Start-ex Limited Privacy Policy


This is the Privacy Policy for Start-ex Limited, located at ADDRESS. Start-ex Limited will be referred to as "Start-ex Limited", "we", "our" and "us" in this Privacy Policy.

The Privacy Policy relates to how we collect, use, share and secure the personal information that you may supply to us. It also describes your choices regarding use, access and correction of your personal information.

We recognise the importance of protecting the privacy of information collected by us, in particular, information that is capable of identifying an individual ("personal information").

This Privacy Policy governs the manner in which your personal information will be dealt with. Start-ex Limited is the entity collecting and holding your personal information in accordance with this Privacy Policy. We reserve the right, at our discretion, to modify or remove portions of this Privacy Policy at any time.

Start-ex Limited is responsible for the processing of personal data that it receives under the COUNTRY Privacy Act ####, and other applicable international laws.

Please take a moment to read this Privacy Policy carefully. If you have any questions about this Privacy Policy, please contact us at privacypolicy@start-ex.com. You should review this Privacy Policy periodically so that you are updated on any changes.

Use of Website

By using this website, you agree to the Privacy Policy of Start-ex Limited, which is set out on this website page. This Privacy Policy is in addition to any other terms and conditions applicable to the website. This website may contain links to other websites not operated or controlled by us, and we do not make any representations about such third-party websites.

Collection of Information

We may collect personal information about you through your conduct on our website, via support services, email, telephone, any contact made by you through social media channels and through any other interaction you may have with us.

We collect and hold personal information about, but not limited to:

  1. users and potential users;
  2. business associates and potential business associates, and their employees and contractors (where applicable);
  3. individuals we deal with in the course of providing services to our users;
  4. suppliers and their employees and contractors;
  5. employees, prospective employees and contractors; and
  6. other people who come into contact with us.

We collect personal information about you in order for us to provide you with our services, for you to take full advantage of our services, and for us to conduct our business and meet our legal obligations.

Personal information is collected when provided by you, via the website, email, support, phone, social media, or any other interactions you may have with us. For example, we may need to collect such information to provide you with services or to answer or forward any requests or enquiries that you submit to us. Information we collect may include (but is not limited to): names, addresses, contact details, occupations, payment details, employment history, education and qualifications, testimonials, feedback and other information which assists us in conducting our business, providing and marketing our services, and meeting our legal obligations.

We may also obtain information from other sources and combine that with information we collect through our services. For example, we may collect information about you from third parties, including but not limited to social media platforms and publicly available sources.

Registration with the website is voluntary. Registration may include submitting (for instance, but not limited to) your name, email address, address, telephone numbers, and selecting an option to receive updates and promotional material and other information. You may view and edit this information at any time by logging in and going to your account.

We may also collect information about you as permitted by law.

In some cases, if personal information we request is not provided, it might adversely impact our ability to supply you with services or perform our obligations to you.

Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you Services when you do choose not to share certain information with us.

Collection and Use of Information Collected Automatically

We receive and store certain types of information automatically, such as whenever you interact with the sites or use our services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, device ID, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer) and your Internet Protocol (IP) address/MAC address/device identifier.

When you visit our website, our web servers gather your IP address to assist with the diagnosis of problems and to enable us to provide the best level of service.

We use cookies on our website to provide you with a better experience. These cookies allow us to increase your security by storing your session ID and are a way of monitoring single user access. This aggregate, non-personal information is collated and provided to us to assist in analysing the usage of the site.

Management of Personal Information

We strive to ensure the security, integrity and privacy of personal information submitted to us, and we regularly review and update our security measures in light of current technologies.

While no data transmission over the Internet can be guaranteed to be totally secure, we will endeavour to take all reasonable steps to ensure the security, on our systems, of the personal information you transmit to us via our online products and services.

In addition, our employees and the contractors who provide services related to our information systems are obliged to respect the confidentiality of any personal information held by us.

Use of Information

Unless we disclose other uses in this Privacy Policy or at the time of collection, personal information about you is used only for the purpose for which it is submitted or for such other secondary purposes that are related to the primary purpose. In general, the purposes for which your personal information is collected, used, held and disclosed are:

  1. to conduct our business;
  2. to provide you with our services and any other services you request;
  3. to market our services to you;
  4. to engage with third parties on your behalf;
  5. to communicate with you;
  6. to help us manage and enhance our services; and
  7. to comply with our legal obligations.

Copies of correspondence sent by you, or from the website that may contain your personal information, are stored as archives for record-keeping and back-up purposes only. All communication from us (including information with regards to new products and services) will provide you with an opportunity to opt out of further communication. You can choose to opt out at any time from receiving marketing communications.

We do not allow the selling of your personal information in any way.

Retention and Disclosure of Information

We take care to allow your personal information to be accessed only by those employees who require it in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it.

We may disclose your personal information:

  1. where you have consented;
  2. where disclosure is necessary to achieve the purpose for which the personal information was submitted; or
  3. when the law permits or requires disclosure.

We may also disclose your personal information in special situations where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering with (intentionally or unintentionally) our rights or property, users, or anyone else who could be harmed by such activities.

We may engage third parties to support our operations and/or provide you with services on our behalf. Where we deem it necessary we may disclose personal information held by us to these third parties.

We generally retain personal data for so long as it may be relevant to the purposes for which it was obtained. To dispose of personal data, we may anonymise it, delete it or take other appropriate steps.

Where we no longer require your personal information, we will comply with our legal requirements in respect of that information.

Access to Information

We will endeavour to take all reasonable steps to keep secure any information which we hold about you, and to keep this information accurate and up to date.

The majority of the information that we hold about you will be available for you to review by logging into your online account with us.

