Effective June 10, 2020
A “controller” is the legal entity which, alone or jointly with others, determines the purposes and means of the processing of personal data. StartupProgram is the data controller for all data we collect and store described by this policy.
A “processor” is a legal entity or other body that processes data on behalf of the controller, as defined above. StartupProgram uses various data processors, including but not limited to our payment processors (as outlined below), with which we have a data processing agreement.
INFORMATION WE COLLECT
The categories of information we collect can include:
Information you provide to us directly
We may collect personal data, such as your name, location, payment information, and email address when you register to access our content, sign up for our mailing list, or otherwise communicate with us. We may also collect any communications between you and StartupProgram and any other information you provide directly to StartupProgram.
Information we receive from third-party sites you connect to our Site
We may receive personal information about you from third parties and combine that with information we collect through our website if your browser settings allow that. The data we receive from these third-party sites is dependent upon that third party’s policies and your privacy settings on that third-party site. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website.
We collect information about your location through GPS, WiFi, wireless network triangulation or other methods in order to obtain your location for the purposes of providing our website and its content, if your browser or your mobile device settings allow it. We may also approximate your location by your IP Address.
COOKIES AND OTHER INFORMATION COLLECTED BY AUTOMATED MEANS
Log Data. When you visit our website, our servers automatically record information that your browser sends whenever you visit a website (“Log Data“). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting. For most users accessing the Internet from an Internet service provider (or “ISP“), the IP address will be different every time you log on. We use this Log Data to monitor use of our website and the content we offer via our website and for the technical administration of our website.
Our website currently uses the following services which may employ cookies:
Our website uses Google Analytics to track how you use our website, including for the following purposes:
For more information on Google’s use of your information, please see Types of Cookies Used by Google. To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on.
HOW WE USE YOUR INFORMATION
We may use the information we collect to:
HOW WE SHARE YOUR INFORMATION
We may share your personal data in the instances described here. For further information on your choices regarding your information, see the “Your Rights and Choices” section below.
We may share your personal data with:
If you have provided personal data to us and you are from a jurisdiction that allows you to know, port, and/or request deletion of that information as outlined below, StartupProgram will comply with the laws of that jurisdiction.
We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
YOUR RIGHTS AND CHOICES
Deletion of personal data.
You may request that we delete your personal data by emailing us at firstname.lastname@example.org. We may reject your request, as permitted by applicable law. For example, StartupProgram may be required by legal, tax or other reasons to retain your personal information in its business records.
You may review, update, or modify your account information, including profile and contact information, by logging into your account. You may delete your StartupProgram account by emailing email@example.com.
CCPA: Under the California Consumer Privacy Act, (AKA the “CCPA,” “personal information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Under the CCPA we must disclose the categories of personal information about California residents that we collect, sell, and/or disclose to third parties or service providers for a business purpose. Please see above for that information.
We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used. Much of that information is provided herein.
Subject to certain exceptions, California residents have the right to make the following requests, at no charge, up to twice every 12 months:
Right of Deletion: California residents have the right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary for any of a list of exempt purposes.
Right to Know – Right to a Copy: California residents have the right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge, either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance.
Right to Know – Right to Information: California residents have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the categories of personal information collected; the sources for that personal information; the purpose for collecting and selling personal information; and to whom we have disclosed that information.
If you would like to have your information deleted or if you would like to exercise your rights under the CCPA to a copy, and / or the right to information we have, please contact us via email at firstname.lastname@example.org. We will respond to verifiable requests received from California consumers consistent with California law.
California Eraser Law. If you are 18 and a California resident, and you discover an image posted on one of our websites taken when you were a minor, the California Eraser law allows you to have us remove the image from view, pursuant to your request. Should you request removal, please be advised that it will be removed only from those sites under our control, and for privacy purposes, we may ask you to verify your request.
European Union Residents.
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. If you have provided us with personal information (e.g., in setting up an account), we will use that information only for the purpose for which you provided it, as outlined herein. In the event that you do not have an ongoing relationship with us (for instance, if you stop receiving our newsletter and your account has been dormant with no credit balance for a period of three years), all personal information except that which we are required to maintain by law) will be deleted in accordance with our internal processes. Once information is deleted, it cannot be recovered.
Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the website), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
You may unsubscribe from receiving marketing or other commercial emails from StartupProgram by following the instructions included in the email. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as order confirmation emails or changes in our website or terms).
Our websites do not knowingly collect personal data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided personal data to us through our websites, please contact us at email@example.com and we will endeavor to delete that information from our databases.
LINKS TO OTHER WEBSITES AND THIRD-PARTY CONTENT
We may provide links to other websites, services, and applications that are not operated or controlled by StartupProgram (the “Third-Party Services”). The policies and procedures we described here do not apply to the Third-Party Services. While we attempt to facilitate access only to those Third-Party Services that share our respect for your privacy, we cannot take responsibility for the content, privacy policies, or practices of those Third-Party Services. We encourage you to review and understand the privacy practices of any Third-Party Services before providing any information to or through them.
DATA STORAGE AND TRANSFER
StartupProgram maintains reasonable administrative, technical, and physical safeguards designed to protect the personal data we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, we cannot guarantee that the measures we maintain will ensure the security of the personal data.
Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose.
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