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Privacy Policy

This privacy policy, as amended and in effect from time to time (hereafter the “Privacy Policy”),describes the data privacy policies of Startors Global Private Limited at 205 Lakshmanan street,Vellore India (hereafter “we”, “us”, or “[Startors Global]”) for data collected through (1) StartorsGlobal's website www.luxexpats.lu (the “Site,” including any successor websites), and (2) anyServices provided through the Site. Any capitalized term not defined in this Privacy Policy shallhave the meaning given in our Terms of Use Agreement. Please refer to our Terms of UseAgreement for more information about our terms and conditions of use in general.

We are committed to protecting your privacy and we comply with the Data Protection Act 1998, asamended (the “Data Protection Act 1998”). This Privacy Policy describes the information we maycollect from you (hereafter “you” or “User”) and explains how we collect, use, process and store it,how you can instruct us if you prefer to limit the use of that information and the procedures that wehave in place to safeguard your privacy.

By accessing the Site, you acknowledge and agree to comply with the terms and conditions of thisPrivacy Policy and our Terms of Use Agreement and you expressly consent to the collection, use,disclosure, retention and protection of your Personally-Identifiable Information (as the term isdefined below) as provided in this Privacy Policy.

By accessing the Site, you represent and warrant that you are (a) 18 years of age or older (or otherage of majority in the state or province in which you reside), and (b) fully able and competent toenter into the terms, conditions, obligations, affirmations, representations, and warranties set forthin this Privacy Policy, and to abide by and comply with this Privacy Policy. The Site and theServices are not designed or intended for persons under the age of 18 (or other age of majority inthe state or province in which you reside). If you are under the age of 18 (or under other age ofmajority in the state or province in which you reside), you (a) cannot access the Site and use theServices in any way without the supervision and consent of a parent, legal guardian, or otherresponsible adult, and (b) must obtain your parent's, guardian's, or other responsible adult'sconsent before providing us with any information.

This Privacy Policy was last updated on 01 January 2017.

1. Personally-Identifiable Information

1.1 “Personally-Identifiable Information” is information about you that is personally identifiable toyou as well as other non-public information to the extent that it is associated with the foregoing.

1.2 We collect, process, and retain Personally-Identifiable Information from you and any devices(including mobile devices) you may use when you: access the Site, use our Services, register foran account with us, provide us information on a web form, update or add information to youraccount, participate in community discussions, chats, or dispute resolution, or when you otherwisecorrespond with us regarding our Services.

1.3 The Personally-Identifiable Information we collect includes, but is not limited to, the following:

  • a) Identifying information such as your name, addresses, telephone numbers or emailaddresses you give us when you use our Services or register for an account with us. Seeking or offering information you provide during a transaction, or other transaction-basedcontent that you generate or that is connected to your account as a result of a transactionyou are involved in.
  • b) Financial information (such as credit card or bank account numbers) you provide inconnection with a transaction.
  • c) Postage, billing and other information used to purchase or post an item.
  • d) Depending on the Services you choose, you may provide age, gender, interests andfavourites related information.
  • e) Additional identifying information we are required or authorized by applicable national lawsto collect and process in order to authenticate or identify you or to verify the information wehave collected.

2. Information Collected Automatically
2.1 In addition to the information indicated in Section 1 above, we automatically collect informationfrom your browser or device when you visit our Site, when you use our Services, register for anaccount with us, provide us information on a web form, update or add information to your account,participate in community discussions, chats, or when you otherwise correspond with us regardingour Services. This information include, but is not limited to, your computer's Internet Protocol (“IP”)address, device ID and type, your browser type and language, internet service provider (“ISP”), theoperating system used by your device, number of clicks, access times, your device's geographiclocation while accessing the Site, and the referring website address.

2.2 We use the information collected automatically to monitor and analyse the use of the Site andfor the Site's technical administration, to increase the Site's functionality and user-friendliness, andto better tailor it to our users' needs. We do not treat the information collected automatically asPersonally-Identifiable information or use it in association with other Personally-Identifiableinformation, though we may aggregate, analyse and evaluate such information for the samepurposes as stated in Section 6 below.

