PRIVACY POLICY

Updated March 3, 2020.

A Starting Point LLC (“A Starting Point”) respects the sensitive nature of any personal information you provide to us.  We have created this Privacy Policy in order to demonstrate our commitment to the privacy of those who use the SP Contributor app (the “App”).  This Privacy Policy describes our information collection, storage and disclosure practices and the choices you have regarding how your personal information is collected and used by us and our service providers.  By accessing and using the App, you consent to the collection, use and disclosure of information through the App as described in this Privacy Policy. 

California residents should consult the section titled “Your California Privacy Rights” for rights that apply to them.

 

We reserve the right to change this Privacy Policy at any time.  In the event we make changes to this Privacy Policy, such policy will be re-posted in the “Privacy Policy” section of our App with the date such modifications were made indicated on the top of the page or we may contact you to inform you about the revisions with a link to the revised Privacy Policy.  All changes are effective on the date listed at the top of this page and will apply to all information that we have about you.  Your continued use of the App or the services that we provide (“Services”) after any change is posted indicates your acceptance of the changes and your continued consent to our processing of your personal data.  If at any point you do not agree to any portion of this Privacy Policy then in effect you should immediately stop using the App and the Services.  Because this Privacy Policy contains legal obligations we encourage you to review this Privacy Policy carefully.  If you have any questions concerning this Privacy Policy or our information collection, storage and disclosure practices, please contact us at info@astartingpoint.com or mail us at A Starting Point, 1626 Wilcox Avenue, Suite 104, Los Angeles, California 90028-6206.

Personal Information That We Collect and How We Use It

A Starting Point may collect Personal Information about you when you visit the App.  “Personal Information” is information that may be used to directly or indirectly identify you or your device, including your name, email address, Device Data, and other information you may provide.  “Device Data” is information tied to the device used to access the App (e.g., your device type and your device identifiers such as your IDFA and IMEI).  The majority of such Personal Information is collected when you establish your account or otherwise use our Services to create content.  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:

We and our service providers use that data to: (i) enable you to log in to the App; (ii) enable you to record and upload video content; (iii) guard against potential fraud; (iv) contact you if there is a problem with your account; and (v) send you push notifications and maintain regular communication with you as may be necessary to inform you of updates and other information regarding A Starting Point and its Services.

Any information you provide in the video content that you record and upload to the App will be shared through the A Starting Point website at https://www.astartingpoint.com/ (the “Website”), and may be shared on third party platforms, including, but not limited to, Instagram, Twitter and Facebook.

Non-Identifiable Data and Aggregated Personal Information

A Starting Point or our service providers may also collect anonymous usage data related to your use of the App for internal business purposes.  Such information may include: your Device Data and internet service provider (ISP); your operating system; how frequently you access the App; click stream data; and the dates and times that you visit the App.  This usage data may be collected using data analytics software or similar tools.  This information is anonymous transactional data that is not associated with any users as individuals.

Usage 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 App to improve its usability.  We also use it to help optimize the App 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, contract with companies or individuals to provide certain services related to the functionality and features of the App, including hosting services, software development, client services, data collection and management, surveys and marketing, 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 App 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 California Consumer Protection Act (“CCPA”).

Notifications and Communications from Our App

Communications Regarding Our Services

We may send you email and push notifications relating the App and our Services from time to time.  You may “opt-out” from receiving such email communications by following the “Unsubscribe” instructions provided in the email, and you may “opt-out” from receiving such push notifications through your phone’s settings.  

Legal or Security Communications

We also send out notices that are required for legal or security purposes.  For example, certain notifications are sent for your own protection.  In other cases, these notifications involve changes to various legal agreements, such as this Privacy Policy or the Terms of Service.  Generally, you may not opt out of such emails.

Account 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 info@astartingpoint.com 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

 

We retain the Personal Information we receive as described in this Privacy Policy for as long as you use the App or our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Privacy in Submitted Materials

If you submit any photos or videos to us, including through a social media platform, such as Instagram, such photos and videos may be displayed on the Website, including photos and videos 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.

Security Policy

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 App.  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 info@astartingpoint.com.

Children Under 13

This App is restricted to the use of adults over the age of majority in their place of residence.  No portion of the App 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 info@astartingpoint.com.

Links to Third Party Platforms

 

This App or communications may contain links to third party websites, over which we exercise no control, including in the form of embedded content, sponsored content or co-branded content.  Except as set forth in this Privacy Policy, we do not share your Personal Data with those third parties and we are not responsible for the privacy policies of any third party or their management of your Personal Information.  Because they may treat your Personal Information differently than we do, we suggest you read the privacy policies on those third party websites prior to submitting any Personal Information to such sites.

 

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”).  

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.

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.

Submitting Requests

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

info@astartingpoint.com

Verifying Requests

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.

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 info@astartingpoint.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 use the App, 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.