At StarLeader, protecting your privacy is a priority.

When you use the www.starleader.io website (the"Site"), we may collect personal data about you.

The purpose of this policy is to inform you about how we process such data in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the "GDPR").

    1. Who is the data controller?

While you are browsing our Website, the data controller is Alphayz, a S.A.S company registered in the Nanterre Trade and Companies Register under number 952 853 109 and whose registered office is located at 33 rue Benoit Malon 92800 Puteaux ("We")

On the other hand, when our customers use our services, we collect and process personal data on their behalf and for their account. Our customers are therefore data controllers in accordance with Article 4 of the GDPR. We act as a processor, as a service provider.

    2. What data do we collect?

Personal data is data that can be used to identify an individual directly or by cross-checking with other data.

We collect personal data in the following categories:

         •   Identification data (name, first name, professional email address);

         •   Data related to your professional life (company name, position / function);

         •   Connection data (connection logs, encrypted passwords);

       •   Browsing data (IP address, pages viewed, date and time of connection, browser used, operating system, user ID, IFA);

         •   Location data.

3. On what legal grounds, for what purposes and for how long do we keep your personal data?

Format: Objectives-Legal basis-Shelf life

1.

• To provide our services available on our Site

• Execution of pre-contractual measures taken at your request and/or execution of the contract that you or your company have signed with Us

• When you have created an account: your data is kept for the duration of your account. Your connection logs are kept for one (1) year. If your account is inactive for 2 years, your personal data will be deleted if you do not respond to our reactivation email

• Improve our services

• Our legitimate interest in improving our services

• Personal data are kept for one (1) year

3.

• Send newsletters, solicitations and promotional messages

• For customers: our legitimate interest in building customer loyalty and keeping customers informed of our latest news For prospects: your consent

• The data is kept for 3 years from your last contact with Us

• Respond to your information requests

• Our legitimate interest in responding to your requests

• The data is kept for the time necessary to process your request for information and deleted once the request for information has been processed

5.

• To draw up statistics (of navigation, of the audience of the Site, etc.) and to improve the functionalities of the Site through the deposit of cookies of audience measurement

• Our legitimate interest in analyzing the composition of our customer base and improving our services

• The data is kept for twenty five (25) months

6.

• Manage requests to exercise rights

• Our legitimate interest in responding to your requests and keeping track of them

• If we ask you for proof of identity, we will only keep it for as long as it takes to verify your identity. Once the verification is complete, the proof of identity is deleted.

    4. Who are the recipients of your data?
Will have access to your personal data:

         (i)   The staff of our company;

         (ii)  Our subcontractors: hosting provider, audience measurement and analysis provider, e-mail provider;

         (iii)   If applicable: public and private organizations, exclusively to meet our legal obligations;

    
5. Will your data be transferred outside the European Union?
Your data is kept and stored for the duration of the treatment on the servers of the company Heroku, located in the European Union.

    6. What are your rights to your data?
You have the following rights with respect to your personal data:

         •   Right to information: this is precisely the reason why we have drafted this policy. This right is provided for in articles 13 and 14 of the RGPD.

         •   Right of access: you have the right to access all your personal data at any time, in accordance with Article 15 of the GDPR.

       •   Right of rectification: you have the right to rectify your inaccurate, incomplete or outdated personal data at any time in accordance with Article 16 of the GDPR.

         •   Right to limitation: you have the right to obtain the limitation of the processing of your personal data in certain cases defined in Article 18 of the GDPR.

         •   Right to erasure: you have the right to request that your personal data be erased, and to prohibit future collection of your personal data on the grounds set out in Article 17 of the GDPR.

         •   Right to lodge a complaint with a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a violation of the applicable texts, in accordance with Article 77 of the GDPR.

         •   The right to set up instructions for the retention, deletion and disclosure of your personal data after your death.

        •   Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR states that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.

         •   Right to portability: under certain conditions specified in Article 20 of the GDPR, you have the right to receive the personal data you have provided to us in a standard machine-readable format and to request its transfer to the recipient of your choice.

         •   Right to object: under Article 21 of the GDPR, you have the right to object to the processing of your personal data. Note, however, that we may continue to process them despite this objection, for legitimate reasons or the defense of legal rights.

You can exercise these rights by writing to us at the address below. We may ask you to provide additional information or documents to prove your identity.

    7. What cookies do we use?

To learn more about how we manage cookies we invite you to consult our Cookie Policy.

    8. Contact point to exercise your rights

Contact email: support@starleader.io.

Contact address : 33 rue Benoit Malon 92800 Puteaux FRANCE.

    9. Changes

We may modify this policy at any time, in particular to comply with any regulatory, legal, editorial or technical developments. These changes will apply as of the effective date of the modified version. You are therefore invited to regularly consult the latest version of this policy. Nevertheless, we will keep you informed of any significant changes to this Privacy Policy.

Effective date: June 06, 2023