EFFECTIVE DATE: April 30, 2021
If you are a California resident or a resident of the European Union, additional provisions may apply to you as set forth the California Privacy Notice and GDPR Notice provisions below.
The Information We Collect About You
We collect information about you directly from you and from third parties, as well as automatically through your use of our Site or Services.
Information We Collect Directly From You: You may browse certain areas of the Site without registering with us or providing us personal information. If you register for our Services, then you must provide your first name, last name, email address, company name, and phone number. In addition, we collect your personal information in the following other ways: such as through job applications you submit, contact forms you complete, and cookies.
In addition, if you are providing personal information for third parties in connection with using our Services, you are responsible for ensuring that you have all required permissions and consents to provide such personal information to us for use in connection with the Services and that our use of such personal information to provide the Services does not violate any applicable law, rule, regulation or order.
Account information for third party services: We also use social buttons provided by services like Twitter, Google+, LinkedIn and Facebook. Your use of these third party services is entirely optional. If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services (e.g., Facebook Connect), or if you share content from our Services through such third party service, the applicable third party service will send us certain personal information (specifically your first name, ID, token and profile picture URL) if the third party service and your account settings allow such sharing. The personal information we receive will depend on the policies and your account settings with the applicable third party service. We process this personal information based on our legitimate business interest of personalizing and optimizing the Services to improve user experience.
Information from our advertising partners: We receive information about you from some of our service providers (e.g., LinkedIn) who assist us with marketing or promotional services related to how you interact with our Site, Services, advertisements or communications. We process this personal information based on our legitimate business interest in providing direct marketing about our products and Services.
How We Use Your Information
We use your information, including personal information, for the following purposes:
Provide our Site and Services
We use your information to provide our Site and Services, communicate with you about your use of our Site and Services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
Provide personalized services
We use your information to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site and Services.
Improve and Develop our Site and Services
We use your information to ensure our Site and Services are working as intended, to better understand how users access and use our Site and Services, both on an aggregated and individualized basis, to detect and correct errors, to make improvements to our Services, to develop new Services, and for other research and analytical purposes.
Marketing and Promotion
We use your information for marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or contact you about products or information we think may interest you. We may in the future provide customized or targeted advertisements to you based upon your personal information (including usage statistics and characteristics), in which case we may allow third party applications to access such data for the purpose of customizing messages or advertising for you. We also may use the information that we learn about you to assist us in advertising our Services on third party websites.
How We Share Your Information
We may share your information, including personal information, as follows:
- Consent. Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your StarTree account or when you participate in promotional activities conducted by StarTree partners or third parties.
- Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries solely for the purpose of providing Services to you; however, if we do so, their use and disclosure of your personally identifiable information will be maintained by such affiliates and subsidiaries in accordance with this Policy.
- Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. These parties include, but are not limited to: (a) analytics service providers; (b) staff augmentation and contract personnel; and (c) hosting service providers.
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, or are in negotiations for any of these types of transactions, we may transfer the information we have collected from you to the other company.
- In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
- Aggregate and De-Identified Information. We may share aggregate or de-identified information about users and their use of the Services with third parties and publicly for marketing, advertising, research or similar purposes.
Please note that except as noted above, we will not sell or share your personal information with any third party for their direct marketing purposes without your consent.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. We may also use Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Services. The Site and Services use the following cookies:
- Essential Cookies. Essential cookies are required for providing you features or services that you have requested. For example, certain cookies enable you to log into secure areas of our Site. Disabling these cookies may make certain features and services unavailable
- Functionality Cookies. Functional cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Performance/Analytical Cookies. Performance/analytical cookies allow us to understand how visitors use our Site and Services such as by collecting information about the number of visitors to the Site, what pages visitors view on our Site, and how long visitors are viewing pages on the Site. Performance/analytical cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
- Retargeting / Advertising Cookies. Retargeting/advertising cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
Most browsers automatically accept cookies but have an option for blocking or deleting cookies, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. You can usually access these options through the “Settings” or similar menu in your browser. For more information about cookies, including how to see what cookies have been set and how to manage and delete cookies, visit www.aboutcookies.org or www.allaboutcookies.org. Please note that if you block or delete cookies, some portions of the Services may not work properly. In some cases, cookies may enable us to aggregate certain information with other personal information we collect and hold about you.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will not be able to browse certain areas of the Site or use the Services.
Third Party Analytics
Third-Party Links and Services
Our Site and Services may contain links to third-party websites or services (“Third-Party Services”). Any access to and use of such Third-Party Services is not governed by this Policy, but instead is governed by the privacy policies of those Third-Party Services. We are not responsible for the information practices of such Third-Party Services.
