Introduction
Starxgen Ltd. provides the following information relating to your privacy when using our website, www.starxgen.com. This privacy policy covers the Starxgen Ltd. website and all associated subdomains.
This Online Privacy Notice ("Notice") applies to the Personal Information that Starxgen Ltd. ("we", "us", "our") — as the data controller — collects when you visit our website (www.starxgen.com) and other platforms that we own or control, including through communications such as subscriptions to our newsletters, downloading our research reports, and email updates. Starxgen Ltd. is a research and media company incorporated in the British Virgin Islands (BVI) and based in Hong Kong.
This Notice describes the types of Personal Information we collect, the purposes for which we collect it, the other parties with whom we may share it, the measures taken to protect your Personal Information, your rights, the choices available to you regarding the use of your Personal Information, and how you can contact us about our privacy practices.
Because our visitors and users come from around the world — including Asia, Australia, the United Kingdom (UK), and the European Union (EU) — our privacy practices are designed to comply with applicable global privacy laws, including the BVI Data Protection Act, the Hong Kong Personal Data (Privacy) Ordinance (PDPO), the Australian Privacy Act 1988, the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and the Privacy and Electronic Communications Regulations (PECR).
This Notice does not apply to, and we are not responsible for, the privacy practices or information of any third parties, including any third-party operating websites to which our website contains a link.
1. Personal Information We Collect and Process
When you access or use our website, we may collect and process the following types of information from you.
Personal Information
"Personal Information" (or "Personal Data") is any information that we can reasonably use to directly or indirectly identify you. We collect the following Personal Information from you when you voluntarily provide it to us:
- Identification and Contact Information— such as your first name, last name, email address, phone number, professional title, and organisation or media outlet affiliation.
- Content Access Information— information provided when you register to download our gated research materials, such as our YouGov reports.
- Communication Information— details related to your exchanges with Starxgen Ltd., including the date, time, and subject of your inquiries or requests.
Automatically Collected Personal Information
Whenever you visit or interact with our website, we use a variety of technologies that automatically or passively collect information about your online activity for Search Engine Optimisation (SEO), analytics, and site functionality. This information is collected in the following ways:
- Through your browser— certain information is collected by most browsers, such as your IP address and internet browser type and version. We use IP addresses for purposes such as calculating website usage levels, helping diagnose server problems, administering the site, and analysing geographic trends among our visitors.
- Through Cookies and Tracking Technologies— we use cookies, web beacons, and similar tracking technologies to facilitate your ongoing access to and use of the website, to understand how you interact with our content, and to improve our SEO. Under UK/EU GDPR and PECR, as well as Australian and Hong Kong guidelines, we require your explicit, opt-in consent before deploying non-essential cookies (such as those used for analytics and tracking). You can manage your cookie preferences through our website's cookie consent banner.
Refusing or Withdrawing Consent
Data protection laws that apply to you may allow you to refuse to consent to our proposed collection, use, or disclosure of your Personal Information. If you have provided consent (e.g., for marketing emails or tracking cookies), you have the right to withdraw that consent at any time. To withdraw consent for marketing, you may use the "unsubscribe" link in our emails. To withdraw consent for cookies, you may adjust your preferences in our cookie management tool.
If you fail to provide certain Personal Information when requested, we may not be able to provide you with the specific services or content you requested, such as access to our gated research reports.
2. Marketing and Newsletters
Personal Information you submit through our website, such as your name and email address, may be collected by Starxgen Ltd. to send you our newsletters, research updates, and other media communications.
In compliance with the UK/EU GDPR, PECR, the Hong Kong PDPO, and the Australian Privacy Act, we operate a strict opt-in policy for direct marketing. We will only send you marketing communications if you have explicitly consented to receive them (e.g., by ticking a box when downloading a report or signing up for our newsletter).
You can choose not to receive marketing emails from us at any time by clicking the "unsubscribe" link included at the bottom of every marketing email you receive from us, or by contacting us directly.
3. Legal Basis for Processing
All processing and use of your Personal Information is justified by a "legal basis" for processing. In most cases, processing will rely on one of the following legal bases:
- Consent— you have explicitly consented to the processing (e.g., signing up for newsletters, downloading gated reports, or accepting non-essential cookies).
- Legitimate Interests— the processing is in our legitimate interests, which are not overridden by your interests and fundamental rights. This includes analysing website traffic for SEO purposes (using anonymised or aggregated data where possible), ensuring the security of our website, and responding to your general inquiries.
