GDPR Privacy Notice
Introduction & Scope
Great North Star International INC. is committed to protecting the
privacy and security of your personal information (collectively
referred to as "the Company", "we",
"us" or "our").
This Privacy Notice ("Notice") describes how we collect
and use personal information about you during and after your
contractual relationship with us, in accordance with the General
Data Protection Regulation ("GDPR").
This Notice applies to all past, present and prospective customers
of the Company located in the EU (collectively referred to as
"Customers", "you" or "your")
including our website users and certain third parties such as your
permitted agents or representatives. This Notice does not form part
of any contract to provide services you may have with the Company
from time to time.
It is important that you read this Notice, together with any other
privacy notice we may provide on specific occasions when we are
collecting or processing personal information about you, so that
you are aware of how and why we are using such information.
We reserve the right to amend this Notice at any time without
notice to you so, if required, please check to ensure that you are
referring to the latest copy of this Notice. We may also notify you
in other ways from time to time about the processing of your
Great North Star International INC of PH Molon Tower, Piso 5 A,
Calle Aquilino de la Guardia, El Dorado, Panama City, Panama is a
"data controller" for the purposes of the GDPR. This
means that we are responsible for deciding how we hold and use
personal information about you. If you have any questions about
this Notice or how we handle your personal information, please
write to the "Data Privacy Manager" at the above
address, or alternatively, email us at email@example.com.
You have the right to make a complaint at any time to the relevant
supervisory authority of your member state. We would, however,
appreciate the chance to deal with your concerns before you
approach the relevant supervisory authority so please contact us in
the first instance.
Data protection principles
We will comply with data protection law. This says that the
personal information we hold about you must be:
Used lawfully, fairly and in a transparent way.
Collected only for valid purposes that we have clearly explained
to you and not used in any way that is incompatible with those
Relevant to the purposes we have told you about and limited only
to those purposes.
Accurate and kept up to date.
Kept only as long as necessary for the purposes we have told you
The kind of information we hold about you
Personal data, or personal information, means any information about
an individual from which that person can be identified. It does not
include data where the identity has been removed (anonymous data).
There are also "special categories" of more sensitive
personal data which require a higher level of protection.
may collect, use, store and transfer different kinds of Personal
Data about you which we have grouped together as follows:
includes title, first name and last name;
includes billing address, shipping address, email address and
Financial Data includes bank account details and payment
Transaction Data includes details of products you have
purchased from us and details about payments to and from you;
Technical Data includes internet protocol (IP) address,
your login data, browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and
platform and other technology on the devices you use to access our
website and any other information obtained through electronic
Usage Data includes information about how you use our
website, products and services.
We also collect, use and share Aggregated Data such as
statistical or demographic data for any purpose. Aggregated Data
may be derived from your personal data but is not considered
personal data in law as this data does not directly or
indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect
Aggregated Data with your personal data so that it can directly or
indirectly identify you, we treat the combined data as personal
data which will be used in accordance with this Notice.
We do not collect any Special Categories of Personal Data
about you (this includes details about your race or ethnicity,
religious or philosophical beliefs, sex life, sexual orientation,
political opinions, trade union membership, information about your
health and genetic and biometric data). Nor do we collect any
information about criminal convictions and offences.
How is your personal information collected?
We collect personal information about you when you correspond with
us directly either by filling in our order forms or by contacting
us by post or email.
We also automatically collect personal information about you as you
interact with our website including data about your equipment,
browsing actions and patterns. We collect this personal data by
using cookies, server logs and other similar technologies, as
almost all websites do, to help provide you with the best
experience we can. You can set your browser to refuse all or some
browser cookies, or to alert you when websites set or access
parts of our website may become inaccessible or not function
How we will use information about you
We will only use your personal information when the law allows us
to. Most commonly, we will use your personal information in the
Where we need to perform the contract we have entered into with
Where we need to comply with a legal obligation.
Where it is necessary for our legitimate interests (or those of a
third party) and your interests and fundamental rights do not
override those interests.
We may also use your personal information in the following
situations, which are likely to be rare:
Where we need to protect your interests (or someone else's
Where it is needed in the public interest or for official
Generally, we do not rely on consent as a legal basis for
processing your personal data and we may process your personal data
without your knowledge or consent, in compliance with the above
rules, where this is required or permitted by law.
Situations in which we will use your personal information
We need all the categories of information in the list above
primarily to allow us to perform our agreement with you and to
enable us to comply with our legal obligations. In some cases we
may use your personal information to pursue legitimate interests of
our own or those of third parties, provided your interests and
fundamental rights do not override those interests.
The situations in which we will most commonly process your personal
information are listed below:
to register you as a new customer;
to process and deliver your orders;
managing the payment of fees and charges;
responding to, or following up on, your comments and questions,
and otherwise providing customer service;
updating and enhancing customer records;
analysis for management purposes and the improvement of our
administering and protecting our business and website;
asking you to leave a review or take a survey;
to monitor your use of our information and communication systems
to ensure network and information security, including preventing
unauthorised access to our computer and electronic communications
delivering relevant website content;
using data analytics to improve our website, products, services,
marketing, customer relationships, and experiences,
crime prevention; and/or
legal and regulatory compliance.