3. Feedbacks
If you send us an email or a mail (including, to provide feedbacks or to ask a question regardingthe Site or our Services), we will collect any information contained in such communication. We mayretain those communications in order to process your inquiries, respond to your requests, andimprove the Site and/or our Services. We will treat the Personally-Identifiable Information in suchcommunication in accordance with this Privacy Policy.

4. Use of Technologies to Collect Information
We use various technologies to collect information from your device and about your activities onthe Site. We may use standard Internet technology, such as web beacons and other similartechnologies, to track your use of our Services and to deliver or communicate with cookies. Wealso may include web beacons in email messages to determine whether messages have beenreceived properly. We also use Mandrill application, among other email and message applications,to receive messages from forms in the website and to send automated emails to users whom haverequested to receive them. The information we obtain in this manner enables us to customise theServices we offer users and to measure the overall effectiveness of our online content,programming or other activities.

5. Cookies and Use of Cookie Data.
A cookie is a small file that requires permission to be placed on your web browser. Once you agree, the file is added to your web browser and the cookie helps analyse web traffic or allow toknow when you visit a particular site. Cookies allow web applications to respond to you as anindividual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We may use cookies or other similar technologies that are required to identify irregular site behaviour, prevent fraudulent activity and improve security, or that allow you to make use of ourServices and the various functions of our Site. In addition, we may use cookies or other similartechnologies to assess the performance of our Site and Services, including to help us understandhow our Users use our Site, determine if you have interacted with our messaging, determinewhether you have viewed an item or link, or to improve our Site content, applications and Services.This helps us analyse data about web page traffic, to understand our Users' preferences and toimprove the Site and our Services. We may also use cookies or other similar technologies thatallow us to offer you enhanced functionality when accessing or using our Sites and Services,including identifying you when you sign into our Site or keeping track of your specified preferences,interests, or past items viewed so that we may enhance the presentation of content on our sites.Furthermore we may use cookies or other similar technologies to control access to certain content on the Site and to process any requests that you make with us. In addition, we may use first-partyor third-party cookies or other similar technologies to deliver content, including ads relevant to yourinterests, on our Site or on third party sites.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies,but you can usually modify your browser setting to decline cookies if you prefer. This may preventyou from taking full advantage of the website.

6. What We Do with the Personally-Identifiable Information We Gather
All Personally-Identifiable Information that we obtain about you will be recorded, used, andprotected by us in accordance with this Privacy Policy. We will use your Personally-IdentifiableInformation in a number of ways, including, but not limited, to:

  • Process and fulfil your transaction orders and requests;
  • Fulfil your requests for information and inquiries;
  • Deliver, evaluate and improve our products and Services;
  • Manage your account or interaction with our Site and Services and provide you withcustomer support;
  • Perform research and analysis about your use of, or interest in, our or others' products,Services, or content;
  • Gauge traffic patterns and determine what types of content and Services are most popularwith our Users;
  • Communicate with you by email, postal mail, telephone and/or mobile devices about ourproducts, Services, news and events, as well products, services, news and events ofcarefully selected third parties, which we think may be of interest to you;
  • Develop, display, and track content and advertising tailored to your interests on the Site,including providing our advertisements to you when you visit other sites;
  • Enforce or exercise any rights in our Terms of Use Agreement;
  • Perform functions or Services as otherwise described to you at the time of collection; and
  • Such other purposes as you may initiate or request.

7. Anonymous InformationWe may use any non Personally-Identifiable Information that it collects or stores for any purpose itdeems appropriate.

8. Newsletters and Alerts
8.1 By registering for recurring newsletters or alerts, you agree to receive on occasion othercorrespondence from us related to the subscribed newsletters and other news and information that you consented to receive during registration. We present the option to not receive these types ofcommunications. The information provided in connection with these communications will not beshared with any third-party other than the agents who have agreed to send e-mails on our behalf. You will be contacted by e-mail or otherwise only by our agents or us.
8.2 We ask for your e-mail address at registration. We will send e-mails to this address to providenewsletters or alerts and to contact you for any other reason. In addition, we may contact youregarding your account status. Generally, Users may not opt-out of these communications, thoughthey can deactivate their account. Your e-mail address will not be shared with any third-party otherthan an agent who has agreed to send e-mails on our behalf.

