Effective as of March 19, 2019
The Information We Collect and How We Use It
We do not collect contact information (e.g., name, address, email address, phone number) from you when you visit our Site unless you voluntarily provide such information when contacting us through the various means provided under the Contact Us page. We use such contact information to respond to your inquiries and provide you with requested information.
From Your Activity
In an ongoing effort to improve the Website, we automatically collect certain information regarding the activity of visitors to our Website. This information includes the device from which you access the Website, your IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, and similar information concerning your use of the Website.
Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. If you do not want our Site to place cookies on your hard drive, you may be able to turn that feature off on your computer. Please consult your Internet browser’s documentation for information on how to do this. However, if you decide not to accept cookies from our Site, our Site may not function properly.
Sharing your Information
We may engage other companies and individuals to perform certain business-related functions on our behalf. Examples may include hosting and storage services, and analytics and marketing providers. These other companies will have access to the personal information only as necessary to perform their functions and to the extent permitted by law. We may also share your personal information with any of our parent companies, subsidiaries, affiliates, or other companies under common control with us for the purposes described herein.
Disclosure to Public Authorities
We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Retention of Personal Information
How We Protect Your Information
We take commercially reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.
Important Notice to All Non-US Residents
Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. Except in the case of data transfers under the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, your decision to provide such data to us, or allow us to collect such data through our Websites, constitutes your consent to this data transfer.
E.U.-U.S. and Swiss-U.S. Privacy Shield Notice
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
In compliance with the Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact us at firstname.lastname@example.org with the subject line “Privacy Shield.”
We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal data to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
Our accountability for personal data that we receive under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that we engage to process the personal data on our behalf do so in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.
Opt-In and Opt-Out to Certain Onward Transfers under the Privacy Shield:
We provide an individual with the opportunity to opt-out before we share your personal data with third parties other than our agents, or before we use it for a purpose that is materially different from which it was originally collected or subsequently authorized. To request to limit the disclosure of such personal data, please submit a written request to email@example.com, with the subject line, “Privacy Shield.”
We will not disclose your sensitive personal information to any third party without first obtaining your opt-in consent, and shall also obtain your opt-in consent before we use sensitive data for a purpose other than which it was originally collected or subsequently authorized, unless an exception applies pursuant to the “Sensitive Data” Privacy Shield Supplemental Principal. You may provide your consent by sending us an email at firstname.lastname@example.org with the subject line “Privacy Shield.” In each instance, please allow us a reasonable time to process your response.
Your Privacy Shield Rights: Upon request to email@example.com with the subject line “Privacy Shield,” we will provide you with confirmation as to whether we are processing your personal data pursuant to the Privacy Shield, and will communicate such data to you within a reasonable time. You have the right to access, correct, amend, or delete the personal data processed pursuant to the Privacy Shield where it is inaccurate or has been processed in violation of our privacy disclosures to you. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries and requests.
How We Protect Your Personal Information under the Privacy Shield: We take very seriously the security and privacy of the personal information that it collects pursuant to the Privacy Shield. Accordingly, we will implement reasonable and appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations.
Your California Privacy Rights
Under California Civil Code Section 1798.83, California residents who have an established business relationship with Starpower may choose to opt out of our sharing their personal information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your personal information to third parties for the direct marketing purposes, please send an e-mail at firstname.lastname@example.org.
In addition, we do not monitor, recognize or honor any opt-out or do not track mechanisms including general web browser, “Do Not Track” settings and/or signals.
How to Contact Us