OVERVIEW
Starcount is a data company who has built a proprietary dataset for the marketing & advertising industry. We and our clients & partners use this data to understand groups of individuals through their interests and behaviours with the aim to ensure that the marketing you see is more relevant through targeting and content optimisation.
This privacy policy provides the details of the Starcount business; the data that we collect; the purpose for this data collection and what your individual rights are with respect to any Personal Data that Starcount may hold on you. Our data falls into two categories;
- Starcount Data – the data we license to improve marketing.
- Business Data – our data of potential and active clients & partners.
Starcount is committed to being transparent about its processes, the data it interacts with and ensuring that the legal rights of individuals are respected and protected. We appreciate that the nature of our business and the legal rights of individuals are complicated topics and that you may have additional questions. If you want to contact us, please email privacy@starcount.com.
Any data we collect is processed in accordance with privacy laws, including GDPR. We advise you to check back with this page from time to time, as we may make changes in accordance with legal requirements.
By using our services and visiting our website, you accept and consent to the terms in this Privacy Policy.
FOR INDIVIDUALS: STARCOUNT DATA
What does Starcount do?
Starcount has created a proprietary data set that shows what customers care about so brands can understand why they buy. We have done this by looking at behaviours across social, demographic and spend data. We analyse these data sources to find individuals that have similar behaviours and group them into audience segments for targeting in omnichannel media.
This way brands can connect with customers and their emotional drivers of purchasing behaviour; creating better and more relevant marketing and improving brand relationships and loyalty.
What is the purpose of Starcount’s Data?
Starcount allows our clients to understand, retain and acquire customers through an understanding of what they care about – their Mindsets and Interests. Our data is used for insight and targeting. The primary use cases include the ability to:
- Understand existing customers or new potential markets.
- Enrich CRM marketing through tailored and relevant messaging or experiences.
- Improve targeting through postcode data in offline channels such as OOH, Mail and local marketing.
- Improving targeting in online channels through audience activation.
- Measuring the effectiveness of advertising through uplifted activity in targeted geos.
Starcount’s clients and partners are contractually obliged to have adequate privacy policies which also facilitate these purposes.Our clients include brands, consultancies, media agencies and media owners.
What data is collected to produce Starcount Data?
In order to create our Services, we license datasets from a number of well-known reputable data suppliers. These suppliers obtain information from individuals who have given these suppliers permission to share this information with other organisations for these purposes.
Our data sources include, but are not limited to:
Twitter: We source publicly available information about Twitter Users and the accounts they follow.
Open Banking Data: We source UK spend data and the categories and brands that are shopped in by different postcodes.
Demographic & Lifestyle Data: We source UK demographic and lifestyle information on individuals through a UK geodemographic provider.
Identity Linking: We work with an identity link partner who has consent to enrich individuals with volunteered identifiers.
Customer Data: Sometimes our clients send us information about their customers, prospects, subscribers, etc. to make our services relevant to them and their customers.
The information we receive in these datasets can include postcodes, hashed email addresses, social handles, demographic data, lifestyle data, publicly available social data and banking transaction data (eg. category spend, retail purchases, enquiries).
We have contractual agreements with all these data sources and suppliers who have confirmed our use case against their privacy policies.
When we receive personal data from clients, or it is contained in the data we license, we will always ensure the organisations who send it to us have the right to let us store and process it for the purposes agreed with the providers.
We don’t really like holding personal information so we will always limit it to the very minimum required to deliver our services; also, due to the nature of our data services, we are able to anonymise much of the personal data we receive and use encryption, hashing and aggregation wherever possible.
What information does Starcount Data hold on individuals?
Starcount Data is a data set that describes audience segments based on finding individuals that have similar behaviours. All output data supplied by Starcount to our clients & partners is aggregated audience behaviour and we never share a profile of an individual.
To build Starcount Data, we license data on individuals which is pseudonymised on entering Starcount’s system. The pseudonymised profile information is aggregated and then organised in to audience segments that fall into categories of interest data (e.g. interest in sports, beauty, fashion etc.), demographic data (e.g. age, gender, geography, lifestage, income band etc.) and purchase data (e.g. shops in electronics, restaurants, online fashion etc.). We never create these categories at an individual level – individual data will be aggregated together to create a group that describes people with similar characteristics.
