PRIVACY POLICY
Starkix – Privacy Policy
Effective Date: October 1, 2024
Starkix Inc. (“Company”, “we” “us”, or “our”) owns, controls, and operates the Democracy Calls platform through our website (https://democracycalls.com/), mobile application, and all subdomains thereof (collectively, the “Platform”).
Your privacy is very important to us, and in order to best protect your information, we have adopted this privacy policy (“Privacy Policy”), which describes the types of information we collect from each user of the Platform (“User”, “you” or “your”), how such information is used, processed, and in certain cases disclosed by us, and your rights and choices regarding information you provide to us that is stored on our servers. Please read this Privacy Policy carefully prior to your use of the Platform. If you do not agree to abide by this Privacy Policy, please do not use the Platform.
By accessing and using the Platform, you are deemed to have read, accepted, executed, and be bound by this Privacy Policy, including, without limitation, the information collection, use, and disclosure practices described herein. This Privacy Policy is governed by our Terms of Service, which includes all disclaimers of warranties and limitations of liabilities. Capitalized terms that are used but not otherwise defined in this Privacy Policy have the respective meanings assigned to such terms in the Terms of Service.
Information We Collect and Receive
In order for us to provide you with the products, services, features, and functionalities offered via the Platform, engage in troubleshooting activities, and improve upon the Platform’s performance, safety and security, we may collect and process personal information (i) from you directly when you provide it to us through the Platform and when you engage in certain actions via the Platform, or (ii) about you automatically from you or your computer, smartphone, or other device when you use, access, or interact with the Platform, as well as from third parties, including, but not limited to the following information:
Information You Provide
We may collect and process information you provide when you create an account on the Platform, use our Platform, request or purchase a Live Meet and Greet through the Platform, receive payments from us (solely as applicable to Stars), or otherwise engage or communicate with us, as described in more detail below.
Identity Data. This includes information that could be directly associated with you, or used to contact or identify you, without the aid of additional information, including, without limitation, your name, age, date of birth, gender, e-mail address, telephone number, physical address, credit or debit card number, social media handles or log in details, Platform account details, or any other information that you provide to us that is defined as personal or personally identifiable information under an applicable law or any other identifier by which you may be contacted online or offline (collectively, “Personal Information”); and
Additional Data You Provide. This includes information you provide when you contact us via the “Contact” link on the Platform, and as applicable may also include information you provide in connection with focus groups, survey responses, contests/sweepstakes, or other means. We may also collect Personal Information at other points on our Platform where you voluntarily provide it or where we state that Personal Information is being collected.
Information Collected Automatically
As is true of many digital platforms, we also may collect and process certain information about you automatically when you use our Platform, as described in more detail below.
Usage Information. This includes information regarding your activity on our Platform, including device identifiers (like IP address or mobile device identifiers), pages or features you use, interact with, or click on, time and date of access and other similar usage history, usage preferences such as language, resolution settings, etc., and other similar usage information.
Transactional Information. When you receive, submit, or complete a transaction via the Platform, this includes information about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction.
Information Collected Through Tracking Technologies. This involves the use of certain tracking technologies, including cookies and web beacons, to automatically collect certain types of usage and device information when you use our Platform or interact with our emails. The information collected through these technologies may include your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage information, and other similar information. See Section 4 of this Privacy Policy for additional information regarding these cookies and other tracking technologies.
Children and Parents
The Platform is intended for a general audience and not for use by anyone younger than the age of 13 in the United States (or under the applicable legal age outside of the United States). We do not knowingly collect Personal Information from children younger than the age of 13 (or under the applicable legal age outside of the United States), without the consent of a parent or legal guardian; if we learn that we have done so, we will promptly remove the information from our active databases. If you are a parent or legal guardian who believes that we have collected or used your child’s Personal Information without your consent, please contact us at .
Information Collected from Other Sources
In addition to the above information, we may also obtain information about you from other sources, as described in more detail below.
Vendors and Business Partners. We may receive Personal Information and/or anonymous data about you from companies that offer their products and/or services for use in conjunction with our Platform or whose products and/or services may be linked from our Platform. We may add this to the data we have already collected from or about you through our Platform.
Advertising Data. This includes data and other information that relates to our ad campaigns that run on other platforms, such as the ads you may have clicked on and other interactions with our ads.
