Last updated: October 15, 2020
use and disclosure of Your information when You use the Service and tells You
about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the
Service, You agree to the collection and use of information in accordance with
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined
under the following conditions. The following definitions shall have the same
meaning regardless of whether they appear in singular or in plural.
- Account means a unique account created for You to access our Service or
parts of our Service.
- Business , for the purpose of the CCPA (California Consumer Privacy Act),
refers to the Company as the legal entity that collects Consumers'
personal information and determines the purposes and means of the
processing of Consumers' personal information, or on behalf of which such
information is collected and that alone, or jointly with others,
determines the purposes and means of the processing of consumers' personal
information, that does business in the State of California.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this
Agreement) refers to Start Sure LLC, PO Box 228 Mill Neck, NY 11765.
For the purpose of the GDPR, the Company is the Data Controller.
- Consumer , for the purpose of the CCPA (California Consumer Privacy Act),
means a natural person who is a California resident. A resident, as
defined in the law, includes (1) every individual who is in the USA for
other than a temporary or transitory purpose, and (2) every individual who
is domiciled in the USA who is outside the USA for a temporary or
- Cookies are small files that are placed on Your computer, mobile device or
any other device by a website, containing the details of Your browsing
history on that website among its many uses.
- Country refers to: New York, United States
- Data Controller , for the purposes of the GDPR (General Data Protection
Regulation), refers to the Company as the legal person which alone or
jointly with others determines the purposes and means of the processing of
- Device means any device that can access the Service such as a computer, a
cellphone or a digital tablet.
- Do Not Track (DNT) is a concept that has been promoted by US regulatory
authorities, in particular the U.S. Federal Trade Commission (FTC), for
the Internet industry to develop and implement a mechanism for allowing
internet users to control the tracking of their online activities across
- Facebook Fan Page is a public profile named Start Sure specifically
created by the Company on the Facebook social network, accessible from
- Personal Data is any information that relates to an identified or
For the purposes for GDPR, Personal Data means any information relating to
You such as a name, an identification number, location data, online
identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA, Personal Data means any information that
identifies, relates to, describes or is capable of being associated with,
or could reasonably be linked, directly or indirectly, with You.
- Sale , for the purpose of the CCPA (California Consumer Privacy Act),
means selling, renting, releasing, disclosing, disseminating, making
available, transferring, or otherwise communicating orally, in writing, or
by electronic or other means, a Consumer's Personal information to another
business or a third party for monetary or other valuable consideration.
- Service refers to the Website.
- Service Provider means any natural or legal person who processes the data
on behalf of the Company. It refers to third-party companies or
individuals employed by the Company to facilitate the Service, to provide
the Service on behalf of the Company, to perform services related to the
Service or to assist the Company in analyzing how the Service is used. For
the purpose of the GDPR, Service Providers are considered Data Processors.
- Third-party Social Media Service refers to any website or any social
network website through which a User can log in or create an account to
use the Service.
- Usage Data refers to data collected automatically, either generated by the
use of the Service or from the Service infrastructure itself (for example,
the duration of a page visit).
- Website refers to Start Sure, accessible from https://startsure.co
- You means the individual accessing or using the Service, or the company,
or other legal entity on behalf of which such individual is accessing or
using the Service, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred to as
the Data Subject or as the User as you are the individual using the
Collecting and Using Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You.
Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol
address (e.g. IP address), browser type, browser version, the pages of our
Service that You visit, the time and date of Your visit, the time spent on
those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect
certain information automatically, including, but not limited to, the type of
mobile device You use, Your mobile device unique ID, the IP address of Your
mobile device, Your mobile operating system, the type of mobile Internet
browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our
Service or when You access the Service by or through a mobile device.
Information from Third-Party Social Media Services
The Company allows You to create an account and log in to use the Service
through the following Third-party Social Media Services:
If You decide to register through or otherwise grant us access to a Third-
Party Social Media Service, We may collect Personal data that is already
associated with Your Third-Party Social Media Service's account, such as Your
name, Your email address, Your activities or Your contact list associated with
You may also have the option of sharing additional information with the
Company through Your Third-Party Social Media Service's account. If You choose
to provide such information and Personal Data, during registration or
otherwise, You are giving the Company permission to use, share, and store it
Tracking Technologies and Cookies
Service and store certain information. Tracking technologies used are beacons,
tags, and scripts to collect and track information and to improve and analyze
You can instruct Your browser to refuse all Cookies or to indicate when a
Cookie is being sent. However, if You do not accept Cookies, You may not be
able to use some parts of our Service.
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on
your personal computer or mobile device when You go offline, while Session
Cookies are deleted as soon as You close your web browser. Learn more about
cookies: All About Cookies
We use both session and persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services
available through the Website and to enable You to use some of its
features. They help to authenticate users and prevent fraudulent use of
user accounts. Without these Cookies, the services that You have asked for
cannot be provided, and We only use these Cookies to provide You with
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
on the Website.
