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 with which you can be personally identified. Detailed information on the subject of data protection can be found in our privacy policy 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 their 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 include, for example, data that you enter into a contact form. Other data is collected automatically by our IT systems when you visit the website. This mainly includes technical data (e.g. internet browser, operating system, or time of page access). 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 the error-free provision of the website. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?
You have the right at any time to receive free information about the origin, recipient, and purpose of your stored personal data. You also have the right to request the correction, blocking, or deletion of this data. For this purpose and for further questions on the subject of data protection, you can contact us at any time using the address provided in the imprint. Furthermore, you have the right to lodge a complaint with the competent supervisory authority. In addition, you have the right, under certain circumstances, to request the restriction of the processing of your personal data. Details can be found in the privacy policy under “Right to Restriction of Processing”.

Analysis Tools and Third-Party Tools
When you visit our website, your surfing behavior may be statistically evaluated. This is done primarily using cookies and so-called analysis programs. The analysis of your surfing behavior is usually anonymous; the surfing behavior cannot be traced back to you. You can object to this analysis or prevent it by not using certain tools. Detailed information about these tools and your objection options can be found 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 with which you can be personally identified. Detailed information on the subject of data protection can be found in our privacy policy listed below this text.

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

The use of the host is for the purpose of fulfilling contracts 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 offering by a professional provider (Art. 6 para. 1 lit. f GDPR).

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

Conclusion of a Data Processing Agreement
To ensure data protection-compliant processing, we have concluded a data processing agreement with our host.

3. General Information and Mandatory Information

Data Protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy. When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. 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 point out that data transmission over the Internet (e.g. communication by email) may have security gaps. Complete protection of data against access by third parties is not possible.

Information on the Responsible Entity
The controller responsible for data processing on this website is:

STARLING FLEET HOLDING AG
Blegistrasse 1
6343 Rotkreuz
Switzerland
Phone: +41 58 589 80 80
Email: contact@starlingfleet.com

The responsible entity is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).

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

Vanessa Egle
Email: datenschutz@starlingfleet.com

Revocation of Your Consent to Data Processing
Many data processing operations are only possible with your explicit consent. You may revoke consent already given at any time. An informal email to us is sufficient. The legality of the data processing carried out up to the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Advertising (Art. 21 GDPR)
If data processing is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR, you have the right at any time to object to the processing of your personal data for reasons arising from your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this privacy policy. If you object, we will no longer process your affected personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves the assertion, exercise, or defense of legal claims (objection pursuant to Art. 21 para. 1 GDPR). If your personal data is processed for direct advertising purposes, you have the right to object at any time to the processing of personal data concerning you for such advertising; this also applies to profiling insofar as it is associated with such direct advertising. If you object, your personal data will no longer be used for direct advertising purposes (objection pursuant to Art. 21 para. 2 GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority
In the event of violations 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 the place of the alleged infringement. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Right to Data Portability
You have the right to receive data that we process automatically on the basis of your consent or in fulfillment of a contract, in a commonly used, machine-readable format, and to have it handed over to you or to a third party. If you request the direct transfer of the data to another controller, this will only be done insofar as it 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 “http://” 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 third parties.

Information, Blocking, Deletion, and Correction
Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of data processing and, if applicable, a right to correction, blocking, or deletion of this data. For this purpose and for further questions on the subject of personal data, you can contact us at any time using the address provided in the imprint.

Right to Restriction of Processing
You have the right to request the restriction of the processing of your personal data. For this purpose, you can contact us at any time using the address provided 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 usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
• If the processing of your personal data was/is unlawful, you may request the restriction of data processing instead of deletion.
• If we no longer need your personal data, but you need it to exercise, defend, or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
• If you have lodged an objection pursuant to Art. 21 para. 1 GDPR, a balancing of your and our interests must be carried out. 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, this data – apart from being stored – may only be processed with your consent or for the assertion, 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 a Member State.

Objection to Advertising Emails
The use of contact data published within the scope of the imprint obligation for the transmission of advertising and information material not expressly requested is hereby objected to. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam emails.

4. Data Collection on our Website

Cookies
Some of the websites use so-called cookies. Cookies do not cause any damage to your computer and do not contain viruses. Cookies serve to make our offering 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 after 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 configure 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 limited. Cookies that are required to carry out the electronic communication process or to provide certain functions requested by you (e.g. shopping cart function) are stored on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in storing cookies for the technically error-free and optimized provision of its services. If other cookies (e.g. cookies for analyzing your surfing behavior) are stored, they 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 for the storage of certain cookies in your browser and to document this in a data protection-compliant manner. The provider of this technology is Borlabs – Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg (hereinafter 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 collected data is stored until you request us to delete it or delete the Borlabs cookie yourself or the purpose for data storage 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/

The use of Borlabs cookie consent technology is to obtain the legally required consents 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 include:

• 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.
The collection of this data is based on 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 – for this purpose, server log files must be collected.

