We know that the privacy of your personal information is important to you. We respect your privacy and are committed to maintaining the confidentiality and security of any personal data which we receive from you and retain on your behalf.

We are committed to responsible data management and comply with applicable data protection legislation. We apply industry best practices to protect the security of the data stored on our systems. We will collect, store and use your personal information only to support and enhance your relationship with us. We will not sell your personal information to anyone. We will not disclose your personal information to anyone outside the Starlings except as necessary to our trusted partners and suppliers to enable our to provide services to you.

1. Introduction and Scope

• This section provides an overview of the Starlings commitment to customer privacy and describes the scope of the privacy policy, including which services are covered (e.g., broadband, ILL, Wi-Fi, etc.).

• It also explains how this policy applies to both existing and potential customers.

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2. Information Collected

Starlings collects two main types of information:

Personally Identifiable Information (PII):

• Personal Information: Customer name, address, phone number, email address, billing information, etc.

• Account Details: Subscription plans, usage history, payment methods, and service preferences.

• Communications: Records of communications between the customer and Starlings, such as support tickets, phone calls, and emails.

Non-Personally Identifiable Information (Non-PII):

• Usage Data: Internet usage statistics, including browsing activity, data consumption, and bandwidth usage.

• Device Information: Information about the devices used to access the Starlings services, such as IP addresses, MAC addresses, browser types, operating systems, etc.

• Cookies and Tracking Technologies: Data gathered from cookies or other tracking mechanisms when customers interact with the Starlings website or services.

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3. Purpose of Collecting Data

The reasons for collecting personal and usage data, which may include:

• Service Delivery: To provide internet services, manage accounts, and deliver technical support.

• Billing and Payments: For billing, payment processing, invoicing, and subscription management.

• Service Improvement: To improve services, monitor usage patterns, and optimize the user experience.

• Marketing and Promotions: To send marketing materials, promotions, and offers based on customer preferences (if the customer opts in).

• Legal and Regulatory Compliance: To comply with legal requirements or respond to requests from law enforcement agencies.

• Security: To detect fraud, prevent cybercrime, and secure the customer’s connection.

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4. Data Retention

Starlings will specify the duration for which customer data is retained. Generally, this would depend on:

• Legal Requirements: Some data, like billing information, may need to be stored for a certain period for compliance with financial regulations.

• Service Requirements: Data related to service performance and troubleshooting may be retained for technical reasons.

• Starlings will also explain how and when customer data is deleted or anonymized after it is no longer needed.

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5. Data Sharing and Disclosure

• Third Parties: Starlings may share customer data with third-party service providers (e.g., payment processors, cloud storage providers, customer support services) to fulfill contractual obligations.

• Legal Compliance: Customer data may be shared with law enforcement agencies or government authorities if required by law or court order, or in the event of a legal dispute.

• Business Transfers: In the case of mergers, acquisitions, or business transfers, customer data may be transferred to the new entity, with the customer’s consent where applicable.

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6. Data Security Measures

The measures it takes to protect customer data, including:

• Encryption: Sensitive data, such as payment details, should be encrypted both in transit and at rest.

• Access Control: Only authorized personnel within the Starlings organization have access to sensitive customer data.

• Firewalls and Security Protocols: To prevent unauthorized access or data breaches.

• Regular Audits and Security Assessments: To assess vulnerabilities and ensure security practices are up to date.

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7. Customer Rights and Choices

• Access to Information: Customers have the right to access, modify, or update their personal information held by the Starlings.

• Opt-Out: Customers can opt-out of receiving marketing communications and promotional emails by following the Starlings unsubscribe process.

• Data Deletion: Customers may request the deletion of their data in accordance with the Starlings data retention policy, subject to legal and regulatory obligations.

• Cookies and Tracking Technologies: Customers can manage cookie preferences through their browser settings.

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8. Children’s Privacy

• Starlings typically include a disclaimer stating that their services are not intended for children under a certain age (often under 13 or 18), and they do not knowingly collect personal data from children.

• In case of the collection of personal data from children, parental consent is usually required.

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9. Cookies and Tracking

• Starlings will disclose the use of cookies or similar tracking technologies on its website or services.

• Cookies are used to collect non-personally identifiable information for the purposes of improving services, remembering user preferences, and analyzing site traffic.

• Customers may be given the option to accept or decline cookies.

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10. Changes to the Privacy Policy

• Starlings reserve the right to update or modify the privacy policy as required. Customers will be notified about significant changes, usually via email or notifications on the Starlings website.

• Customers may be asked to review and accept the updated privacy policy when they continue using the services after such changes.

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11. Contact Information

• Starlings will provide contact details for customers who have concerns, complaints, or queries regarding their privacy rights or data processing practices.

• Typically, a customer support team will handle such inquiries.