Privacy Policy

Our Privacy Policy

This Privacy Policy applies when StarterStudio is the controller of your Personal Data as described in this Privacy Policy. This Privacy Policy does not apply to the extent we process Personal Data in the role of a processor on behalf of our customers, including when we offer to our customers various services through which our customers and/or their affiliates collect, use, share or process Personal Data via our services. For detailed privacy information related to where a StarterStudio customer and/or a customer affiliate who uses the StarterStudio services is the controller, please reach out to the respective customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those set forth in this Privacy Policy. Also, please see “Your Rights Relating to Customer Data” below.

What Information do We Collect Directly from You?
We collect information (including Personal Data) from you when you fill out a form on our site, including the “Contact” form, register to use our site, sign up for an event or webinar, or download certain content. In those cases, you may be asked to enter your contact information, which may include your name, title, e-mail address, username, password, phone number, address, your organization name and number of employees. You may, however, visit our site anonymously. In addition, if you register for an event or webinar, it may necessary for you to provide us your billing information, such as billing name, address, credit card or bank account information. If you attend one of our in-person events (such as the Entrust Conference), we may, without requesting additional consent, scan your attendee badge, which will provide us your information such as your name, title, company name, address, phone number and email address. If you visit our offices, you may be required to register as a visitor and provide your name, title, email address, phone number, organization name, time and date of arrival and information about the party you are visiting.

What Device and Use Data do We Process?
In addition, we gather certain information automatically as part of your use of our services. This information may include IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files viewed, searches and other actions you take, usage data and error logs for your login sessions so that our services can ‘talk’ to your device while you are logged in, operating system and system configuration information and date/time stamps associated with your usage. If you use certain features of our services on a mobile device, we may also collect device event information (such as crashes, system activity, hardware settings, browser language), attributes of your device (such as model, type, language, operating system), and location information (through IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers). This information is used to maintain the security of the services, to provide necessary functionality, as well as to improve performance of the services, to assess and improve customer and user experience of the services, to review compliance with applicable usage terms and conditions, to identify future opportunities for development of the services, to assess capacity requirements, to identify customer opportunities and for the security of our company in general (in addition to the security of our products and services). Some of the device and usage data collected within the services, whether alone or in conjunction with other data, could be personally identifying to you. Please note that this device and usage data is primarily used for the purposes of identifying the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers (where we act as a processor).

What do We Use your Information for?
Any of the information (which includes Personal Data) we collect from you may be used in one of the following ways:
* To personalize your experience of the site and services: Your information helps us to better respond to your individual needs;
* To provide and improve our website and services: We continually strive to improve our website offerings based on the information and feedback we receive from you.
* To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
* To perform our agreement with you for the use of our website and services and to fulfill our obligations under applicable terms and conditions of use/service; where we have not entered into an agreement with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our websites and to provide you with the necessary functionality required during your use of the websites and services and to provide you with the content you access and request;
* To manage your registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
* To manage payments: If you have provided financial information to us, we process Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete the transaction and perform our contract with you;
* To review compliance with applicable terms of use: We may process your Personal Data to review compliance with the applicable terms and conditions in our customer’s agreement, to the extent that it is in our legitimate interest to ensure compliance with the relevant terms;
* To administer a contest, promotion, survey or other site feature, to the extent you registered for the same;
* To send information to the email address you provided for order processing and updates pertaining to your order;
* To fulfill your request and communicate with you, if you fill out the “Contact” form or otherwise request user support, or if you contact us by other means including via phone call, we will process your Personal Data to the extent necessary to perform these tasks;
* To send emails to you that may include company news, updates, related product or service information, to the extent you provided prior consent; Note: If at any time you would like to unsubscribe from receiving future emails, we include easy to understand unsubscribe instructions at the bottom of each email; * To manage event registrations and attendance: We process your Personal Data to plan, host and operate events or webinars for which you have registered or that you attend, including sending related communications to you, to perform our agreement with you;
* To register office visitors: We need to process your Personal Data for security reasons, to register visitors to our offices and to manage non-disclosure agreements that visitors may be required to sign, to the extent this is necessary for our legitimate interest in protecting our offices and confidential and proprietary information against unauthorized access;
* To comply with legal obligations: We may need to process your Personal Data to cooperate with government authorities, courts or regulators to ensure we comply with our legal obligations to the extent this requires processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse of our site, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders, or legal processes or to respond to lawful requests.

