The purpose of these Terms & Conditions is to define the terms and conditions of use of the Services provided by Starton. The Services can be accessed through https://starton.com or other support provided and controlled by Starton.
The Client shall have access to the following Services, in a format and according to the technical means that Starton deems the most appropriate.
From a general point of view, Starton provides an API-platform to connect any application to blockchains. More specifically, Starton offers the Client:
To perform our Services, Starton allows The Client a certain number of Compute Units depending on chosen Services Plan.
Starton takes care and monitors the Services actively and constantly, in order to detect and solve issues immediately.
Upon request of the Client and acceptance of Starton, Starton could deliver specific consultancy services. These services shall be defined by the parties and confirmed by Starton. These services shall be invoiced according to (i) the general principles as set out in the present Agreement and (ii) the prices defined by the parties.
Each Party shall be entitled to display, solely in post-use, on any support, the partnership between Starton and the Client, notably by displaying the logo and text provided by the other Party.
Starton shall create an account in Client’s name, giving Client access to his own personal space which shall enable him to use the Services in a format and according to the technical means that Starton deems the most appropriate for providing said Services.
The Client guarantees that all information he provides for is exact, up to date and sincere and is in no way misleading or dishonest. The Client agrees to immediately update the information in his Personal Space in the event that any of it should change in order to continuously meet the above-mentioned criteria.
The Client is hereby informed and accepts that the information provided by him for the update of his Account is valid as proof of his identity. Details entered by Client shall be binding upon confirmation.
The Client can access his Personal Space by logging in to https://starton.com (or other support provided by Starton) using his connection ID and his password. The Client agrees to use the Services himself personally and agrees not to allow any third party to use him on his behalf, unless accepting full responsibility for the consequences. Any use of the Services with the ID and password shall be deemed made by the according Client.
On the date of termination, The Client retains access to its Personal Space and to the Compute Unit balance available.
In the same way, Client is responsible for keeping his connection ID and password confidential and safe. The Client is fully responsible for all activities that occur under the account.The Client must contact Starton immediately if he notices that his account has been used without his knowledge or any other breaches of security. The Client acknowledges Starton’s right to take all measures it deems appropriate in a case such as this, including (but not limited to) the closing of the account / Personal Space.
Starton will not be liable for any acts or omissions by you, including any damages of any kind incurred as a result of such acts or omissions.
Without prejudice to other obligations provided for in this Agreement, the Client:
- is solely responsible for the use of the Services.
Starton shall have no liability nor warranty resulting from or in relation to:
The Client shall pay compensation for the Services in accordance with the fees set out upon sign up procedure or otherwise agreed. Fees depend on the functional perimeter and the chosen Services Plan. All subscription fees for the Services are based on access rights acquired and extra-usage, and will be invoiced to the Client in accordance with the present Agreement. When starting to use the Services, the Client agrees to lose its right to a refund and waive any cooling off period.
The case may be, the fee for the Subscription is invoiced according to the applicable purchase order, for the period to be delivered. Starton shall email invoices to the Client. The Client shall provide Starton with complete and accurate billing contact information including a valid email address. The Client will make payments according to the Purchase Order via credit card, direct debit or, by default, by electronic bank transfer.
The Client is hereby informed and expressly agrees that any payment delay of all or part of an amount, within the framework of this Agreement, at its due term, shall automatically entail, without prejudice to Starton’s other rights and with a 8 days prior formal notice (or immediately in case of emergency as reasonably estimated by Starton):
All prices and fees are excluding VAT and exclude any other additional applicable taxes and charges.The Client will self-assess and remit all value added taxes payable as required by applicable laws of France. The Client is responsible for paying all taxes.
The duration of the Agreement shall be for an undefined duration.Unless otherwise agreed, The Client has the right to terminate the Agreement with immediate effect
In the event of a breach by a Party of any of the provisions of this Agreement or more generally of the applicable laws, the other Party reserves the right, with a prior formal notice (except in case of serious misconduct as estimated by non- defaulting Party) remained without effect more than 15 days, fully (de plein droit) take any measures it deems appropriate without further formality, and in particular to terminate the Agreement and thus, without prejudice to its other rights.