Some of the above grounds for processing will overlap and there may
be several grounds which justify our use of your personal
If you fail to provide personal information
Where we need to collect personal data by law, or under the terms of
a contract we have with you and you fail to provide that data when
requested, we may not be able to perform the contract we have or are
trying to enter into with you. In this case, we may have to cancel a
contract you have with us but we will notify you if this is the case
at the time.
Change of purpose
We will only use your personal information for the purposes for which
we collected it, unless we reasonably consider that we need to use it
for another reason and that reason is compatible with the original
purpose. If we need to use your personal information for an unrelated
purpose, we will notify you and we will explain the legal basis which
allows us to do so.
We do not envisage any decisions will be taken about you by automated
means, however we will notify you in writing if this position
changes. Automated decision-making takes place when an electronic
system uses personal information to make a decision without human
may have to share your Data with third parties. We will only share
your Personal Data with third parties where required by law, where
it is necessary to administer your contract or where we have
another legitimate interest in doing so.
"Third parties" includes third-party service providers
such as our contractors, suppliers and designated agents. We may
also need to share your personal information with a regulator or to
otherwise comply with the law.
In particular, the following third party service providers may
process personal information about you for the following purposes:
CCNow, Inc., 333 Washington Ave. North Suite 300, Minneapolis, MN
55401, United States - to facilitate the online payment of your
Shipping and Delivery Companies (both national and international)
- to facilitate the delivery of your purchased goods.
parties in the United Kingdom and the EU are subject to the
provisions of the GDPR or similar regulations in relation to your
Our third-party service providers are required to take appropriate
security measures to protect your personal information and we do
not allow our third-party service providers to use your personal
data for their own purposes. We only permit them to process your
personal data for specified purposes and in accordance with our
outside the EU
GDPR restricts data transfers to countries outside the EEA in order
to ensure that the level of data protection afforded to individuals
by the GDPR is not undermined. We transfer personal data
originating in one country across borders when we transmit, send,
view or access that data in or to a different country.
may transfer Personal Data outside the EEA if one of the following
European Commission has issued a decision confirming that the
country to which we transfer the personal data ensures an adequate
level of protection for the data subjects' rights and freedoms;
safeguards are in place such as binding corporate rules (BCR),
standard contractual clauses approved by the European Commission,
an approved code of conduct or a certification mechanism;
have provided explicit consent to the proposed transfer after
being informed of any potential risks; or
the transfer is necessary for one of the other reasons set out in
the GDPR including the performance of your contract with us,
reasons of public interest, to establish, exercise or defend legal
claims or to protect your vital interests where you are physically
or legally incapable of giving consent and, in some limited cases,
for our legitimate interest.
The Company carries out its business in Panama. Accordingly, we
will process your data outside of the EEA for the purposes of
processing and delivering your orders. If
you have any questions about the safeguards in place that allow us
to process your data outside the EEA, please contact the Data
Privacy Manager directly.
The GDPR requires us to put in place procedures and technologies to
maintain the security of all personal data from the point of
collection to the point of destruction. We ensure that reasonable
security measures are taken against unlawful or unauthorised
processing of personal data, and against the accidental loss of, or
damage to, personal data.
We have also put in place procedures to deal with any suspected
data security breach and will notify you and any applicable
regulator of a suspected breach where we are legally required to do
If you have any questions about our current organisational and
technical security procedures, please contact the Data Privacy
How long will you use my information for?
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
To determine the appropriate retention period for personal data, we
consider the amount, nature, and sensitivity of the personal data,
the potential risk of harm from unauthorised use or disclosure of
your personal data, the purposes for which we process your personal
data and whether we can achieve those purposes through other means,
and the applicable legal requirements.
In some circumstances we may anonymise your personal information so
that it can no longer be associated with you, in which case we may
use such information without further notice to you.
Rights of access, correction, erasure, and restriction
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.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known
as a "data subject access request"). This enables you to
receive a copy of the personal information we hold about you and
to check that we are lawfully processing it.
Request correction of the personal information that we hold
about you. This enables you to have any incomplete or inaccurate
information we hold about you corrected.
Request erasure of your personal information. This enables
you to ask us to delete or remove personal information where there
is no good reason for us continuing to process it. You also have
the right to ask us to delete or remove your personal information
where you have exercised your right to object to processing (see
Object to processing of your personal information where we
are relying on a legitimate interest (or those of a third party)
and there is something about your particular situation which makes
you want to object to processing on this ground. You also have the
right to object where we are processing your personal information
for direct marketing purposes.
Request the restriction of processing of your personal
information. This enables you to ask us to suspend the processing
of personal information about you, for example if you want us to
establish its accuracy or the reason for processing it.
Request the transfer of your personal information to
If you want to review, verify, correct or request erasure of your
personal information, object to the processing of your personal
data, or request that we transfer a copy of your personal
information to another party, please contact the Data Privacy
Manager in writing.
No fee usually required
You will not have to pay a fee to access your personal information
(or to exercise any of the other rights). However, 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
What we may need from you
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.
Right to withdraw consent
In the limited circumstances where you may have provided your consent
to the collection, processing and transfer of your personal
information for a specific purpose, you have the right to withdraw
your consent for that specific processing at any time. To withdraw
your consent, please contact the Data Privacy Manager. Once we have
received notification that you have withdrawn your consent, we will
no longer process your information for the purpose or purposes you
originally agreed to, unless we have another legitimate basis for
doing so in law.
If you have any questions about this Notice, please contact the
Data Privacy Manager.