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 handling your request. We do not pass this data on without your consent. The processing of this data is based on Art. 6 para. 1 lit. b GDPR, provided your inquiry is related to the fulfillment of a contract or is required to carry out 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 inquiries addressed to us. The data you send to us via contact inquiries remains with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage 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 an analysis of your use of the website. 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 analyzing user behavior in order to optimize both its web offering and its advertising.

IP Anonymisation
We have activated the IP anonymization function on this website. As a result, your IP address is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before transmission to the USA. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website usage and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics is not merged with other Google data.

Browser Plugin
You can prevent the storage of cookies by setting your browser software accordingly; however, we point out that in this case you may not be able to use all functions of this website to their full extent. You can also prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser plugin 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 verify whether data entry on this website (e.g. in a contact form) is carried out by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior 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, length of stay of 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 storage and analysis of the data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its web offerings from abusive automated spying and from 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 on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

Further information on Google reCAPTCHA can be found in Google’s privacy policy and Google’s terms of use at the following links:
https://policies.google.com/privacy?hl=en
https://policies.google.com/terms?hl=en.

Objection to Data Collection
You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set that prevents the collection of your data during future visits to this website: Disable Google Analytics. More information on how Google Analytics handles user data can be found in Google’s privacy policy:

Order Processing Agreement
We have concluded a data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Storage period
User- and event-level data stored by Google that is linked to cookies, user identifiers (e.g. User ID), or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) is anonymized or deleted after 14 months. Details can be found at the following link: https://support.google.com/analytics/answer/7667196?hl=en.

Google Tag Manager
This website uses Google Tag Manager, which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Tag Manager is a tool that allows tracking or statistics tools and other technologies to be integrated into this website. Google Tag Manager itself does not create user profiles, does not store cookies, and does not carry out independent analyses. It serves to manage and deploy the tools integrated through it. It collects your IP address, which is transmitted to Google’s parent company in the United States.

Legal basis for data processing:
The legal basis for data processing is Art. 6 para. 1 lit. f GDPR. 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 on the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

LinkedIn Insight Tag
Our website uses the LinkedIn Insight Tag. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. By using the LinkedIn Insight Tag, we collect information about visitors to our website. If a visitor is logged into LinkedIn, this enables us to analyze the professional details (such as career level, company size, country, location, industry, and job title) of our visitors in order to better tailor our site to the respective target groups. In addition, we can use the LinkedIn Insight Tag to measure whether visitors to our website make a purchase or perform another desired action (conversion tracking). This measurement can also be carried out across devices, e.g. from a PC to a tablet. The LinkedIn Insight Tag also offers a retargeting function that allows us to display targeted advertising to visitors to our website outside of the website. According to LinkedIn, no identification of advertising recipients takes place.

LinkedIn also collects so-called log files that contain information such as URL, referrer URL, IP address, device and browser characteristics, and time of access. The IP addresses are either shortened or (if used to identify LinkedIn members across devices) pseudonymized. LinkedIn deletes the direct identifiers of members after seven days. The remaining pseudonymized data is deleted within 180 days.

The data collected by LinkedIn cannot be assigned to individual persons by us as the website operator. LinkedIn stores the collected personal data of website visitors on its servers in the USA and uses it as part of its own advertising measures. Further details can be found in LinkedIn’s privacy policy:
https://www.linkedin.com/legal/privacy-policy#choices-oblig

Legal Basis
The use of the service is based exclusively on your consent.

6. Plugins and Tools

WPML (Multilingual Plugin)
We use the multilingual plugin WPML by OnTheGoSystems Limited, 22/F 3 Lockhart Road, Wanchai, Hong Kong, to provide our website in multiple languages.

WPML sets cookies to store the language you have selected and to deliver our website in the corresponding language version. Without these cookies, multilingual use of our website would not be possible. In this process, technical data such as IP address, device and browser information, and usage data (e.g. pages visited) may be processed. The legal basis for the use of WPML is Art. 6 para. 1 lit. f GDPR (legitimate interest) in conjunction with § 25 para. 2 TTDSG (technically necessary cookies). Our legitimate interest lies in ensuring a user-friendly and linguistically correct presentation of our website. Further information on the cookies used by WPML and on data processing can be found here: https://wpml.org/documentation/privacy-policy-and-gdpr-compliance

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 MapsThis site uses the Google Maps mapping 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 store your IP address. This information is usually transmitted 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 attractive presentation of our online offerings and easy findability of the locations specified by us on the website. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

More information on how Google handles user data can be found 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 to the extent necessary to establish, define the content of, or modify 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 fulfillment of a contract or pre-contractual measures. We collect, process, and use personal data regarding the use of this website (usage data) only to the extent necessary to enable the user to use the service or to bill for it.

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