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use
the Website, such as remembering your login details or language
preference. The purpose of these Cookies is to provide You with a more
personal experience and to avoid You having to re-enter your preferences
every time You use the Website.
For more information about the cookies we use and your choices regarding
cookies, please visit our Cookies Policy or the Cookies section of our Privacy
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service , including to monitor the usage of
- To manage Your Account: to manage Your registration as a user of the
Service. The Personal Data You provide can give You access to different
functionalities of the Service that are available to You as a registered
- For the performance of a contract: the development, compliance and
undertaking of the purchase contract for the products, items or services
You have purchased or of any other contract with Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other
equivalent forms of electronic communication, such as a mobile
application's push notifications regarding updates or informative
communications related to the functionalities, products or contracted
services, including the security updates, when necessary or reasonable for
- To provide You with news, special offers and general information about
other goods, services and events which we offer that are similar to those
that you have already purchased or enquired about unless You have opted
not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
We may share your personal information in the following situations:
- With Service Providers: We may share Your personal information with
Service Providers to monitor and analyze the use of our Service, for
payment processing, to contact You.
- For Business transfers: We may share or transfer Your personal information
in connection with, or during negotiations of, any merger, sale of Company
assets, financing, or acquisition of all or a portion of our business to
- With Affiliates: We may share Your information with Our affiliates, in
Affiliates include Our parent company and any other subsidiaries, joint
venture partners or other companies that We control or that are under
common control with Us.
- With Business partners: We may share Your information with Our business
partners to offer You certain products, services or promotions.
- With other users: when You share personal information or otherwise
interact in the public areas with other users, such information may be
viewed by all users and may be publicly distributed outside. If You
interact with other users or register through a Third-Party Social Media
Service, Your contacts on the Third-Party Social Media Service may see
Your name, profile, pictures and description of Your activity. Similarly,
other users will be able to view descriptions of Your activity,
communicate with You and view Your profile.
Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary
Personal Data to the extent necessary to comply with our legal obligations
(for example, if we are required to retain your data to comply with applicable
laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage
Data is generally retained for a shorter period of time, except when this data
is used to strengthen the security or to improve the functionality of Our
Service, or We are legally obligated to retain this data for longer time
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's
operating offices and in any other places where the parties involved in the
processing are located. It means that this information may be transferred to —
and maintained on — computers located outside of Your state, province, country
or other governmental jurisdiction where the data protection laws may differ
than those from Your jurisdiction.
information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data
of Your Personal Data will take place to an organization or a country unless
there are adequate controls in place including the security of Your data and
other personal information.
Disclosure of Your Personal Data
If the Company is involved in a merger, acquisition or asset sale, Your
Personal Data may be transferred. We will provide notice before Your Personal
Under certain circumstances, the Company may be required to disclose Your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no
method of transmission over the Internet, or method of electronic storage is
100% secure. While We strive to use commercially acceptable means to protect
Your Personal Data, We cannot guarantee its absolute security.
Detailed Information on the Processing of Your Personal Data
Service Providers have access to Your Personal Data only to perform their
tasks on Our behalf and are obligated not to disclose or use it for any other
We may use Your Personal Data to contact You with newsletters, marketing or
promotional materials and other information that may be of interest to You.
You may opt-out of receiving any, or all, of these communications from Us by
following the unsubscribe link or instructions provided in any email We send
or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
We may provide paid products and/or services within the Service. In that case,
we may use third-party services for payment processing (e.g. payment
We will not store or collect Your payment card details. That information is
provided directly to Our third-party payment processors whose use of Your
processors adhere to the standards set by PCI-DSS as managed by the PCI
Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express and Discover. PCI-DSS requirements help ensure
the secure handling of payment information.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given Your consent for processing Personal Data for one
or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the
performance of an agreement with You and/or for any pre-contractual
- Legal obligations: Processing Personal Data is necessary for compliance
with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect
Your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is
carried out in the public interest or in the exercise of official
authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the
purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis
that applies to the processing, and in particular whether the provision of
Personal Data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data
and to guarantee You can exercise Your rights.
- Request access to Your Personal Data. The right to access, update or
delete the information We have on You. Whenever made possible, you can
access, update or request deletion of Your Personal Data directly within
Your account settings section. If you are unable to perform these actions
yourself, please contact Us to assist You. This also enables You to
receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. You have
the right to to have any incomplete or inaccurate information We hold
about You corrected.
- Object to processing of Your Personal Data. This right exists where We are
relying on a legitimate interest as the legal basis for Our processing and
there is something about Your particular situation, which makes You want
to object to our processing of Your Personal Data on this ground. You also
have the right to object where We are processing Your Personal Data for
direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to
delete or remove Personal Data when there is no good reason for Us to
continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to
a third-party You have chosen, Your Personal Data in a structured,
commonly used, machine-readable format. Please note that this right only
applies to automated information which You initially provided consent for
Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on
using your Personal Data. If You withdraw Your consent, We may not be able
to provide You with access to certain specific functionalities of the
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and
opposition by contacting Us. Please note that we may ask You to verify Your
identity before responding to such requests. If You make a request, We will
try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our
collection and use of Your Personal Data. For more information, if You are in
the European Economic Area (EEA), please contact Your local data protection
authority in the EEA.