9. Security
9.1 We are committed to ensuring that your Personally-Identifiable Information is secure. In orderto prevent unauthorised access or disclosure, we have implemented generally accepted standards of technology and operational security in order to protect your Personally-Identifiable Informationgathered online from loss, misuse, alteration, or destruction. Although we make good faith effortsto protect the storage and transmission of your Personally-Identifiable Information, we cannotguarantee that unauthorized persons will not obtain access to your Personally-IdentifiableInformation. We shall not be liable for any such unauthorised access or loss of personalinformation that is beyond our control.
9.2 Only our authorized personnel, representatives, affiliates and third-party vendors are providedaccess to Users' Personally-Identifiable Information, and these authorized employees,representatives, affiliates, and third-party vendors are required to treat this information asconfidential, not to disclose and not to use this information other than to provide the Servicesrequested by us.
9.3 We may share aggregated or non-Personally Identifiable Information with our servicespartners and sponsors but such information is not linked to your Personally-Identifiable Information.
9.4 Please be aware that, whenever you voluntarily post information to message boards or anyother public forums, such information can be accessed by anyone and, if such information includesyour Personally-Identifiable information, third-parties may use it, including to send you unsolicitedcommunications.

10. Links to Other Websites
The Site contains links to third-party websites or information as a service to our Users. If you clickon another third-party link, you will be directed to that third-party's website. The fact that we link toa website is not an explicit or implicit endorsement, sponsorship, recommendation, authorization orrepresentation of our affiliation with that third-party, the third-party's website, or the informationcontained therein, nor is it an explicit or implicit endorsement of their privacy or information securitypolicies or practices, and we shall not be responsible or liable for your use of the third-partywebsite, or the information contained therein. We do not exercise control over third-party websitesor information. These other websites may place their own cookies or other files on your computer,collect data or solicit personal information from you. Other sites follow different rules regarding theuse or disclosure of the personal information you submit to them. We encourage you to read theprivacy policies or statements of the other websites you visit.

11. User Forums
You should be aware that whenever you publicly disclose information online, that information couldbe collected and used by others. We are not responsible for any action or policies of any third-partywho collects information that Users publicly disclose in any such forums on the Site.

12. Controlling your Personally-Identifiable Information
12.1 We shall not intentionally disclose, offering, distribute, or transfer (and shall take reasonable stepsto prevent the unauthorized or accidental disclosure of) your Personally-Identifiable Information tothird parties other than our authorized personnel, representatives, and affiliates without yourconsent, except as follows:

  • a) We may provide access to your Personally-Identifiable Information to third-party vendorsthat we engage to provide Services related to the Site (including but not limited to emailcommunication services), provided that such vendors shall first agree to maintain the strictconfidentiality of such information and to ensure the same level of data security as providedby us;
  • b) For the purposes set out in this Privacy Policy, your Personally-Identifiable Information maybe disclosed to third-party consultants, contractors or other service providers who mayprocess such information on our behalf when providing services (including but not limited toIT support services) to us;
  • c) We may be compelled to disclose and surrender Users' Personally-Identifiable Informationif required by a subpoena or other judicial or administrative order, if required or permitted bylaw, rules, and regulations of any applicable jurisdiction;
  • d) We may disclose Users' Personally-Identifiable Information at our discretion if we believe ingood faith that such disclosure is necessary to comply with the law, prevent imminentphysical harm or financial loss, or investigate, prevent, or take action regarding illegalactivities, suspected fraud, threats to our property, or to prevent the violation of our Termsof Use Agreement or our rights or the rights of any third party; and
  • e) In the event of a violation of our Privacy Policy or our Terms of Use Agreement or any otherterms on the Site, including but not limited to a violation of any restrictions on use ofmaterials provided in or through the Site, we may disclose Users' Personally-IdentifiableInformation to affected parties and legal authorities in furtherance of potential or on-goinglegal proceedings.

