Privacy Policy

AWAAS ("we," "us," or "our"), doing business as StarLead, operates the website starlead.ai (the "Platform") and the StarLead outbound sales platform (the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Platform or use our Service.

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Platform or use the Service.

1. Individuals We Collect From or About

We collect data about two groups of individuals:

• Clients: Individuals who register for, purchase, or use our Service.
• Prospects: Business contacts whose data is stored, enriched, or processed through our Platform for B2B marketing purposes, and that may be sold or transferred to our Clients as part of the Service.

Unless otherwise specified, all references to "You" or "your" within this document apply to either a Client or a Prospect.

2. Sources of Data

For Clients: We collect data directly from you, such as when you fill out forms on our Platform, sign up for our Service, communicate with us via email or phone, or connect third-party accounts.

For Prospects: We collect data from:

• Publicly available sources, such as company websites and social media platforms (e.g., LinkedIn)
• Third-party data providers and data brokers (e.g., Apollo.io)
• Our Clients, who upload or import contact lists into the Platform

3. Information We Collect

3.1 Clients

• Contact and title information: Name, title, employer, email address, phone number
• Billing information: Credit card details, billing address, transaction history, services purchased or considered
• Account data: Login credentials, platform usage history, frequency and duration of visits
• Communication data: Feedback, comments, support tickets, emails, and any other information you provide
• Campaign data: Email copy, sequences, brand-voice guidelines, ICP filters, and targeting criteria you upload

3.2 Prospects

• Name, email address (which we may infer), and sometimes mobile number
• Current employer, employment history, and company firmographic data
• Current and previous job titles
• Performance data (e.g., whether emails sent to you bounced, whether a reply was received, open/click activity)
• Any other information required to provide the Service to our Clients

3.3 Automatically Collected Information

When you access the Platform or use the Service, we automatically collect:

• Usage Data: IP address, browser type, operating system, access times, pages viewed, referring URLs, URI addresses, time of request, method utilized to submit the request to the server, size of file received in response, numerical code indicating server status, country of origin, and time spent on each page
• Device Information: Device identifiers, hardware model, and network information
• System Logs: For operation and maintenance purposes, we collect files that record interaction with the Platform (system logs) and use other personal data (such as IP Address) for this purpose
• Tracking Technologies: Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting

4. Purpose of Collection

Personal data is collected to allow us to:

• Provide and improve our Service to Clients
• Perform contractual obligations
• Comply with legal obligations
• Respond to enforcement requests
• Protect our rights and interests (or those of our Clients or third parties)
• Detect malicious or fraudulent activity
• Display content from external platforms
• Interact with external social networks and platforms
• Perform analytics and monitor web traffic
• Record Client sessions and heatmaps for platform optimization
• Access third-party accounts (with explicit authorization)
• Process payments and manage subscriptions

5. Legal Basis of Processing

For Clients: We process your personal information so that we can provide the services to you under our contract with you. We need your data to perform our contractual services.

For Prospects: Processing of your data is necessary for the purposes of the legitimate interests pursued by us and our Clients (B2B marketing and sales outreach), and those interests are not outweighed by undue prejudice to you.

Where required by law, we will obtain your consent before processing.

6. Detailed Information on the Processing of Personal Data

Personal data is collected for the following purposes and using the following services:

6.1 Access to Third-Party Accounts

This type of service allows the StarLead Platform to access data from your account on a third-party service and perform actions with it. These services are not activated automatically, but require explicit authorization by you.

Stripe Account Access (Stripe, Inc.): This service allows the Platform to connect with your account on Stripe for payment processing. Personal data processed: Various types of personal data as specified in the privacy policy of the service. Place of processing: United States.

6.2 Analytics

Google Analytics (Google LLC): Google Analytics is a web analysis service provided by Google LLC. Google utilizes the personal data collected to track and examine the use of this Platform, to prepare reports on its activities, and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

Microsoft Clarity and Microsoft Advertising: We partner with Microsoft to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising.

6.3 Contacting You

Mailing List or Newsletter: By registering on the mailing list or for the newsletter, your email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Platform. Your email address might also be added to this list as a result of signing up to the Service or after making a purchase.

6.4 Displaying Content from External Platforms

Google Fonts (Google LLC): Google Fonts is a typeface visualization service provided by Google LLC that allows this Platform to incorporate content of this kind on its pages.

6.5 Heat Mapping and Session Recording

Hotjar Heat Maps & Recordings (Hotjar Ltd.): Hotjar is a session recording and heat mapping service provided by Hotjar Ltd. Hotjar honors generic "Do Not Track" headers.

6.6 Interaction with External Social Networks and Platforms

Facebook Like Button and Social Widgets (Meta Platforms, Inc.): The Facebook Like button and social widgets are services allowing interaction with the Facebook social network.

6.7 Platform Services and Hosting

Amazon Web Services (AWS): Our Platform is hosted on Amazon Web Services infrastructure. AWS provides cloud computing, database management, and storage services.

6.8 Lead Enrichment and Data Providers

Apollo.io: We integrate with Apollo.io to retrieve and enrich business contact data for Prospects.

