Privacy Policy

This Privacy Policy applies to Personal Information we collect from you. By “Personal Information,” we mean information that identifies you personally. We are headquartered in the United States. If you decide to use our Website, we will obtain your Personal Information. If you prefer not to have your Personal Information transferred to us or our commercial partners, do not use the Website, or register to receive our services.

We generally collect only Personal Information you voluntarily provide to us. If you cannot or choose not to provide us with the Personal Information we reasonably require, we may be unable to provide you with the information or services you have requested.

We may work with online advertising vendors to provide you with relevant and useful ads. This may include ads served on or through the Website. This may also include ads served on other companies’ websites. These ads may be based on information collected by us or third parties. For example, your zip code may be used to target an ad for people in your area. These ads may also be based on your activities on the Website or on third party websites.

We may process and may disclose your Personal Information to:

• Respond to your questions about our services;
• Send you communications, including ads, electronic newsletters, or offers tailored to you;
• Enable our advertisers to provide you with more personalized content, and track the effectiveness of certain advertising campaigns;
• Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities;
• Help us run our business; or
• For any other everyday business purposes, such as product development and Website administration

We may otherwise disclose Personal Information as permitted or required by law, when we believe in good faith it is necessary for safety purposes, required for legal reporting, or to protect our legal rights or any applicable rules, or to protect the rights of others. We may also disclose Personal Information to our auditors, legal advisors, or to respond to a subpoena.

Supplement – For California Persons Only

A. Consumer Privacy. The California Consumer Privacy Act, Cal. Civ. Code §1798.100 et. seq. (“CCPA”), grants residents of California certain rights with respect to their Personal Information and requires us to provide such individuals with certain information, as described in this Section.

California residents may exercise the rights described below free of charge by contacting our Privacy Policy Coordinator by email at: kristi@startuptools.com, or telephone at 313-300-2804.

B. Your Rights. You have the right under the CCPA and certain other privacy and data protection laws, as applicable, to exercise free of charge:

1. Disclosure of Personal Information We Collect About You

You have the right to know:

• • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting information;
  • The categories of third-parties with whom we share personal information, if any; and
  • The specific pieces of personal information we have collected about you.

Please note that we are not required to:

• • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information is not retained;
  • Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.

2. Disclosure of Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third- party for a business purpose, you have the right to know certain information.

• • You have the right to know the categories of personal information about you that we sold and the categories of third-parties to whom the personal information was sold.
  • You have the right to know the categories of personal information that we disclosed about you for a business purpose.

3. Sale of Personal Information

We will never sell your Personal Information.  CCPA considers some transfers of Personal Information to third-parties in exchange for value as “sales,” even if no money changes hands, such as when online identifiers, Device IDs, and other information is shared with Third-Party businesses to further their own commercial purposes such as generating profiles about individuals. We will never transfer your Personal Information to third-parties in exchange for anything of value.  Note that we can still share Personal Information with third-parties if those transfers aren’t “sales”, such as with our commercial partners and service providers.

4. Right to Deletion

Subject to certain exceptions set out below, upon receipt of a verifiable request from you and no more than 45 days after such verification, we will:

• • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

• • Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

5. Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

• • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate, or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to you by your personal information.

C. Online Erasure. California’s “Online Erasure” law, Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services to allow registered users who are under the age of 18 and residents of California to request removal of content they post. If you fit that description and posted content on a section of our website that is directed to minors, you may request removal of the content by contacting our Privacy Policy Manager by email at kristi@startuptools.com or by telephone at: 313-300-2804. In response to your request, we may elect to make the content invisible to other users and the public (rather than deleting it entirely), in which case the content may remain on servers we control and/or may be publicly available elsewhere if a third-party copied and reposted the content.