General information
The following information provides a simple overview of what happens to your personal data when you visit our website. Personal data is any data which can be used to personally identify you. Detailed information on the subject of data protection can be found in our data protection declaration listed below this text.

Data collection on our website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. You can find the operator’s contact details in the imprint of this website.
How do we collect your data?
On the one hand, your data is collected when you provide it to us. This may, for example, be data that you enter in a contact form.
Other data is collected automatically by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time of page view). This data is collected automatically as soon as you enter our website.
What do we use your data for?
Some of the data is collected to ensure that the website is provided without errors. Other data can be used to analyse your user behaviour.
Which rights do you have regarding your data?
You have the right to receive information about the origin, recipient and purpose of your stored personal data free of charge at any time. You also have the right to request the correction, blocking or deletion of this data. You can contact us at any time at the address given in the imprint if you have any further questions on the subject of data protection. You also have the right to lodge a complaint with the competent supervisory authority.
You also have the right to request the restriction of the processing of your personal data under certain circumstances. For details, please refer to the privacy policy under “Right to restriction of processing”.

Analysis tools and third-party tools
When you visit our website, your browsing behaviour may be statistically evaluated. This is mainly done using cookies and so-called analysis programs. The analysis of your browsing behaviour is usually anonymous; the browsing behaviour cannot be traced back to you and you can object to this analysis or prevent it by not using certain tools. You can find detailed information about these tools and your options for objecting in the following privacy policy.

2. Hosting and Content Delivery Networks (CDN)

External hosting
The following information provides a simple overview of what happens to your personal data when you visit our website. Personal data is any data that can be used to identify you personally. Detailed information on the subject of data protection can be found in our data protection declaration listed below this text.

This website is hosted by an external service provider (hoster). The personal data collected on this website is stored on the hoster’s servers. This may include IP addresses, contact requests, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.

The hoster is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f GDPR).

Our hoster will only process your data to the extent necessary to fulfill its performance obligations and follow our instructions with regard to this data.

Conclusion of a contract for order processing

In order to guarantee data protection-compliant processing, we have concluded an order processing contract with our hoster.

3 General notes and mandatory information

Data protection
The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
When you use this website, various personal data is collected.
Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.
We would like to point out that data transmission over the Internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information on the controller
The controller responsible for data processing on this website is:
STARLING FLEET HOLDING AG
Blegistrasse 1
CH-6343 Rotkreuz
Phone: +41 58 589 80 80
Email: kontakt@starlingfleet.com
The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).

Statutory data protection officer
We have appointed a data protection officer for our company.

Vanessa Egle
c/o officekomplett Informatik GmbH
Friedmattastrasse 5
CH-6260 Reiden

Phone: +41 58 589 80 80
E-mail: datenschutz@starlingfleet.com

Withdrawal of your consent to data processing
Many data processing operations are only possible with your express consent. You can withdraw your consent at any time. All you need to do is send us an informal e-mail. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to the collection of data in special cases and to direct marketing (Art. 21 GDPR)
If the data processing is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation; this also applies to an objection based on these provisions. The respective legal basis on which processing is based can be found in this privacy policy. Your data will no longer be processed after a revocation, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves the assertion, exercise or defense of legal claims. (objection pursuant to Art. 21 (1) GDPR).
If your personal data are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is associated with such direct marketing. If you object, your personal data will subsequently no longer be used for the purpose of direct marketing (objection pursuant to Art. 21 (2) GDPR).

Right of complaint to a supervisory authority
In the event of infringements of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to data portability
You have the right to have personal data which you have provided to us handed over to you in a structured, commonly and machine-readable format or transferred to another controller, provided that the processing is automated. A direct transfer of your personal data to another controller will only take place if this is technically feasible.

SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from
“https://” to “https://” and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by others.

Information, blocking, deletion and correction
You have the right to request information about your stored personal data, its origin and recipient and the purpose of the data processing and, if necessary, a right to correction, blocking or deletion of this data at any time within the framework of the applicable legal provisions at no charge. You can contact us at any time at the address given in the imprint if you have further questions on the subject of personal data.

Right to restriction of processing
You have the right to request the restriction of the processing of your personal data.
You can contact us at any time at the address given in the imprint. The right to restriction of processing exists in the following cases:

• If you dispute the accuracy of your personal data stored by us, we generally need time to check this. You have the right to request the restriction of the processing of your personal data for the duration of the review.
• If the processing of your personal data was/is carried out unlawfully, you can request the restriction of data processing instead of erasure.
• If we no longer need your personal data, but you need it for the exercise, defense or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
• If you have lodged an objection pursuant to Art. 21 (1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – apart from their storage – may only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or
legal person or for reasons of important public interest of the European Union or of a Member State.

