Privacy Policy

1.1. METHODS OF COLLECTION

In the general conduct of business, Star Projects London collects information relevant to the services being sought across the range of services it offers from:

• yourself

• next of kin/ spouse / partner / family member

• business associates

• Employers

• “trusted” sources including:

• Government / Land / Police registers

• Credit / Default Agencies

• Financial Institutes (Banks, Building Societies, Loan Agencies, Credit Card companies)

• Insurance Companies

• Health providers

• through consent to third parties disclosing information about you to us that they have collected

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Such information will generally be collected directly via email, or through a telephone conversation or face to face meeting with you.

In addition, you may choose to submit information directly to us via several methods, including:

• through Star Projects London website

• in response to marketing or other communications

• through social media

• by signing up for a Star Projects London service

• in connection with an actual or potential business or employment relationship with us.

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You may also agree to third parties disclosing information about you to us that those third parties have collected.

We, our service providers and partners may collect certain information by using automated means, such as cookies and web beacons, when you interact with our advertisements, mobile applications or visit our websites. The information we collect in this manner may include: IP address, browser type, operating system, referring URLs and information on actions taken or interaction with our digital assets.

We may use third-party web analytics services on our websites and mobile apps. The analytics providers that administer these services use technologies such as cookies and web beacons to help us analyse how visitors use our websites and apps.

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“Your Rights and Choices” section of this Privacy Notice specifies your ability, to opt out or limit the usage of the information collected.

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1.2. PURPOSES OF COLLECTION

Generally, we will collect, use and hold your information for the purposes of:

• Assessing the suitability of new potential clients for Star Projects London Ltd services

• Conducting business, developing relationships with Star Projects London Ltd and affiliates

• Process payments including: Accounting, Billing, Complaints and related dispute resolution activities

• Protect against and prevent fraud, unauthorised transactions, money laundering (please see below), tax evasion, claims, other liabilities and manage risk exposure and agent /franchise quality, integrity, compliance and security of business processes

• Provide, administer and communicate with you about Star Projects London Ltd services

• Compile business directories, including business contact information

• Operate, monitor, evaluate and improve our services, websites, mobile applications, other digital assets and business

• Managing communications, assess effectiveness and optimisation of advertising

• Functionality of our websites, mobile applications and other digital assets

• Evaluate your interest in employment and contact you regarding possible employment opportunities

• Enforce Star Projects London Ltd “Terms & Conditions of Use”, other legal rights as may be required by applicable laws and regulations or requested by any judicial process or governmental agency having or claiming jurisdiction over Star Projects London Ltd or its affiliates.

• Comply with industry standards and Star Projects London Ltd policies.

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ANTI-MONEY LAUNDERING

In addition to help you with a property related service we have to comply with certain regulations for example the “Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (referred to as “the Regulations).” Star Projects London Ltd are required to obtain certain information from you to comply with regulations. The information provided will only be used by Star Projects London Ltd in relation to complying with the Regulations and will not be shared with any other party outside of Star Projects London Ltd unless we are required to do so under law. If you decide to enter in to a business relationship with Star Projects London Ltd or any wholly owned subsidiary to comply with certain regulations.

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We will require two separate Identification documents one primary and one secondary document even if it appears on both lists. The information may be required at various stages of the process:

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Primary documents – proof of ID

• Valid Passport with MRZ

• Valid full UK photo driving licence

• Valid full UK Driving licence (Non photo, paper) issued before 1998

• Valid EU/EEA/Switzerland photo driving licence.

• Valid EU/EEA/Switzerland national Identity Card.

• Valid UK Armed Forces ID Card.

• Valid UK Biometric Residence Permit (copy of both sides.)

• Valid Blue disabled drivers pass. (With photo)

• Valid Freedom Pass

• Valid Local Authority Bus pass.

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Secondary documents – proof of residence (home.)

• Valid full UK photo driving licence.

