PRIVACY POLICY
Last modified on 28/05/2024
Overview of Privacy Protections
This Privacy Policy explains how StartSunny gathers, utilizes, distributes, and safeguards personal information, and the privacy rights and choices we offer, in connection with our websites, online services, and products and services (collectively, our “Services”). In this Privacy Policy, “StartSunny” refers to Jonas Jakstas.
Types of Information Collected.
Information you provide to us. Examples of personal data you might supply include:
Contact details, such as your first and last name, organization name, email and mailing addresses, and phone number.
Account data, such as the username and password that you may use to establish an online account with us.
Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
Order and purchase history, including your interactions with our checkout page.
Payment details, such as your payment card number, bank account number and shipping address. We rely on payment providers, such as Stripe, to process payments and we do not have access to payment card numbers.
Subscriber survey data, including the information you provide when you fill out surveys, and recordings of video or voice chats with our marketing team.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Automated Gathering of Data. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with our websites, online services and our communications, such as:
Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.
We collect this information using cookies and other similar technologies. For more information, please visit our Cookie Policy.
How We Use Personal Information
We use personal information for the following purposes:
Provision of Services. We use personal information to perform our contractual obligation under our terms of use, including to:
Provide, operate and improve our Services and our business;
Process your payments and complete transactions with you; and
Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages.
For our legitimate interests:
To improve, monitor and protect our Services. We use personal information to improve and keep our services safe for our users, which includes:
Understanding your needs and interests, and personalizing your experience with the Services and our communications;
Engaging in surveys and focus groups, and recording our video and audio chats with consumers
Troubleshooting, testing and research to keep the services secure; and
Investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.
For research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you.
For direct marketing. We may send you direct marketing communications as permitted by law (e.g. where we have a commercial relationship with you) and in line with your marketing preferences to keep you updated about our products, activities, promotions, and other initiatives. For example, we will email you our newsletter in accordance with your subscription preferences. You may opt-out of our marketing communications as described in the Opt-out of marketing section. Where required under applicable law, we will only send you direct marketing communications with your consent.
For interest-based advertising. We may engage third-party advertising companies to display our ads on their online services. We may also share information about our users with these companies to facilitate advertising for our services to them or similar users on other online platforms. We conduct these interest-based advertising activities to ensure we present you with relevant updated on our products, activities, promotions and other initiatives in line with your interests. Where required under applicable law, we will only engage in interest-based advertising with your consent. You can learn more about your choices for limiting interest-based advertising by visiting our Cookie Policy.
To comply with our legal obligations:
Our legal obligations necessitate the use of personal information, including to:
Ensure our compliance with applicable laws (including consumer laws with respect to purchases you make), lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
Audit our internal processes for compliance with legal requirements;
Enforce the terms and conditions that govern our Services;
Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims).
How We Disclose Personal Information
We may disclose personal information to:
Affiliates. Within StartSunny for purposes consistent with this Privacy Policy
Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, survey platform providers and website analytics services).
Payment processors. When you make a purchase at StartSunny, your payment card information is collected and processed directly by our payment processors. We do not record or maintain payment card or bank account details. These payment processors may use your payment data in accordance with their privacy policies.
Third parties. Third parties, such as advertising companies, data providers and data co-ops, such as Oracle and Epsilon, for interest-based advertising and other marketing purposes, including those third parties’ own purposes. To learn how to opt-out, please see the “Privacy Rights and Choices” section below.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, StartSunny (including, in connection with a bankruptcy or similar proceedings).
Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties or the public on or through our Services, that information can be seen, collected and used by others. We are not responsible for any use of such information by others.
Privacy Rights and Choices
Account choices. If you have a StartSunny account, you can review and update certain account information by logging into your account. Registered users may also contact us to request deletion of their account and certain personal information.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the emails you receive from us. You may continue to receive service-related and other non-marketing emails.
Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information
Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
Opt out of the sale of personal information and the processing and sharing of personal information for targeted advertising. We engage in targeted advertising activities and may share personal information with third parties to provide you with offers and promotions, which may qualify as a data “sale” under certain applicable laws.
Correction of personal information that is inaccurate or out of date.
Deletion of personal information that we no longer need to provide the services or for other lawful purposes.
Additional rights, such as to object to the processing of your personal information for our legitimate business interests or any marketing related purposes, to request that we restrict our use of personal information, and where applicable, you may withdraw your consent to our processing of your personal information.
How to submit personal information requests:
To request access or deletion of your personal information, please submit a request via our privacy request portal.
To opt out of the sale of your personal information, please click here.
For other personal information requests, please write to us as provided in the “How to Contact Us” section below.
We may ask for specific information from you to help us confirm your identity. You are entitled to exercise the rights described above free from discrimination.
Depending on your jurisdiction, you may designate an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws.
Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.
Complaints. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below. If you are based in certain jurisdictions, you may lodge a complaint about how we handle your personal information with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.
Other Sites and Services
Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions
Google reCAPTCHA.