6.9 Email Infrastructure and Deliverability

We use third-party email infrastructure providers (such as SendGrid, Mailgun, or similar) to send, monitor, and optimize email deliverability on behalf of our Clients.

7. Place of Processing

Your personal data is processed primarily in our hosted service provider infrastructure (Amazon Web Services) located in the United States. Your data may also be processed by our staff or contractors located in other jurisdictions for technical support and platform maintenance.

We take reasonable steps to ensure that your data is protected by those we trust with access to your data, in accordance with applicable data protection laws.

8. Protection of Your Data

We take appropriate technical and organisational security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of your personal data.

In addition to us, in some cases, your personal data may be accessible to third parties involved with the operation or hosting of our Platform, appointed, if necessary, as data processors by us. The updated list of these parties may be requested from us at any time.

Measures include:

• Encryption of data in transit (TLS/SSL) and at rest
• Access controls and role-based permissions
• Regular security assessments and monitoring
• Secure authentication protocols

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security.

9. Data Retention

Personal data shall be processed and stored for as long as required by the purpose it has been collected for.

• Clients: Personal data collected for purposes related to the performance of a contract between us and the Client shall be retained until such contract has been fully performed, and then after as required for billing, legal, and marketing purposes.
• Prospects: Personal data shall be retained for as long as it is relevant, up to date, and accurate in accordance with our data retention policy.

Once the retention period expires, personal data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after expiration of the retention period.

10. The Rights of Clients and Prospects

You may exercise certain rights regarding your personal data processed by us.

10.1 Do Not Sell / Objection

If you are a Prospect and you follow the "Do not sell my data" link on our Platform, or email us at the address below, we will ensure that your data is never sold or transferred to our Clients by us.

10.2 General Rights

• Access your Data: You have the right to learn if personal data is being processed by us, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the personal data undergoing processing.
• Verify and seek rectification: You have the right to verify the accuracy of your personal data and ask for it to be updated or corrected.
• Restrict the processing of your personal data: You have the right, under certain circumstances, to restrict the processing of your personal data. In this case, we will not process your personal data for any purpose other than storing it.
• Have your personal data deleted or otherwise removed: You have the right, under certain circumstances, to obtain the erasure of your personal data by us.
• Receive your Data and have it transferred to another controller: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
• Lodge a complaint: You have the right to bring a claim before your competent data protection authority. You should first contact us to give us an opportunity to resolve your complaint before it is escalated to a regulator.

10.3 How to Exercise These Rights

Any requests to exercise your rights can be directed to us through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by us as early as possible and always within 30 days. We will ask you to verify your identity before exercising your rights to ensure that you are the correct person.

11. Cookie Policy

Our Platform uses trackers. To learn more, you may consult our Cookie Policy.

12. How "Do Not Track" Requests Are Handled

This Platform does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honor the "Do Not Track" requests, please read their privacy policies.

13. Additional Information About Data Collection and Processing

13.1 Legal Action

Your personal data may be used for legal purposes by us in Court or in the stages leading to possible legal action arising from improper use of this Platform or the related services. You accept that you are aware that we may be required to reveal personal data upon request of public authorities.

13.2 Additional Information About Your Personal Data

In addition to the information contained in this privacy policy, this Platform may provide you with additional and contextual information concerning particular services or the collection and processing of personal data upon request.

13.3 Information Not Contained in This Policy

More details concerning the collection or processing of personal data may be requested from us at any time. Please see the contact information at the end of this policy.

14. International Data Transfers

Your information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

15. Children's Privacy

Our Service is not intended for use by children under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personally identifiable information from children. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.

16. Third-Party Links

Our Platform may contain links to third-party websites and services that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

17. Changes to This Privacy Policy

We reserve the right to make changes to this privacy policy at any time by notifying you on this page and possibly within this Platform and/or — as far as technically and legally feasible — sending a notice to you via any contact information available to us.

It is strongly recommended to check this page often, referring to the date of the last modification listed at the top. Changes to this Privacy Policy are effective when they are posted on this page.

18. Definitions and Legal References

• Personal Data: Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
• Usage Data: Information collected automatically through this Platform (or third-party services employed in this Platform), which can include IP addresses, domain names, URI addresses, time of request, browser and operating system details, time spent on pages, and other parameters about the device environment.
• You: The individual using this Platform who, unless otherwise specified, coincides with the Data Subject and could be either a Client or a Prospect.
• Data Subject: The natural person to whom the personal data refers.
• Data Processor: The natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Controller.
• Data Controller (or Owner): The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. The Data Controller is AWAAS (d/b/a StarLead).
• This Platform: The StarLead web service.
• Service: The service provided by this Platform as described in the relative terms and on this site/application.
• European Union (or EU): Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
• Cookie: Cookies are Trackers consisting of small sets of data stored in your browser.
• Tracker: Tracker indicates any technology — e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting — that enables the tracking of you, for example by accessing or storing information on your device.

19. Contact Us

This privacy policy relates solely to this platform, if not stated otherwise within this document.

If you have any questions about this Privacy Policy, or if you wish to exercise your data protection rights, please contact us:

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