Privacy Policy

The purpose of this privacy policy (this “Privacy Policy”) is to provide individuals with a description of the types of personal information we at StartProto, Inc. (“we”, “us” or the “Company”), collect about individual persons through our products and services and through our website www.startproto.com (the “Site”). This Privacy Policy does not describe technical or other information collected or stored (such as product descriptions or specifications) which is not related to individual persons. In addition to the provisions of this Privacy Policy, information we collect is also governed by the terms of the website terms of use and/or service agreement to which you agreed regarding your use of the Site and our products and services. In this Privacy Policy, our “Products” means our products and services, including those provided through our website, and “Personal Information” means any information that we possesses relating to an identified or identifiable user of our Products.​

INFORMATION COLLECTED
In order to provide you with use of our Products, we may gather and process some or all of the following information:
Content: any information that is collected from or stored by you when you use our Products, other than Registration Information, Customer Service Communications or Product Generated Data.
Registration Information: any information provided when voluntarily registering for use of our Products, including, but not limited to, username and password and email address.
Customer Service Communications: any information that is reported to us about the operation of our Products, including bug reports or requests for enhancements.
Product Generated Data: When you use some Products, or equipment which is connected to our Products, our servers automatically record information that the Product sends. These server logs may include information such as your use of the Product (or the machines which interface with a Product), Internet Protocol address, other addressing information, the date and time of your use and an authentication token used to validate the identity of you and your device. In general, Product Generated Data does not include specific information provided by an individual, but only reflects the use by an individual operator of a piece of equipment relating to the operation of that equipment.​

HOW WE COLLECT INFORMATION
We collect information you provide to us when you request or purchase products, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in public forums or other activities on our sites and applications, or otherwise interact with us online or offline.We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons, including when you visit our sites and applications or use our applications on third-party sites or platforms using one or more devices, whether or not you are logged in or registered.We collect information using analytics tools, including when you visit our sites and applicationsWe acquire information from other trusted sources to update or supplement the information you provided or we collected automatically, such as when we validate postal address information using third party services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it.​

USE OF COLLECTED INFORMATION
Our primary purpose in collecting information is to provide you with an efficient user experience. We may use the information defined in this Privacy Policy to: provide the Product and any customer support you request; resolve disputes, collect fees, and troubleshoot problems; enforce our contractual agreements; customize, measure, and improve our Products; inform you about updates; compare information for accuracy, and verify your identity; provide other services for you as described when we collect the information. In addition, although initially we are not initially doing so, if we choose to provide you with promotional offers or advertising, we may use your information in order to provide you such items. Additionally we may use your information as described below.Registration InformationWe ask for Registration Information in order to verify your identity and to enable your use of our Products. For services for which we charge individuals, we use third party banking organizations and other providers of payment services to bill you, and in that case we will, therefore, provide this billing provider with the necessary billing data. We respect the privacy of personal email accounts and we will store your email addresses just as securely as other Personal Information. We will not send you unwanted email messages or junk mail, and your details will not be passed to third parties for their marketing purposes without your explicit permission. However, we will use email to send you messages about faults and service issues. We may also use email to keep you up to date with news about StartProto. If you do not want to be kept informed in this way by email, please contact us at admin@startproto.com. Further, we reserve the right to use email to notify you of any eventual claims related to your use of our Products, including without limitation claims of violation of third party rights.ContentIn general, we will not review or provide third parties access to Content. However, if required by law, we reserve the right to pre-screen, review, flag, filter, modify, refuse or remove any or all of Content from our Products.Customer Service CommunicationsInformation which is voluntarily submitted in feedback is used for the purposes of reviewing this feedback and improving our Products. We reserve the right to utilize anonymous information for marketing purposes, for instance by displaying selected comments on our Products or in other communications. Further, we may from time to time ask you to provide information on your experiences which will be used to measure and improve quality. You are at no time in any obligation to provide any of such data. We will never use any personally identifiable (feedback) information without your explicit permission thereto.Product Generated DataWe will use this information to operate our Products, evaluate and analyze and behavioral patterns of equipment connected to our Products, and improve the functionality and usefulness of our Products.​

TRANSFER OF PERSONAL INFORMATION
Except as provided below, we shall not sell, rent, trade or otherwise transfer any Registration Information or Content to any third party without your explicit permission, unless we are obliged to do so under applicable laws or by order of the competent authorities. Product Generated Data is provided to our customers who use the Products, generally in connection with operation, maintenance, and other aspects of their use of the equipment connected to the Products. Product Generated Data may contain or be derived from interactions with individuals based on their use of the Product, and accordingly may contain or be derived from Personal Information. We may share your information with our affiliates and other service providers and third parties for which we are providing our Product in connection with your use. We may offer some of our Products in connection with other service providers. Registration Information that you provide to us may be sent to those providers in order to deliver the product or service provided by them; similarly, Personal Information that you provide to those sites may be sent to us in order to operate our Products. Information collected by us may be stored and processed in any country in which we and our affiliates maintain facilities. We reserve the right to transfer information outside of the country where you reside and/or from which you use our Products. By using our Products you consent to any such transfer of information. As we continue to develop our business, we might sell or buy subsidiaries or business units. In such transactions as well as in the event all or substantially all of our assets are acquired by a third party, Personal Information of our users will generally be one of the transferred business assets. We reserve the right to include your Personal Information, collected as an asset, in any such transfer to a third party. Notwithstanding anything to the contrary in this Privacy Policy, we may access, use, preserve or disclose any information we have access to if we have a good faith belief that such access, use, preservation or disclosure of any information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce our contractual agreements, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of us, our users or the public as required or permitted by law.​