- Legal Obligation— the processing is necessary for us to comply with legal and regulatory obligations in the BVI, Hong Kong, or other applicable jurisdictions.
4. Sharing Your Personal Information
We share your information internally at Starxgen Ltd. to facilitate the delivery of our research and media content. We may also share your Personal Information with third parties whom we engage to process data on our behalf, such as:
- Email marketing and newsletter service providers.
- Website hosting and IT support vendors.
- Analytics and SEO service providers (subject to your cookie consent).
Starxgen Ltd. may also share your Personal Information with government and law enforcement agencies or regulators to comply with legal processes or defend against legal claims.
Starxgen Ltd. does not sell your Personal Information to third parties for their use in direct marketing, advertising, or promotion of their products or services.
5. International Transfer of Personal Information
Starxgen Ltd. is incorporated in the BVI and operates out of Hong Kong. Therefore, Personal Information that you provide to us will be transferred to, processed, and stored in Hong Kong and potentially other jurisdictions where our service providers operate.
If you are located in the UK, the EU, or Australia, please be aware that the data protection laws in Hong Kong and the BVI may differ from those of your home country. By providing us with your information, you acknowledge this transfer.
When we transfer Personal Information from the UK or EEA to jurisdictions not deemed to have "adequate" data protection frameworks, we implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) or International Data Transfer Agreements (IDTAs), to ensure your data remains protected in accordance with applicable laws.
6. Individual Privacy Rights
Depending on your jurisdiction (including the UK, EU, Australia, and Hong Kong), you may have the following rights regarding your Personal Information:
- Right to Access— you have the right to request access to the Personal Information we hold about you.
- Right to Rectification— you have the right to request that we correct any inaccurate or incomplete Personal Information.
- Right to Erasure (Right to be Forgotten)— you have the right to request that we delete your Personal Information, subject to certain legal exceptions.
- Right to Restrict Processing— you have the right to request that we limit the processing of your Personal Information under certain circumstances.
- Right to Data Portability— where applicable, you may request that we transfer your Personal Information to you or a third party in a structured, commonly used, machine-readable format.
- Right to Object / Opt-Out— you have the right to object to the processing of your Personal Information for direct marketing purposes at any time.
- Right to Withdraw Consent— you have the right to withdraw any consent you previously provided to us.
- Right to Make a Complaint— you have the right to lodge a complaint with your local data protection supervisory authority (e.g., the Information Commissioner's Office in the UK, the Office of the Australian Information Commissioner, or the Privacy Commissioner for Personal Data in Hong Kong) if you believe we have not processed your data lawfully.
To exercise any of these rights, please contact us using the information in the "Contact Information" section below. We will not discriminate against you for exercising your privacy rights.
7. Access and Choice
You can choose not to receive marketing or newsletter emails from us by using the "unsubscribe" instructions included in any such email you receive from us. You can also manage your preferences regarding cookies and SEO tracking technologies via the cookie consent banner available on our website.
8. Document Retention
To the extent permitted by applicable law, we keep your Personal Information for as long as needed to fulfil the particular purpose for which it was collected (e.g., to send you newsletters you subscribed to). If the legal basis for processing is based solely on consent, we will delete the Personal Information once consent is withdrawn, unless we are legally required to retain it for compliance or dispute resolution purposes.
9. Information Security
Starxgen Ltd. takes the security of your Personal Information seriously. We protect your information using reasonable physical, administrative, and technical safeguards to reduce the risk of loss, misuse, unauthorised access, disclosure, or modification of your information.
10. Third-Party Links
Our website may include links to third-party websites and services that we do not operate. If you visit a third-party website via a link on our site, you are subject to that third party's privacy practices and policies. This Notice does not apply to any Personal Information that you provide to third-party websites.
11. Contact Information
For more information on how we collect and process your Personal Information, to exercise your privacy rights, or if you have any complaints, please contact us at:
Hong Kong Operational Address
Starxgen Ltd.
14/F, Tower II Admiralty Centre
18 Harcourt Road
Hong Kong
BVI Registered Office
Please email [email protected] for details.
12. Updates to Notice
Starxgen Ltd. reserves the right to modify this Notice at any time. If we make any material changes to this Notice, we will provide you notice on our website. Where required by applicable data protection laws, we will also seek your consent to any material changes that affect how we use your Personal Information.
13. Effective Date
The effective date of this Notice is .