Starcount does not directly collect any Personal Data such as full name, email address, physical address or any other identifier that would allow us to recognise an individual or contact them. Starcount does receive personal data from third parties which we immediately pseudonymise and aggregate to postcode level, with the original data being destroyed.
In addition, we do not collect or infer data that we consider to be sensitive. The definition of Sensitive Data within the EU (as defined by Article 9.1 of the General Data protection Regulation or “GDPR”) includes:
- Racial or ethnic origin
- Political opinions
- Religious or philosophical beliefs
- Trade union membership
- Genetic or biometric data
- Personal health data
- Sexual orientation
- Financial vulnerability
For information relating to our age data policies, please refer to the Protecting Children’s Data section of this policy below.
What is Starcount Data used for?
Starcount’s data is designed to enable organisations and brands to understand customers and discover new audiences, with the aim to improve the customer experience or marketing by making it more relevant. The Starcount Data helps advertisers find audiences who have behaviours and interests which are similar to their existing customers or their desired audiences.
Starcount Data is licensed to brands, organisations and agencies who act on behalf of organisations for strategy, insight, marketing and advertising purposes.
For some brands, we also work on their Customer Data as we provide a wide range of insight services to clients, typically using the data they have sent us. We might also enrich their Customer Data with our Starcount Data. All work we undertake for clients is done at their instruction and is founded on the rights they have obtained or established to use your information. The data we receive and process from each client is used solely in helping that specific client and the results of our analysis and recommendations are shared solely with the client for which they were performed.
What is Starcount’s legal basis for processing Starcount Data?
The legal basis for processing Starcount Data is legitimate interest; to trade as a business; to deliver services to organisations to better understand their customers and audiences; with the intention to deliver these services to benefit individuals in receiving relevant customer experiences and marketing.
We have conducted the required tests to process Starcount Data under legitimate interest.
To do this we have:
- identified a legitimate interest for Starcount to trade as a business;
- shown that the processing is necessary to achieve it;
- balanced our interest against individual’s rights and freedoms.
If you would like to understand the logic and results of this test, please contact us on privacy@starcount.com.
If we received your data from one of our clients, we act as the data processor in this scenario and the legal basis for us to receive, store & process your data will be inherited from the client from which it was received.
How long does Starcount store Starcount Data for?
We retain our data for as long as we have an active relationship with our data source partners or clients, unless otherwise specified, or until it is deleted following a request from the subject of the data.
We have processes in place to ensure that we keep our data up-to-date and reflect any changes from our data sources. Most data is refreshed monthly and all data is refreshed annually. For example, if an individual requests for their data to be removed from one of our data sources, this is communicated with us and updated in the Starcount Data.
For avoidance of doubt, we never keep your data without an active contract to act as a data processor for this information.
What Starcount Data is shared with third parties?
Starcount shares the Starcount Data to brands who license our data and services, as well as to partners who provide marketing and insight services to marketers, advertisers, and publishers.
The Starcount Data may be shared with authorized employees, independent contractors, consultants, and subsidiaries when they are contracted by Starcount to perform professional and technical functions in relation to Starcount’s business.
We may also use the services of third-party service providers for cloud data storage, analysis, and processing facilities and to provide operational or other support services. These entities are subject to confidentiality restrictions and are not authorized to use, access or transform information they receive from us for any purpose other than providing their services to Starcount.
We may be required to share Starcount Data and information with regulatory authorities, government agencies, and law enforcement officials, as permitted or enforced by law. Additionally, we may share data and information to defend or protect our legal rights, our intellectual and physical property, our employees and service providers, the safety and security of our business partners and to protect us against fraud.
Finally, we may share some or all Starcount Data and information assets if our company is sold, acquired, transferred or merged, files bankruptcy, undergoes debt refinancing, undergoes any form organisational change or any other business transaction that may require assets under our control to transferred to third parties as part of the business transaction. In these instances, Starcount will take the steps necessary to ensure that the Starcount Data and information will continue to be governed by this privacy policy.
