At StarLeaf Limited (“StarLeaf” or “we” or “us”), we care about privacy, security and transparency; these are core tenets in our company’s mission. Toward that, this privacy notice tells you what to expect when StarLeaf collects personal information about you, including:

StarLeaf Limited holds registration number 066215999 with a registered address at 6th Floor, One London Wall, London, EC2Y 5EB, United Kingdom. The main websites for StarLeaf are https://starleaf.com and via StarLeaf Services Portal at https://portal.starleaf.com .

This privacy policy is effective as of 25 September 2020.

How StarLeaf collects data.

One of the purposes of this Privacy Notice is to explain how we collect and process personal data. The primary ways we collect information are as follows: (a) by visiting one of our websites; (b) by subscribing to our service through a partner, a reseller, or directly from StarLeaf (c) if you have been invited to attend a meeting using the StarLeaf service.

Please be informed that this website is not intended for children, defined as age 15 and under; we absolutely do not knowingly collect data from children and will immediately delete it if discovered.

We encourage you to read this Privacy Notice. It has been written to ensure you understand how we collect information, how it is safeguarded, what is collected, how it is processed, where it is processed, with whom we may share it, and your rights under the law.

Understanding who controls your data.

When you subscribe to StarLeaf services through a reseller or partner, we act as a Data Processor (“Processor”) under the instructions of the Data Controller. In this instance, all future requests or exercises of your rights must be made to the Controller.

When the StarLeaf service is used in the context of US healthcare, a Business Associate Agreement between StarLeaf and the Partner/Reseller is required. We use appropriate safeguards to prevent the use or disclosure of ePHI other than as provided for in the agreement. We use administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the electronic PHI that is created, received, maintained, or transmitted via the service on behalf of the subscribed Covered Entity or Business Associate.

When you share information with us directly by visiting our website, or when you subscribe to our service directly, StarLeaf acts as a Data Controller (“Controller”) according to the definitions in Article 4 of the GDPR. This Privacy Notice applies when we are acting as the Controller with respect to the personal data we process about you. In other words, where we determine the purpose and the means of the processing, we are identified as the Controller and we are responsible for controlling and safeguarding your personal data.

Toward that, we have assigned a Data Protection Officer (“DPO”) to superintend all aspects of this Privacy Notice, ensuring your questions are answered and your rights are respected. Whenever you have questions, you should contact the DPO via one of the venues below:

StarLeaf Limited

Rebekah Allendevaux, DPO

7 Hatters Ln, Croxley Park

Watford WD18 8YN

United Kingdom

Email: dpo@starleaf.com

Phone: +44 (0) 330 440 1847

StarLeaf’s lawful basis for processing your data.

StarLeaf will only process your data according to the allowance permitted by law. In most instances, we will only use your data in the following situations:

  • when you provide us with your consent to process your personal data which may be revoked by you at any time and for any reason;
  • when it may be necessary for our legitimate interest;
  • when we may need to respond to a legal requirement or regulatory action; and
  • where we need to fulfill our obligation to provide services when you subscribe to our services.

In the following table, we describe ways your personal information may be used; each of these uses are tied to a legal basis for processing. Further, we have also outlined wherever we have a legitimate interest to process your data where appropriate.

Processing Data

Personal Data

Lawful Basis

Requesting information and relationship management including emails to us, requests for marketing information, enquiries about services, responding to feedback, notifying you about changes to our terms and conditions, notifying you about changes to our Privacy Notice, sending you communication through out newsletters and news bulletins, asking you to update your contact information, communicating with you about our service.

Identity data, contact data, communication data, marketing preferences.

Article 6: (b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract. (c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations). (f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

Subscribing to StarLeaf cloud services.

Name, email address, regional settings, call detail records, account login credentials, conference data including meeting participants to scheduled conferences, media streams and recordings if employed, telephone numbers, contacts added to the StarLeaf app, connection history, public and private IPv4 addresses, network performance history, technical information about your device hardware and operating system, call diagnostics, instant messages, video and voice mails, organisation type and ID, last login and operating system, last active and connected date, scheduler used in the last 90 days (O365, Google, Outlook, Portal), userID, time zone, administrative flags, localisation.

Article 6: (b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

Service desk support for the cloud service.

If working with our service desk to troubleshoot an issue, we may also gather information about the type of computer systems you use, including associated devices such as microphones and video cameras as these are relevant to the services offered by StarLeaf. The information may also include your IP address, operating system, browser type, language preferences, and other relevant details to help StarLeaf ensure your service is working correctly.

Article 6: (b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

Website analytics.

Please be informed that we use a third-party analytics service called Google Analytics to collect, analyze and tally metrics regarding website visits. Analytics help us to determine many things, including the quantity of visitors over time, the geographic location from which visitors arrive, timeframes of high and low usage, the sites most frequented, the pages most frequented, and other helpful data. The Company processes data in ways to ensure individual identity is not stored, only anonymous metrics. Furthermore, it is forbidden for Google to determine, or attempt to determine, the identity of individuals visiting our websites, and this anonymity is inherited by StarLeaf.

Article 6: (a) Consent: the individual has given clear consent to process personal data for a specific purpose.

Understanding StarLeaf services.

This section applies to users of StarLeaf services. If you only use the StarLeaf public website, this section does not apply to you.