Starton undertakes to facilitate the reversibility / transferability in the best possible conditions. Reversibility is defined as the actions and modalities Starton must comply with in order to transfer all necessary data to the new operator at due date or when the Agreement has been terminated, whatever the reason of such termination. During this phase, Starton remains in charge of the maintenance tasks and shall take all means to ensure the continuity of service and limit the duration of the reversibility operation, whatever the reason of such termination. The Client notifies Starton (by registered letter) the decision to launch the reversibility operation as well as the identity of the new operator and the wished kick-off date. This notice shall be sent at least 30 days before the wished date. Starton confirms this date or proposes another one. Prices of the reversibility / transferability operations are based on the tariffs applicable at the date of the order by the Client.
As between Starton and the Client, the Client owns all right, title and interest to its data.
As between the Client, Starton and Starton’s licensors, Starton and Starton’s licensors own and reserve all right, title and interest to the Services, documentation, and other Starton IP. Except for the limited rights expressly granted to the Client hereunder, Starton shall retain all rights, title and interest in and to software, documentation and Services including all related IP. Starton keeps the right to fix software. Starton shall have a royalty-free, worldwide, transferable, sub-licensable, irrevocable, perpetual license to use or incorporate into its services any Client input.
Starton only grants to the Client a revocable, non-transferable, non-exclusive and non-sublicensable license to use the Services solely to access Starton platform and within the limits and conditions set out in the present Agreement, and for the duration of the Agreement.
Starton respects the intellectual property of others. If the Client or any third party believes that work has been copied in a way that constitutes copyright infringement, please contact us at email@example.com
8.1 Starton guarantees to the Client that he shall use peacefully the Services during the duration of the Agreement subject to the respect, by the Client, of the present Agreement and the laws. Starton shall have no liability for claims or losses to the extent arising from: (i) modification of the Services by anyone other than Starton; (ii) use of the Services in a manner inconsistent with this Agreement or the documentation or in violation of this Agreement; or (iii) if such loss or claim is in relation to the use of the Services in combination with any other product or service not provided by Starton. Accordingly, Starton shall fully indemnify, hold harmless and defend the Client from and against all claims, demands, actions, suits, damages, liabilities, losses, settlements, judgments, costs and expenses (including but not limited to reasonable attorney's fees and costs), whether or not involving a third party claim based on a European patent or trademark or an unfair competition act, which arise out of (i) any violation of the Agreement or (ii) Client’s use of the Services. This guarantee is subject to the following conditions: (a) the Client must alert immediately Starton, (b) the Client must cooperate and provide Starton with any and all necessary information and elements and (c) Starton shall keep the monopole of the argumentation towards any court or authority.
8.2 Starton agrees to provide the Services with diligence and in compliance with trade practice, specifying that it has an obligation to provide means (obligation de moyens), but this without any obligation of result, and this is expressly acknowledged and agreed by the Client. Services are provided “AS IS” and on an “AS AVAILABLE” basis without warranty or condition of any kind, except expressly provided in the present Agreement.
8.3 Starton’s intervention is limited to the provision of the Services described in Article 2. Starton claims no ownership or control over content stored and/or processed within the context of the Services. Consequently, Starton cannot be held liable for such content. The Client acknowledges and agrees that Starton may communicate and/or suppress from the Services any unlawful content that Starton may have knowledge of, especially (but not limited to) due to a claim from a third party or in case of a court decision. Starton shall make its reasonable efforts to warn the Client before any communication and/or suppression, being understood that, in case of any administrative / judicial procedure, authorities and third parties may demand communication and/or cancellation without any prior notice.
8.4 Each party warrants that it has the authority to enter into this Agreement and, in connection with its performance of this Agreement, shall comply with all applicable laws. Starton warrants that during the term: (i) the Services shall perform materially in accordance with the documentation as set out in https://docs.starton.com/; (ii) the functionality of the Services will not be materially decreased; and (iii) to the best of Starton’s knowledge, the Services do not contain, and Starton will not knowingly introduce, any viruses, worms, time bombs, Trojan horses and other malicious code, files, scripts, agents or programs. Starton does not guarantee the Client (i) that the Services, which are subject to constant research to improve their performance and progress, will be totally free of errors, faults or defects, (ii) that the Services, being standard and not offered specifically to any one given the Client according to that Client’s own personal constraints, shall specifically meet that Client’s needs or expectations. In the event of a breach of the warranty set forth in Section 8.4, Starton shall correct the non-conforming Services at no additional charge to the Client, and if Starton is unable to correct such deficiencies after good-faith efforts, Starton shall refund the Client amounts paid or at the request of the Client, Starton shall respectively reimburse any amounts in proportion to the amounts payable attributable to the defective Service from the date Starton received such notice or the Client shall provide evidence that the defect has occurred. The Client shall notify Starton in writing within thirty (30) days of identifying a deficiency, but Client’s failure to notify Starton within such period shall not affect Client’s right to receive warranty remedies unless and to the extent that Starton is somehow unable to, or impaired in its ability to, correct the deficiency due to Client’s failure to notify. The remedies set forth in this Section 8.4 shall be Client’s exclusive remedy and Starton’s sole liability for breach of these warranties unless the breach of warranty constitutes a material breach of this Agreement, in which case Client may elect to terminate this Agreement in accordance with Clause 13.
