Privacy Policy

Sterrayet LTD Privacy Policy

Introduction

At Sterrayet LTD, we are fully committed to safeguarding your personal information and maintaining transparency regarding its use. This document outlines our approach to data protection, ensuring compliance with the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018. We are transparent about the information we collect, the reasons for its collection, and how we intend to use it. This document highlights the methods through which we obtain, collect, process, and store your information, as well as any sharing practices with third parties and details of your rights.

Sterrayet LTD operates with fundamental principles regarding your data:

We never sell, rent, distribute, or publicly disclose your personal data. 

Data collection and processing occur only when absolutely necessary. 

We maintain a duty of care to safeguard this data. 

We ensure that the rights of data subjects are respected lawfully, fairly, and transparently.

Personal Data Collection – What personal data is collected?

Personal data, also referred to as personal information, includes any data about an individual that can be used to identify said person and is essential for Sterrayet LTD to deliver its services effectively to clients. 

We may process various types of Personal Data concerning website visitors and in connection with our services, including basic identifying information, contact details, professional information, and device identifiers. Additionally, our Website utilises cookies, facilitated by Google Analytics and HubSpot, to enhance user experience and optimise site performance; the cookies may record information such as your IP address, geographical location, details of the system you use and the potential pages you visit on Sterrayet's Website. Users have the option to opt out of cookie tracking on our Website.

Sterrayet LTD collects, uses, stores, and transfers various kinds of personal data, which can be acquired from Website visitors or may be required for the processing and delivery of our Services:

• A range of personal identifiers such as first and last names, usernames, gender and other types of Identity information.
• Billing addresses, delivery addresses, email addresses, telephone numbers and other types of Contact information.
• Bank account details, payment card information and other Financial information.
• Your job title, position, information about your organisation and other Professional information.
• Purchases and payments and other types of Transactional information for any of our services which you have acquired.
• IP addresses, browser details, device specifications and other types of Technical information.
• Usernames, purchase history, feedback, survey responses and other types of Profile information.
• Preferences regarding marketing communications and communication channels are also stored and processed.

Sterrayet LTD does not collect any Special Categories of Personal Data, including details related to race, ethnicity, religion, health, or criminal history. Additionally, we do not gather information on criminal convictions or offences.

Failure to provide necessary personal data required by law or contractual agreements may impact our ability to fulfil our obligations. If essential data is not provided, Sterrayet LTD may be unable to proceed with contracted services, potentially leading to the cancellation of products or services. However, users will be duly notified in such instances.

Data Management Responsibility – Who manages your information?

This Website is owned and maintained by Sterrayet LTD. All traffic between this Website and your browser is encrypted and delivered over HTTPS.

We utilise cloud computing applications such as HubSpot and Google Workspace, which may involve data storage outside the UK.

Sterrayet LTD is responsible for the collection and proper management of any personal information you submit. We keep your personal details secure and use the information you provide in accordance with applicable privacy and data protection laws and the terms outlined in this Privacy Policy.

Personal Data Processing - How do we receive your personal data?

We may collect or receive your Personal Data (Identity, Contact, Financial Data, etc) when certain actions, interactions or events happen, such as:

• Visiting and interacting with our Website. 
• Communicating with us via mail, telephone, email, or other methods. 
• Clicking on one of our advertisements, social media posts, or opening our emails.
• Completing forms on our Website.
• Applying for our products or services.
• Registering an account on our Website.
• Subscribing to our services or newsletters.
• Receiving it from other affiliates of Sterrayet LTD. 
• Requesting marketing materials or gated content.
• Providing feedback or contacting us.
• We obtain it from publicly available sources. 

Personal Data Processing – How will Sterrayet LTD use your information?

We may process your Personal Data based on various legal grounds, including:

• Consent: Your explicit consent allows us to process your Personal Data for specified purposes. You have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• Contractual Obligations: When entering into or performing a contract with you, we process the Personal Data necessary to fulfil our contractual obligations. Without this data, we may be unable to provide the agreed-upon services.
• Legitimate Interests: Processing may occur to serve our legitimate interests, such as marketing our Services, provided your rights and interests are not overridden. We carefully balance these interests to ensure fairness and transparency.
• Legal Obligations: Processing may be required to comply with applicable laws and regulations or fulfil legal obligations mandated by authorities.
• Other Grounds: We may process Personal Data based on other grounds as required or permitted by applicable law.

