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Dated 16 December 2020







1. Use of personal data

2. Log Files

3. Cookies

4. Social Plugins

5. Contact Form / Registration Form

6. Duration of Data Storage

7. Transfer to Third Parties

8. Rights of the Data Subject

9. Liability for Content

10. Liability for Links
11. Data Security

12. Updates and Modifications

13. Data Protection Officer


Protecting your privacy is important to Starfish Digital. The following describes how we, Starfish Digital Pte. Ltd (Unique Entity Number: UEN 202036574G) (together with our subsidiaries, our holding company, or subsidiaries of our holding company from time to time, collectively "we"), collect, process, and use your personal data (hereinafter referred to as the “use” of your data) when you visit our website ( associated websites at this domain, or other websites which we operate, and which contain a direct link to this privacy policy (our “websites”). Please read our privacy policy carefully.


1. Use of personal data
Personal data are any information that relates to an individual or can be used to establish a connection to an individual. This includes personal or material information about you.


a) Collection of personal data

Users can request free demos on our websites, register for webinars, contact us to subscribe to our e-mail newsletter, download content such as whitepapers and success stories, or register to use certain areas of the website. Starfish Digital collects and stores only the personal data that you explicitly share with us through our contact and registration forms, or when signing up for the newsletter. The data we collect varies by activity and may include personal information such as first and last name, e-mail address, telephone number, postcode, city, and other address information. In certain cases, we may also collect your job title and area of activity, as well as other information we may need to provide you with full access to our products and services.


b) Use of personal data

We use the personal data you provide exclusively to process your particular request. For example:

  • To respond to and fulfil your requests, such as sending you requested documents, information and marketing materials about our products and services, or the newsletter to which you subscribed.

  • To register you for our webinars, events or training sessions/workshops.

  • To provide customer services and handle support requests.

  • To send marketing e-mails that may be of interest to you, provided you have given us special permission to do so.

  • To personalise our websites with information and product-related content tailored to your needs.

  • To register you for our partner portal or restricted customer areas.

It is your decision whether to provide us with your data for the purposes mentioned above. To the extent that your request allows, you may also remain anonymous to us or use a pseudonym. Starfish Digital will always obtain your express consent to use your personal data for other purposes (in particular for marketing purposes).


Furthermore, various plugins are used on our websites, some of which collect personal data. For details, see section 6.


The newsletters offered on our websites contain news, offers, invitations to webinars, trade fair dates, and other information about the products and services offered by Starfish Digital.

If you request a newsletter and have given your consent to receive the newsletter when you registered, we will use your personal data as follows: When you register for a newsletter or event, your first name, surname, and e-mail address are collected and stored. When you register for an event, we also collect/save your postcode, city, company, and job title. We use this information for providing better services, and to establish new business relationships. 


To document that you submitted your declaration of consent, we also store your IP address and the dates on which you registered for and confirmed the newsletter.

If you no longer wish to receive the newsletter, you can unsubscribe at any time to stop receiving the newsletter. To do so, click the link contained in each newsletter to be guided through the unsubscribe process. Alternatively, you can send us your request to unsubscribe by e-mail (see section 12).


2. Log Files

We also collect and store information from the log files that your browser transmits to us. This includes:


  • IP (Internet Protocol) address of the computer accessing the website in order to maintain/improve the quality of our website, determine your geographic location, and enforce general security measures and access controls.

  • Browser type/version and operating system used in order to ensure that the websites are displayed in a way that is most compatible with your device settings.

  • Time of the server request to gather statistical information about which areas of our website were visited and how much time a visitor spent in each area.


These data are collected for technical reasons. They are evaluated exclusively for statistical purposes and without any reference to a specific person. They are deleted after six months.


3. Cookies

Cookies are stored on your computer when you use this website. Cookies are small text files in which the web browser stores information about internet pages you have visited. This may include information about the page visit such as duration, login data, user inputs, etc.

This website uses the following cookies:


  • Transient cookies

  • Persistent cookies

  • Third-party cookies

  • Flash cookies.


(1) Transient cookies are automatically deleted when you close your browser. This category includes session cookies, among others. Session cookies store a session ID, which can be used to assign various requests from your browser to the shared session. This allows your computer to be recognised when you return to the site. Session cookies are deleted when you log out or close your browser.


(2) Persistent cookies are automatically deleted after a specified time, which varies depending on the cookie. You can delete these cookies in your browser’s security settings at any time.


(3) Information on third-party cookies can be found in section 


(4) Flash cookies are not recorded by your browser but rather by your Flash plugin. These cookies store the necessary data independent of the browser used and have no automatic expiry date. If you do not want your computer to process Flash cookies, you must install a corresponding add-on. The legal basis for this data processing is Art. 6(1) lit. f) of the GDPR. We have a legitimate interest in processing this data because it enables us to carry out statistical evaluations regarding the use of our website and to optimise our online offerings for users.


You can configure your browser settings according to your needs, for example, to refuse third-party cookies or all cookies. If you do so, however, you may not be able to use all the functions of this website.


If you do not wish our cookies to be stored, please do not confirm the opt-in prompt displayed when you first visit the website.


4. Social Plugins

Our websites employ social networking plugins. These plugins are usually labelled with the provider’s logo. We use plugins from “LinkedIn” (provider: LinkedIn Corporation, 1000 West Maude Avenue, Sunnyvale, CA 94085, USA) and “Twitter” (provider: Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103) When you visit our websites, no data are automatically transmitted to social networks. Only when you actively click the button does your internet browser establish a connection to the servers of the corresponding social network. In other words, by clicking the button you agree to allow your internet browser to establish a connection to the servers of the social network and transmit usage data to the network operator.

