• Exostar Privacy Policy - English

    (Effective May 1, 2016)


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  • For the convenience of Exostar subscribers and visitors to the Exostar site, we may provide translations of the following in other languages. In such case, we will use reasonable efforts to provide accurate translations; however, Exostar does not guarantee the accuracy of any translation from the English and under no circumstance should any translation be relied upon without independent verification. Only the English language version is binding. 

    Tthis Privacy Policy sets forth the policy of Exostar LLC ("Exostar") with respect to the privacy of information Exostar collects from its visitors and registered users (collectively, "users") on the web based trading exchange located on the Internet at http://www.exostar.com (the "Exostar Portal").

    1. COLLECTION AND USE OF INFORMATION

    A. Registration Information. In order to become a registered user on the Exostar Portal, a user must first register and provide certain contact information and information about the user's company (collectively, "Registration Information"). Exostar uses the Registration Information to communicate with users about maintenance updates to the service, and community adoption updates through newsletters or direct email campaigns. As Exostar’s service provides value to the community through increased adoption by other community members, Exostar reserves the right to disclose the name of the user’s company (without identifying the user) to other users and to potential community members in order to promote community membership. Exostar may also include the Registration Information in a User Directory for distribution to other users (please see section 4 below for details on how to opt out of the User Directory). Except as provided in this Privacy Policy, Exostar will not disclose Registration Information to third parties without the consent of the applicable user.

    B. User Information. Users communicate and exchange information with Exostar and other users in connection with their business relationship with each other and with Exostar (collectively, "User Information"). User Information includes, without limitation, information submitted to the Exostar Portal or others via online communications facilitated by the Exostar Portal. Except as provided in this Privacy Policy or with the consent of the applicable user, Exostar will not disclose User Information to third parties or to Exostar users other than ones to which the User Information was communicated.

    C. Tracking Information. When a user accesses the Exostar Portal, the Exostar Portal captures, records and retains general data about such user's usage of the Exostar Portal including, without limitation, the user's domain name, the web page(s) from which the user entered the Exostar Portal, the web page(s) which the user visited on the Exostar Portal, and the amount of time the user spent on each web page of the Exostar Portal (collectively, "Tracking Information"). Exostar uses such information to determine the demographics of users and to develop and distribute to third parties statistics and general information about the Exostar Portal. Except as provided in this Privacy Policy, Exostar will not disclose Tracking Information in a manner that reasonably permits such information to be identified with an individual user or specific user transaction.

    D. Cookies. A "Cookie" is a small piece of information sent by a web server to be stored on a web browser so it can later be read back from that web browser. The information collected from Cookies is currently used to improve the functionality of the Exostar Portal. The information on the Exostar Portal is organized and presented based on Exostar's analysis of the aggregate usage of the site. Cookies are also useful in allowing more streamlined log-in for users. Cookies may play an integral part in assuring that information provided to users will reflect their preferences and be most relevant to their needs. If a user disables Cookies, he/she may not be able to log into the Exostar Portal.

    E. Other Information. A user may choose to send Exostar a question via e-mail, register for a special service or otherwise communicate with Exostar. Exostar uses such information to communicate with users and to enhance the Exostar Portal to better meet the needs of users. Except as provided in this Privacy Policy, Exostar will not disclose such information in a manner that reasonably permits such information to be identified with an individual user or specific user transaction.

    F. Sale of Company. In the unlikely event of a sale of Exostar or its assets, Exostar is likely to disclose Registration Information, User Information and Tracking Information to the new owners, subject to a requirement that such information be used only in accordance with this Privacy Policy.

    2. DISCLOSURE OF AGGREGATED DATA

    Exostar reserves the right to use, develop, analyze and disclose information in aggregated form that does not reasonably identify an individual user or specific user transaction on the Exostar Portal ("Aggregated Data") using Registration Information, User Information, Tracking Information and other user data collected, retained, stored or accumulated through the Exostar Portal, for internal and commercial purposes, including without limitation: (i) developing and making available to third parties aggregated information regarding trends, purchasing patterns and retail intelligence and research; (ii) performing its duties and obligations under agreements with third party licensors or other users; (iii) internal record keeping and internal reporting by Exostar; (iv) measuring the performance of third-party licensors and service providers; and (v) reporting performance and other statistical information concerning the Exostar Portal. Exostar will not disclose Aggregated Data in a manner that reasonably permits such information to be identified with an individual user or specific user transaction.

    3. DISCLOSURE UNDER LAW

    Exostar may disclose Registration Information, User Information or Tracking Information if Exostar is required to make such a disclosure under applicable laws. In addition, Exostar reserves the right to disclose a user's Registration Information, User Information, Tracking Information and other data collected, retained, stored or accumulated through a user's use of the Exostar Portal to report a violation or suspected violation of applicable laws to governmental authorities to which notification is appropriate or may be required.

    4. OPT OUT

    Participation in the Exostar Portal is voluntary. To opt out of processing of personal data pursuant to this Privacy Policy, a user should send an e-mail to Exostar at  privacypolicy@exostar.com as follows:

    • To opt out of the User Directory, the e-mail subject line should state “Opt Out Directory” and the body of the e-mail shall include the Exostar-issued ID number; 
    • To opt out of receiving marketing communications from Exostar, the e-mail subject line should state “Opt Out Communications” and the body of the e-mail shall include the Exostar-issued ID number (if applicable); and 
    • To opt out of both of the above, the e-mail subject line should state “Opt Out All” and the body of the e-mail shall include the Exostar-issued ID number (if applicable). 

    Notwithstanding any such opt-out request, Exostar reserves the right to continue to process user data for purposes related to Aggregated Data as set out in paragraph 2.

    5. QUESTIONS, ACCESS AND COMPLAINTS

    Users may contact Exostar at privacypolicy@exostar.com with (i) questions about this Privacy Policy, (ii) requests to review, change, update, or delete information previously provided and/or (iii) complaints about this Privacy Policy or its implementation.

    6. INTERNATIONAL TRANSFERS AND SAFE HARBOR

    Exostar transfers information between the countries where its users are based and its servers in the United States, in accordance with the principles set forth in this Privacy Policy.

    Exostar complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland (the “Safe Harbors”).  Exostar has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  Exostar has committed to cooperate with EU and Swiss data protection authorities in any enforcement action under the respective Safe Harbor Frameworks.  To learn more about the Safe Harbors, and to view Exostar's certification, please visit http://www.export.gov/safeharbor/. Since the effect of the Safe Harbors was substantially limited by the European Court of Justice Schrems decision, Exostar has adopted alternate approaches based on consent and model contract clauses for transfers of personal data from the EU and Switzerland, and is monitoring the negotiations to replace the Safe Harbors.

    7. UPDATES TO THE PRIVACY POLICY

    Updates to the Privacy Policy will be posted on the Exostar Portal and this page and will be effective upon posting. Exostar will take reasonable steps to inform users of such updates.