10star.com
Website Privacy and Cookie Policy
30 January 2023 – Version 1.0

Privacy and Cookie Policy: Introduction
This website, www.10star.com (the “Site”), is owned and operated by Diez Star Holding Limited (“10star”), a company registered in Malta with registration number C 94194 with registered address at Level 4, The Penthouse, Suite 2, Ewropa Business Centre, Triq Dun Karm, Birkirkara BKR9034. References to “us” and “we” in these Terms and Conditions include 10star and our subsidiaries and group companies from time to time.

This Privacy and Cookie Policy forms a part of our Terms and Conditions and explains how we use the information we collect about you, how this information is shared, your rights under applicable data protection legislation and the protocols we have in place to safeguard your information.

10star is the data controller responsible for this Site and for processing personal data collected via the Site and we are committed to protecting and respecting your privacy.

We regularly review our privacy practices and may amend this policy from time to time without notice. If you have any questions regarding this policy or how we use the information we may collect about you, please contact us at dataprivacy@10star.com or send us a notice in the post at the address listed above.

What do we collect?
‍We collect information about you whenever you use our Site, including personal data (i.e., information that may allow us to identify you directly or indirectly). Some of this data is collected from information you directly provide to us by interacting with our Site to get in touch with us, or from using cookies that are stored in your web browser that enable us to recognize your computer when you visit our Site. However, we will only collect personal data that is reasonably necessary to fulfil the purpose for which it’s being collected – for example, to respond to your inquiry regarding our products and services.

Some of the information we may store about you is listed in the below, non-exhaustive list:

Your name
Your email address
Your telephone number
Your point of access
Your correspondence with 10star, including any information contained therein
Details of your visits to our Site, including, but not limited to, traffic data, location data, web logs, page views, ad data and other similar data

Some personal data is afforded a higher level of protection under applicable data protection law because this information is more sensitive. This “special category data” includes personal data relating to your racial or ethnic origin, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sex life and/or sexual orientation. We do not request any special category data via our Site.

How do we collect your personal information?
‍Directly from you
‍We may collect personal information from you directly when you provide to us information to respond to your query to contact us.

‍Indirectly through publicly available sources
‍After you have submitted personal data to us via our Site, we may sometimes use publicly available sources in order to obtain further information about you. For example, if you send us a query about licensing our products and services, we may review your profile on LinkedIn to understand your professional background and familiarity with what we have to offer.

‍By automated technologies
‍Our Site uses browser cookies that are stored in your web browser which enable us to recognize your computer when you visit our Site, and so we can distinguish you from other users. As you interact with our website, we automatically collect data about your machine, browsing actions, and browsing patterns. We collect this personal data by using cookies, server logs and similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.

What are cookies?
‍Some of the information we gather about is collected by use of cookies. Cookies are stored in your web browser, allowing us to recognize your computer, laptop, or mobile device when you visit our Site.

When you use our Site, we may collect information about your computer, such as your IP address and/or browser, which we will use for administration purposes and statistical analysis. This information will not usually identify you personally and instead identify your use patterns, device and browser. When you use our Site, we may obtain information about your activity and interaction on our Site by using tracking pixels, tags, or by placing a cookie (i.e., a small data file comprised of letters and numbers) on your computer's hard disk. We may use the following types of cookies:

Functionality Cookies that recognize you whenever you visit our Site and remember your preferences as a user of our Site. Functionality Cookies may or may not store information about you, though they are strictly used for improving the performance of our Site. For example, these cookies can speed up access to our Site and help us make our Site work better.
Advertising Cookies that build a profile about you so that our marketing and advertising efforts are more relevant to you. These cookies may record your visit to our Site, the pages you have visited and the links you have followed, allowing us to make our Site and the advertising displayed on it more relevant to you.

How do we use your personal information?
‍We may use information collected about you in the following manners:

Purpose	Personal Data Processed	Lawful Reason
To help us identify you to respond to a query	Contact details, such as name, email address, and phone number Details on the query	Legitimate interests (to answer your query for business development)
To provide you with marketing materials, including 10star news, updates, and product information	Contact details, such as name, email address, and phone number Marketing preferences	Consent, unless withdrawn at any time by unsubscribing or contacting us
To make our site easier to use	Statistics on Site interactions and use patterns	Legitimate interests (to monitor and improve the quality of our Site and accessibility)
To track and monitor your engagement and interaction with the content on our site	Statistics on Site interactions and use patterns	Legitimate interests (to monitor and improve the quality of our Site, relevance of our content, and attractiveness of our information)
To operate and improve our Site and services	Statistics on Site interactions and use patterns	Legitimate interests (to monitor and improve the operation of our Site and accessibility)
To notify you of any changes to our Site or products and services which may affect you	Contact details, such as name, email address, and phone number Marketing preferences	Consent, unless withdrawn at any time by unsubscribing or contacting us
To perform research and analysis aimed at improving our products and services	Contact details, such as name, email address, and phone number Marketing preferences Statistics on Site interactions and use patterns	Consent, unless withdrawn at any time by unsubscribing or contacting us Legitimate interests (to improve our Site and present compelling and interesting content for business development)