We have no control over the nature and extent of the data collected by the social networks. Please refer to the privacy policies of the various social networks for information about the purpose and scope of the data collection, how your data are processed and used by the social networks, your rights under data protection law, and optional settings you can configure to protect your privacy.

Information about how your personal data is used can be found at for LinkedIn and for Twitter


5. Contact Form / Registration Form

On our website, you can send us a request using the encrypted contact field on the “Contact” tab. Cookies are automatically saved as soon as you fill out this field, even if you have rejected the saving of cookies. You may also use a registration form to register for webinars or other events. All of the following information applies to both the contact and registration forms.


In order to process your request as accurately as possible, we ask you to enter personal data in our input mask. This might include your company, your name, your e-mail address (to ensure we can contact you), your country (to assign you to the appropriate office), your contact number, and your job title. We collect this data so that we may advise you as best we can.

The data you provide will only be used to contact you and process your request. These data are processed on the server; see section 6. a). The data will not be used for other purposes or passed on to third parties without your express consent (e.g., if you registered for our newsletter). We have a legitimate interest in collecting this data because they are needed to process or answer your message.


6. Duration of Data Storage

The data you provide to us will only be stored for as long as is necessary to fulfil the purpose for which they were provided or to comply with statutory provisions.


7. Transfer to Third Parties

Your personal data will be passed on to third parties only in the following cases:

  • If you have given your express consent in accordance 

  • If transferring the data is necessary to fulfil contractual obligations 

  • If we are legally obliged to disclose the data 

  • If disclosure of the data is in the public interest within the meaning of Art. 6(1) lit. e) of the GDPR

  • If disclosure of the data is necessary to protect our legitimate interests or the legitimate interests of a third party unless your interests in protecting your data prevail


If you have given us your consent to do so, we may pass on the data collected during your visit to our websites to other Starfish Digital companies (Legal entities under Starfish Digital and Partners) in order to improve our range of services, to market Starfish Digital products and services, and to establish new business relationships.


In addition, when processing your request, it may be necessary for Starfish Digital to disclose your personal data to external service providers acting on our behalf, including in non-European third countries. These service providers may be tasked with operating servers or sending news messages, for example. Starfish Digital requires  and external service providers to use your personal data only in accordance with our policies and in accordance with this privacy policy, as well as with statutory requirements for order processing or similar requirements.

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:


​“Digital Marketing Service Providers


We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.  Our appointed data processors include:


(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here:  Sopro is registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at:”


8. Rights of the Data Subject

You have the following rights regarding the processing of your data:


  • You have the right to obtain from us information about the processing of your personal data regarding the purpose of the processing, the categories of data processed, the recipients or categories of recipients to whom the data have been or will be disclosed, and the envisaged duration of storage or the criteria for determining the duration. You also have rights of rectification, deletion, restriction of processing, or objection to processing of your data, as well as the right to lodge a complaint with a supervisory authority. You also have the right to obtain information on the origin of the data, if applicable, information on the existence of any automated decision-making and, if data are transferred to a third country or international organisation, information on safeguards for the transfer.

  • You have the right to deletion of stored personal data if the data are no longer necessary for the purposes for which they were collected or otherwise processed, if the data subject has withdrawn their consent and there is no other legal basis, or if an objection to processing has been filed and the data may no longer be processed. You also have the right of deletion if the data have been unlawfully processed, if the deletion is necessary to fulfil a legal obligation, or if the data have been collected in relation to information society services offered. This does not apply if the processing is necessary to exercise the right to freedom of expression and information, to fulfill a legal obligation, for reasons of public interest, or to assert, exercise or defend against legal claims.

  • You have the right to data portability, i.e. the right to receive the personal data that you have provided to Starfish Digital in a structured, commonly used and machine-readable format or to transmit the data to another controller.

  • You have the right to object at any time to the processing of your personal data on grounds relating to your particular situation unless Starfish Digital has compelling legitimate reasons for the processing that outweigh your interests or the processing serves to assert, exercise or defend against legal claims.

  • You have the right to lodge a complaint with a supervisory authority. The right of the complaint shall be without prejudice to other administrative or judicial remedies.


9. Liability for Content

The content on our website was created with the utmost care. However, we do not guarantee the accuracy, completeness, or timeliness of the content.


10. Liability for Links

Our website may contain links to external, third-party websites over whose content we have no control. We, therefore, assume no responsibility for third-party content.

The provider or operator of a linked website is always responsible for the content on the site. The linked site was checked for possible legal violations at the time of linking. No illegal content was discernible at the time of linking. Constant monitoring of the content on linked sites is not reasonable without concrete evidence of a legal violation. If we become aware of an infringement, we will remove such links immediately.


11. Data Security

We have taken technical and organisational measures to protect your data from loss, alteration, or unauthorised access. We continuously improve these security measures in line with technological developments. Our website uses the industry-standard SSL (Secure Sockets Layer) for encryption. This guarantees the confidentiality of your personal data when transmitted over the internet.


12. Updates and Modifications

We may change or update portions of this privacy policy without prior notice. Please review the privacy policy before using our services to ensure that you are always up to date with any changes or updates.


Last update of privacy policy: 29 March 2022


13. Data Protection Officer

If you have questions, please contact our data protection officer at: dpo@starfish.digtial Starfish Digital

Marina One West Tower

9 Straits View #05-07

Singapore 018937

Last updated: 6 January, 2022 

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