8.5 The Client shall fully indemnify, hold harmless and defend Starton from and against all claims, demands, actions, suits, damages, liabilities, losses, settlements, judgments, costs and expenses (including but not limited to reasonable attorney's fees and costs), whether or not involving a third-party claim, which arise out of or relate to (i) any violation of the Agreement, (ii) Client’s use of the Services or (iii) the unauthorized use of the Services. This warranty is determined by the fact that (a) Starton has promptly notified the Client of such demand or action, (b) Starton fully cooperates and provides all information necessary to the Client and (c) the Client and Starton participate in the argument.
8.6 In any event, any liability that could be incurred by Starton within the framework of this Agreement is expressly and solely limited to direct actual damages suffered by the Client and shall not exceed, all faults and damages aggregated, the total amount paid by the Client concerned within the year preceding these damages. Any procedure against Starton must be started within one (1) year following the damage concerned.
THE PARTIES UNDERTAKE TO KEEP AS CONFIDENTIAL, DURING THE TERM OF THIS CONTRACT AS WELL AS 12 MONTHS AFTER ITS END ALL INFORMATION DATA OR DOCUMENTS ISSUED BY ONE OF THE PARTIES TO THE OTHER FOR THE PURPOSES OF THIS CONTRACT. CONFIDENTIAL INFORMATION SHALL INCLUDE, WITHOUT ANY RESERVATION, ANY CONCEPT, TRADE SECRETS, KNOW HOW, INVENTIONS, TECHNIQUES, PROCESSES, PROGRAMS, SCHEMATICS, SOFTWARE SOURCE DOCUMENTS, DATA, CUSTOMER LISTS, FINANCIAL INFORMATION AND SALES AND MARKETING PLANS ("CONFIDENTIAL INFORMATION"). All Confidential Information are considered to be “trade secrets” in accordance with the French Commercial Code. The Parties undertake that the Confidential Information communicated within the scope of the services (i) shall be protected and remain strictly confidential and will not be disclosed either directly or indirectly to any third party and (ii) shall not be reproduced, copied, duplicated either partly or totally, without the prior express Contract of the Party which issued the information and (iii) shall only be communicated to the personnel of the other Party for the purposes of the services and provided that the personnel of the said Party assigned to the services are bound by a confidentiality.
10.1 Starton has the right to amend these Terms and Conditions. The Client shall be informed of any such amendments through a notification via e-mail or via Starton’s web site. The Client shall be regarded as having received the notification at the latest one (1) week from the date on which the notification was sent by e-mail or announced on the web site. If the change has an appreciable adverse effect on the Client, the Client has the right to terminate the Agreement within thirty (30) days of the date on which the notification was regarded as having been received in accordance with the above. If the Client does not terminate the Agreement within the period stipulated above, the Client shall be regarded as having accepted the new Terms and Conditions.
10.2 Starton DPA (Appendix 1) provides for the obligations and rights of the Parties regarding GDPR.
10.3 Starton is fully and resolutely committed to the promotion of CSR and complies with the applicable French legal and regulatory mandatory framework.
10.4 According to the French applicable laws, each Party acknowledges and represents that:
10.5 The Client shall not disclose, transfer, export, or re-export, directly or indirectly, any software (or direct products thereof) provided under this Agreement to any destination, end user, or end use prohibited under the EU Regulation 1334/2000 (as amended) and EU Regulation 428/2009 (as amended) and the applicable national laws or any other applicable export control laws, without the prior written approval of the European Commission, the customs or other relevant agency.