We will only use your personal data for the purpose for which we collected it and for reasons that are in line with the original purpose in our reasonable discretion. If we need to use your personal data for an unrelated purpose or a purpose incompatible with the original purpose of collection, we will contact you and explain the legal basis which allows us to do so.

How do we share your personal information?
‍We will not sell your personal data to third parties. We may share your personal data with the following third parties, only where it is necessary to do so and for the specified purposes for which it was collected, who may process the information on our behalf or as required by law:

Companies within the 10star group, including our affiliates and subsidiaries, which includes our companies located in Malta, the United Kingdom, and the United States.
Organizations that provide services to us, such as:
a) Webflow
b) Microsoft Office 365
c) Microsoft Azure
Potential acquirors who may be prospective buyers of our business in whole or in part
Governments or governmental agencies, including police and law enforcement
Our professional advisors solely to enable them to render professional advice

Where is my personal information shared?
We may store and process your personal data in any country where we carry out our operations. This will involve transferring your personal data electronically outside of the country in which you access our Site, including Malta, the United Kingdom, and the United States.

As and when it is necessary to transfer your personal data outside the European Economic Area (EEA - which is made up of the EU Member states plus certain countries considered to offer a standard of data protection equivalent to that of Europe), we will ensure that a similar degree of protection is in place that will protect your personal data to the standards set in GDPR or as close to as possible, including, in our reasonable discretion either (1) transferring your personal data to countries that have been deemed by the EEA to provide an adequate level of protection for personal data, or (2) using standard contractual clauses that have been approved for use in the EEA.

Is my personal information secure?
All your personal information will be stored securely by 10star. Any business partners who deal with your personal data will be obliged to comply with GDPR legislation. We further restrict access to your personal data to those employees, agents and contractors who have a legitimate need to know and whom will only process your personal data on our instructions and are subject to a duty of confidentiality.

10star will take appropriate security measures against unlawful or unauthorized processing of your personal information, and against the accidental loss of, or damage to, your information.

Our objective is to maintain the confidentiality, integrity, and availability of your personal information as follows:

Confidentiality – only authorized people can access the personal information we collect about you.
Integrity – your personal information collected by us should be accurate and suitable for the purpose for which it is processed.
Availability – your personal information is only available to authorized people for legitimate purposes.

How long will you keep my personal information?
We will store your personal information only for the time necessary to fulfil the purposes for which it was collected or as otherwise required by applicable law or regulation. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe that there is a threat of litigation regarding our relationship with you.

We will keep your contact details for a period of two (2) years after the date of last contact for business inquiries.

We will keep your contact details and marketing preferences until you unsubscribe or contact us to withdraw your consent.

We will keep statistics on Site interactions and use patterns for an undefined period of time after anonymizing such data after a period of two (2) years since last contact.

What are my rights to my personal information you collect?
You have a number of rights under data protection laws regarding your personal data, as listed below.. Please note there may be exceptions to these under applicable data legislation, such as the GDPR.

Right to access to personal data: You have a right to view a copy of the personal data we hold about you at any time.
Right to correct personal data: You can amend or correct your personal information that we hold about you if it is incorrect or incomplete.
Right to withdraw consent: You have the right to opt out of receiving our emails or being contacted by us.
Right to object to processing of personal data: You have the right to object to our legitimate interests of processing of your personal data.
Right to data portability: You have a right to receive the personal data that we hold on you, of which you consented to in order for us to provide a service.
Right of erasure: You have the right to request that personal information we hold about you is erased if the information is no longer necessary for the purposes for which it was collected or if our processing of the information was based on your consent and there is no other lawful reason for which we may process the information.

Changes to our Privacy and Cookie Policy
10star may revise this Privacy and Cookie Policy at any time by posting an amended version on our website. We will use reasonable efforts to ensure that any important changes will be notified to you by an appropriate method, such as a notice on the website or an email. However, it is your responsibility to check the Privacy and Cookie Policy regularly to take notice of any changes we make, and you agree to do so. Any changes to the Privacy and Cookie Policy are binding on you from the first time you visit the website after the relevant change. If you do not agree with any changes or additions we make, please refrain from using our Site immediately.