Do We Disclose Any Information to Outside Parties?
We do not sell, trade, or otherwise transfer to outside parties your Personal Data. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. This may include service providers that provide IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment, legal and financial services, sponsorship of contests or promotions for which you register, and with affiliates within the StarterStudio corporate group that we may acquire in the future when they are made part of the StarterStudio corporate group, to the extent such sharing of data is necessary to fulfill a request you have submitted via our websites or for customer support, marketing, technical operations and account management purposes. In addition, if we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by third party, we may need to share your Personal Data with such third party. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect our or others’ rights, property, or safety. We may also share anonymous usage data with our service providers for the purpose of helping us in such analysis and improvements. Additionally, we may share such anonymous usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our services.

We do not sell information in the traditional sense; however, in case any actions we take may be considered a “sale” under the expanded definition of “sale” under the California Consumer Privacy Act (CCPA), California consumers have the right to opt-out of the sale of your “personal information” as defined in the CCPA. Please see “Your California Privacy Rights” for more information on how to exercise your right to optout. Any Personal Data or other information you choose to submit in communities, forums, blogs, or chat rooms on our website may be read, collected and used by others who visit these forums. Third Party Links Occasionally, at our discretion, we may include or offer third party products or services on our website or service. These third party sites have separate and independent privacy policies, and we encourage you to review those policies, but we are not responsible for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Nevada Revised Statutes Chapter 603A Compliance
A sale under Nevada law is the exchange of covered information for monetary consideration. It is the position of StarterStudio that we do not collect any “personal information” under Nevada law. Additionally, we do not sell any “covered information” under Nevada law. If you would like to submit a request relating to our compliance with Nevada law, please contact us as at info@starterstudio.org include the words “Nevada Rights” in the subject line.

Children
Our website, products and services are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are under 16, please navigate away from this site. Additionally, our website, products and services are not directed at children under the age of 13 and we do not knowingly collect Personal Data from children under the age of 13. If we become aware that we have inadvertently received personal information from someone under 13, we will delete the information from our records. If you believe that we have collected Personal Data from a child under 13 without parental consent, you may report this to us at info@starterstudio.org and include the words “COPPA” in the subject line.

International Transfer of Personal Data
Your Personal Data may be collected, transferred to and stored by us in the United States. Therefore, your Personal Data may be processed outside the European Union (EU) and the European Economic Area (EEA), and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection. In this event, we will ensure that the recipient of your Personal Data offers an adequate level of protection by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers. Your California Privacy Rights If you are a California resident, you have specific data rights including:
* Right to notice of collection
We’ve provided details on what information is collected about you earlier in this Privacy Policy; however, to ensure compliance with the CCPA, the following categories of “personal information” as defined by the CCPA may have been collected over the past year:
* To administer a contest, promotion, survey or other site feature, to the extent you registered for the same;
* To send information to the email address you provided for order processing and updates pertaining to your order;
* Direct identifiers such as your name, User ID, and email;
* Commercial information such as your transactions and purchases;
* Internet or other electronic network activity including your search history on this website, analytics regarding your use, and device identifiers for location and security;
* Audio and electronic data including your signature and voice recordings collected with your consent while speaking to our sales team;
* Information inferred and derived from other categories to determine your preferences and trends;
* Right to notice of your data rights;
* Right to opt out of sale (“Do Not Sell My Information”);

Your EU/EEA Rights Relating to Your Personal Data
If you are located in the EU/EEA, you have certain rights relating to your Personal Data. Such rights include:
* To access your Personal Data held by us (right to access);
* To rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete (right to rectification);
* To erase/delete your Personal Data, to the extent permitted by applicable data protection laws (right to erasure; right to be forgotten);
* To restrict our processing of your Personal Data, to the extent permitted by law (right to restriction of processing);
* To transfer your Personal Data to another controller, to the extent possible (right to data portability);
* To object to any processing of your Personal Data carried out on the basis of our legitimate interests (right to object). Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
* Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects (“Automated Decision-Making”). Automated Decision-Making currently does not take place on our websites or in our services; and * To the extent we base the collection, processing and sharing of your Personal Data on your consent, to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal. How to Exercise Your EU/EEA Rights To exercise your rights, please contact us by using the information in the “Contacting us” section, below. Please note that the rights enumerated in the “Your Rights Relating to Your Personal Data” section above are subject to local data protection laws, and therefore may not be applicable to you if you are not located in the EU/EEA. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive.

If you are an employee of a StarterStudio customer, we recommend you contact your company’s system administrator for assistance in correcting or updating your information. If you are a customer of StarterStudio, please contact support at info@starterstudio.org to update your billing information and/or request return or deletion of your Personal Data and other information associated with your account. Your Rights Relating to Customer Data As described above, we may also process Personal Data submitted by or for a customer to our services. If not stated otherwise in this Privacy Policy or in a separate agreement, we process such Personal Data in the role of a mere processor on behalf of a customer (and/or its affiliates) who is the responsible.