right to object against the processing based on our legitimate interests as a legal basis. We are required to assess and act on your request.

If you wish to exercise any of the rights set out above, please contact us at hello@star.global.

In the event of merge or sale

If Star should ever file for bankruptcy or have its assets sold to or merge with another entity, information Star receives from you through a Star website is a Star asset and may be transferred.

Changes and updates to the privacy policy

We may occasionally update this Privacy Policy. When we do, we will also revise this policy. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal information that you have provided to us, we will attempt to obtain your consent before implementing the change. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect. Your continued use of a Star website constitutes your agreement to this Privacy Policy and any updates.

Contacting Star

If you have any questions, comments, or concerns about this Privacy Policy, please email us at hello@star.global or write to us at Postal Mail Address: Star, 1250 Borregas Ave Sunnyvale, CA 94089 USA.

Recruitment Privacy Notice

Star (hereinafter – "Star", "We") holds and processes a wide range of information related to individuals who apply to work for Star. This Recruitment Privacy Notice explains the type of information We process, why and how that processing may affect individuals with our recruitment process and programs.

This Privacy Notice only applies to the personal data of job applicants, potential candidates for employment or partnership and those who participate in our recruiting programs and events. Star receives this personal data directly through the online application process, follow-up communications and/or alternative channels (e.g., via professional recruiting firms). We may also collect and process your personal data if we engage in due diligence related to a potential corporate acquisition of your current employer.

This Privacy Notice does not apply to our employees, contractors or clients, or other personal data that Star collects for other purposes.

We may engage third-party service providers to assist in the recruitment process. These providers are contractually obligated to implement appropriate security measures and comply with data protection laws.

Breezy: HR Recruitment System
JIRA

We will process your personal data in accordance with this Privacy Notice unless this processing conflicts with the requirements of applicable law, in which case, the applicable law will prevail.

By submitting your personal data to us, you acknowledge that you have read and understood this Privacy Notice and agree to the use of your personal data as set out herein.

Joint data processing

In the recruitment processes, personal data is jointly controlled by different administrators, each responsible for different purposes or stages of the processing, depending on the position for which the candidate is being recruited. Personal data may be transferred between entities, including outside the European Economic Area (EEA). The principles of joint data administration are outlined in the Data Sharing Agreement, which includes as an annex the Standard Contractual Clauses (SCCs). These clauses regulate, among other things, the methods of securing data and the technical and organizational measures to ensure data security, including data encryption, cryptography, access control, VPN, and pseudonymization.

The entity responsible for handling the data subjects' inquiries is Star Global Consulting, INC.
List of entities jointly controlling personal data:

Star Global Consulting, INC., registered in the state of California under registration number 3211834 in the register maintained by the California Secretary of State, with its registered office at 1250 Borregas Ave, Sunnyvale, CA 94089, USA,
Star Poland Sp. z o. o. with its registered office in Wrocław, ul. Grabarska 1, 50-079 Wrocław,
Star Denmark ApS based in Copenhagen, Denmark, with its registered office at Frederiksborggade 15, 2 floor, 1360 Copenhagen,
Star Global Consulting Ltd. based in London, United Kingdom, with its registered office at 82 St John Street, London, United Kingdom, EC1M 4JN,
Star Ukraine Limited Liability Company based in Kiev, Ukraine, with its registered office at 04050, Kyiv, 12 Ilyenko Str.,
Star Global Consulting GmbH based in Munich, Germany, with its registered office at Bayerstrasse 85, 80335 Munich,
Star Co., Ltd. based in Tokyo, Japan, with its registered office at 2-21-1, Shibuya, Shibuya-ku, Tokyo, 150-8510,
Star Global Consulting Vietnam Co., Ltd. based in Ho Chi Minh, Vietnam, with its registered office at 8th Floor, 63A Nam Ky Khoi Nghia Street, Ben Thanh Ward, District 1, HCMC, Vietnam,

Information collection

We will comply with data protection law and principles, which means that your data will be:

Used lawfully, fairly and in a transparent way
Collected only for valid purposes that We have clearly explained to you and not used in any way that is incompatible with those purposes
Relevant to the purposes We have told you about and limited only to those purposes
Accurate and kept up to date
Maintained only for as long as necessary for the purposes We have told you about, i.e. in relation to the recruitment exercise
Kept securely and protected against unlawful processing and loss or destruction using appropriate technical and organizational measures
Children’s Data: Our recruitment process is not intended for individuals under the age of 16. We do not knowingly collect personal data from children without verified parental or guardian consent. If we become aware that we have collected personal data from a child without such consent, we will take steps to delete that information

