Residents of the European Economic Area (“EEA”), which includes the member states of the European Union (“EU”), should consult the sections of this policy relating to the “Rights of EEA Residents” and “International Data Transfers” for provisions that may apply to them.
California residents should consult the section titled “Your California Privacy Rights” for rights that apply to them.
Personal Information That We Collect and How We Use It
A Starting Point collects personal data about you when you visit the Site. “Personal Information” is information that may be used to directly or indirectly identify you, including your name, email address, physical address, phone number or other information about you. The majority of such Personal Information is collected when you register with the Site, use our Services, subscribe to updates, sign up for our mailing list or otherwise provide us with your contact information. Some of this Personal Information will be required if you wish to partake in the Services that we provide.
In general, the type of Personal Information we collect includes, but is not limited to:
- Personal Information to contact you to promote our Services or alert you to features or matters of interest;
- Personal Information necessary to use the Services that you have requested, including establishing an account;
- Un-identifiable and aggregated Personal Information pertaining to your Site visits that help us maintain the appropriate features, functionality and user experience
We and our service providers use that data to: (i) enable you to log in to the Site; (ii) enable you to contact your government representatives; (iii) guard against potential fraud; (iv) contact you if there is a problem with your account; (v) provide answers to your inquiries or questions; and (vi) maintain regular communication with you as may be necessary to inform you of offers, updates and other information regarding A Starting Point and its Services.
Non-Identifiable Data and Aggregated Personal Information
A Starting Point or our service providers, including Google Analytics, may also collect web surfing data related to your use of the Site. Such information may include: your Internet Protocol (IP) address, browser type, and internet service provider (ISP); your operating system; which of our web pages you access and how frequently you access them; referral or exit pages; click stream data; and the dates and times that you visit the Site. This data may be collected using cookies, web beacons, page tags or similar tools. As with cookies, the web surfing information is anonymous, “click stream” transactional data that is not associated with any users as individuals.
Web surfing data and similar information may be aggregated for administrative purposes. A Starting Point may, for example, use this aggregated information in the administration of the Site to improve its usability and to evaluate the success of particular marketing and advertising campaigns, search engine optimization strategies, and other marketing activities. We also use it to help optimize the Site based on the needs of our users.
How and When Your Information Is Shared With Other Parties
A Starting Point does not sell, trade or license Personal Information about its users for marketing purposes. We do, however, work with a number of trusted partners who perform vital functions as part of our operations, including processing users’ postal codes to determine their government representatives and allowing users to contact and send messages to their government representatives. We do not share your Personal Information unless it is necessary to fulfill our responsibilities, including providing information or services to you.
Additional Sharing of Information
We contract with companies or individuals to provide certain services related to the functionality and features of the Site, including content streaming, email, messaging and hosting services, software development, client services, data collection and management, and other administrative functions. We call them our “Service Providers.” We may share your information with our Service Providers as appropriate for them to perform their services for us and our Service Providers are permitted to use your Personal Information only for such purposes. Our Service Providers are legally required to keep your Personal Information private and secure.
We may share your Personal Information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your Personal Information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your Personal Information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or our services, or to protect the rights, property or personal safety of A Starting Point, its users, issuers, or others.
We may share your Personal Information in connection with a corporate reorganization or transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Notwithstanding any of the above, we will not share your Personal Information if such sharing is prohibited by applicable privacy and data protection law, including, without limitation, the EEA’s General Data Protection Regulation effective May 25, 2018 and the California Consumer Protection Act (“CCPA”).
Rights of EEA Residents
From May 25, 2018, all processing of Personal Information of EEA Residents is performed by A Starting Point in accordance with the General Data Protection Regulation (2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of Personal Information and on the free movement of such data (“GDPR”).
Under the GDPR, A Starting Point is both the controller and a co-processor of the Personal Information of EEA Residents. A Starting Point’s purpose for collecting and processing Personal Information from EEA Residents is to authenticate user accounts and subscriptions to our mailing lists and to provide marketing information about our Services. The legal basis for collecting Personal Information for subscribing to our email lists is your consent, including during the sign up process. You may withdraw consent for obtaining such communications by following the “Unsubscribe” instructions on any communication or by contacting us at firstname.lastname@example.org.
EEA Residents may obtain information about the Personal Information that A Starting Point holds about them by contacting A Starting Point at email@example.com.
International Data Transfers
If you are resident outside the United States, including in the EEA, we transfer Personal Information provided by you for processing in the United States. Under the GDPR, A Starting Point is considered a “controller” and a “co-processor” of the Personal Information of EEA Residents. By providing Personal Information to A Starting Point for the purpose of obtaining Services, you consent to the processing of such data in the United States. The transfer of your Personal Information to the United States is necessary for the performance of a contract between you and A Starting Point for obtaining Services.
