Last revised: 22 October 2018 – Version 1
STAR (also referred to below as Star Group, ‘we’, ‘our’, ‘us’) values your privacy and will treat the personal data of those concerned with due care. Therefore, we confirm that the personal data will be processed in accordance with both the applicable national data protection and privacy laws, as well as the Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereafter GDPR).
STAR is committed to preserving the privacy of all visitors (‘you’) to our website www.star-specialists.com which include our customers, suppliers, employees and candidates applying for STAR.
STAR Group is the collective name for the companies that belong to this Group, being:
This privacy notice provides information about the personal data that STAR collects through our website and contact form, and the purposes for and legal bases on which we use that personal data.
Personal data collection
Personal data can be defined as being any information relating to an identified or identifiable natural person (‘data subject’). STAR processes the following data which may include personal data of the data subject from the website:
If you wish to make use of the contact form you are being asked to provide us with your last name, first name, e-mail address and your message. You can also enter your phone number if you agree that we may contact you by telephone.
If you wish to register for our member section on the website you are being asked to provide us with your last name, first name, title (reference to gender), e-mail address and you need to create a password. Optional are your phone number, address, education, skills, languages preferred sector and other preferences, as well as a cover letter and CV.
If you wish to receive job alerts you are being asked to provide us with your last name, first name, e-mail address, job preferences (location, work type and work sector).
If you wish to refer our website to a friend you are being asked to provide us your and your friend’s last name, first name, e-mail address, telephone number and (optionally) work sector.
If you wish to submit your CV you are being asked to provide us with your last name, first name and e-mail address. We collect personal data of you when you provide your CV to us. In some cases, we will collect personal data of you which you have made publicly available yourself through other means such as public accessible information on other (job search) websites, such as LinkedIn
Our website also contains social media buttons that link to our pages on Facebook, Twitter and LinkedIn. The use of personal data by social media companies is governed by the privacy notices of the relevant companies. We encourage you to review these specific privacy notice.
Personal data use
We use the information you submit via one of the provided services made available on our Website listed above to manage your request and to provide our services to you accordingly.
As you put in directly the personal data for our processing, we rely on you to provide all necessary and correct information.
Our use of personal data collected via this website, depending on the type of processing, is based on:
1. Your explicit consent: it is possible that we ask your consent to process your personal data and to contact you for the purposes of direct marketing.
2. Performance of our contract, e.g. when subscribing to the website and when you provide your CV, you enter in a (pre)contractual relationship with us.
3. The legitimate interests we pursue, which essentially comes down to connecting the right people to the right projects in our areas of expertise (e.g.: when we send you promotional communications for interesting career or business opportunities if you have submitted your email address) or
4. If we want to use the data you provided us for another purpose than initially indicated, we will ask for your explicit consent beforehand.
Confidentiality and security of your personal data
STAR has in place reasonable technical and operational measures to protect all personal data you provide via this website from unauthorised and/or accidental access, disclosure, alteration, loss or destruction.
Personal data collected by STAR will be stored on secured computer storage facilities within the EEA. All information you submit via this website is subject to the application of security and encryption technologies, and STAR shall on a regular basis evaluate and adjust if required, the appropriateness of the taken security measures in accordance with article 32 of the GDPR. Your personal data is only accessible by a limited number of authorized persons who have been assigned special access rights to our systems and offices, and are obliged to keep the information confidential.
Disclosure of personal data to third parties
As long as in accordance with the above-mentioned purposes and compliant with the legal basis, we may disclose your personal data to
Furthermore, your personal data may be disclosed to third parties as part of a corporate transaction, such as a sale, divestiture, reorganisation, merger or acquisition, to which STAR is a party. It goes without saying that in case of such transaction your rights as mentioned below shall remain unaffected.
In addition, we may have to disclose personal data to law enforcement, regulatory or other government agencies or other authorized third parties in order to comply with legal or regulatory obligations or requests.
Transfer of personal data outside the EEA
Due to the international nature of our business, we may need to transfer your personal data to third parties in other countries outside of the European Economic Area (EEA), in connection with the purposes set out in this privacy notice. For this reason, we may transfer your personal data to other countries that may have different laws and data protection compliance requirements, including data protection laws of a lower standard to those that apply in the country in which you are located.
Where we transfer your personal data to other countries, we do so on the basis of:
In this case, we will put in place the necessary safeguards and contractual and technical security measures to ensure that all personal data transferred are adequately protected against loss or unlawful processing. You will in any case maintain all of your rights and legal remedies made available under European Union Law.
If you want to receive more information about the safeguards applied to international transfers of personal data, please do not hesitate to contact the DPO and the privacy office under email@example.com
We take reasonable steps designed to ensure that:
your personal data that we process are accurate and, where necessary, kept up to date, and any of your personal data that we process that are inaccurate (having regard to the purposes for which they are processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your personal data we have of you.
We take reasonable steps designed to ensure that your personal data that we process are limited to the personal data reasonably required in connection with the purposes set out in this statement.
Personal data retention period
The period of time for which your personal data is being stored depends on the applicable (statutory) retention periods.
As a starting point, STAR will retain the personal data you provide via this website for as long as is necessary in order to provide you with our services. We respect regulations and local laws that define the required retention periods.
At all times you have the possibility to exercise your rights as described in the GDPR. You can do this free of charge by contacting us, using the contact details of our Privacy Office under firstname.lastname@example.org.
As the data subject you can exercise the following rights:
You always have the opportunity to request all your collected personal data (including processing purposes, categories of personal data, estimated retention period).
You have the right to have incorrect personal data corrected or completed and the right to have your personal data removed from our files. You acknowledge that, if you refuse to provide certain data or ask for the erasure of your personal data, we will no longer be able to provide certain services. You also have the right to ask for the restriction of the processing of your personal data.
If you no longer wish for us to process your personal data, e.g. you wish to no longer be informed about any updates or receive direct marketing, you are entitled to make such request by contacting us using the contact details provided in the contact section or you can click on the unsubscribe-link available in every received e-mail concerned. Please note that you are not entitled to object to the processing of your personal data if such personal data is necessary for the execution of a standing agreement between STAR and you, for example for invoicing you for the provided services.
You have the right to receive your personal data, processed by us in a structured, commonly used and machine-readable format and/or to transmit those data to another controller.
If you believe that STAR has infringed your personal data, you have the right to lodge a complaint with the Supervisory Authority responsible for you:
2594 AV Den Haag (Netherlands)
Gegevensbeschermingautoriteit/ Autorité de protection des données
Drukpersstraat/ Rue de la Presse 35
1000 Brussel/ Bruxelles (Belgium)
Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit
Ludwig Erhard Strasse 22,
Changes to our cookie statement and/or privacy notice
We may modify or amend our cookie statement and/or privacy notice from time to time. Such modified or amended statement or notice will be applicable as to you and your personal data as of the revision date as mentioned at the top of this notice. We will inform you by e-mail prior to the changes and ask for your consent to accept the changes in case you gave us prior consent. We encourage you to regularly review this notice to be informed about how we protect your privacy.
When you have any questions, comments or concerns about any of the information in this notice and/or relating to the use of your personal data by STAR, please do not hesitate to contact the DPO and the Privacy Office under email@example.com.