Services offered by SC Startleworks SRL are only commercial. All aspects related to data confidentiality and security are very important to our business, and are detailed below.

1. Contact Form / E-mail Contact / Telephone Calls

Purpose of data processing / Legal basis: The personal data you provide us by filling in the contact forms, by phone or by e-mail are treated confidentially. We use your data for the sole purpose of processing your request. The legal basis for data processing is art. 6 para. (1) lit. (f) of the GDPR. Our interest results from the desire to serve the interests and to respond to the requests of our customers and visitors of this website, thus obtaining and supporting customer satisfaction.

Recipients / Recipient categories: We categorically exclude the transmission of data to third parties outside Startleworks. Exceptionally, data is processed by data controllers at our request. They are carefully selected, are heard by us and also have a contractual obligation, according to art. 28 of the GDPR. Next, we may need to send excerpts from your request to our contractual partners (for example, suppliers, in the case of product-specific requests), in order to process your request. However, in these cases, the request is anonymized, so that third parties cannot make any connection between you and the request. If the transmission of personal information may be necessary, we will inform you about this and ask for your consent.

Storage time / Criteria for determining the storage time: All personal data you have provided to us in the requests (suggestions, appreciations or criticisms), through this website or by e-mail, are deleted by us no later than 90 days after the final answer given to you, respectively they are securely anonymized. Retention for a period of 90 days is explained by the fact that it is rare for you, as a customer, to contact us again in connection with a reply in the same regard, and we must be able to consult the previous correspondence. Experience has shown that, as a rule, after 90 days, there are no more questions about our answers.

2. Cookies Usage

On this web page, we use the so-called “cookies” (small files that a server sends to your computer), which manage the connection to our pages.

When visiting our page, they are sent from our web server to your device (PC, laptop, smartphone or tablet) and there they are saved in the internet browser used. The cookies to be used can perform different functions. The following subsections inform about the individual purposes of the different cookies that can be used.
You can set the browser so that it is informed about the placement of cookies. Thus, the use of cookies becomes transparent to you. In addition, you can set your browser to generally not accept cookies or refuse cookies from individual providers. However, we would like to inform you that, in certain circumstances, the functionality of this page may be affected.

2.1 Google Conversion Tool

Purpose of data processing / Legal basis: This website also uses the Google Conversion Tool for internal and anonymous analysis of the effectiveness of launched ads. If you browse another web page, on our website, a cookie is saved in your browser from the banner ad there. If the banner refers to an advertising campaign ordered by Google, Google saves the appropriate cookie if the banner is clicked. Neither our conversion partner nor Startleworks can identify what other web pages you’ve called. We do not collect or receive information with which we could personally identify the user. The information collected using Conversion Tracking is used exclusively to create statistics on the success and use of our campaigns. These cookies lose their validity after 30 days. The legal basis for this use of cookie technology is art. 6 para. (1) lit. (f) of the GDPR. If you do not want to participate in this analysis, you can disable the saving of cookies by setting in the browser.

2.2 Google Display Advertising

Purpose of data processing / legal basis: We use Google’s advertising technologies on our web pages. Cookies are used by us to recognize your computer on other web pages that are part of the Google display ad network, based on recorded data (visit our web page, including date and time, preferred and used language, browser type, system operating system) and to display advertisements tailored to your possible interests. The legal basis for this use of cookie technology is art. 6 para. (1) lit. (f) of the GDPR. With Google’s Ads Preferences Manager, you can see, remove, or add categories that show you interest-based advertising across the entire Google display ad network with this technology. With this tool, you can completely oppose the use of interest-based advertising cookies on the Google display ad network by downloading and installing the browser disable cookie reference for ad references.

2.3 Facebook Conversion Tracking Tool

Purpose of data processing / legal basis: On our websites, we use the “Facebook Conversion Pixel” and “Facebook Remarketing” services. With the help of Facebook Conversion Pixel, we can identify with Facebook if someone clicked on our Facebook ad and if it was directed to our page. We can’t see what other web pages you’ve called. The information collected using Facebook Conversion Pixel is used to create statistics on the success and use of our Facebook ads. We do not collect or receive information with which we could personally identify the user. Through Facebook re-marketing technology, users who have visited our web pages can be approached on Facebook web pages again through targeted advertising. We do not collect or receive information about who Facebook users are actually targeting. For us, it is not possible to identify individual users here. The legal basis for this data processing is art. 6 para. (1) lit. f) of the GDPR.

More detailed information about the purposes and level of collection and processing of your personal data through Facebook, as well as the setting possibilities for the protection of your privacy, within Facebook, can be found in the Facebook Data Use Policy. Through the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, and the European Interactive Digital Advertising Alliance in Europe, or through your device settings, you can turn off a display so that your interest-free online ads no longer appear. by Facebook or other participating businesses.

Recipients / Categories of recipients: With the help of Facebook Conversion Pixel, we can identify with Facebook if someone clicked on our Facebook ad and if it was directed to our page. The information generated by the module and / or graphics regarding the use of this page is transmitted to a Facebook server in the USA, where it is saved. Facebook uses the information thus obtained to evaluate your usage behavior with respect to ads on Facebook. If necessary, Facebook also transmits this information to third parties, if required by law or to the extent that third parties process this data on behalf of Facebook. The IP address is not associated with Facebook with other data saved by Facebook.

3. Encryption

We take technical and organizational security measures to protect the data as much as possible against unauthorized access. In addition to ensuring the operational environment, we use encryption methods. The information provided by you is transmitted and verified automatically, in encrypted form, using an SSL (Secure Socket Layer) protocol, to prevent the misuse of third party data. You may notice that your browser status bar contains the padlock symbol and that the address line starts with “https…”

4. Your rights 

According to art. 15 para. (1) of the GDPR, you have the right to obtain, on request, free of charge, information about your personal data, stored by Startleworks.
In addition, if there are legal requirements, you have the right to modify (art. 16 of the GDPR), to delete (art. 17 of the GDPR) and to limit (art. 18 of the GDPR) the processing of personal data .
To the extent that the data processing is based on art. 6 para. (1) lit. (e) or (f) of the GDPR, you have at your disposal a right of opposition, according to art. 21 of the GDPR. To the extent that you object to a data processing, it shall no longer be valid in the future, unless the controller demonstrates that he has compelling reasons justifying the processing and prevailing over the interests, rights and freedoms of the data subject.
If you agree to the data processing, you have a right to transfer the data, according to art. 20 of the GDPR.
To the extent that the data processing is based on a consent, according to art. 6 para. (1) lit. (a) or art. 9 para. (2) lit. (a) of the GDPR, it may be revoked at any time, with effect in the future, without prejudice to the lawfulness of the earlier processing.
In the above situations, if there are open questions or in the case of written or e-mail complaints, please contact us at contact@startleworks.com.
In addition, you have the right to lodge complaints with a data protection supervisory authority. The data protection supervisory authority of the country where the responsible person resides or is located shall be competent for this purpose.