While certain types of information described above, such as Usage Information and information collected from third parties, are generally non-identifying on a standalone basis, we may in certain instances combine this information with other information collected on the Platform, as described above. If we ever combine non-identifying information with Personal Information or other information that enables you to be identified, we will treat such combined information as Personal Information. We do not currently use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.
Lawful Basis for Collecting Information
Certain jurisdictions where Users of the Platform are citizens or residents have laws and regulations that require a “lawful basis” for collecting and retaining Personal Information (e.g., the European Union General Data Protection Act 2016/679 [“GDPR”] and the California Consumer Privacy Act of 2018 [“CCPA”]).
In accordance with these laws and regulations, the “lawful basis” for the information collection and processing described in this Privacy Policy is: (i) your consent, (ii) in order to comply with our legal obligations under applicable law (such as retention of certain records for tax purposes), and (iii) to pursue our legitimate interests in connection with the provision of the Platform and the fulfillment of our obligations thereof, including, without limitation, keeping the Platform safe and secure, improving the user experience, and introducing new services, features, and functionalities, etc.
How We Use Your Information
We may use the information that we collect and process for a variety of purposes related to the Platform, including, without limitation, to:
Identify you and potentially improve and/or customize the Platform, including products and services offered or made available to you
Process transactions that you complete via the Platform
Send you administrative notices
Address inquiries and respond to customer service requests, questions, and comments
Send you newsletters and transaction confirmations via email
Send you more relevant marketing communications, promotional materials, and general Company and Platform information/product updates
Identify trends, conduct data analysis, and determine the effectiveness of our marketing and promotions and other Platform offerings
Improve your experience and increase the efficiency and effectiveness of the Platform and functionality offerings
Maintain security
Enforce our Terms of Service and applicable law and to screen for potential fraud
Analyze Platform usage, User preferences, browser behavior, and other trend data
Maintain business records and processes
Solicit feedback, reviews, and other information regarding your experience with the Platform, including, without limitation, with respect to certain features and functionalities that you would like to see on the Platform, or that we have recently rolled out onto the Platform
Test new features, Platform offerings and functionalities on the Platform
To comply with our legal and regulatory obligations, including but not limited to “Know Your Customer” and anti-money laundering checks, tax reporting, assisting with law enforcement, investigations, and/or judicial proceedings;
Other purposes that we believe are necessary to protect our rights and the rights of others, or as otherwise described to you at the time of collection
We may also use certain collected information on an aggregated and/or anonymized basis in order to conduct market research, engage in project planning, for troubleshooting purposes, to help detect and protect against error, fraud, or other criminal activity.
Email Notifications and Opt-Out
We maintain a strict “no-spam” policy. As applicable, by accepting the Terms of Service, which includes this Privacy Policy, you expressly agree that we may use your information to contact you by email in order to deliver you information that is relevant to your use of the Platform such as administrative notices, transaction confirmations, product/service enhancements or “newsletters” (collectively, “Email Notifications”). You may choose to stop receiving Email Notifications from us by following the instructions included in such communications. If a third party vendor provides such Email Notifications, you may unsubscribe in accordance with the instructions provided by such third party. If you are having problems unsubscribing, please contact us at privacy@starkix.com (forwarding the Email Notification, if applicable, and including in the subject line the words “Unsubscribe”), and you will be removed within seven (7) business days. Please note that we will not process any unsubscribe requests submitted as direct replies to any Email Notification.
How We Share Your Information
We may share aggregated usage information and may otherwise disclose non-Personal Information that we collect to third parties. However, absent your prior consent, we will not sell or share your personal information to third parties except as set forth in this Privacy Policy.
We may use third parties to outsource one or more aspects of our business and/or Platform operations (such processing transactions that you initiate through the Platform, customer service functions, data processing, web analytics, maintenance, and security execution and clearing services), in which case, we may provide your Personal Information to such third parties in connection with the performance of such activities. Such third parties will only use your Personal Information to the extent necessary to perform their functions and will be contractually bound to process your Personal Information only on our behalf and in compliance with our requests.
In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your Personal Information is treated, transferred, or used.
We will also share your information with any member, subsidiary, parent, or affiliate of our corporate group, only for the purposes set out above, to assist in the improvement and optimization of the Platform, in order to prevent illegal uses, increase user numbers, development, engineering and analysis of information or for our internal business purposes.