In order to protect our website and other features, we use Google reCAPTCHA provided by Google Inc. (“reCAPTCHA”) for all United States visitors. We employ reCAPTCHA to check whether data is entered into our forms by a person or by an automated program, script or bot. reCAPTCHA analyzes the behavior of the person entering the data using various features. This analysis starts automatically as soon as the website is accessed. For analysis, reCAPTCHA evaluates various information (e.g., IP address, browser type, settings, and plugins, URL of the referring website, time spent on the respective website, mouse movements, input characteristics of the data entry, including speed, sequence and selection of inputs, etc.). The data collected during the analysis is forwarded to a Google server, where it is stored and evaluated. Your use of reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service. For more information about reCAPTCHA, please visit: https://www.google.com/recaptcha.
Security
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of personal information.
International Data Transfer
You may provide personal information directly to our website in the United States. We may also transfer personal information from Europe to our affiliates and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.
When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the “How to Contact Us” section below.
Data Privacy Framework
StartSunny complies with the EU-U.S. Data Privacy Framework, the UK Extension of the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework (collectively, the “Data Privacy Framework”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, United Kingdom, and Switzerland to the United States. StartSunny has certified to the Department of Commerce that it adheres to the Data Privacy Framework Principles (the “Principles”). If there is any conflict between the terms in this Privacy Policy and the Principles, the Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
StartSunny may transfer personal information to third parties as described in this Privacy Policy. StartSunny maintains contracts with its third-party service providers restricting their access, use, and disclosure of personal information in compliance with our Data Privacy Framework obligations. StartSunny may be liable if these third parties fail to meet those obligations and we are responsible for the event giving rise to the damage.
In compliance with the Principles, StartSunny commits to resolving complaints about our collection or use of personal information. European individuals with inquiries or complaints regarding our Privacy Policy should first contact StartSunny at hello@startsunny.com. StartSunny has further committed to refer unresolved Data Privacy Framework complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit https://www.jamsadr.com/eu-us-data-privacy-framework for more information or to file a complaint. The services of JAMS are provided at no cost to you. If neither StartSunny nor JAMS resolves your complaint, you may have the ability to engage in binding arbitration through the Data Privacy Framework Panel. Additional information on the arbitration process is available on the Data Privacy Framework website at https://www.dataprivacyframework.gov.
StartSunny may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.. StartSunny’s commitments under the Principles are subject to the investigatory and enforcement powers of the Federal Trade Commission.
Children
Our Services are not intended for use by children under 16 years of age. If we learn that we have collected personal information through our Services from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.
Job Applicants
When you visit the “Careers” portion of our websites, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics, and to respond to surveys. We may also use this information to provide improved administration of our websites, and as otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend our or others’ rights or property; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms & Conditions.
Retention of Personal Information
We retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
Changes to This Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our websites and online services. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through our Services. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of our Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.
How to Contact Us
StartSunny is the entity responsible for the processing of personal information and is the data controller in respect of such processing. You can reach us by email at hello@startsunny.com or phone number +37062361601
Privacy Snapshot
Here is a high-level snapshot of our privacy practices, but you need to read the entire Privacy Policy for complete information.
Data Category Collected
Identifiers such as a real name, Internet Protocol address, email address, or other similar identifiers
How We Collect
When you visit or use our Services; from third-party sites and services
Primary Purposes of Processing
To deliver our Services; to improve, monitor, and personalize our Services; and for marketing and advertising
Key Disclosures
Service providers (Can You Limit Sharing: No)
Third parties (Can You Limit Sharing: Yes)
Data Category Collected
Personal information categories listed in the California Customer Records Statute (e.g., name, contact details)
How We Collect
When you visit or use our Services; from third-party sites and services
Primary Purposes of Processing
To deliver our Services; to improve, monitor, and personalize our Services; and for marketing and advertising
Key Disclosures
Service providers (Can You Limit Sharing: No)
Third parties (Can You Limit Sharing: Yes)
Data Category Collected
Commercial information, including but not limited to records of products or services purchased
How We Collect
When you visit or use our Services
Primary Purposes of Processing
To deliver our Services; to improve, monitor, and personalize our Services; and for marketing and advertising
Key Disclosures
Service providers (Can You Limit Sharing: No)
Third parties (Can You Limit Sharing: Yes)
Data Category Collected
Internet or other electronic network activity information, including but not limited to browsing history and search history
How We Collect
When you visit or use our Services
Primary Purposes of Processing
To improve, monitor, and personalize our Services; and for marketing and advertising
Key Disclosures
Service providers (Can You Limit Sharing: No)
Third parties (Can You Limit Sharing: Yes)
Data Category Collected
Inferences drawn from information to create a profile about your behavior, preferences, etc.
How We Collect
When you visit or use our Services; from third-party sites and services
Primary Purposes of Processing
To improve, monitor, and personalize our Services; and for marketing and advertising
Key Disclosures
Service providers (Can You Limit Sharing: No)
Third parties (Can You Limit Sharing: Yes)
Data Category Collected
Geolocation data
How We Collect
When you visit or use our Services
Primary Purposes of Processing
To improve, monitor, and personalize our Services; and for marketing and advertising
Key Disclosures
Service providers (Can You Limit Sharing: No)
Third parties (Can You Limit Sharing: Yes)
