Privacy Policy

Star Group Services LLC and STAR Group UK Services LLP (collectively “STAR,” “we,” “our,” or “us”) are committed to protecting the privacy and personal information of individuals that use our website (the “Website”) or otherwise interact with us during the ordinary course of operating our business (collectively and as applicable “you” or “your”), including ensuring that your personal information is handled in a safe and responsible manner. This Privacy Policy (the “Policy”) outlines how we collect, use, disclose, and safeguard your personal information and sets out the legal rights that you may be entitled to in relation to the processing our personal information. By using our Website, you acknowledge that your personal information may be collected and further processed in the ways and for the purposes described in this Policy.

Please note that the terms of this Policy do not apply in circumstances where we process personal information exclusively on behalf of a third party, including where we act as a processor or service provider in the context of providing our services. In such circumstances, our privacy obligations will be addressed in a separate agreement with the relevant third party, rather than in this Policy.

Personal information We Collect

The types of personal information that we collect depend on the nature of our relationship with you. We collect personal information and non-personal information to provide our services, improve your experience, and comply with legal obligations. The information we collect includes:

1.1 Website users

When you use or initiate contact with us through the Website then we may collect the following types of personal information:

Contact Information: Name, email address, business phone number, office mailing address, job title and employing organization.
Inquiry Information: other personal information you provide when contacting us or submitting inquiries through forms on the Website, including the nature of your inquiry and the time and manner of submission.
Technical Information: personal information collected through the operation of cookies and similar tracking technologies (collectively “Cookies”) on the Website which may include your IP address, browser type, device information, operating system, pages visited, time spent on the Website, referring/exit URLs and any consent preferences you select in relation to the use of Cookies. Please refer to section 10 of this Policy and our Cookies Policy for more details of how we use Cookies on the Website

1.2 Business contacts

When you interact with us in the ordinary course of operating our business and services, including where you act as a representative of a customer, vendor, service provider or other third party (collectively “business contacts”), then we may process the following types of personal information:

Contact Information: name, business email address, business phone number and office mailing address, job title, job location and details of the organization you represent.
Service Information: personal information that we collect and process in the context of providing or services to you and/or your employing organization.
Relationship Information: personal information collected in order to develop and manage our relationship with you or the organization you represent, including your marketing preferences and details of meetings or events that you attend in relation to our business or services, including CCTV imagery where operational at any of our offices that you attend.
Communications Information: information contained in or related to communications with us.

We do not intentionally process any personal information that includes “sensitive” or “special category” personal information, except in limited cases where we collect information relating to dietary requirements in connection with event catering. Neither our services nor the Website are intended for use by legal minors. We ask that you do not provide any such information to us and that you notify us promptly if you become aware that any such information has been provided to us.

How We Collect Your Personal Information

Most of the personal information that we collect is provided either directly by you or, where you act as a representative of an organization (including your employing organization), by that organization. However, there may be cases where we receive your personal information from another member of our group of companies, from our network of business contacts or from other publicly available sources (such as online professional profiles and social media). To the extent that we collect Technical Information, this is collected automatically based on any consent preferences that you select, including from third party service providers that we engage to enable and improve operation of the Website.

How We Use Your Information

We use the information collected for different purposes depending on the nature of our relationship with you.

We process the personal information of Website users for the following purposes:

To provide, improve and ensure the security of the Website.
To communicate with you, including responding to inquiries and requests.
To obtain your consent in connection with the use of Cookies deployed through the Website or (where applicable) in connection with direct marketing communications, and to manage your consent preferences thereafter.
To personalize your experience on our Website.
To monitor and analyze usage trends and improve Website functionality.
For record-keeping purposes and to conduct statistical analysis in connection with usage of the Website.
To comply with our legal and regulatory obligations.
To seek and receive advice from our professional advisors, including accountants, lawyers, and other consultants.
To safeguard our legal rights and business interests, including by establishing, exercise or defend legal claims or rights such as by enforcing the terms of use of the Website.

We process the personal information of business contacts for the following purposes:

To communicate with you, including responding to inquiries and requests.
To address any due diligence or identity verification requirements that apply, including “know your customer” requirements and any other checks that are required pursuant to applicable law or our internal policies or procedures.
To develop and manage our relationship with you or the organization you represent, including for administration of contractual rights and obligations, for billing and invoicing purposes, to send out periodic updates and news regarding our business, and to organize and conduct meetings and events.
For record-keeping purposes.
To conduct statistical analysis and market research.
To comply with our legal and regulatory obligations.
To seek and receive advice from our professional advisors, including accountants, lawyers, and other consultants.
To safeguard our legal rights and business interests, including by establishing, exercise or defend legal claims or rights.