12.2 We may use your Personally-Identifiable Information to send you promotional informationabout third-parties which we think you may find interesting if you tell us that you wish this tohappen. We present the option to not receive these types of communications.
12.3 You may request details of Personally-Identifiable Information, which we hold about you underthe Data Protection Act 1998. If you would like a copy of the information held on you pleasecontact us by email at contact@luxexpats.lu.
12.4 If you believe that any information we are holding on you is incorrect, outdated, or incomplete,please email us as soon as possible at contact@luxexpats.lu. Please include your name, addressand/or email address when you contact us as this information helps us ensure that we acceptrequests for correction, amendments or updates only from authorized persons. We will promptlycorrect or update any information found to be incorrect, outdated and incomplete.

13. International Transfer
Your information may be transferred to — and maintained on — computers located outside of yourstate, province, country or other governmental jurisdiction where the privacy laws may not be asprotective as those in your jurisdiction. If you are located outside the European Union and chooseto provide information to us, we may transfer personal information to the European Union andprocesses it here. Your consent to this Privacy Policy followed by your submission of suchinformation represents your agreement to that transfer and hosting of such information.

14. Data Retention Policy
14.1 We store your Personally-Identifiable Information for various purposes as notified to you inthis Privacy Policy. For each of these different purposes, we only retain Users' Personally-Identifiable Information for so long as it is serving its notified purpose and/or it is necessary toprovide our products and Services.
14.2 If you no longer want us to use your Personally-Identifiable Information to provide youServices, you may close your account by contacting us by email at contact@luxexpats.lu. You mayalso unsubscribe from newsletters, mailing lists or any registrations on the Site. To do so, pleaseeither follow the instructions on the page of the Site on which you have provided such information,subscribed or registered or contact us by email at contact@luxexpats.lu. Please note that we willretain and use your Personally-Identifiable Information to the extent necessary to comply with ourlegal obligations, resolve disputes, and enforce our agreements in accordance with this PrivacyPolicy and any applicable laws and regulations.

15. Consent; Changes to Privacy Policy
We reserve the right to make changes to this Privacy Policy at any time and in our sole discretion.If we believe that the changes are material, we'll notify you by posting the changes on the Site orsending you an email about the changes. Changes will be effective upon the posting of thechanges or the receipt of the email notifying of such changes, whichever occurs earlier. You areresponsible for reviewing and becoming familiar with any changes. Continued use of the Sitefollowing the changes constitutes your acceptance of the updated policy.
This Privacy Policy was last updated on 01 January 2017

16. Contact our Privacy Department
If you have any questions about our Privacy Policy, please contact us by email at contact@luxexpats.lu.

17. Language
This Privacy Policy is prepared and entered into in the English language only, whose languageshall be controlling in all respects. Any translation of this Privacy Statement into any otherlanguage are for reference only and shall have no legal or other effect.

18. The Data Protection Act 1998
We will act as Data Controller for the purposes of the Data Protection Act 1998. We will at all timesseek to comply with the requirements of the Data Protection Act 1998 and any applicable laws andregulations to ensure that the Personally-Identifiable Information you give us is kept appropriatelysecure and processed fairly and lawfully.

19. Jurisdiction
This Privacy Policy shall be governed by, and construed in accordance with, the laws of Indiawithout regard to its conflict of law provisions. You agree to submit to the exclusive jurisdiction ofthe courts located in the Republic of India.

20. Miscellaneous
20.1 This Privacy Policy and any other rules or policies set forth into our Terms of Use Agreementcomprise the entire agreement between us and supersede all prior agreements between us.
20.2 Our failure to exercise or enforce any right or provision of this Privacy Policy shall notconstitute a waiver of such right or provision.
20.3 If any provision of this Privacy Policy is found by a court of competent jurisdiction to be invalid,the parties nevertheless agree that the court should endeavour to give effect to the parties'intentions as reflected in the provision, and the other provisions of this Privacy Policy shall remainin full force and effect.
20.4 The section titles in this Privacy Policy are for convenience only and have no legal orcontractual effect.
20.5 Any notices intended to have legal effect: (a) to you may be made via email, regular mail orthrough the Services, and (b) to us must be made by delivery receipt-requested mail atcontact@luxexpats.lu ATTN: Legal Service.

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