Please note that the United States does not have data protection laws equivalent to those in the EEA and other jurisdictions.
Notifications and Communications from Our Site
Communications Regarding Our Services
We will send you email notifications and free newsletters from time to time with suggestions and other information. Some notifications are communications relating to us and our Services. You may “opt-out” from receiving such communications by following the “Unsubscribe” instructions provided in the email.
Legal or Security Communications
We may also send communications providing customer support or responses to questions regarding the operation of the Services. Generally, you may not opt out of such emails.
Deleting Your Information
If you want us to delete your Personal Information and your account, please contact us at firstname.lastname@example.org with your request. We will take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
Personal Information Retention
Links to Other Sites
Privacy in Submitted Materials
If you submit any photos to us, including through a social media platform, such as Instagram, such photos may be displayed on the Site, including photos of yourself or other individuals. By submitting such materials you forego any privacy rights in such materials. Please consult the Terms of Service for other conditions relating to submission of materials to A Starting Point through social media sites.
We take commercially reasonable steps to protect our customers’ Personal Information against unauthorized disclosure or loss. However, no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, while we strive to protect user information we cannot ensure or warrant the security of any information you transmit to us or from the Site. You engage in such transmissions at your risk.
If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at email@example.com.
Children Under 13
This Site is restricted to the use of adults over the age of majority in their place of residence. No portion of the Site is directed to children under the age of 13. Consequently, we do not knowingly collect personal identifying information from any person we know is a child under the age of 13. If we learn that we have collected personal information from a child under age 13 we will delete that information as quickly as possible. If you are a parent or guardian of a child under 13 years of age and you believe your child has provided us with Personal Information, please contact us at firstname.lastname@example.org.
Links to Third Party Platforms
In addition, you may be redirected to a third party platform for certain functions. See above section regarding “Additional Sharing of Information.”
Your California Privacy Rights
The following section pertains to the rights of individuals or households in California (“California consumers”).
- Civil Code Section 1798.83
Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer’s Personal Information with third parties for direct marking purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes.
- Rights under the CCPA
After January 1, 2020, the CCPA (California Civil Code Section 1798.100 et seq.) will provide California consumers with additional rights regarding Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household. The categories of Personal Information we collect are generally described above but differ for individual consumers depending on the Services used by such consumers.
Under the CCPA, qualifying California consumers may have the following rights:
Right to Know and Right to Delete
A California consumer has the right to request that we disclose what Personal Information we collect, use, disclose and sell. A California consumer also has the right to submit requests to delete Personal Information.
When we receive a request to know or delete from a California consumer, we will confirm receipt of the request within 10 days and provide information about how we will process the request, including our verification process. We will respond to such requests within 45 days.
Right for Disclosure of Information
A California consumer may also submit requests that we disclose specific types or categories of Personal Information that we collect.
Under certain circumstances, we will not provide such information, including where the disclosure creates a substantial, articulable and unreasonable risk to the security of that Personal Information, customers’ account with us, or the security of our systems or networks. We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, or account passwords and security questions and answers.
If you are a California consumer and would like to make any requests under the CCPA, please direct them as follows:
A Starting Point, 1626 Wilcox Avenue, Suite 104, Los Angeles, California 90028-6206
If we receive any request we will use a two-step process for online requests where the California consumer must first, clearly submit the request and then second, separately confirm the request. We will use other appropriate measures to verify requests received by mail or telephone.
In submitting a request, a California consumer must provide sufficient information to identify the consumer, such as name, email address, home or work address, or other such information that is on record with us so that we can match such information to the Personal Information that we maintain. Do not provide social security numbers, driver’s license numbers, account numbers, credit or debit card numbers, medical information or health information with requests. If requests are unclear or submitted through means other than outline above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If we cannot verify the identity of the requestor, we may deny the request.
- California Do Not Track Disclosures
Although some browsers currently offer a “do not track (‘DNT’) option,” no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers’ DNT signals.
Your Rights and Obligations
We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided us by contacting us at email@example.com. You represent and warrant that all Personal Information you provide us is true and correct and relates to you and not to any other person.
If you are a resident of the EEA and wish to access or correct the Personal Information that A Starting Point has about you or have any questions relating to the processing of your Personal Information, please contact us at firstname.lastname@example.org with the subject line “GDPR Data.”
If you use the Site, you are responsible for maintaining the confidentiality of your account and for restricting access to your computer or device, and you agree to accept responsibility for all activities that occur under your account.