Objection to advertising emails
We hereby object to the use of contact data published as part of our duty to provide an imprint for the purpose of sending unsolicited advertising and information material. The operators of this website expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.

4. Data collection on our website

Cookies
Some of the web pages use so-called cookies. Cookies do not damage your computer and do not contain viruses. Cookies are used to make our website more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and saved by your
browser.
Most of the cookies we use are so-called “session cookies”. They are automatically deleted at the end of your visit. Other cookies remain stored on your end device until you delete them. These cookies enable us to recognize your browser on your next visit.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.
Cookies that are required to carry out the electronic communication process or to provide certain functions that you have requested (e.g. shopping basket function) are stored on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the storage of cookies for the technically error-free and optimized provision of its services. Insofar as other cookies (e.g. cookies to analyze your surfing behavior) are stored, these are treated separately in this privacy policy.

Cookie consent with Borlabs Cookie
Our website uses the cookie consent technology of Borlabs Cookie to obtain your consent to the storage of certain cookies in your browser and to document this in compliance with data protection regulations. The provider of this technology is Borlabs – Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg, Germany (hereinafter referred to as Borlabs).

When you enter our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the revocation of these consents are stored. This data is not passed on to the provider of Borlabs Cookie.

The data collected will be stored until you ask us to delete it or delete the Borlabs cookie yourself or until the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. Details on data processing by Borlabs Cookie can be found at https://borlabs.io/kb/what-information-does-borlabs-cookie-store/

Borlabs cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 sentence 1 lit. c GDPR.

Server log files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are

• Browser type and browser version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server request
• IP address

This data is not merged with other data sources.
This data is collected on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – the server log files must be recorded for this purpose.

Inquiry by email, telephone or fax
If you contact us by email, telephone or fax, your inquiry, including all resulting personal data (name, inquiry), will be stored and processed by us for the purpose of processing your request. We will not pass on this data without your consent.
This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on your consent (Art. 6 para. 1 lit. a
GDPR) and / or on our legitimate interests (Art. 6 para. 1 lit. f GDPR), as we have a legitimate interest in the effective processing of the inquiries addressed to us.
The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

5. Analysis tools and advertising

Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and enable your use of the website to be analyzed. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
The storage of Google Analytics cookies and the use of this analysis tool are based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the analysis of user behavior in order to optimize both its website and its advertising.

IP anonymisation
We have activated the IP anonymisation function on this website. This means that your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information on behalf of the operator of this website for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Browser plugin
You can prevent the storage of cookies by selecting the appropriate settings in your browser software; however, please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

The purpose of reCAPTCHA is to check whether data is entered on this website (e.g. in a contact form) by a human or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, time spent on the website by the website visitor or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The reCAPTCHA analyses run completely in the background. Website visitors are not informed that an analysis is taking place.

The data is stored and analyzed on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its website from abusive automated spying and SPAM. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.

For more information about Google reCAPTCHA, please refer to the Google Privacy Policy and the Google Terms of Use at the following links: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en.

Order processing
We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Storage period
Data stored by Google at user and event level that is linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) is anonymized or deleted after 14 months. For details, please see the following link: https://support.google.com/analytics/answer/7667196?hl=en.

6. Plugins and tools

Google Web Fonts
This site uses so-called web fonts provided by Google for the uniform display of fonts. When you access a page, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.

For this purpose, the browser you are using must connect to Google’s servers. This provides Google with information that this website has been accessed via your IP address. The use of Google WebFonts is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the uniform presentation of the typeface on its website. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; consent can be revoked at any time.

If your browser does not support web fonts, a standard font will be used by your computer.

Further information about Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=en.

Google Maps
This site uses the Google Maps map service via an API. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

To use the functions of Google Maps, it is necessary to save your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transmission.

The use of Google Maps is in the interest of an appealing presentation of our online offers and to make it easy to find the places we indicate on the website. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR represent. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; consent can be revoked at any time.

You can find more information on the handling of user data in Google’s privacy policy: https://policies.google.com/privacy?hl=en.

7. eCommerce and payment providers

Processing of data (customer and contract data)
We collect, process and use personal data only insofar as it is necessary for the establishment, content or modification of the legal relationship (inventory data). This is done on the basis of Art. 6 para. 1 lit. b GDPR, which permits the processing of data for the performance of a contract or pre-contractual measures. We collect, process and use personal data about the use of this website (usage data) only insofar as this is necessary to enable or charge the user for the use of the service.

The customer data collected will be deleted after completion of the order or termination of the business relationship. Statutory retention periods remain unaffected.