10.6 The Agreement (including any appendix and/or amendment) constitutes the full, complete, final and integrated agreement between the Parties hereto relating to the subject matter hereof and supersedes all previous written or oral negotiations, commitments, agreements, transactions, or understandings with respect to the subject matter hereof. In the event of any inconsistency in respect of any non-technical terms between this Agreement, the terms of this Agreement shall prevail.
10.7 The Parties shall be deemed to be independent contractors, and this Agreement shall not be construed to create between Starton and the Client any other relationship, whether employer-employee, principal-agent, joint-venturer, co-partners or otherwise. Neither Party shall have authority to act for or bind the other Party in any manner, whatsoever. Any contracts and agreements entered into by one Party (but not the other) shall be for that Party’s sole account and risk, and such contracts and agreements shall not bind the other Party in any respect.
10.8 If any provision, including any phrase, sentence, clause, section or subsection, of this Agreement is determined by a court of competent jurisdiction to be invalid, inoperative or unenforceable for any reason, such circumstances shall not have the effect of rendering such provision in question invalid, inoperative or unenforceable in any other case or circumstance, or of rendering any other provision herein contained invalid, inoperative or unenforceable to any extent whatsoever. Upon any such determination, the Parties shall negotiate in good faith to modify this Agreement so as to effect the original intent of the parties as closely as possible in an acceptable manner in order that the transactions contemplated hereby be consummated as originally contemplated to the fullest extent possible.
10.9 No amendment, modification or discharge of this Agreement, and no waiver hereunder, shall be valid or binding unless set forth in writing and duly executed by the Party against whom enforcement of the amendment, modification, discharge or waiver is sought. Any such waiver shall constitute a waiver only with respect to the specific matter described in such writing and shall in no way impair the rights of the Party granting such waiver in any other respect or at any other time. Neither the waiver by any of the Parties hereto of a breach of or a default under any of the provisions of this Agreement, nor the failure by any of the parties, on one or more occasions, to enforce any of the provisions of this Agreement or to exercise any right or privilege hereunder, shall be construed as a waiver of any other breach or default of a similar nature, or as a waiver of any of such provisions, rights or privileges hereunder. The rights and remedies herein provided are cumulative and none is exclusive of any other, or of any rights or remedies that any Party may otherwise have at law or in equity.
10.10 Should any part or provision of this Agreement be held unenforceable or invalid, the invalid or unenforceable provision shall be replaced with a provision which accomplishes, to the extent possible, the original business purpose of such provision in a valid and enforceable manner, and the remainder of this Agreement shall remain binding upon the Parties.
10.11 Except where the context expressly requires otherwise, (a) the words “include”, “includes” and “including” shall be deemed to be followed by the phrase “without limitation”; (b) the word “will” shall be construed to have the same meaning and effect as the word “shall”; (c) any reference herein to any person shall be construed to include the person’s successors and permitted assigns; (d) the words “herein”, “hereof” and “hereunder”, and words of similar import, shall be construed to refer to this Agreement in its entirety and not to any particular provision hereof; (e) all references herein to Sections, Exhibits or Schedules shall be construed to refer to Sections, Exhibits or Schedules of this Agreement, and references to this Agreement include all Appendices hereto; (f) the word “notice” means notice in writing (whether or not specifically stated) and shall include notices, consents, approvals and other written communications contemplated under this Agreement; (g) provisions that require that a Party, the Parties or any committee hereunder “agree,” “consent” or “approve” or the like shall require that such agreement, consent or approval be specific and in writing; (h) references to any specific law, rule or regulation, or article, section or other division thereof, shall be deemed to include the then- current amendments thereto or any replacement or successor law, rule or regulation thereof; (i) the term “or” shall be interpreted in the inclusive sense commonly associated with the term “and/or”, and (j) references herein to this “Agreement” shall be deemed to include any Appendix entered into pursuant hereto, subject to the preceding sentence.
10.12 Neither party shall be liable for any failure or delay in performance under this Agreement for causes beyond that party’s reasonable control and recognized as a force majeure event by the relevant jurisprudence and so occurring without that party’s fault or negligence. Dates by which performance obligations are scheduled to be met will be extended for a period equal to the time lost due to any delay so caused.