Facebook Fan Page
Data Controller for the Facebook Fan Page
The Company is the Data Controller of Your Personal Data collected while using
the Service. As operator of the Facebook Fan Page
Company and the operator of the social network Facebook are Joint Controllers.
The Company has entered into agreements with Facebook that define the terms
for use of the Facebook Fan Page, among other things. These terms are mostly
based on the Facebook Terms of Service: https://www.facebook.com/terms.php
more information about how Facebook manages Personal data or contact Facebook
online, or by mail: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road,
Menlo Park, CA 94025, United States.
We use the Facebook Insights function in connection with the operation of the
Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized
statistical data about Our users.
For this purpose, Facebook places a Cookie on the device of the user visiting
Our Facebook Fan Page. Each Cookie contains a unique identifier code and
remains active for a period of two years, except when it is deleted before the
end of this period.
Facebook receives, records and processes the information stored in the Cookie,
especially when the user visits the Facebook services, services that are
provided by other members of the Facebook Fan Page and services by other
companies that use Facebook services.
For more information on the privacy practices of Facebook, please visit
Your Rights under the CCPA
have the following rights:
- The right to notice. You must be properly notified which categories of
Personal Data are being collected and the purposes for which the Personal
Data is being used.
- The right to access / the right to request. The CCPA permits You to
request and obtain from the Company information regarding the disclosure
of Your Personal Data that has been collected in the past 12 months by the
Company or its subsidiaries to a third-party for the third party's direct
- The right to say no to the sale of Personal Data. You also have the right
to ask the Company not to sell Your Personal Data to third parties. You
can submit such a request by visiting our "Do Not Sell My Personal
Information" section or web page.
- The right to know about Your Personal Data. You have the right to request
and obtain from the Company information regarding the disclosure of the
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the
- Categories of third parties with whom We share Personal Data
- The specific pieces of Personal Data we collected about You
- The right to delete Personal Data. You also have the right to request the
deletion of Your Personal Data that have been collected in the past 12
- The right not to be discriminated against. You have the right not to be
discriminated against for exercising any of Your Consumer's rights,
- Denying goods or services to You
- Charging different prices or rates for goods or services, including the
use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to You
- Suggesting that You will receive a different price or rate for goods or
services or a different level or quality of goods or services.
Exercising Your CCPA Data Protection Rights
In order to exercise any of Your rights under the CCPA, and if you are a
California resident, You can email or call us or visit our "Do Not Sell My
Personal Information" section or web page.
The Company will disclose and deliver the required information free of charge
within 45 days of receiving Your verifiable request. The time period to
provide the required information may be extended once by an additional 45 days
when reasonable necessary and with prior notice.
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner
with (for example, our advertising partners) may use technology on the Service
that "sells" personal information as defined by the CCPA law.
If you wish to opt out of the use of your personal information for interest-
based advertising purposes and these potential sales as defined under CCPA
law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need
to opt out on every browser that you use.
You can opt out of receiving ads that are personalized as served by our
Service Providers by following our instructions presented on the Service:
- From Our "Cookie Consent" notice banner
- Or from Our "CCPA Opt-out" notice banner
- Or from Our "Do Not Sell My Personal Information" notice banner
- Or from Our "Do Not Sell My Personal Information" link
The opt out will place a cookie on Your computer that is unique to the browser
You use to opt out. If you change browsers or delete the cookies saved by your
browser, you will need to opt out again.
Your mobile device may give you the ability to opt out of the use of
information about the apps you use in order to serve you ads that are targeted
to your interests:
- "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on
- "Limit Ad Tracking" on iOS devices
You can also stop the collection of location information from Your mobile
device by changing the preferences on your mobile device.
"Do Not Track" Policy as Required by California Online Privacy Protection Act
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities.
If You are visiting such websites, You can set Your preferences in Your web
browser to inform websites that You do not want to be tracked. You can enable
or disable DNT by visiting the preferences or settings page of Your web
Your California Privacy Rights (California's Shine the Light law)
Under California Civil Code Section 1798 (California's Shine the Light law),
California residents with an established business relationship with us can
request information once a year about sharing their Personal Data with third
parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light
law, and if you are a California resident, You can contact Us using the
contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions
Code Section 22581)
California Business and Professions Code section 22581 allow California
residents under the age of 18 who are registered users of online sites,
services or applications to request and obtain removal of content or
information they have publicly posted.
To request removal of such data, and if you are a California resident, You can
contact Us using the contact information provided below, and include the email
address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive
removal of content or information posted online and that the law may not
permit or require removal in certain circumstances.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us.
If You click on a third party link, You will be directed to that third party's
We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.
We will let You know via email and/or a prominent notice on Our Service, prior
to the change becoming effective and update the "Last updated" date at the top
* By email: [email protected]