Security of My Personal Information
We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
What Rights Do I Have Regarding My Personal Information
You may request access, a copy, modification or deletion of personal information that you have submitted to us by contacting us at email@example.com. We will use reasonable efforts to accommodate such requests to the extent required by law, provided that we may be required to retain personal information to comply with legal obligations, accounting requirements, or for other business purposes. We may request additional information to verify the identity of the requesting party before responding to a request. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.
What Choices Do I Have Regarding Use of My Personal Information for Marketing?
We may send periodic promotional or informational emails to you. We may also use technology to alert us via a confirmation email when you open an email from us. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us.
Location of Information
Our Site and Services are offered from the United States. We store any information we collect in the United States. If you access the Services or Site from outside the United States, you agree to the transfer of your information to the United States, which may have less protections for your personal information than your jurisdiction of residence.
Our Site and Services are not designed for children under 13 or under 16 if you are a resident of the European Union, United Kingdom, Lichtenstein, Norway, or Iceland. If we discover that a child under 13 (or 16 in the case of the other countries listed) has provided us with personal information, we will delete such information from our systems. If we learn that we have collected personal information from a child under the ages listed above, we will delete that information as quickly as possible. If you believe that a child under these ages may have provided us personal information, please contact us at firstname.lastname@example.org.
If you have questions about the privacy aspects of our Site or Services or would like to make a complaint, please contact us at email@example.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on the Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site or if you have an account with us, providing notice to the email address in your account (for this reason you should make sure to update your account information promptly if it changes).
CALIFORNIA PRIVACY NOTICE
Under California Civil Code § 1798.83, California residents who have provided personal information to StarTree may obtain information regarding StarTree’s disclosures, if any, of personal information to third parties for third-party direct marketing purposes. Requests must be submitted to the following address: firstname.lastname@example.org. Within 30 days of receiving such a request, we will provide a California Privacy Disclosure, which will include a list of certain categories of personal information disclosed during the preceding calendar year to third parties for their direct marketing purposes, along with the names and addresses of the third parties. This request may be made no more than once per calendar year.
This Notice applies to data subjects of the European Union and the United Kingdom. It describes certain rights such residents have with respect to the processing of your personal information, pursuant to the European Union General Data Protection Regulation 2016/679 and its amendments (“GDPR”)(and for UK residents the application of those principles under the UK Data Protection Act).
The controller of personal information collected through the Site is StarTree, Inc. 148 Castro St, B20, Mountain View, CA, 94041
LEGAL BASIS FOR PROCESSING OF PERSONAL INFORMATION
We process the personal information collected for the purposes described in the sections entitled “The Information We Collect About You” and “How We Use Your Information” in our Policy. The legal basis for our processing activities include the following:
- processing personal information as necessary to comply with our contractual obligations, such as processing a transaction with you;
- compliance with our legal obligations;
- our legitimate business interests, such as developing and improving our Site and Services and the marketing and promotion of our Site and Services; and
- pursuant to your consent. If we rely on your consent, you may withdraw that consent at any time by emailing us at email@example.com. Such withdrawal shall not affect the processing of your personal information prior to receipt of the withdrawal.
The particular legal basis for the processing of your personal information is based on the purpose for which such information was provided or collected.
We retain personal information about you for the time necessary to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship and for any period thereafter as legally required or permitted by applicable law. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally. Our retention policies reflect applicable statute of limitation periods and legal requirements.
DATA SUBJECT RIGHTS
Data subjects of the European Union have the following rights:
- Access, Correction and Erasure Requests: You have the right to:
- contact us to confirm whether we are processing your personal information
- receive information on how your personal information is processed
- obtain a copy of your personal information
- request that we update or correct your personal information
- request that we delete personal information in certain circumstances
- Right to Object to Processing: You have the right to request that we cease processing of your personal information for marketing activities, including profiling for statistical purposes where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your personal information for the establishment, exercise or defense of a legal claim.
- Right to Restrict Processing: You have the right to request that we limit the processing of your personal information:
- while we are evaluating or in the process of responding to a request by you to update or correct your personal information where such processing is unlawful and you do not want us to delete your data
- where we no longer require such data, but you want us to retain the data for the establishment, exercise or defense of a legal claim
- where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request
- Data Portability Requests: You have the right to request that we provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.
If you believe our processing of your personal information violates data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged violation. Residents of the United Kingdom can lodge a complaint with the Information Commissioner’s Office.
Submitting GDPR Requests: You can submit requests contacting us at firstname.lastname@example.org. We will respond to all such requests within 30 days of our receipt of the request, unless there are extenuating circumstances, in which event we may take up to 60 days to respond. We will inform you if we expect our response to take longer than 30 days. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity. We may charge you a reasonable fee for subsequent copies of personal information that you request. In addition, if we consider that a request is manifestly unfounded or excessive, we may either request a reasonable fee to deal with the request or refuse to deal with the request.