Please note that the purposes or processing outlined in this section are not mutually exclusive and may be overlapping or complementary, depending on the nature of our relationship with you.

How We Share Your Information

We do not sell or rent your personal information. However, we may share your personal information with the following categories of recipients:

Service Providers: We may share information with trusted third-party service providers, suppliers and business partners who assist us in operating our Website or that provide services to us or on our behalf.
Professional Advisors: We may share your personal information with professional advisors that we engage for specific purposes from time to time, including lawyers, accountants, auditors, and consultants.
Group Companies: We may share your personal information with other companies within out group of companies, in particular where appropriate to facilitate the provision of our services or for our internal purposes.
Legal Compliance: We may disclose your information if required by law or in response to valid legal requests (e.g., subpoenas or court orders), including with regulatory or governmental authorities, law enforcement agencies and courts.
Business Transfers: In the event of a merger, acquisition, or sale of all or part of our assets, your information may be transferred to the acquiring entity, its professional advisors and ultimate beneficial owner.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. Once the applicable retention period has expired then we will securely destroy your personal information in accordance with our data retention policy and procedures.

Please note that in some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case it no longer constitutes your personal information, and we may retain and use such information without further notice to you.

Additional Information for UK and EEA Residents

A. Data controller
The data controller of your personal information is Star Group Services LLC.

B. Our lawful basis of processing
We will only process your personal information where we have a lawful basis of processing, including one or more of the bases set out below.

Legitimate interests. We may process your personal information where necessary in pursuit of our legitimate interests or those of a third party, provided the interests pursued are not outweighed by the risks involved. The legitimate interests relied on may include:
- enabling the provision of our services, our clients’ services, and the Website.
- improving our services and the Website.
- promoting our services, including by providing news and updates and by requesting feedback on your experience of working with us.
- facilitating effective business organization and administration.
- complying with our legal and contractual obligations.
- establishing, exercising, or defending legal claims or rights.
Contractual necessity. We may process your personal information to the extent necessary to enter into a contract with you, or to exercise rights or perform obligations under an existing contract with you.
Legal obligation. We may process your personal information to the extent needed to comply with our legal obligations.
Consent. In rare circumstances, we may process your personal information based on your specific consent. Where this applies, you can subsequently withdraw your consent at any time provided that doing so shall not affect the lawfulness of any processing that has already occurred based on your valid consent.

Please note that where the processing of your personal data is necessary to enter into or perform a contract, or to comply with our legal obligations and you fail to provide such information when requested, this may prevent us from being able to comply with our legal and contractual obligations.

C. Your legal rights
The following rights may be available to you in certain circumstances under applicable data protection laws in your jurisdiction:

Access: Request a copy of the personal information we hold about you.
Correction: Request corrections to any inaccurate or incomplete personal information.
Deletion: Request the deletion of your personal information.
Restriction: Request that we restrict processing of your personal information.
Objection: Object to the processing of your personal information, including by Opting-out of receiving promotional emails by clicking the “unsubscribe” link in our emails or contacting us directly using the contact information provided in this Policy.
Portability. Request that you receive personal information that you provided to us in in a structured, commonly used, and machine-readable format or/and to have this information transmitted to another data controller.
Complaint. While we would welcome the opportunity to resolve any complaints in the first instance, you may have the right to complain to the relevant data protection supervisory authority in your jurisdiction. If you are located in the European Economic Area then details for the relevant data protection supervisory authority can be found here: Our Members | European Data Protection Board. If you are located in the United Kingdom (“UK”), then the relevant supervisory authority is the Information Commissioner’s Office (“ICO”) who can be contacted here: Contact us | ICO.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is

another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

In addition, please note that, while we would not usually charge any fee to access your personal information (or to exercise any of the other statutory rights), we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in certain circumstances.

To exercise these rights or to get more information about when these rights apply, please contact us using the Contact Us form.