10.13. Unless expressly stated otherwise, all notices under this Agreement shall be in writing. Notices to Starton shall be sent to the address shown in the Purchase Order addressed to the attention of the Legal department with a copy sent by email to firstname.lastname@example.org. Notices to Client shall be sent to the address shown in the Purchase Order. Each party may modify its recipient of notices by providing notice pursuant to this Agreement.
10.14. This Agreement is governed by French law.
10.15 IN THE EVENT OF DISPUTE CONCERNING THE VALIDITY, INTERPRETATION AND/OR APPLICATION OF THIS AGREEMENT, ALL PARTIES AGREE TO TRY TO REACH AN OUT-OF-COURT AGREEMENT IN A REASONABLE TIMEFRAME. ACCORDINGLY, ALL DISPUTES ARISING OUT OF OR IN CONNECTION WITH THE VALIDITY, INTERPRETATION, PERFORMANCE, NON-PERFORMANCE OR TERMINATION OF THIS CONTRACT SHALL BE SUBMITTED TO MEDIATION UNDER THE CMAP (CENTRE FOR MEDIATION AND ARBITRATION OF PARIS) RULES OF MEDIATION TO WHICH THE PARTIES UNDERTAKE TO ADHERE. IN THE EVENT OF DISPUTE CONCERNING THE VALIDITY, INTERPRETATION AND/OR APPLICATION OF THIS AGREEMENT, ALL PARTIES AGREE THAT THE COURTS OF PARIS SHALL BE THE ONLY COMPETENT JURISDICTION CAPABLE OF JUDGING THE DISPUTE, SAVE CONFLICTING MANDATORY RULES OF PRACTICE
© Starton – October 2023
The present data processing agreement (“DPA”) completes any contractual document / T&C / contract between Starton and any client. According to the nature of the tools and services of Starton and according to the Guidelines of EDPB dated 7 July 2021, the nature of the processing is stated as follows:
Otherwise specifically expressed in the present DPA, the terms “Authority”, “Personal Data”, “Data Subject”, “BCR”, “Controller”, “Processor”, “Subcontractor”, “Processing” and “Personal Data Breach” shall have the same meaning as in the Regulation 2016/679 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 (“GDPR”).
Applicable data protection Laws: Any and all national, European and international laws, regulations, statutes and other norms, applicable to the Processing of Personal Data set out in the present agreement, including the GDPR, the French law dated 6 January 1978, the applicable e-privacy regulations. Applicable data protection Laws are interpreted by the national Authorities and the EDPB.
Starton GDPR obligations are limited to the following. Starton warrants the Client against any verification, action or procedure raised by a third party based on the following obligations, shall keep the Client harmless and pay all fees, condemnations, attorneys’ fees and other sums that the Client shall bear due to these procedures.
Starton shall process Personal Data only on documented instructions from the Client or according to the Agreement, including with regard to transfers of personal data to a third country, unless required to do so by Union or Member State law to which Starton is subject. In such a case, Starton shall inform the Client of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest.
Starton shall keep and maintain an up-to-dated record of instructions from the Client. This document shall contain the mention provided by article 30 of the GDPR. Furthermore, the Processing implied by the Agreement and/or the Processing provided in this Appendix III shall be deemed as an instruction of the Client and therefore, recorded by Starton.
Although Starton is not a law firm or a law company, shall Starton estimate, in its opinion, that a documented instruction from the Client regarding the Processing infringes the GDPR or other Applicable data protection Law, Starton shall immediately inform the Client, being specified that the Client shall remain the final and sole responsible of the validity of the said instruction.
Starton has implemented internal procedures allowing the demonstration of the respect of the Applicable data protection Laws as Processor.
On a reasonable basis, Starton agrees that the Client may, with a 15 days written prior notice, request information necessary to demonstrate compliance with the obligations laid down in this DPA and, accordingly, send specific questions and requests of documentation. These questions shall be limited to the respect of the Applicable data protection Laws in the framework of the performance of the Agreement. Starton shall answer promptly (and in case within one month). By exception, Starton shall answer within the reasonable timeframes provided in case of request or control of a data protection Authority.
Starton undertakes to assist the Client regarding specific and written request in relation to rights or obligations as provided by articles 32 to 36 of the GDPR, taking into account the Processing concerned and the information available to Starton, and notably:
Accordingly, the Client shall provide Starton with a specific and circumstantial request, allowing Starton to know precisely the nature of the questions and its tasks. Starton shall answer promptly. Parties agrees that should such assistance be beyond an hour per week, Starton shall be entitled to invoice over time according to a 1000€/day rate.
