Privacy Policy

This privacy policy (the “Privacy Policy”) governs the manner in which Starhome BV, a private company with corporate seat in Amsterdam, the Netherlands, and office address at Strawinskylaan 411, Tower A, 4th floor, 1077 Amsterdam, the Netherlands, registered with the Trade Register under number 34119625 and its affiliated companies (“Starhome Mach”) collects, uses, maintains and discloses data collected from, customers and/or users (each, a “User” or “Users”) of its website (the “Website”) or the services provided on it (the “Services”).

Compliance with Data Protection Law

Starhome Mach acknowledges and undertakes to comply with the laws and regulations governing the processing of personal data, including, but not limited to, the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”) and any other Luxembourg applicable laws or regulations governing the processing of personal data in the framework of the use of the Website or the Services.

Data protection officer

Starhome Mach acts as data controller for data it collects from Users. Starhome Mach has appointed a data protection officer.
The data protection officer appointed by Starhome Mach shall be contacted by using the following information:


Personal data

Starhome Mach may collect personal data when Users visit the Website or use the Services when they register on it or fill out a form. Users may be asked for, as appropriate, name, date of birth, email address, mailing address, phone number, etc.

Non-personal data

Starhome Mach may collect non-personal data about Users whenever they use the Website or the Services. Non-personal data may include technical information about Users means of connection, such as the operating system and the Internet service provider utilized, geographical information such as country of origin, behavioural information such as time spent on the Website, as well as further non-personal analytical data to improve customer experience, products and services.

Each User recognizes and accepts that the performance of the Website and the Services may depend on the collection and processing of personal data and non-personal data.

Web browser cookies

Starhome Mach may use cookies to improve the User’s experience on the Website and the Services provided. In that case, the User’s Internet navigator places cookies on his hard drive to gather a certain set of data used to customize the navigation on the Website and the use of Services, thus enabling certain unique functionalities. All information related to the cookies policy are available on

How STARHOME MACH uses collected data

Principally, personal and non-personal data is used to provide the Users with the Website and the Services and to insure their full effectiveness.

In this framework, Starhome Mach may collect and use Users personal and non-personal data for the following purposes:

  • To improve Services: Information Users provided will help Starhome Mach to respond to certain Users requests.
  • To personalize User experience: Starhome Mach may use non-personal data to understand how Users as a group use the Website and the Services.
  • To improve the Website and other internet presence as well as other communication tools or tools for specific Services: Starhome Mach may use feedback that Users provide to improve its products and services.
  • To send periodic emails and other text messages and/or notifications: Starhome Mach may use the User’s personal data for marketing purposes. For the case that, at any time, Users would like to unsubscribe from the Periodic Information Service, Starhome Mach includes detailed unsubscribe instructions at the bottom of each such email or other text message.

How STARHOME MACH protects personal data

Starhome Mach adopts appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users personal data within the limits of Starhome Mach role with respect to the relevant Services (as certain specific services might be rendered by third parties).

Sharing personal data

Starhome Mach does not sell, trade, or otherwise transfer to third parties Users personal data. However, each User accepts that his/her personal data can be transmitted, in the framework of the use of the Website or the Services, to Website hosting and editing partners and other sub-contractors who assist Starhome Mach in providing the Services, conducting its business, or servicing the User, so long as those sub-contractors undertake to process the data only according to Starhome Mach instructions and to comply with the applicable law regarding the protection of personal data. Starhome Mach may also release User’s personal data when it believes that such release is necessary to comply with the law, enforce its Website general terms of use, or protect its or others’ rights, property, or safety.

However, Users non-personal data may be provided to third parties for marketing, advertising, or other uses.

Changes to this Privacy Policy

Starhome Mach has the discretion to update this Privacy Policy at any time. Starhome Mach will therefore revise the “last update date” at the bottom of this page. Starhome Mach encourages Users to frequently check this page for any changes. Users acknowledge and agree that it is their responsibility to review this Privacy Policy periodically and become aware of modifications.

Data Retention

Starhome Mach takes all reasonable measures to ensure that Users personal data are processed for the minimum period necessary for the purposes set out in this Privacy Policy. The Personal Data will be retained by Starhome Mach according to the following criteria:

  1. as long as Starhome Mach maintain an ongoing relationship with the User (e.g., where the User is a recipient of Starhome Mach services, or is lawfully included in Starhome Mach’s mailing list and has not unsubscribed);
  2. as long as the User’ personal data are necessary in connection with the purposes set out in this Privacy Policy, for which Starhome Mach has a valid legal basis
  3. until the expiry of a period of two (2) months following the end of any applicable limitation period under applicable law; and
  4. with the User’s prior consent, until the expiry of any additional retention period.

Starhome Mach undertakes to delete or to anonymise the Users personal data upon expiry of the retention period as described above.

Data Security and data transfer

Starhome Mach has implemented appropriate technical and organizational security measures designed to protect the Users personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable law.

The User is responsible for ensuring that any personal data that he/she send to us are sent securely.

Starhome Mach does not transfer personal data to any third country nor to any international organisation, except as the case may be on the basis of:

  • adequacy decisions;
  • suitable Standard Contractual Clauses; or
  • other valid transfer mechanisms under GDPR.

Data Accuracy and minimization

We take reasonable measures:

  • to ensure that the Users personal data are accurate and, where necessary, kept up to date and accurate; and
  • that the Users personal data are collected on an as needed basis in connection with the purposes set out in this Privacy Policy.

Data subject rights

Each User benefits under data protection law from a right of access, modification and opposition to the processing of its personal data, a right to erasure and a right to portability of its personal data by sending an email to Those rights may only be exercised within the limits of any contractual or legal obligation. Each User has also a right to lodge a complaint with the Luxembourg supervisory authority, namely the Commission nationale pour la protection des données (

Acceptance of these terms

By using the Website and the Services, Users confirm their acceptance of this Privacy Policy. If a User does not agree with this Privacy Policy, Starhome Mach recommends to such User that he shall not use them. The continued use of the Website and the Services following the posting of changes to this Privacy Policy will be deemed as an acceptance of those changes.

This Privacy Policy is applicable from 25th May 2018.