Privacy Policy

BLUESTAR PRIVACY STATEMENT

Last updated: November 2022

INTRODUCTION

At BlueStar Europe Distribution, we are committed to maintaining the highest standards of integrity in our business. In the course of business, it is necessary to collect, record, store, process, transmit, and otherwise handle Personal Information about individuals. We take these activities seriously and seek to provide fair, secure, and appropriate methods for the handling of Personal Information. All such activities are intended to be consistent with both generally accepted privacy ethics and standard business practices.

This Policy applies to any subsidiary, branch or affiliate of BlueStar Europe Distribution BV (henceforth collectively referred to as "BlueStar" or "we"). We provide this privacy policy to inform you of our practices with respect to how we collect, use, and protect personal information about visitors to our website or webstore, our Customers or Vendors. Personal Identifiable Information (PII) is information that can be linked to a natural person.

This Policy (together with our Terms of use, our Cookie Policy and any other document referred to in it) sets out the basis on which any personal data we collect from you or you provide to us, will be processed or stored by us.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

DATA CONTROLLER

BlueStar Europe Distribution BV is the Data Controller under the Act, which means that it determines what purposes personal information held, will be used for. It is also responsible for notifying the Information Commissioner of the data it holds or is likely to hold, and the general purposes that this data will be used for.

OBTAINING YOUR CONSENT

The purpose for which Personal Information is collected will be specified on or before the collection of the information, and any change of purpose will be communicated to you. This consent will be expressed in writing, given verbally, electronically, or through an authorized representative.

Consent to collect, use, and disclose Personal Information can be withdrawn at any time, subject to legal and contractual restrictions and reasonable notice.

COLLECTION

BlueStar aims to only collect, handle and store only the necessary Personal information required for normal operations and within the parameters as set out by the relevant legislation. We are also committed to only collect information for the purpose(s) identified and communicated within this Privacy statement and our Privacy Policy and/or any relevant policies. Only lawful means will be used to collect personal information.

a) What data do we collect

Visiting our Website or Webstore

BlueStar does not require that you enter any personal information to visit the company website but may collect the following data about you when you visit our site:

• Information you provide by filling in forms on our website. This includes information provided at the time of registering to use our site, subscribing to our service or requesting further services, signing up for newsletters and promotions or using contact forms. Please refer to the sections Subscribing to Marketing Mails and Becoming a Reseller / Customer / Requesting a BlueStar Account below for more details on the information collected using our forms.
• Your username created after registration.
• A record of any correspondence with you.
• Details of your visits to our site including, but not limited to traffic data, location data, web logs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that you access.
• Information on whether you have opened and clicked on certain content in our emails sent to you.
• Information about your computer, including where available your IP address, operating system, browser type and device ID, for system administration and to report aggregate information to our advertisers; and information obtained from cookies. Please find further information about this under Cookie Policy. This information does not necessarily enable us to personally identify you.
• Cookies and similar technologies. When you use our website we collect information via cookies and similar technologies. For more information please refer to our Cookie policy.
• BlueStar may collect, store and process certain Non-personal and Personal Information of Customer-Visitors ("Customer-Visitors Information"). We are able to import, collect and manage contacts via our Website and take orders via the online store. Such contacts are then stored with our marketing tool / database solely if consent is provided by the customer.
• Social networking. If you choose to login with Facebook Login or Google+ Sign-in you are permitting BlueStar to use and store that information related to the profile allowing us to make use of any social media features on our website or apps. The social media provider may send us information in line with their policies which may include your name, profile picture, gender, job title, friend lists and any other information you have chosen to make available. Other information regarding recommendations exchanged may also be shared. If you wish to prevent that sharing, you can do so by editing your Facebook or Google+ privacy settings or the relevant settings/preferences for other social media providers.

Subscribing to Marketing Mails

For and after subscription to receive BlueStar marketing content or emails BlueStar requests and saves the following information;

• Non-personal Company details
• First Name, Last Name, Job Title
• How you use the newsletter service i.e. if you open, click or unsubscribe. This is to give you relevant information and to understand your level of interest. If you e.g. have not opened any marketing emails from us within a year we might stop sending you marketing emails. Visit our Cookie policy for more information on this.
• We always treat your personal information with the utmost care. We do not sell it to third parties.

You can of course choose to unsubscribe at any time via the unsubscribe link found in all our emails.

You can ask us to delete your information. We can do this unless we are legally required to keep it.

Becoming a Reseller / Customer / Requesting a BlueStar Account

When you register as a Customer, Reseller or Vendor you will be prompted to complete a form and provide the following information:

• Non-personal Company details
• First Name, Last Name, Job Title

You can ask us to delete your information. We can do this unless we are legally required to keep it.

b) How do we collect?

Use of Services

We collect information through your use of the Services. In other words, when you are visiting our Site or using our Services, including when you browse the Website or Webstore, register as a Customer, Vendor or Reseller; we are aware of it and may gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed below in the section THIRD PARTIES, including through the use of Cookies and other tracking technologies, as further detailed in our Cookie policy and THIRD PARTIES section below.

Voluntary Provision

We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register as a Customer, Vendor, Reseller, when you purchase a product from our webstore; when you Opt-in to receive marketing content, sign-in via third party services such as Facebook or Google; when you submit or upload such Personal Information while using any of our Services; and/or when you contact us directly.