Your information may be utilised in several ways, including:

• Personalising Website Visits: Through tools like Google Analytics and HubSpot, we analyse website traffic and user behaviour to enhance user experience and provide tailored services.
• Form Submissions: Information submitted via website forms, including name and email address, is securely stored in our HubSpot CRM and used for specified purposes outlined in the form. Opt-in options for additional communications are available.
• Marketing Communications: If you opt-in, we may use your Personal Data to send Email Newsletters or Marketing Emails directly from our CRM system, HubSpot. You can unsubscribe at any time via the provided links or by contacting us.
• Contact Forms and Email Links: Data provided via contact forms or email links is directly entered into our HubSpot CRM system. Visitors are only contacted for marketing purposes after explicit consent is obtained. Opt-out options are available.
• Protection of Children's Privacy: Our Website is not intended for children under 16, and we do not knowingly collect information about them. If you believe we have inadvertently collected such information, please get in touch with us to facilitate its deletion.

Personal Data Processing – On what basis is your information processed?

Sterrayet LTD collects your personal data directly from our Website via email, online forms, and telephone. We maintain records of customers as contact and company records featuring information required to perform services, which falls under the lawful basis of legitimate interest (GDPR Article 6(f)) and being necessary for the performance of a contract (GDPR Article 6(b)).

Any personal data collected is processed entirely for the legitimate interest of maintaining contact between you (our customer or potential customer) and us to deliver our service and fulfil any existing contracts. We do not process any special category data within the meaning of GDPR.

We may process your Personal Data for the following purposes:

• Providing you with access to our Website: This involves facilitating access to our digital platform, enabling you to explore our offerings, access resources, and engage with our services. The lawful basis for this processing aligns with the necessity for contract performance, ensuring seamless interaction with our online platform as part of our service provision.
• Registering you as a new customer: When we register you as a new customer, we undertake contractual obligations to facilitate your engagement with our services. This processing activity is grounded in the execution of contractual duties, ensuring a smooth onboarding process for our clientele.
• Processing or delivering your order, including managing payments, fees, and charges: Essential for contract performance, this activity encompasses the processing and delivery of your orders placed through our platform. It also involves managing associated payments, fees, and charges. Furthermore, this processing is necessary for our legitimate interests, as it enables us to recover any owed debts related to the provided services.
• Managing and nurturing our relationship with you, encompassing notifications of policy changes and requesting reviews or surveys: This encompasses various aspects of customer relationship management, including communicating policy changes, seeking feedback through reviews or surveys, and addressing any inquiries or concerns you may have. It is essential for contract performance, ensuring effective communication and engagement with our clientele. Additionally, this processing activity is necessary to comply with legal obligations and supports our legitimate interests in maintaining updated records and understanding customer behaviour to enhance our services.
• Responding to your requests and questions: We are committed to addressing your queries and requests promptly and efficiently. This activity involves responding to inquiries, providing assistance, and offering relevant information as needed. It is essential for maintaining a positive customer experience and fostering trust and satisfaction. This processing aligns with our legitimate interests in ensuring customer satisfaction and engagement.
• Enforcing our legal obligations and complying with applicable laws and regulations: As a responsible data controller, we adhere to all relevant laws, regulations, and industry standards governing data protection and privacy. This includes enforcing legal obligations related to data processing and ensuring compliance with applicable laws and regulations. This processing activity is necessary to fulfil our legal obligations and safeguard user rights and interests.
• Administering or protecting our business and Website: This involves the administration and protection of our business operations and digital platform. It includes tasks such as troubleshooting, data analysis, system maintenance, and ensuring network security. This processing is necessary for our legitimate interests, as it supports the smooth functioning of our business operations and the provision of IT services. Additionally, it aligns with our legal obligations to safeguard user data and maintain a secure online environment.
• Delivering relevant website content and ads and assessing advertising effectiveness: This activity revolves around delivering tailored website content and advertisements to enhance user experience and evaluate the effectiveness of our marketing efforts. It is necessary for our legitimate interests, enabling us to understand customer preferences, improve our products/services, and refine our marketing strategies based on user interactions.
• Employing data analytics for website enhancement, product/service refinement, and customer experience improvement: This involves utilising data analytics to analyse user behaviour, enhance website functionality, refine products/services, and improve overall customer experience. It is essential for our legitimate interests, allowing us to define customer demographics, maintain website relevance, and inform business development strategies based on data-driven insights.
• To provide suggestions and recommendations on goods or services of potential interest: This entails offering personalised suggestions and recommendations to enhance customer engagement and satisfaction. It is essential for our legitimate interests in order to improve our products/services and foster business growth by catering to customer needs and preferences.

Data Retention – How long will Sterrayet LTD hold your information for?

Our retention policy ensures that your information is stored only for necessary purposes and to meet legal requirements. Once data is no longer needed, we securely dispose of it from our systems.

We retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including legal, regulatory, tax, accounting, or reporting requirements. Extended retention may occur in the event of a complaint or potential litigation related to our relationship with you. Factors considered in determining the appropriate retention period include:

• Volume, nature, and sensitivity of personal data.
• Risks associated with unauthorised use or disclosure.
• Purposes for data processing and alternative means to achieve them.
• Applicable legal, regulatory, tax, accounting, or reporting requirements.

Personal data is retained in compliance with legal, regulatory, tax, accounting, and reporting requirements. Extended retention periods may be necessary to satisfy these obligations, ensuring adherence to applicable laws and regulations. Additionally, we may anonymise your personal data for research or statistical purposes, ensuring it cannot be associated with you. Anonymised data may be used indefinitely for these purposes without further notice.

Under certain circumstances, you can request deletion of your data. Please refer to the legal rights section below for further information on exercising your rights.

Your Legal Rights – As the data subject, what are your rights?

As a Data Subject whose Personal Data we process, you have certain rights under applicable privacy laws. Your Rights Include:

1. Access Request: You can request access to your personal data, known as a "data subject access request." This allows you to obtain a copy of the personal data we hold about you and verify its lawfulness.
2. Data Correction: You have the right to request correction of any incomplete or inaccurate personal data we hold about you. We may need to verify the accuracy of the updated data.
3. Data Erasure: You can request deletion or removal of your personal data where there is no legal basis for continued processing, subject to certain exceptions.
4. Objection to Processing: You can object to the processing of your personal data based on legitimate interests or for direct marketing purposes. We may continue processing if we have compelling, legitimate grounds that override your rights.
5. Data Processing Restriction: You can request suspension of processing your personal data under specific circumstances, including verifying data accuracy, or pending legal claims:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. 

6. Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and transfer it to another data controller.
7. Withdrawal of Consent: You can withdraw your consent for processing personal data, though this does not affect the lawfulness of processing prior to withdrawal. If you withdraw your consent, we may be unable to provide you with certain products or services. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us. 
8. No Fee Requirement: You do not need to pay a fee to access your personal data or exercise your rights unless your request is unfounded, repetitive, or excessive, in which case we may refuse to comply with it.
9. Information Verification: We may request specific information to confirm your identity and ensure your right to access personal data.  We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10. Response Time: We aim to respond to all legitimate requests within one month. Complex requests or multiple inquiries may take longer, in which case we will notify you and keep you informed of any delays.

This policy applies only to Personal Data processed by Sterrayet LTD as a data controller. If you visit linked websites from our site, please review their privacy policies, as we are not responsible for their data practices.

Data Processing – Does Sterrayet LTD have any third-party processors?

We collaborate with carefully chosen third parties, including Google and HubSpot, ensuring compliance with relevant regulations and legislation. Both Google and HubSpot are located in the USA and adhere to EU-U.S Privacy Shield standards.

Sterrayet LTD is operating from the UK. There is no data transfer outside of the UK/EU (our CRM uses HubSpot's EU Data Center) except when our clients (you) request data transfers outside of the UK for third parties; or it is necessary to provide the services you have requested from us; or it is otherwise required or permitted by law.

Sometimes we may have to give our technical service providers, including processors and regulatory authorities in the United Kingdom, access to our information systems and the information stored on them, which may include your personal information. Depending on the circumstances, the people who get access to that information might be outside the UK and the European Economic Area. Despite potential locations outside the UK or the European Economic Area, access by these entities is governed by contracts adhering to UK data protection laws.

For further details on the mechanisms used to transfer your personal data out of the UK, please contact us.

Disclosures of Data – Does Sterrayet LTD ever share personal data?

Your personal data remains confidential and is not shared with external third parties beyond designated data processors. However, there are circumstances where we may disclose your information to third parties. For instance, in the event of a business sale or acquisition, your personal data may be shared with prospective buyers or sellers.

In cases where services we provide also involve working with additional, client-approved, third-party companies or services, it is the client's responsibility to review these third parties and their policies. We uphold stringent standards for data security and require all third parties to adhere to these standards. Our policy mandates that third-party service providers handle your personal data responsibly, strictly for the purposes specified by Sterrayet LTD, and in full compliance with legal requirements. They are prohibited from utilising your data for their own purposes, ensuring that your information remains protected and used only as instructed by us.

Consent Updates & Contact – When does Sterrayet LTD contact you in the future?

We would like to provide you with updates about our products, services, and offerings from chosen third parties. These communications may be delivered via postal mail, phone, email, or SMS unless you have opted out of receiving such communications. Before permitting third parties to contact you via email, we will seek your explicit consent.