D. Safeguarding international transfers
Where the General Data Protection Regulation (including as retained under the domestic law or the UK) applies to transfers of your personal information, then we will only transfer your personal information to a third party located outside of the UK or EEA (as applicable) where:

That jurisdiction has been deemed to provide an adequate degree of protection by the European Commission or UK Government, as appropriate. For more information in this regard, please see the guidance issued by the European Commission (available here) and guidance issued by the ICO (available here).
Personal information may be lawfully transferred under an adequacy framework approved by the relevant supervisory authorities, including where a recipient is certified under the EU-US Data Privacy Framework or the UK Extension to the EU-US Data Privacy Framework. For more information about operation of the EU-US Data Privacy Framework, please see the summary provided by the EU Commission which is available here. For more information about how the UK Extension to the EU-US Data Privacy Framework operates, please see the UK Government’s explainer which can be accessed here.
We have entered into the appropriate form of model contract clauses for the transfer of your personal information, including Standard Contractual Clauses approved for use by the European Commission and model clauses issued by the ICO (including the UK Addendum to the EU Standard Contractual Clauses and the UK International Data Transfer Agreement). More information about the EU Standard Contractual Clauses can be found here and details of UK-specific model clauses can be accessed here.

For more information about the specific safeguards we rely on in this context, please contact us using the Contact Us form.

Additional Information for California Residents

A. Processing of personal information

The information set out in section 1 and section 3 of this Policy respectively describe the categories of personal information that we have collected or disclosed within the preceding 12 months and the purposes for which was used.
Your personal information may have been collected from the sources set out in section 2 of this Policy.
In the preceding 12 months we may have disclosed your personal information to the recipients or categories of recipients set out in section 4 of this Policy.
We have not “sold” personal information as defined by the California Consumer Privacy Act 2020 as amended (“CCPA”). For this purpose, “sold” or “sale” means the disclosure of personal information for monetary or other valuable consideration but does not include, for example, the transfer of personal information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

B.Your legal rights
You have the right to request that we disclose what information we collect, use, disclose and sell. Specifically, you may request that we:

Disclose to you the following information covering the 12 months preceding your request:
- The categories of personal information we collected about you and the categories of sources from which we collected such information;
- The specific pieces of personal information we collected about you;
- The business or commercial purpose for collecting (if applicable) personal information about you; and
- The categories of personal information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such personal information (if applicable).
Delete personal information we collected from you.

We will respond to your request in a manner consistent with applicable law and you have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Please note that you must provide us with enough information that we can verify your identity and that you are a California resident. If you designate an authorized agent to make an access or deletion request on your behalf, we may require the agent to show written authorization from you and require you to verify your identity with us.

You can make a request based on the rights described above by contacting us:

Using the Contact Us form on the Website available here
Toll-free telephone number: [TBD]

Additional Information for Canadian Residents

By law you have the right to request access to and to correct the personal information that we hold about you. If you want to review, verify, correct, or withdraw consent to the use of your personal information, or to request access to, correct, or delete any personal information that you have provided to us, then please email us at Contact Us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Please note that we may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact us using the Contact Us form.

Cookies and Tracking Technologies

We use Cookies to support and secure the Website, as well as to improve functionality and enhance your user experience on. For more information about how we use Cookies on the Website, please refer to our Cookie Policy. Please note that we do not currently honor “Do Not Track” signals that may be applied through your browser settings, unless otherwise required by applicable law.

Third-Party Links

Our Website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to review their privacy policies before providing any personal information.

Please note also that the security of internet transmission cannot be guaranteed, and we do not accept responsibility for the security of personal information that you submit over the internet, including when using the Website.

International Users

If you are accessing our Website from outside your country of residence, please note that your information may be transferred to and processed in a country that may not have the same data

protection laws as your home jurisdiction. In particular, by using our Website, you acknowledge that your personal information may be processed in any jurisdiction where we or our affiliates operate, including the United States of America.

Your Duty to Inform Us of Changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Amendment of this Policy

We may update this Policy from time to time to reflect changes in our practices or legal requirements. The updated policy will be posted on this page with the date of last revision, and we encourage you to review this page periodically, so that you are fully aware of how we use your personal information. In the event that we make material changes to this terms of this notice then, to the extent possibly and as legally required, we will notify you of such changes.

Contact Us

If you have any questions or concerns about this Privacy Policy or how we handle your personal information, please contact us using the Contact Us form provided.

By using our Website, you acknowledge that you have read and understood this Privacy Policy. Thank you for trusting Star Group Services LLC with your information.

Last revised: February 2025