• Valid full UK Driving licence (Non photo, paper) issued before 1998

• Local authority council tax bill (dated within the last 12 months).

• UK Bank / Building societies statements/bills showing activity, dated within the last six months. Including account number and sort code. (Internet printed acceptable.)

• UK mortgage statement (dated within the last 12 months.) (Internet printed acceptable.)

• Utility bill dated within the last 6 months including – Electricity bill (with MPAN number), Landline, Gas, Satellite TV, Water. (Internet printed acceptable.) (Not mobile phone bills.)

• Her Majesty’s Revenue and Customs (HMRC) Inland Revenue (IR) Coding / assessment / statement (dated within the last 12 months) with National Insurance number.

• Department for Works & Pensions letter confirming pension details and NI Number. (Dated within the last 12 months).

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We reserve the right to employ third party electronic verification for the purpose of verifying identity. This search will not affect your credit rating.

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1.3. LAWFUL BASIS OF PROCESSING

Star Projects London Ltd processes your information under the following

• Performance of a contract: where you enter into a contract with Star Projects London Ltd and we need to process your information as part of this contract

• Legitimate interests: some information is processed by Star Projects London Ltd as part of its legitimate interests which include: Fraud, risk assessment, due diligence, network and information security, suppressions and managing opting out of communications, profiling, direct marketing, monitoring, web analytics, cloud storage, acquisitions, updating customer details, lettings, sales, financial services and other core services provided by the data controller

• Public interest: some information is processed in accordance with public interest such as relocations

• Consent: where we process information under consent we will seek your clear and unambiguous consent prior to processing your data

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2. INFORMATION WE SHARE

We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Policy or as indicated via the consent process at the time the data is collected. We share the information we collect with, but not limited to:

• Landlords and landlord associates and sub processors

• Vetted affiliates and partners / Financial Institutions / Insurance Companies for business facilitation to provide required services, such as mortgages, insurance cover etc.

• Formally contracted service providers to perform services on our behalf:

• Hosting Datacentres, Infrastructure, Applications (Development / Support), Cloud Services (Software as a Service – SaaS, Platform as a Service – PaaS, Infrastructure as a Service – IaaS)

• Helpdesk, Call Centres etc. We contractually require these service providers to safeguard the privacy and security of personal information they process on our behalf and authorise them to use or disclose the information only as necessary to perform services on our behalf or comply with legal requirements

• Councils, health and care providers

• Other Law firms

• Credit agencies, Land Registry Office, Her Majesty’s Revenue and Customs (HMRC), Financial Conduct Authority (FCA) and other relevant regulatory bodies

• Additionally we may share information about you, if required legally, to prevent harm or financial / reputation loss, for investigation of suspected or actual fraudulent or illegal activities.

• Perspective employers requesting references via your written consent

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On websites, features can be accessed where we partner with other entities that are not affiliated with Star Projects London Ltd. These include social networking, geo-location tools etc. are operated by third parties (indicated appropriately) who may use or share personal information in accordance with their own privacy policies. It is recommended that you review the third parties’ privacy policies if you use the relevant features.

Star Projects London Ltd reserve the right to transfer your information in the event of a sale or transfer (wholly or partially) of our business or assets, with reasonable efforts for the acquirer to protect/ use your information consistent with our Global Privacy Notice. You can exercise your rights to contact the acquiring entity with questions concerning the protection and processing of your information.

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2.1 HOW LONG DO WE KEEP INFORMATION FOR

We will keep information for a reasonable amount of time in order to perform the purposes listed above.

We only keep your information for as long as necessary. We generally keep personal information for 7 years after last contact with you. However, Star Projects London Ltd reserves the right to keep information for longer if we feel that this is in the legitimate interests of Star Projects London Ltd.

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2.2 PROFILING

For the purposes of business conduct, enhancement, identification of fraud, money laundering and other potential un-authorised activities, Star Projects London Ltd engages profiling activities via direct use or anonymisation of sensitive personal information.