Individuals Data Rights
You can make a Subject Access Request at any time to exercise your rights of your data as an individual. These rights include:
- The right to request and access a copy your data
- The right to have your data deleted
- The right to have your data rectified if inaccurate
- The right to withdraw any consents previously given
- The right to restrict or object to the processing of your data
- The right of data portability, to transfer data to other organisations
- The right to lodge a complaint
If you would like to exercise any of these rights, please submit a Subject Access Request to privacy@starcount.com. We will then respond as quickly as we can, verify your identity and act on your request within 30 days.
To make a complaint about Starcount’s handling of your data, you can reach out to the Information Commissioner’s Office (ICO), please contact them here.
FOR CLIENTS & PARTNERS: BUSINESS DATA
Starcount is a B2B organisation and we work with our clients & partners to offer our services.
Starcount collects partner and client data for business purposes such as delivering our services, billing, account maintenance and other customer services, marketing to current and prospective customers, recruitment, responding to general inquiries and also for website analytics, detecting and preventing malicious behavior on our website and improving and organising the content of our website and online portals.
These data sets are collectively known as Business Data.
What Business Data does Starcount collect?
If you message us or register to receive information from Starcount (for example – newsletters, marketing material etc), we will ask you to provide some personal information – this can include:
- your name
- an email address
- a contact telephone number
- the company you work for
- a username and password
and other information relevant to the Services we provide. For information requests, we do not insist on the information you provide to be your business information.
If you apply for a job with Starcount, we may also ask for your CV.
If you request a demo or register for our online portals, we will ask you to provide some business-related personal information – this can include:
- your name
- a business email address
- a business contact telephone number
- the company you work for
- your business address
- a username and password
and other information relevant to the Services we provide. The administrator for your Client account may provide this information on your behalf. For our online portals, we will always request the information you submit to be your business personal information rather than your personal information.
If you use our website or online portals, we collect technical information;
- your IP address
- the browser you are using
- the type of device you are using
- your operating system
- broad location (country or city)
This technical information we collect is generally anonymous unless you are logged in to one or more of our services, or you have provided your details to receive communication from us; when this is the case, we are able to link you to the technical information we collect.
We also collect usage information when you use our website or online portals;
- the pages you visit
- requests you have made
- what links you have clicked
- how long you stay on each page
This usage information we collect is generally anonymous unless you are logged in to one or more of our services, or you have provided your details to receive communication from us; when this is the case, we are able to link you to the usage information we collect.
Based on the information you have provided or made available to us, we may infer other information to allow us to improve our service to you. This may include customising your experience of our Services or to suggest other Starcount Services you may be interested in trying.
As we constantly improve and expand our services, we may require the collection of new information from you. Whenever this occurs, this privacy policy will be updated.
Our website and platforms may, from time to time, contain links to and from websites of our Partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Why do Starcount collect this Business Data?
The Business Data is used only for the purposes of marketing, communicating with our customers, responding to general enquiries, providing our services and recruitment.
The information you provide when registering for our online insight portals will be used to fulfil our contract with you and your organisation to provide our data services to you. We will also use this information to help us understand how you use our services and, therefore, how we can improve them in the future. We will only use your contact information to communicate with you about the services we provide.
If you message us or register to receive information from Starcount, we will use your contact details to provide you the information you requested. We may also contact you regarding other Starcount services you may be interested in.
If you contacted us regarding a job application, we will use the information provided to evaluate your suitability for the role applied for, and to contact you regarding the position. We will never share this information with 3rd parties.
If we collect data on your website behaviour or usage of our online portal, we may use this to improve our website and platform content and user experience.
We also collect information on new individuals for sales and marketing purposes through LinkedIn and outreach platforms with the purpose of expanding, managing and operating our business.
Do Starcount share Business Data?