We may collect the following personal information from you:

Contact details (e.g., name, email, telephone number)
Education, academic and professional qualifications
Locations and interest in global opportunities
Employment history
Areas of interest and specialized knowledge/subject matter
Other information within your resume/CV that you choose to submit

We may also obtain the following personal information about you from third party sources:

Social media profile information, if you choose to provide us with a link to your profile page
Information from social media sites you are a member of, specific to your engagement with our recruitment campaigns

Information use

We collect and use your personal data for legitimate human resources and business management reasons, including:

Identifying and evaluating candidates for potential employment, as well as for future roles that may become available
Maintaining records relating to recruiting and hiring
Ensuring compliance with legal requirements
To attract talent and market opportunities at Star, including by arranging, hosting and participating in events, marketing and advertising opportunities, including on social media, and using recruiters to help find talent for us
To identify and source talent, including by searching our talent pool and publicly available sources (such as professional networking and job websites you are a member of)
To evaluate you for open positions that match your interests and experience throughout the Star network, manage your talent profile, send you email notifications, surveys and other announcements, request additional information or otherwise contact you regarding recruitment, events, thought leadership or other opportunities We believe may interest you
To conduct statistical analyses and create reports
To administer and manage our careers websites and communicate with you about careers at Star
Any other purposes stated when you provide the information to Star

We do not use automated decision-making or profiling methods in our recruitment processes. All candidate evaluations and hiring decisions are made with human involvement to ensure fairness and transparency.

Legal basis for processing your personal data

We process your personal data for the purposes mentioned above, based on:

Consent - If a candidate voluntarily provides additional information that is not required for the recruitment process (e.g., details about personal interests, social activities, or other non-essential data) as well as retention of data for future recruitment, will be processed only with the consent of the data subject
Legitimate interest – Evaluating your application to manage our relationship with you, to ensure that We recruit appropriate employees, and to evaluate and maintain the efficacy of our recruiting process more generally
Legal obligation – Complying with applicable law with regard to personal data necessary to satisfy our legal or regulatory obligations

Providing your personal data is voluntary. However, if you do not provide certain necessary information, we may not be able to process your job application or proceed with the recruitment process.

Data sharing

We will share your personal data internally for recruitment purposes with members of the recruitment team, interviewers involved in the recruitment process, managers in the area with a vacancy and support staff if access to the data is necessary to perform their roles.

We will share your personal data with the third parties contractually obligated to follow security and data protection measures. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data in line with our policies.

We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and following our instructions.

Data Transfers Outside the EEA

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States, where data protection laws may differ from those in your country.

To ensure the protection of your personal data when transferred outside the EEA, we implement appropriate safeguards, including:

The use of Standard Contractual Clauses (SCCs) approved by the European Commission
Compliance with an adequacy decision by the European Commission (where applicable)
Additional technical and organizational measures to enhance data security

Additionally, personal data may be transferred outside the EEA in connection with authorizations granted to individuals employed by companies within the Star Group, where such transfers are necessary for the performance of recruitment-related tasks.

For more information on the safeguards in place, please contact us at recruitment_dsar@star.global.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal data according to our specific instructions, and they are subject to a duty of confidentiality.

Information retention

We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements.

If your application is successful, your data will be retained in accordance with our general data privacy notice
If your application is unsuccessful, With your explicit consent, we will retain your data for 3 years after the recruitment process concludes to consider you for future opportunities
If required by law, we may retain certain information for longer periods
After the retention period, your personal data will be securely deleted or anonymized

Your rights

In accordance with applicable law, you may have one or more of the following rights:

To request a copy of the personal data that We hold about you and details of how We use that information
To amend or rectify your personal data if any of the information held about you is incorrect or out of date
To the portability of your personal data
To request the erasure of your personal data
To demand that We cease the processing of your personal data or that we restrict the processing of your personal data
To withdraw your consent to the processing of your personal data, to the extent our processing relies on your consent as the lawful basis for processing
To provide us with instructions as to the processing of your personal data in case of death

To make any of these requests or to ask that We transfer a copy of your personal information to another party, contact the Star Recruitment team at recruitment@star.global.

Changes to this privacy notice

We may occasionally change this privacy notice. When We do, the "last updated" date at the top of this page will also change. Any changes to this privacy notice will apply to you and your data immediately. If these changes affect how your personal data is processed, We will take reasonable steps to let you know.