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Privacy Policy

This privacy policy (the “Privacy Policy”) governs the manner in which Starhome Mach S.a r.l., a private company and affiliated companies (“MACH”) collects, uses, maintains and discloses data collected from, customers and/or users (each, a “User” or “Users”) of its website www.mach.com (the “Website”) or the services provided on it (the “Services”).
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Compliance with Data Protection Law

MACH undertakes to do its best efforts to comply with the laws and regulations governing the processing of personal data, including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and any other national applicable laws or regulations governing the processing of personal data applicable to it.

MACH acts as data controller for data it collects from Users. MACH  has appointed a data protection officer which can be contacted by sending an email to privacy@tomiaglobal.com.

 

Personal Data collected by MACH through the Website and purpose of the processing

The Website is an informative site on which Users can browse to obtain information about MACH and the Services.

To that extent, the following personal data is collected:

Content of Users’ messages on the contact form: Users may contact MACH by various means, including through the contact form available on the Website, social networks, to request additional information, make a complaint, for example. The personal data collected depends on what information are provided by the User in the message box.

Identification and contact detail: When contacting MACH, Users may be asked to provide MACH (i) when using the contact form, with their full name, their email address, the name of the Company they are working in/with and the country they are located in and/or (ii) when using social network, their User name chosen on such social network and any other information the User decides to disclose.

Metadata: these elements correspond to the operations carried out on the Website, i.e. the data flows generated by User activity. In principle, this data is not used by MACH, whose Website is just the medium for the exchange of this data. However, some of these elements may be used by MACH to refine the profile of Users (for example, if the User is redirected to third party sites).

Technical data: These technical information includes browser type, language settings, country and time zone, ID and cookie settings, type of device used for connection, hardware model and operating system, unique identifiers or user ID, IP addresses and mobile network information, social network sharing, geolocation data. MACH never uses the precise GPS location of the User’s device except with the User’s explicit consent. This data is used to ensure optimal use of the Website and to customize the Website for each User (by offering the Website in mobile version if the connection came from a mobile phone).

 

Social networks

The personal data of Users collected in the context of the use of social networks may be processed by MACH, which has a legitimate interest in using them for marketing purposes and to improve its advertising materials and its image on the basis of the voluntary information transmitted or published by Users.

MACH is present on various social networks and acts as joint data controller with them for certain processing operations, in particular when the logo of the social network used appears on the Website.

For more information on the processing of personal data on the various social networks, Users may consult the following information notices in particular:

 

Facebook

Privacy policy: Facebook Privacy Explanation
Joint controller agreement and security measures: Facebook Legal Terms

 

LinkedIn

Privacy policy: Linkedin Privacy Policy

Other social networks may also be added at any time by MACH.

 

Web Cookies

MACH may use « cookies » to improve the User’s experience in regard of the Services. In that case, the User’s Internet navigator places cookies on his hard drive to gather a certain set of information used to customize the navigation in the framework of the Services, thus enabling certain unique functionalities. MACH also uses cookies to compile anonymous global statistics to understand the use of the Website by Users and to improve its structure and content.

Some cookies do not require the consent of Users because they are purely technical, and their use is in the legitimate interests of MACH. For others, MACH collects the consent of Users before collecting personal data about them via cookies.

For more information, including information on how long cookies are kept, Users may consult MACH’s cookie policy by clicking on the following link: Cookie Policy.

 

How MACH protects Personal Data

MACH has implemented appropriate technical and organizational security measures designed to protect the User personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable law.

The User is responsible for ensuring that any personal data that he/she send to us are sent securely.

 

Sharing of Personal Data

MACH does not sell, trade, or otherwise transfer to third parties Users’ personal data.

However each User accepts that his/her personal data can be transmitted which MACH’s group and to website hosting and editing partners and other sub-contractors who assist MACH in providing the Services, conducting its business, or servicing the User, so long as those sub-contractors undertake to process the personal data only according to MACH’s instructions and to comply with the applicable law regarding the protection of personal data.

MACH may also release User’s personal data when it believes that such release is necessary to comply with the law, enforce its websites’ general terms of use, or protect its or others’ rights, property, or safety.

However, Users’ non-personal data may be provided to third parties for marketing, advertising, or other uses.

MACH intends to transfer personal data outside the European Economic Area or to international organisation, only on the basis of:

adequacy decisions adopted by the European Commission (for more information, please refer to the European Commission website: EU Adequacy Decisions );

suitable Standard Contractual Clauses in accordance with Article 46 of the GDPR which are available at MACH’s office upon request addressed to MACH.Connects@mach.com

 

Data Retention

MACH takes all reasonable measures to ensure that personal data is processed for the minimum period necessary for the purposes set out in this Privacy Policy.

 

Acceptance of these terms

By using the Services or connecting to the dedicated MACH’s official pages on social networks, Users confirm that they are aware of the terms of this Privacy Policy and their acceptance of this Privacy Policy. If a User does not agree with this Privacy Policy, MACH recommends to such User that he shall not use the Services.

MACH has the discretion to update this Privacy Policy at any time. MACH will therefore revise the “last update date” at the bottom of this page. MACH encourages Users to frequently check this page for any changes. Users acknowledge and agree that it is their responsibility to review this Privacy Policy periodically and become aware of modifications. The continued use of the Services following the posting of changes to this Privacy Policy will be deemed as an acceptance of those changes.