In addition to the foregoing, we also reserve the right, and you hereby authorize us, to share or disclose (including, without limitation, to law enforcement agencies, public authorities, governmental departments, or other similar organizations) information we collect, including your Personal Information, and any other information, records or electronic communications of any kind, when we determine (in our sole discretion), that the disclosure of such information is necessary to identify, contact, or bring legal action against you if:
you are or may be violating the Terms of Service or this Privacy Policy, or if otherwise necessary to enforce our Terms of Service or other policies governing the Platform;
you are interfering with our or any third party’s rights or property;
you are violating any applicable law, rule, or regulation;
necessary or required by any applicable law, rule, or regulation, including a subpoena or similar legal process or request/order;
necessary or required for purposes of public importance, to protect our rights, protect your safety or the safety of others, investigate security, technical issues, or fraud, or respond to a government request;
requested by governmental authorities in the event of any investigation, act of terrorism or instance of local, regional, or national emergency;
necessary to support any audit, or to comply with similar corporate governance functions; and/or
otherwise consented to by you.
Cookies and Other Tracking Technologies
Cookies
We may use cookies, for example, to keep track of your preferences, or to engage in certain retargeting activities that we feel will better enhance your experience and the efficiency and effectiveness of the Platform and certain services and functionalities offered thereon. Cookies are also used to collect general usage and volume statistical information that does not include Personal Information. We also partner with certain third-party service providers to collect non-personally identifiable information to compile aggregated statistics and engage in analytics, auditing, research, and reporting. These third parties may use server logs, web beacons, tags, pixels, and similar technologies, and they may set and access cookies on your computer or other device.
Cookies are small pieces of information that are stored as text files by your Internet browser on your computer's hard drive. Most Internet browsers are initially set to accept cookies. You can set your browser to refuse cookies from Platforms or to remove cookies from your hard drive, but if you do so, you may not be able to access or use portions of the Platform, or certain offerings on the Platform may not function as intended or as well. Also, some browsers have “do not track” features that allow you to tell a Platform not to track you. These features are not all uniform. If you block cookies, certain features on the Platform may not work. If you block or reject cookies, not all of the tracking described herein will stop. Please note that certain options you select are browser- and device-specific.
A more detailed list of the cookies we currently use and how we use, or may use, them are as follows:
Security: We secure the Platform with cookies that facilitate security features and allow us to detect activity that might violate our rules and Terms of Service, such as unauthorized access or activity.
Localization: We use some cookies to help us provide localized experiences, such as displaying the Platform in the local language.
Service Features: We use certain cookies to provide greater functionality to the Platform and help us deliver our products and services.
Performance: We use performance cookies to help us route traffic between servers and understand how the Platform is performing so we can provide users with the best experience possible.
Analytics and Research: We use certain cookies and other technologies also help us to understand, improve, and research features and content on the Service.
Web Beacons
Our Platform may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how the Platform is used, including, for example, how many Users access a specific page and which content items or features such User’s clicked on. This aggregated information I used to understand and optimize how the Platform is used.
Do not Track
If you are accessing the Platform on a desktop device, please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to Platforms and online service you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many Platforms and online services, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
For mobile applications, you may be able to limit certain advertising practices using the settings on your mobile device. On most mobile devices, you can install the DAA’s AppChoices app to make choices about cross-app interested-based advertisements from participating third parties. For information from NAI about opting out on mobile devices, click here. If you utilize an Apple iPhone device, you have the ability to request that a mobile application discontinues tracking your activity across third party mobile applications by selecting the “Ask App Not To Track” feature, which you can learn more about by clicking here.
Links to Third Party Platforms
The Platform may include links to other Platforms, mobile applications, or services (collectively, “Third Party Sites”), whose privacy practices may differ from those set forth herein. Such links are not an endorsement by Company of those Third Party Sites and/or the products or services they offer. If you visit Third Party Sites or submit information to any of those Third Party Sites, your visit and information provided is governed by their privacy statements and policies. We encourage you to carefully read the privacy statements and policies of any Third Party Site you visit, as it may differ substantially from that of this Privacy Policy. We make no representations or warranties with respect to, nor are we responsible for the privacy statements and policies of, any Third Party Sites. If you decide to click on any such links or access any Third Party Sites appearing on the Platform, you do so at your own risk.
Sweepstakes, Contests and Promotions
We may offer sweepstakes, contests, and other promotions through the Platform (“Promotions”) that may require registration. If you choose to participate in any Promotions, you acknowledge that you are agreeing to the official rules that govern such Promotions, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of such Promotions to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with such Promotions. Additionally, if you choose to enter any Promotions, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotions, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the official rules of such Promotions, such as on a winner’s list.