We share data with authorized third parties to perform services on our behalf that are related to the purposes stated in this statement. Other third-party service providers used by Starcount include, but aren’t limited to: a) cloud computing, data storage and file storage providers, b) email marketing providers, c) website and b2b sales analytics providers, d) customer relationship management, contact database vendors, data hygiene vendors and project management software providers, e) customer billing systems partners, f) login authentication providers to ensure that the logins to our systems are working efficiently, g) social media platforms for advertising and marketing purposes, h) outsourced computer programmers helping ensure our systems are operating properly, i) auditing, debugging and security vendors. Data is shared only to enable these entities to perform professional and technical functions in relation to Starcount’s business. These entities are subject to confidentiality restrictions and are not authorized to use, access or transform information they receive from us for any purpose other than providing their services to Starcount.
We may disclose Business Data to third parties when we believe we are reasonably required to do so by law, and in order to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to fraud and situations involving potential threats to the physical safety of any person.
We may transfer Business Data, including any personally identifiable data, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, debt refinancing, or other corporate change. In these instances, Starcount will take the steps necessary to ensure that the Business Data will continue to be governed by this privacy statement.
How long do Starcount keep Business Data for?
We retain our data for as long as we have an active relationship with our clients and partners unless otherwise specified, or until it is deleted following a request from the subject of the data. We have processes in place to ensure that we keep our data up-to-date and reflect any changes where we can and are notified.
What is Starcount’s legal basis for collecting and processing Business Data?
As a client or partner, you may have access to Starcount’s data or data platform. When you sign up to this service, you consent to us processing your data with regards to this privacy policy and our commercial contract with you.
When you sign-up to our newsletter or ‘contact us’ website section, you consent to us processing your data with regards to this privacy policy.
We process data for sales and marketing purposes under our Legitimate Interest in expanding, managing and operating our business.
Clients & Partners: Opt-out Information
You are entitled to opt-out from our marketing lists and databases at any time. If you wish to update or change any information previously provided to Starcount via our website, please submit a request to update your details to privacy@starcount.com.
Please allow up to 72 hours for your contact details to be removed from our database. Please note, if you do decide to opt-out and you or your business have a contractual agreement with Starcount regarding the provision of products or services, we may still be required to send you emails in regards to these services and to support our contractual obligations.
DATA PROTECTION & TRANSFER
How is the data you collect secured & protected?
Starcount takes appropriate security measures to safeguard our data and other information in our possession against unauthorized access, use, modification, disclosure, and destruction.
Our security measures include physical security, firewalls, appropriate encryption, and restricted access to guard against the unauthorized use of data or information.
While we take all precautions to protect the data in our control, no security measures, however thorough, are perfect nor can they be guaranteed to be completely secure. Therefore, we cannot ensure or warrant absolute security of any data or other information. In particular, we cannot guarantee that our data or information will not be disclosed, altered, accessed or destroyed in accidental circumstances or by unauthorized acts of others.
Do Starcount transfer data to other countries?
Yes, Starcount works with partners who operate outside of the European Economic Area. When we do so, we always make sure to have a data processing agreement in place that ensures this partner will adhere to data privacy laws that continue to protect your data and use the standard EU-approved model contract clauses.
Protecting children’s data
Starcount does not collect age data on users under the age of 13. However, in our Twitter data set, we do process accounts of individuals aged 13 and above. To protect under 18s, Starcount removes under 18s data from any of our outputs for activation and only ever reveals the age of younger audiences as insight.
Industry Self-Regulation
Starcount supports industry self-regulation, and we endorse and align our business processes to the best practices and self-regulatory requirements that apply to our industry. We are regularly monitoring changes in Data Legislation and make any required changes to reflect our business practices.
PRIVACY POLICY QUESTIONS & UPDATES
Questions
If there are any questions, comments, concerns or complaints related to this policy, please contact us at privacy@starcount.com, or please write to us at the following address:
Rhomu Limited t/a Starcount, 120 New Cavendish Street, London, W1W 6XX
Status of This Privacy Policy
Starcount reserves the right to update this Privacy Policy from time to time to reflect our practices and the law. For any material changes, we would update you via email where possible. By continuing to use any of our services, this will be treated as your acceptance of our updated Privacy Policy.