PROTECTION OF PERSONAL INFORMATION
We take appropriate organizational and technical measures to protect the data provided to us or collected by us, and do not retain it any longer than permitted in order to operate our Products or as required under relevant legislation, with due observance of the applicable obligations and exceptions under the relevant legislation. You should be aware that internet communications are not always secure. Although we do take what we consider appropriate steps to protect your data, protection of information available over the internet is subject to attack from third parties, and accordingly we cannot promise you that third parties cannot access Content.​

RETENTION OF PERSONAL INFORMATION
We will retain your information for as long as is necessary to: (1) provide the use of our Products; (2) invoice charges and to maintain records until invoices cannot be lawfully challenged and legal proceedings may no longer be pursued; (3) communicate with you regarding other Products that we offer; (4) comply with applicable legislation, regulatory requests and relevant orders from competent courts; (5) enforce our contractual agreements; or (6) fulfill any of the other purposes detailed in this Privacy Policy.If you wish to access, correct, update or request deletion of your personal information, please email us at: admin@startproto.com.​

COOKIES
A cookie is a piece of data stored on the user’s hard drive containing information about the user. Usage of a cookie will in no way linked to any personally identifiable information while using our Products. Once the user closes their browser, the cookie simply terminates. For instance, by setting a cookie on our Product, the user would not have to log in a password more than once, thereby saving time while on our Products. If a user rejects the cookie, they may still use our Products. The only drawback to this is that the user will be limited. Cookies can also enable us to track to enhance the experience using Products and for analytic purposes to help us understand the use of our Products. Some of our business partners may use cookies. However, we have no access to or control over these cookies. In addition, although initially we are not initially doing so, if we choose to provide you with promotional offers or advertising, the third party business party may use cookies for that purpose.​

DATA SECURITY
We follow commercially accepted industry standards to protect the Personal Information submitted to us or otherwise collected by us, both during transmission and once we receive it. While we strive to use commercially acceptable means to protect Personal Information, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee its absolute security. In the event of an inadvertent disclosure of Personal Information we will take all commercially reasonable steps to limit and remedy the disclosure as required by the applicable law. If individuals have any questions about security regarding our Service, they can contact us at admin@startproto.com.​

COMMUNICATIONS WITH YOU; RIGHT OF OPT-OUT, ACCESS AND CORRECTION
We will periodically send you free newsletters and emails that directly promote the use of our Site or Service. We also may, from time to time, contact you on behalf of third-party businesses about a particular offering that may be of interest to you. In those cases, we do not transfer your unique Personal Information to the third party. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information below). Despite your indicated email preferences, we may send you Product related communications, including notices of any updates to our Product agreement, terms of use, or Privacy Policy. You can correct or update your personally identifiable information by re-registering or by contacting us by email at admin@startproto.com.​

CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits customers who are California residents and who have provided the Company with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident with questions regarding this, please contact us at admin@startproto.com.​

PRIVACY AND THIRD-PARTY LINKS
This Privacy Policy applies solely to information collected by our Site and Product. In an attempt to provide you with increased value, we may include third-party links on our Site. These linked sites have separate and independent privacy policies, and we do not have control over and do not review these linked sites. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these linked sites (including if a specific link does not work).​

GOVERNING LAW
This Privacy Policy is governed by the laws of the Commonwealth of Massachusetts, U.S.A. without giving effect to any principles of conflict of law.​

AGE LIMITATION
Our Products are not directed to persons under the age of 18. If you become aware that a child has provided us with Personal Information, please contact us at admin@startproto.com. We do not knowingly collect or solicit information concerning persons under 18 years old. If we become aware that a person under 18 has provided us with Personal Information, we take steps to remove such information and terminate the person’s account.​

EFFECTIVE DATE; POLICY CHANGES
This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Information, we may notify you by sending you an email to the last email address you provided to us and/or by prominently posting notice of the changes on our Site. If you have registered as an account holder, or order products or services through us, we will normally (as a part of any transaction relating to your account or order) require you to explicitly accept the changes as a condition to the continued provision of the Product to you. Any changes to this Privacy Policy that make it less protective of your information will not apply to your information acquired by us prior to such change unless and until you consent as described above. Please note that at all times you are responsible for updating your Personal Information to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our email to you containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your Personal Information, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Continued use of our Site or Product, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.​

CONTACT US
To contact us with your questions or comments regarding this Privacy Policy or the information collection and dissemination practices of the Product, please email us at admin@startproto.com. All trademarks, service marks, and other proprietary materials herein are the property of the Company or its affiliates. All rights reserved.

​EEA RESIDENT RIGHTS
If you are a resident of the European Economic Area, you have the following data protection rights:If you wish to access, correct, update or request deletion of your personal information, please email us at: admin@startproto.com.In addition, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us: admin@startproto.com.You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you. Registered users can manage their account settings and email marketing preferences as described in the "Choices Regarding Your Personal Information" section below. If you are an unregistered user, or to opt-out of other forms of marketing (such as postal marketing or telemarketing), you may email us: admin@startproto.com.Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Notwithstanding the foregoing, we reserve the right to keep any information in our archives that we deem necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.