StarLeaf services are driven by an Internet-based communication platform designed to enable business users to communicate using messaging, video and voice calls. In this privacy notice, the word “Portal” means a secure website of the service configured to permit authorized users to view, add, remove and manage users. The person adding you for the first time to an organisation will provide certain information about you for provisioning, such as your name, company name, work email address and work telephone number. Using this information, we will provide you with a user ID (an email address) and account activation email to access the Service.

Wherever possible, the media associated with all StarLeaf originating or terminating audio and video communications (“calls”) is encrypted and cannot be accessed by any StarLeaf employees or partners or resellers. Calls are not monitored or recorded, except for videomail and voicemail messages explicitly recorded and saved using StarLeaf’s recording services. Videomail and voicemail messages cannot routinely be accessed by StarLeaf employees. Recordings saved using StarLeaf’s recording services products cannot, under any circumstances, be accessed by StarLeaf employees. Where you have given us your consent, we may monitor call metrics in order to investigate bugs and service issues. Call records will not be made available to anyone outside of StarLeaf without the prior consent of the organisation whose StarLeaf services account was used to originate the calls. StarLeaf may de-identify or depersonalize data into anonymized and aggregate data that it derives from customers (“Anonymous Data”). Anonymous Data means data that includes no personal data or unique identifiers that could later be used to refer to the personal data to which the data was once associated. StarLeaf uses only anonymous data in performing analytics and may disclose anonymous data to its customers who have requested such analyses and to third parties where we are contractually entitled to do so.

Information sharing and transborder flows.

StarLeaf respects your right to privacy and we do not use or share your personal information in any other way beyond what has been written in this Privacy Notice. For instance, we do not sell your information to anyone, including but not limited to third parties for their own marketing use.

As a Data Processor, StarLeaf is acting under the instructions of the Data Controller and may share your data with the Controller in support of your service. The Controller has administrative access to the StarLeaf portal and may access call detail records for the purpose of troubleshooting, diagnostics, capacity management, billing and reporting. It should be noted that the content of your video meetings is not shared with anyone, and this capability does not exist in the administrative portal.

We will inform you or your Data Controller if we are required to share your information under any of the following circumstances: (i) to the extent that we are required to do so by applicable law, by a governmental body or by a law enforcement agency, or for crime prevention purposes; (ii) in connection with any legal proceedings (including prospective legal proceedings); (iii) in order to establish or defend our legal rights; (iv) in the event that we buy or sell any business or assets, in which case we may disclose your personal data to the prospective sellers or buyer of such business or assets; or (v) if a third party acquires all (or substantially all) of our business and/or assets, we may disclose your personal information to that third party in connection with the acquisition.

Some of our external third parties are based outside the European Economic Area (EEA). In those cases, processing of your personal data will involve a transfer of data outside the EEA. A list of the external third parties may be viewed here.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by employing at least one (or more) of the following safeguards:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries .
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries . In these cases, due diligence of the legal system in the third country to which personal data will be transferred is carried out; the rules for disclosure to and access by government agencies is verified as is whether the service provider is bound by these laws. The likelihood that the service provider will be disclosing personal data of StarLeaf to the authorities in that third country is evaluated, including categories and volume of personal data transferred, purposes of the processing by the service provider, duration of data retention in the third country and any past practices of such disclosures. The service provider’s policies and procedures for:
    • notifying StarLeaf to the extent permitted by law, if a government demand extends to the exporter’s data;
    • providing an opportunity to resist production; and
    • complying with its obligation to notify StarLeaf that it can no longer comply with the requirements of the model contract clauses and cease processing the personal data in the event of any government demand that would not allow it in practice to comply with the contractual clauses.

StarLeaf will confirm, on the basis of the due diligence carried out, that the model contract clauses, in conjunction with any other applicable contractual terms for the relationship, are sufficient to address any issues raised as to the protection of personal data in the third country in that context or whether the circumstances require more specific terms.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Security, compliance and certification assurance.

At StarLeaf, we have a security and compliance team actively working to keep your information protected, auditing the security posture and improving safeguards from unauthorized access, accidental loss, disclosure or destruction. Toward this, we employ physical, technical, administrative, and organisational safeguards to protect the personal information we collect and process. Administrative and organisational policies and procedures are documented in the StarLeaf Information Security Management System (ISMS) where appropriate controls are designed to maintain an adequate level of data confidentiality, integrity and availability. We also test the StarLeaf continuity of operations plan supporting our services, including the core infrastructure and networking components distributed throughout our global data centers.

StarLeaf employs independent auditors to maintain ISO/IEC 27001:2013 certification through the BSI Group, and technical vulnerability scanning and penetration testing through Allendevaux & Company.

Your data protection rights.

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), if it is shown we have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c ) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the above rights, please contact us at infosec@starleaf.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

In exercising these rights, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data retention.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after ceasing to be a customer for taxation purposes. With respect to information you provide to us in relation to an application for a job, we may keep this information for up to twelve years to make the processes by which we evaluate and assess candidates more efficient. In some circumstances you can ask us to delete your data. In other cases, we may anonymise your personal data so that it can no longer be associated with you for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Future changes to this Privacy Notice.

As our services evolve, this Privacy Notice may change or other privacy notices may be written and posted specific to new offerings or to keep pace with data privacy laws. When changes are substantial, we will endeavour to make you aware of any forthcoming changes by attempting to contact you via our user interfaces, portals, or through your partner or reseller. If you have questions or comments on a future privacy policy, you may write us at infosec@starleaf.com.

Questions for StarLeaf.

If you have any questions about how we collect, store and use personal information, or if you have any other privacy-related questions, please contact us by email at infosec@starleaf.com.