Why do we collect the data?

• To provide and operate our Service for Customers, Visitors and Vendors
• To provide a microsite to Visitors on behalf of our Vendors
• To provide assistance to Customers
• For direct marketing purposes
• To maintain and improve security and to detect and prevent misuse and fraud
• To comply with laws and regulations
• To improve and develop our Services, based on Visitors’ and Customers’ shared or individual choices, behavior and feedback

LOCATION OF DATA STORAGE

The Personal data you provide to us via the above mentioned means, is stored on our secure servers and services. Currently, our servers are located within the European Economic Area (EEA). The data that we collect from you may be transferred to, and stored at, a destination outside the EEA. The transfer may be to other members of the BlueStar group, to employees or contractors or to third parties as set out in this policy. In particular, the contents of a website is transferred to any person or entity requesting it, as part of the normal and intended operation of the service, without any restrictions or regard to their location. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

We may be required by law, to hold your data in a specific location dependent upon the location from which you will access BlueStar services. Regardless of the location in which your data is stored we will take adequate measures to protect the security of your personal data.

These countries may have different and/or less stringent privacy/data protection and data security rules than those of your own country. As a result, your personal information may be subject to access requests from governments, courts, or law enforcement in those countries according to laws in those countries.

THIRD PARTIES

BlueStar partners with several third-party services to provide and improve our own service. These include payment and billing services, domain registrars, e-mail delivery, web analytics, hosting services, content delivery networks, marketing and performance data services, services to detect and prevent fraud, spam and abuse, electronic data and computing security services, session recording services as well as legal, financial and auditing advisors.

These third-party services access or receive aggregate data about or personal data of visitors, users and users of users. The data may include part or all of this personal data depending on the particular function the third party in question serves, and the third parties may only use the data for the purpose for which they are contracted.

We may disclose your personal information for any of the purposes mentioned above to any member of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries. This also includes entities which we may acquire as part of an acquisition at a future date.

We may also share your personal information in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims, if we have a good faith belief that the law requires us to do so, with or without notice to you.

Integration list

USE AND DISCLOSURE

Personal information will not be used or disclosed for purposes other than those specified to you, except:

Where required by law; or

To protect the interests of BlueStar against criminal activity, fraud, and material misrepresentation in connection with a contract.

RETENTION OF RECORDS

Keeping Personal Information only as long as it is necessary, including for the purposes of updating the product or services or as required by law. When the Personal Information is no longer required, it will be destroyed either by shredding or other approved destruction methods to prevent unauthorized parties from gaining access to the information during and after the process.

• You can of course choose to unsubscribe at any time via the unsubscribe link found in all our emails.
• You can ask us to delete your information. We can do this unless we are legally required to keep it.

SAFEGUARDING INFORMATION IN OUR CUSTODY

We have developed and will maintain security procedures to safeguard Personal Information against loss, theft, copying, and unauthorized disclosure, use, or modification. Access to Personal Information is restricted to employees and authorized service providers who need it to perform their work.

BlueStar uses industry-standard measures to safeguard the confidentiality of personally identifiable information, including encryption, firewalls and SSL (Secure Sockets Layer).

Data on payments and payment method details are subject to particularly stringent security measures and are handled by approved service providers that are compliant with the PCI (Payment Card Industry) standards and have appropriate safeguards setup.

BlueStar reviews the security procedures and evaluate appropriate new technology and methods on an ongoing basis. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly examine new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Customers’ privacy.

Should BlueStar experience a data breach and your information be involved, we will contact you if there is a risk of your data being misused and if we are legally obliged to do so. In some instances BlueStar will also be legally obliged to contact (data protection) authorities when a breach of private information occurs.

RIGHTS OF THE USER

Access to your information

• You have the right to have access to any personal information stored by BlueStar.
• You have the right to be informed of the nature and source of Personal Information that BlueStar has on its records concerning you.

Correction, Deletion or Blocking of your information

• You have the right to request the correction or deletion of inaccurate, incomplete, or obsolete information in your file. We can do this unless we are legally required to keep it.

BlueStar is committed to respond to all requests relating to privacy and data protection and will do so within thirty (30) days from the point of receipt. We will take appropriate action within the guidelines of the relevant legislation and based on requests that are valid, legal and reasonable.

Accordingly, if you wish to access, correct, amend, or delete inaccurate information collected, stored or processed by BlueStar please contact our internal GDPR team in writing by sending your request to: eu-gdpr@eu.bluestarinc.com.

OTHER CONTACTS

BlueStar’s Data Protection Officer

BlueStar has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:

BlueStar Europe Distribution BV

Att: Data Protection Officer

Koninginnegracht 19

2514 AB Den Haag

The Netherlands

mbaranera@eu.bluestarinc.com

Registration of a Privacy-Related Complaint

If you are not satisfied as to how we have handled your personal information please direct your complaint to the dedicated GDPR team by sending an email to eu-gdpr@eu.bluestarinc.com or the Data Protection Officer as identified above.

We will explain our complaints handling procedure and inform you of other complaint procedures that may be available to you.

If a complaint is justified, we will take appropriate action to resolve the situation and if necessary change our Policies, Procedures, or Practices.

General enquiries

If you have any questions or comments about BlueStar's Privacy Statement or Policies you may contact the internal GDPR team at eu-gdpr@eu.bluestarinc.com.