Starton shall perform the Agreement with reasonable efforts (obligation de moyens). However, in case of security breach, Starton undertakes to (i) alert promptly the Client and provide him with reasonable and necessary information (to the extent possible to Starton), (ii) assist the Client and, the case may be, the data protection Authority, and (iii) assist on a reasonable basis the Client for remedies. Starton shall cooperate with the Client in case of request or control of a data protection Authority.
From a general point of view, Starton shall engage another processor without any specific information or authorization from the Client where no Personal Data are concerned. However, in case of sub-contracting for Processing of Personal Data, Starton shall be entitled to engage another Processor with a prior specific notice of the Client. The Client may refuse such sub-contracting for cause (juste motif). Any silence beyond 15 days shall be deemed as a tacit acceptation.
Starton shall only engage another Processor who are able to ensure the compliance of the Processing to the Applicable data protection Laws. Processors shall provide for sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of Applicable data protection Laws and ensure the protection of the rights of the data subject.
Where that other Processor fails to fulfil its data protection obligations, Starton shall remain liable, according to the Agreement, to the Client for the performance of that other processor's obligations.
Starton ensures that persons authorized to process the Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality in the performance of the Agreement.
Accordingly, Starton informs the Client that all employment agreements with employees contain a confidentiality provision as well as supply agreements with Subprocessors, without prejudice to the legal and/or mandatory applicable rules. Furthermore, Starton provided an awareness-raising and training of staff involved in Processing operations.
Should Starton is required to disclose Personal Data by Applicable data protection Law or a court or other tribunal of competent jurisdiction or to a Authority or governmental Authority, Starton shall (to the extent possible to Starton) notify the Client of such obligation and shall reasonably cooperate with the Client to protect the confidentiality of the Personal Data.
Starton has implemented internal procedures allowing the demonstration of the respect of privacy by design principles.
Starton has implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk aiming at:
Accordingly, Starton has taken into account the state of art, the modalities and nature of the Processing as described there before, and the security requirements as provided by French laws applicable to Starton.
Starton shall maintain and update these technical and organizational measures and, the case may be, implement new technical and organizational measures as long as the Agreement is in force.
Starton shall inform the Client of any Personal Data Breach in relation to the Personal Data. This communication shall be “without undue delay after becoming aware of a Personal Data Breach” according to article 33.2 of the GDPR. Starton undertakes to implement and/or propose to the Client any necessary remedy to (i) identify the origin, nature and consequences of such Data Protection Breach and/or (ii) limit or neutralize the consequences.
The information provided to the Client according to the present Section, shall :
Where, and in so far as, it is not possible to provide the information at the same time, the information may be provided in phases without undue further delay.
Starton undertakes to make its reasonable efforts to assist the Client in the framework of its obligations of notification of Personal Data Breach to the applicable Authorities as well as, the case may be, to the Data Subjects.
At the execution date, Starton shall not transfer any Personal Data outside the EU.
Starton shall retain Client’s Personal Data according to the durations defined by the Client and to the Processing specifications as set out therebefore. The Client acknowledges that Starton shall retain the Client’s data for a duration of 12 months as from the end of this Agreement if the Client does not provide for a duration. The Client shall bear sole liability regarding the definition of retention duration. After the duration, Starton shall erase Client’s data. In case of Personal Data erasure, Starton shall keep all necessary evidence of such erasure.
The GDPR obligations of the Client are limited to the following. The Client warrants Starton against any verification, action or procedure raised by a third party based on the following obligations, shall keep Starton harmless and pay all fees, condemnations, attorneys’ fees and other sums that Starton shall bear due to these procedures.
The Client declares and warrants that he has properly (i) informed Data Subjects and provided to them with all mandatory mentions and information regarding their rights and/or (ii) collected the consent of the Data Subjects according to the Applicable data protection Laws.
The Client warrants that he has implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk aiming at:
As controller, the Client undertakes and warrants that he has defined, for each category of Personal Data and each purpose, a retention duration in accordance with the GDPR and the Applicable data protection Laws. The Client undertakes to communicate by written to Starton these durations.
© Starton – October 2023