Should you wish to modify your preferences regarding how we utilise your data for direct marketing purposes, kindly adjust your user preferences or contact us at customersupport@sterrayet.com

Data Breach – What happens if there is a data breach?

We have implemented procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

As per the GDP regulations, all data breaches will be reported to the ICO within 72 hours. This includes those of any 3rd parties where it is apparent that personal data stored has been compromised. 

Who can we contact if we have any queries about this policy or how our data is held? Please contact us if you have any questions about our privacy policy or information we hold about you. 

By email: customersupport@sterrayet.com

By phone: +447448176888

Or by post at Sterrayet LTD, 48 West George Street, 2nd Floor, Suite 2/3, Glasgow, G2 1BP 

Cookie Policy

Last updated: MAY 2024

Sterrayet LTD ("we", "us", or "our"") uses cookies on www.sterrayet.com (the "Service"). In compliance with the GDPR and Data Protection Act 2018, we seek your explicit consent for the use of cookies when you visit the service. This Cookie Policy explains how Sterrayet uses cookies and similar technologies to recognise you when you visit our Website, explaining what these technologies are and why we use them, as well as your rights to control our use of them. Please note that this cookie policy is subject to change and may undergo occasional modifications and updates from time to time, so it is advisable to revisit this page periodically.

Our Website may employ cookies or browser tracking technologies to distinguish you from other users and enhance your user experience. This data aids us in refining the site to cater to different browser types, operating systems, and visit frequencies. These methods do not collect personal information unless specifically consented to by the user. Aggregate cookie and tracking information will not be shared with any third parties. Our Cookies Policy delineates the nature of cookies, their usage, how third parties we may collaborate with utilise cookies on the Service, your choices regarding cookies, and additional information about them.

What are cookies?

A cookie is a small file containing a string of characters sent by a web server to your web browser upon visiting a website. It enables the site to recognise your browser upon return visits, storing user preferences and other relevant information. This feature streamlines user experience by saving time and notifying the web server of your return to specific pages. For instance, if you customise pages on our Website, cookies assist in retrieving your specific details during subsequent visits, facilitating the use of personalised features.

Cookies are categorised as ''first-party cookies'' when set by the website owner (in this instance, Sterrayet LTD) and as "third-party cookies" when set by other parties. Third-party cookies empower additional functionalities, like advertising, interactive content, and analytics. Those setting these cookies can identify your computer across visits to the Website in question and certain others. Cookies can either be "persistent" or "session" cookies. Persistent cookies remain stored by a web browser until their set expiry date, unless manually deleted before that date. Conversely, session cookies expire at the end of the user session upon closure of the web browser.

Typically, cookies do not contain information personally identifying a user. However, personal data stored about you may be linked to the information stored in and obtained from cookies.

What types of cookies do we use, and how do we use them?

• Authentication cookies - to identify you during website visits and navigation;
• Status cookies - to determine if you are logged into our Website;
• Personalisation cookies - to store your preferences and personalise our Website;
• Security cookies - as part of security measures to protect user accounts and our Website;
• Advertising cookies - to display relevant advertisements;
• Analysis cookies - to analyse website usage and performance; 
• Cookie consent - to store your preferences regarding cookie usage.

Our service providers may also use additional cookies, which may be stored on your computer when you visit our Website and over which we have no control. Through these cookies, they gather information to:

• Track your browsing activity across various websites.
• Create a profile reflecting your online behaviour.
• Deliver targeted advertisements tailored to your potential interests.

We use HubSpot to report and manage website activity. This service uses cookies to track activity across our site. You can view their privacy policy at https://legal.hubspot.com/privacy-policy. We also utilise Google Analytics to analyse website usage. Google Analytics collects information via cookies to create usage reports. Google's privacy policy is available at: https://www.google.com/policies/privacy/

Most browsers enable you to easily manage your cookies so that you can refuse or delete cookies. Each browser and its versions have different ways to manage cookies. For up-to-date information on blocking and deleting cookies, you can visit the browser's help and support pages or policy pages. The links below provide examples of where such policies and cookie customisations are found for different browsers.

Chrome: https://support.google.com/chrome/answer/95647?hl=en

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Safari: https://support.apple.com/en-is/guide/safari/sfri11471/16.0/mac/11.0

Opera: http://www.opera.com/help/tutorials/security/cookies/

Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

Blocking all cookies may diminish the usability of many websites. If you block cookies, you may not be able to utilise all features on our Website. For any queries about our cookie usage on our service, please contact us at customersupport@sterrayet.com