Subject to the exceptions set out in the Privacy Act 1993, you may seek access to the personal information that we hold about you. We will require you to verify your identity, and to specify what information you require. A fee may be charged for providing access. If a fee is to be charged, we will advise you of the likely cost in advance.

If, at any time, you discover that information held about you is incorrect, you may contact us to request to have the information corrected in accordance with the Privacy Act 1993.

Links to External Websites

We provide links to websites outside of our websites, as well as to third party websites. These linked sites are not under our control, and we cannot accept responsibility for the conduct of companies linked to our website. Before disclosing your personal information on any other website, we advise you to examine the terms and conditions of using that website and its privacy statement.

Legal bases for processing personal information

The laws in some jurisdictions require companies to tell you about the legal ground they rely on to process, use or disclose your personal data. To the extent those laws apply, our legal grounds are as follows:

  1. you consent to such processing;
  2. such processing is required to satisfy our legal obligations;
  3. such processing is necessary in order to carry out our obligations as part of any contracts we may have with you, or as part of negotiations before entering into a contract with you; or
  4. such processing is required in order for us to protect our property and rights, or the safety of Start-ex Limited, our users, contractors, or other affiliates.

Direct Marketing

If you are a current user, we will only contact you by electronic means (email or SMS) with information regarding any services which are similar or related to those in which you have previously expressed an interest, be that through transaction history or enquiry.

If you are a new user, we will only contact you by electronic means for marketing purposes if you have consented to receive such communications. Direct marketing includes any communications to you regarding advertising or the promotion of products and services. If you do not want to receive marketing communications, at any time and free of charge, you may use the opt-out link provided in any communication from us, or contact us at privacypolicy@start-ex.com.

Individual Rights

We believe that users should be treated equally no matter where they are, and so we are making the following options to control your data available to all users regardless of their location.

You can update certain information by logging into your account with us and accessing your account information and settings. You can also contact us at privacypolicy@start-ex.com so that we may consider your request under applicable law.

We encourage you to make any individual rights requests through our user support process (https://www.start-ex.com/Support) because this ensures that you have been authenticated already. Otherwise, when we receive an individual rights request via email we may take steps to verify your identity before complying with the request to protect your privacy and security.

Right to withdraw consent. You have the right to withdraw your consent to our processing of your personal information collected on the basis of your consent at any time. Pease note that withdrawing this consent does not affect the lawfulness of processing we may have undertaken prior to the withdrawal of consent. The withdrawal of consent will not affect the lawfulness of processing of information for which consent is not required.

Right of access to and rectification of your personal information. You have the right to request that we provide you with a copy of all personal information pertaining to you that we hold. This information will be provided without undue delay, unless such provision adversely affects the rights and freedoms of other users, contractors or affiliates of Start-ex Limited. If a fee is to be charged for this service, the full amount will be made known to you in advance. You may also request that we rectify any false personal information pertaining to you that we keep on record. Your right to access and rectification shall only be limited where the expense of providing such access becomes disproportionate to the risks to your privacy, or where the rights of other users, contractors or affiliates may be violated.

Right to erasure. You have the right to request that we erase personal information that pertains to you if that information:

  1. is no longer necessary in relation to the purposes for which it was collected;
  2. was collected in relation to processing to which you had previously consented, but later withdrew such consent; or
  3. was collected in relation to processing activities to which you object, and there are no legitimate overriding grounds for such activities.

If we have made your personal information public and are obliged to erase that information, we will take reasonable steps to inform relevant third parties that are processing your personal information that you have requested the erasure, including all links to, or copies or replications of, your personal information. The above is subject to limitations by relevant data protection laws.

Right to data portability. You have the right to request that we make available any personal information pertaining to you, which we obtained through a contract with you or based on your consent, in a structured, commonly-used and machine-readable format. You may also request that we transfer this information directly to another "controller" where technically feasible, unless the exercise of this right adversely affects the rights and freedoms of others. A "controller" is a natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of your personal information.

Right to restrict or object to processing. You have the right to restrict or object to us processing your personal information where one of the following applies:

  1. You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.
  2. The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.
  3. We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise, or defend legal claims.
  4. You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.

Restricted personal information shall only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.

Notification of erasure, rectification and restriction. We will communicate any rectification or erasure of your personal information or restriction of processing to each recipient to whom your personal information has been disclosed, if any, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request this information.

Right to object to processing. Where the processing of your personal information is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defence of legal claims, or for any other exceptions permitted by applicable law.

Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

Right to lodge a complaint. If you believe that we have infringed your rights, we encourage you to contact us first at dataprotection@start-ex.com so that we can try to resolve the issue or dispute. You can also complain about our processing of your personal information to the relevant data protection authority. If you are a resident of the European Economic Area, you can complain in the EU member state where you live or work, or in the place where the alleged breach of data protection law has taken place.

You can also complain to the COUNTRY Privacy Commissioner.

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Storage of your personal information. We will try to limit the storage of your personal information to the extent that storage is necessary to serve the purpose(s) for which the personal information was processed, to resolve disputes, enforce our agreements, and as required or permitted by law.

Data Protection Officer. You may reach the Start-ex Limited Data Protection Officer at dataprotection@start-ex.com.

Your rights to personal information. Your rights to personal information are not absolute. Access may be denied when:

  1. Denial of access is required or authorised by law;
  2. Granting access would have a negative impact on other's privacy;
  3. To protect our rights and properties; and
  4. Where the request is deemed frivolous or vexatious.

Problems or Questions

If we become aware of any ongoing concerns or problems with our websites, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our Privacy Policy, please contact us in writing at privacypolicy@start-ex.com.