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2.2.1 DIRECT PROFILING

Direct profiling is engaged for the fair and lawful purposes, to provide Star Projects London Ltd the ability to enforce Star Projects London Ltd “Terms & Conditions of Use”, legal reporting as may be required by applicable laws, regulations, policies / standards or requested by any judicial process or governmental agency having or claiming jurisdiction over Star Projects London Ltd or its affiliates; including, but not limited to.

• Background checks for existing and new employees, clients, business partners, affiliates

• Financial Viability analysis / reports

• Business partner / client portfolio position, performance, risk positions

• Anti-money laundering

• Tax reporting

• Credit defaulting / exposure

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2.2.2 INDIRECT PROFILING

Indirect profiling via anonymisation of personal information is also used for preparing and furnishing aggregated data reports showing anonymised information, including, but not limited to, the following:

• Compilations, analyses, analytical and predictive models and rules, and other aggregated reports for the purpose of advising our partners / affiliates and servicing institutions, retailers and other customers regarding past and potential future patterns of service usage, spending, fraud, and other insights that may be extracted from this data.

• Compiling and communicating promotional and marketing information about services that Star Projects London Ltd, affiliates and other organisations that we have affiliations with have and that may be of interest to you.

• Conducting market research.

• Facilitating our internal business operations, including the fulfilment of any legal requirements.

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2.3 YOUR RIGHTS AND CHOICES

Your rights regarding the sensitive/ personal information we maintain about you enable you to exercise choices about what personal information we collect from you, how we use that information, and how we communicate with you.

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2.4 ACCESS AND CORRECTION

You may have the right to:

• obtain confirmation that we hold personal information about you

• request access to and receive information about the personal information we maintain about you

• receive copies of the personal information we maintain about you

The right to access personal information may be limited in some circumstances by local law requirements.

To exercise these rights, please contact us as set forth below.

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2.5 UPDATE AND CORRECT INACCURACIES IN YOUR PERSONAL INFORMATION

If you feel that the information we hold about you in incorrect or inaccurate you can contact us outlining the information you feel is incorrect of inaccurate

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2.6 OBJECT TO THE PROCESSING OF YOUR PERSONAL INFORMATION

If you would like to object to any processing of your information by Star Projects London Ltd you can contact us outlining what processing of information you would like to object to.

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2.7 HAVE THE INFORMATION BLOCKED, ANONYMISED OR DELETED

If you would like Star Projects London Ltd to delete, block or anonymise information we hold about you, you can contact us outlining what information you would like deleted, blocked or anonymised.

To update your preferences, ask us to remove your information from our mailing lists or submit a request to access, update, correct or delete your personal information, please contact us as specified in the “How To Contact Us” section below.

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2.8 OPTING OUT OF PROCESSING

You can opt out collection of personal information by automated means e.g. when visiting our website or visit third-party websites and interact with our adverts, by using the Cookie Consent tool displayed in the website (the browser you use may provide options on how to opt out of receiving certain types of cookies). However, without cookies you may not be able to use all of the website features and/or online services.

You can at any time tell us not to send you marketing communications by:

• e-mail hello@starprojects.london

• unsubscribing via the “unsubscribe link” within the marketing e-mails you receive from us, or

• contacting Star Projects London Ltd as indicated below.

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2.9 WITHDRAWAL OF CONSENT

If we obtain your information by consent you have the right to withdraw any consent you previously provided to us.

If we process your information under legitimate interest you can object at any time on legitimate grounds, to the processing of your personal information.

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3 How to Contact Us / Complaints and Feedback

If you:

• make a complaint about a breach of your personal information, applicable privacy laws/ principles or a concern about Star Projects London Ltd’s privacy practices

• would like access and/or update information or preferences you provided to us.

You also may e-mail us at:

Julia Starzyk
hello@starprojects.london

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©2021 Star Projects London Ltd