Starpower LLC

Privacy Policy

 

Effective as of March 19, 2019

 

We at Starpower LLC (“Starpower,” “we,” “us,” or “our”) have created this privacy policy (the “Privacy Policy”) because we know you care about how information you provide us is used and shared.  This Privacy Policy describes how we gather information from you when you visit our website located at http://starpowerllc.com/ (“Site”), and how we may use and share that information.  By visiting our Site, you are accepting the practices described in this Privacy Policy.

 

The Information We Collect and How We Use It

 

Contact Information

 

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

 

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.

Business Transfers

In the event of a merger, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy.

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

 

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, or as allowed under applicable law.

 

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

 

Privacy Shield: If your personal information is transferred from the EEA or Switzerland to the US pursuant to the Privacy Shield, then the rights, remedies, and protections set forth in this section apply to you. We comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union member countries (including Iceland, Liechtenstein, and Norway) and Switzerland, respectively, to the United States, pursuant to the EU-US and Swiss-US Privacy Shield. We have certified that we adhere to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this Privacy Policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

 

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 privacy@starpowerllc.com 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.

 

Onward Transfer to Third Parties under the Privacy Shield: Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information and their functions are: hosting and storage services and analytics and marketing providers. To the extent such third parties function as our agents, they do so pursuant to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Policy and implemented by us. 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 in this Privacy Policy.

 

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 privacy@starpowerllc.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 privacy@starpowerllc.com 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 privacy@starpowerllc.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.

 

Retention of Personal Information under the Privacy Shield: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing such personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of our privacy disclosures. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.

 

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.

 

Changes to Our Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy.  We may change this Privacy Policy from time to time, and will any changes on our Site or notify you via e-mail, at our option, as soon as they go into effect.  By using the Site after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

Children

 

We do not knowingly collect personal information from children under the age of 13 through the Site. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide their personal information to us. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will endeavor to delete that personal information from our databases.

 

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 privacy@starpowerllc.com.

 

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.

 

External Websites

 

Our Site may contain links to third-party web sites.  Starpower has no control over the privacy practices or the content of any of our business affiliates, advertisers, sponsors, or other web sites to which we provide links from our Site.  As such, Starpower is not responsible for the content or the privacy policies of web sites to which our Site may link.  You should check the applicable privacy policy of the web site sponsor when visiting any other web sites.

 

How to Contact Us

 

If you have questions about this Privacy Policy, please contact us via e-mail at privacy@starpowerllc.com with “PRIVACY POLICY” in the subject line.