Here at StarfieldConnects Ltd., we understand that your privacy is important to you and respect that you care about how your information is used and shared online.
1. About StarfieldConnects Ltd.
1.1. Our Site, https://www.starfield.ca, is owned and operated by StarfieldConnects Ltd., whose registered address is StarfieldConnects Ltd., 111 Nisbet Blvd., Waterdown, ON, L8B 0L4
1.2. Our data protection officer is Rodger King who can be contacted at firstname.lastname@example.org.
This Policy applies to your use of our Site and our Services. It does not extend to any websites that are linked to from our Site (whether we provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
3. The types of personal data we process
3.1. Name, passport number and other identifying information. For example, we may record your First Name (as it appears on passport), Last Name (as it appears on passport), Student No., AGE (at the time of travel), Birth Date, School name, Campus name, Telephone number, email address, street address, passport number, VISA number, medical insurance policy number,
3.2. Your contact details, such as your email address and telephone number.
3.3. Demographic information such as zip code, preferences and interests;
3.4. Information you choose to give us, such as your study abroad programme and city;
3.5. Information about your bookings with StarfieldConnects Ltd.. This information may include details about your trip, prices and the date of your booking. In addition, we may process information in relation to ancillary services and bookings through third-parties. We may also process details of travel arrangements you give us.
3.6. Our communications with you.
3.7. Cookies and similar technologies. When you use our website, we may automatically collect your IP address, web browser type and version and your operating system. We may also automatically collect a list of URLs starting with a referring Site, your activity on our Site, and the Site you exit to.
3.8. Financial information such as credit / debit card numbers via our Payment Service Provider (if you book a tour with StarfieldConnects Ltd.).
4. How we use your data
4.1. All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
4.2. We use your data to provide the best possible products and services to you. This may include:
4.2.1. Personalising and tailoring your experience on our Site;
4.2.2. Supplying our products and services to you;
4.2.3. Personalising and tailoring our products and services for you;
4.2.4. Personalising our marketing to you, such as via retargeting through Facebook Advertising and Google AdWords once you leave our Site;
4.2.5. Responding to communications from you;
4.2.6. Supplying you with email e.g. newsletters, alerts etc. that you have subscribed to. You may unsubscribe or opt-out at any time by updating your preferences in the footer of any email, or contacting email@example.com;
4.2.7. Market research;
4.2.8. Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience;
4.3. In some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you without your consent for us to be able to use such data.
4.4. With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone, text message, or post with information, news and offers on our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015. Additionally; we comply with the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA).
4.5. Under GDPR and PIPEDA we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a. you have given consent to the processing of your personal data for one or more specific purposes;
b. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c. processing is necessary for compliance with a legal obligation to which we are subject;
d. processing is necessary to protect the vital interests of you or of another natural person;
e. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
5. How and where we store your data
5.1. We only keep your data for as long as we need to in order to use it as described above in section 4, and/or for as long as we have your permission to keep it. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy:
5.2. We will retain customer information for as long as your account is active or as long as needed to provide you with our Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.
5.3. We will conduct an annual review to ascertain whether we need to keep the data.
5.4. We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so.
5.5. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information.
5.6. The servers of our booking software provider, TrekkSoft, are located in Europe (Zurich, Switzerland and AWS Europe). According to TrekkSoft’s GDPR processes, we can anonymize personal customer data (but not delete) when requested.
5.7. Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using our Site and submitting information to us. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage and the use of the EU-approved Model Contractual Arrangements.
5.8. Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Site.
5.9. Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting data via the internet.
6. Disclosing or sharing your data with third-parties
6.1. We may share your data with other companies in our group. This includes partner companies and our software provider, TrekkSoft AG.
6.2. We may contract with third parties to supply products and services to you on our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
6.3. We may compile statistics about the use of our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymized and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
6.4. In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.
6.5. If we expand or reduce our business this may involve the sale and/or the transfer of control of all or part of our business. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Policy, be permitted to use the data for the purposes for which it was originally collected by us.
7. How you can control your data
7.1. When you submit information via our Site, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details.
7.2. You can request a correction of the personal data we hold about you at any time. You can access your “Email preferences” in the footer of any email we send you to adjust these details. Or you can email us at firstname.lastname@example.org for a copy of your personal data. We can then make any corrections.
8. Your right to withhold information and your right to withdraw information after you have given it
8.1. You may access certain areas of our Site without providing any data at all. However, to use certain features and functions available on our Site or to book a tour with StarfieldConnects Ltd. you will be required to submit or allow for the collection of certain data.
8.3. You may withdraw your consent for us to use your personal data as set out in section 3 at any time by contacting us using the details set out in section 12, and we will delete Your data from our systems. However, you acknowledge this may limit our ability to provide the best possible products and services to you.
9. How you can access your data
You have the legal right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us for more details at email@example.com, or using the contact details below in section 12. You can also request that we delete your data, which we will do within one month.
10. Cookies and tracking technologies
10.2. Some of these cookies may be placed immediately when you first visit our Site and it may not be possible for us to obtain your prior consent.
10.3. You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
10.4. You can choose to delete Cookies at any time however you may lose any information that enables you to access our Site more quickly and efficiently including, but not limited to, login and personalization settings.
10.5. This website also uses analytical tools e.g. Hotjar to track user activity, page content, click/touch, movement, scroll, and keystroke activity (in some cases).
10.6. We also use Google Analytics, Google AdWords (Conversion Tracking), LinkedIn (Conversion Tracking), and Yahoo (Conversion Tracking). Some or all of these tools may be used to track information about your behavior on our website depending on your region. For more information or to opt-out, please visit the respective website(s) of these vendors or contact us at firstname.lastname@example.org.
11. Summary of your rights under GDPR
Under the GDPR, you have:
a. the right to request access to, deletion of or correction of, your personal data held by us;
b. the right to complain to a supervisory authority;
c. be informed of what data processing is taking place;7
d. the right to restrict processing;
e. the right to data portability;
f. object to processing of your personal data;
g. rights with respect to automated decision-making and profiling.
12. Contacting us