Your Rights; Information Access and Control.
In certain circumstances you have the right to access the Personal Information that we collect/store about you and to correct, update, or request deletion of such Personal Information.
Users who are citizens or residents of the European Economic Area or United Kingdom have certain rights under the GDPR, including the right to: (i) request access to, and obtain a copy of, your Personal Information (free of charge); (ii) request rectification or erasure of your Personal Information; (iii) object to or restrict certain processing of your Personal Information; (iv) request portability of your Personal Information; and (vi) take legal action in relation to any breach of your rights regarding the processing of your Personal Information, and to lodge complaints before the competent data protection regulators. Additionally, if we have collected and processed your Personal Information with your consent, you have the right to withdraw your consent at any time.
If you are a California resident, you have certain rights under the CCPA. Residents of Colorado, Virginia, Nevada, and other states also have (or may in the future have) certain rights under the applicable privacy laws of such state. These include the right to (i) request access to, details regarding, and a copy of the Personal Information we have collected about you and/or shared with third parties; (ii) request deletion of the Personal Information that we have collected about you; and (iii) the right to opt-out of sale of your Personal Information. As the terms are defined under the CCPA (and other applicable state privacy laws), we do not “Sell” your “Personal Information.”
If you wish to exercise your rights under the GDPR, CCPA, or other applicable data protection or privacy laws, please contact us at privacy@starkix.com, specify your request, and reference the applicable law. We may ask you to verify your identity, or ask for more information about your request before we can take action to address your request. We will consider and act upon any above request in accordance with applicable law. We will not discriminate against you for exercising any of these rights.
Security
The security of your information is important to us, and we take steps to ensure that your information, both during transmission and once we receive it, is treated securely and in accordance with this Privacy Policy. However, no method of transmission over the Internet is one hundred percent secure, and the complete and absolute security of any information collected, stored, or used by us cannot be guaranteed. Although we will do our best to protect your Personal Information (for example, by encryption) and mitigate the nature of security risks (which are constantly evolving along with the technical and organizational industry standards for managing risk), we cannot guarantee the security of your information transmitted through the Platform; any transmission is at your own risk. In the unlikely event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information.
Storage, Transfer and Retention of Information
Information collected by us may be stored and processed in the United States or any other country in which we or our agents maintain facilities. By using the Platform, you expressly consent to any such transfer and storage of information outside of your country of residence, where data protection laws may be different and/or less stringent. However, we will endeavor to take reasonable measures to keep up an adequate level of data protection when sharing your Personal Information with such countries.
We make no representation or warranty with respect to any duty to permanently store any information you may provide or that we otherwise collect about you. We strive to keep our processing activities with respect to your Personal Information as limited as possible. In the absence of specific retention periods set out in this Privacy Policy, we will retain the information we collect from or about you only as long as necessary to provide you with the Platform or our services, which includes for the duration of, but could extend beyond, your active participation on the Platform, or as otherwise set forth in this Privacy Policy, and to the extent set out in this Privacy Policy and as necessary to comply with our legal and/or statutory obligations, resolve disputes, enforce our agreements, and protect our legal rights. Additionally, we may retain indefinitely any aggregated, anonymized, or pseudonymized information which we may collect and maintain, and may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format. By using the Platform and providing us with information (including Personal Information), you waive any claims that may arise under your own or any other local or national laws, rules or regulations or international treaties. We may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format. This Privacy Policy applies to your information for as long as your information is in our possession, even if you terminate or discontinue your use of the Platform.
Updates; Notification of Privacy Policy Changes
We may update this Privacy Policy to reflect changes to our information collection and processing practices from time to time in our sole discretion. If we make any material changes to this Privacy Policy, we will notify you by posting such changes on the Platform prior to the change becoming effective. We will also update the “Last Updated” date at the top of this Privacy Policy, which reflects the effective date of such Privacy Policy, and we encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. Once a change becomes effective, your continued use of the Platform will automatically constitute your acceptance of such changes.
How to Contact Us
In the event that you wish to make a complaint or request concerning your Personal Information or our privacy practices, or have questions, concerns, or comments about this Privacy Policy, please contact us in the first instance at privacy@starkix.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute process set forth in the Terms of Service.
