StarTech.com Privacy Policy

Welcome to StarTech.com’s privacy policy ("Privacy Policy").

StarTech.com respects your privacy and is committed to protecting your personal data (as defined below). This Privacy Policy will inform you as to how we look after your personal data when you interact with us.

You can download a pdf version of the policy here: Privacy Policy. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.

This Privacy Policy aims to give you information on how StarTech.com collects, uses, discloses and otherwise processes your personal data through your access and use of our website at www.startech.com (the "Site"), including any data you may provide through this Site when you sign up for a customer account, purchase a StarTech.com product, subscribe to receive our newsletter, publications or marketing information, post comments, or interact with us through our customer service and technical advisory teams (including through use of our chat feature or by responding to customer feedback surveys). This Privacy Policy also describes how we collect and process your personal data when you access and use our community site hosted by an external service provider (including participation in our Idea Station and general polls, questions and forum discussions) at www.community.startech.com ("Community Site").

This Site is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

StarTech.com as a global enterprise is made up of different legal entities, including the following operating entities: StarTech.com Ltd., StarTech.com USA LLP, StarTech.com Limited, StarTech.com Japan K.K., StarTech.com (Hong Kong) Limited, StarTech.com New Zealand Limited, StarTech.com Australia PTY Limited and StarTech.com Mexico S. de R.L. de C.V. (collectively, the “StarTech.com Group”). This Privacy Policy is issued on behalf of the StarTech.com Group so when we mention "Company”, "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the StarTech.com Group responsible for processing your data. StarTech.com Ltd. as the parent company is the owner and responsible for this Site.

If you have any questions about this Privacy Policy or our privacy practices, please contact us in the following ways:

If you believe we may have infringed upon or violated your rights regarding your personal data, you may be entitled to file a complaint with the Office of the Privacy Commissioner of Canada under the Personal Information Protection and Electronics Documents Act (Canada) (often referred to as PIPEDA) (www.priv.gc.ca). Other regulators may also have oversight over our activities depending on where you are resident and where the processing of your data has taken place. We would, however, appreciate the chance to deal with your concerns before you approach a regulator so please contact us in the first instance.

We keep our Privacy Policy under regular review. This version was last updated on May 26, 2022. Historic versions can be obtained by contacting us at [email protected].

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This Site may include links to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or how they collect, use or disclose your personal data. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

"Personal data", or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, disclose, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name and last name and title;
• Contact Data includes billing address, delivery address, email address and telephone numbers;
• Financial Data includes payment card details collected through an external service provider that we have engaged;
• Transaction Data includes details of products and services you have purchased from us;
• Technical Data includes internet protocol ("IP") address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Site;
• Profile Data includes purchases or orders made by you, your interests, preferences, polls, product suggestions, feedback, comments, and survey responses. We do not collect passwords to StarTech.com or Community Sites as a means to profile our customers;
• Usage Data includes information about how you use our Site, products and services; and
• Marketing and Communications Data includes your preferences in receiving marketing material from us.

We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any "Special Categories of Personal Data" about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to complete the purchase and sale of StarTech.com products). In this case, we may have to cancel an order from you but we will notify you if this is the case at the time.

• Direct interactions.You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • create an account on our Site or create a login in order to access our Community Site;
  • purchase our products;
  • subscribe to our newsletter, publications or marketing information;
  • interact with us through our customer service and technical advisory teams (including through the Site chat feature or through recordings of our voice calls with you);
  • participate in our Site including participating in discussion topics, comments, polls, questions and forums;
  • participate in our Community Site including providing new product suggestions or responding to a new product poll, and participating in discussion topics, polls, questions and forums;
  • respond to us through a customer feedback survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties such as those listed in Section 11.2.
• Technical Data. From analytics providers such as Google.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• where we need to comply with a legal obligation; or
• with your consent, express or implied.

Please see the Glossary below and the definition of “lawful basis” to find out more about the types of lawful basis that we will rely on to process your personal data.

By accessing and using our Site and Community Site, we assume that you consent to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

We will get your consent before sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or using the unsubscribe mechanisms made available in such communications, as further described below in Sections 5.2 and 5.3 of this Privacy Policy.

We have set out below, in a table format, a description of the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

You may receive marketing communications from us if you have an existing business relationship with us (for example, you have purchased goods from us or you have a contract with us), or if you have expressly consented to receive those marketing materials.

You can ask us to stop sending you marketing messages at any time by following the “unsubscribe” links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, product experience or other transactions.

You can set your browser to refuse cookies that are not strictly necessary from our Site. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

We will only use your personal data for the purposes for which we collected it, unless, and only where permitted by applicable laws, we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.

We use contractual or other means to provide a comparable level of protection while the information is being processed by a third party. Measures in this regard may include: (i) requiring all third parties to respect the security of your personal data and to treat it in accordance with the law; or (ii) not allowing our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We share your personal data within the StarTech.com Group. Your personal data is stored and processed on servers located in Canada. If you correspond with us via email, your personal data may also be stored on servers located in the United States.

Some of our external third parties are based in the United States of America so their processing of your personal data will involve a transfer of data outside of Canada. Accordingly, your personal information may be subject to the laws of jurisdictions in which you are not resident, including laws regarding the disclosure of personal information to government authorities in such jurisdictions.

Whenever we transfer your personal data out of Canada, we ensure a similar degree of protection is afforded to it. This may include implementing various safeguards, such as the following:

• transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data under applicable laws; or
• where we use certain service providers, we may use specific contractual terms which give personal data the similar level of protection it has in Canada.

Please contact us if you want further information on the specific mechanisms that may be used by us when transferring your personal data out of Canada.

We endeavour to maintain physical, technical and administrative security measures to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and who are under an obligation to process your personal data on our instructions and a duty of confidentiality.

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

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law in Canada and the UK we may need to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. There are longer retention periods in other jurisdictions that may be applicable.

In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Subject to applicable laws and reasonable notice, your right to your personal data may include the following:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no lawful reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you reasonably believe it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data's accuracy;
• 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; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time  where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. 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 at [email protected].

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

For the purposes of Section 5, each lawful basis is defined as follows:

"Legitimate interest" means the interest of our business in conducting and managing our business to enable us to give you high quality products and service and a secure experience. We endeavour to consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

"Performance of contract" means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

"Comply with a legal obligation" means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Internal Third Parties

Other companies in the StarTech.com Group acting as joint controllers or processors and who are based Canada and the US providing functional services in the following areas: IT and system administration, human resources, supply chain, logistics, vendor management, finance and legal. Certain of these functions will also undertake leadership reporting to executive team members in Canada and the US.

External Third Parties

• Service providers acting as processors based in Canada and the US who provide IT and system administration services including services related to website and operating system architecture; third parties that collect and disseminate reviews and comments on our website; and third parties who host our Community Site.
• A service provider acting as a joint controller based in the US who providers an e-commerce credit card payment system.
• Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in Canada, the US, the UK, Japan, Hong Kong, Australia, New Zealand, Mexico and the Netherlands who provide consultancy, banking, legal, insurance and accounting services.
• Canada Revenue Agency, the Internal Revenue Service, HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in Canada, the US, the United Kingdom and various countries where StarTech.com products are sold who require reporting of processing activities in certain circumstances.