Privacy Policy – Starling Search

Privacy Policy

This privacy policy sets out the privacy practices for in relation to how visitor data is handled on this website, Starling Search (the “Website”).

In order to provide our services to you and to promote our business, we will need to collect and process certain personal information about you.

We are committed to protecting the privacy and security of your personal information, in accordance with the applicable data protection laws, including the General Data Protection Regulation, together the “Data Protection Laws”.

This privacy policy describes how we collect and use personal information about you during and after our relationship with you and your employer as appropriate.
If you have any questions at all about this policy or the Website, or about how we use and process your personal information, please do not hesitate to contact us by e-mail at Info@starlingsearch.com.
If we change our privacy policy we will post the changes on this page, and may place notices on other pages of the Website, so that you may be aware of the information we collect and how we use it at all times. Continued use of the Website will constitute your agreement to any such changes.

1. Our role
In order to enable us to provide our services to you via our Website, we have been provided with certain personal data by you including your name & email address. We also collect certain other personal information about you, as described further in this privacy policy.
For the purposes of the applicable Data Protection Laws, is the data controller of your personal data collected in connection with your use of our Website.

What information we collect
In addition to the information provided to us by you, we will collect certain personal information about you when we, or you contact us by phone, e-mail or otherwise.
We will, therefore, hold the information provided by your/your employer to create your profile and further information you provide to us.
We also work with third parties (including, for example, business partners, sub-contractors in technical and payment services, advertising networks, analytics providers, search information providers) and may receive certain information about you from them.
When we wish to send you information about our services, and you do not currently use our services, we may collect your contact details, for example, your name, email address and job title. This information may be provided directly by you, when you express interest in our website.
We use cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you use the Website and also allows us to improve our Website. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy below.
Lawful basis and purposes of processing of your personal information
We collect information about you so that we can:

identify you and manage your profile on our Website;
improve our services;
promote our business and market our services;
manage our business, including for accounting and auditing purposes;
conduct our regular group reporting activities on the performance of our company, in the context of a business reorganisation or group restructure;
maintain our IT systems and manage hosting of our data;
prevent fraud; and
comply with our regulatory obligations.

We will only use your personal information when the law allows us to, i.e. when it is necessary to:

comply with our legal and regulatory obligations;
pursue our legitimate interests (e.g. conducting our business in an efficient, compliant and profitable manner and the overall promotion of the business), and where your interests and fundamental rights do not override these interests. We will also rely on our legitimate interests for the proper administration of our Website, and to manage our operations (for example, maintaining appropriate records and databases).

We will rely on legitimate interests of the business to send you electronic communications, but we will always provide you with an option to opt out from future communications of this kind.
Some of the above grounds and purposes for processing will overlap and there may be several grounds which justify our use of your personal information.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Uses made of the information
We will use the information we receive from you to:
   communicate with you in response to a specific action performed by you on our Website;
2.    to provide you with support in using our Website;
3.   to notify you about changes to our services, our terms and conditions of use of the Website or this privacy policy; and
4.    to ensure that content from our Website is presented in the most effective manner for you and for your computer and/or your mobile device.

We will use the information we collect about your use of our Website:

   to administer our Website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
2.    to improve our Website to ensure that content is presented in the most effective manner for you and for your computer and/or your mobile device;
3.   to help us improve and personalise our services;
4.    to allow you to participate in interactive features of our Website when you choose to do so;
5.    as part of our efforts to keep our Website safe and secure;
6.   to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
7.    to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.

Disclosures of your Information
We do not sell or share your personal data with third parties for them to use for marketing purposes.
We may allow our staff, consultants and/or external service providers acting on our behalf, to access and use your personal data for the activities we have described above. We only permit them to use it to deliver the relevant service, and if they apply an appropriate level of security protection.
We will share your personal information with the following third parties:

our agents and service providers;
our regulators, including the Financial Conduct Authority;
law enforcement agencies in connection with any investigation to help prevent unlawful activity; and
in the context of the possible sale or restructuring of our business.

We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information. 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 in accordance with our instructions.
We also reserve the right to disclose the information collected about you to our professional advisors and/or if we, in good faith, believe it necessary to protect the personal safety of users or the public.
We may partner with another party to provide specific services. When you sign up for these services, we will share names or other contact information that is necessary for the third party to provide these services.
These parties are not allowed to use any personally identifiable information except for the purpose of providing these services. We may also use such aggregated information and statistics for monitoring the Website usage in order to help us develop the Website and our services and may provide such aggregate anonymous information to third parties.

Keeping your data secure
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us (see our contact details below).
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
Retention periods
We will only retain your personal information for as long as necessary to fulfil 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.
In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer our customer, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Your rights
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law, you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information and to check that we are lawfully processing it.
2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
3. Request erasure of your personal information (often referred to as “the right to be forgotten”). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
4. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it, or if we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings.
6. Request the transfer of your personal information to another party.
If you would like to exercise any of the above rights, please:

email, call or write to us (see our contact details below);
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill). This is to allow us to verify your identity and prevent disclosure to unauthorised third parties; and
let us know the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.

Please note that if you request erasure, object to our processing of your personal data or request the restriction of our processing of your personal data we may not be able to provide our services and we may need to deactivate your account on our Website.
You also have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at: Info@starlingsearch.com.
You can always unsubscribe from our email communications at any time by following the unsubscribe link in our email communications, or by updating your email preferences on your profile on our Website.

9. Contact us or the ICO
If you have any concerns or complaints about our privacy activities, you can contact us on Info@starlingsearch.com You can also contact the Information Commissioner’s Office on 0303 123 1113.
For more details about your rights under the Act, the rules we have to adhere to in collecting and storing your information, and how you can check your data records, please visit https://www.gov.uk/data-protection/the-data-protection-act.