PRIVACY & COOKIE POLICY

This PRIVACY AND COOKIE POLICY (this “Privacy Policy”) outlines the type of information we collect, why we collect it, and how we use it. By accessing or using this website (StartToday.com) (together with its pages and features, the “Site”), you agree to the collection and use of your information in accordance with this Privacy Policy.


Topics: 

1. “Personal Data” Explained 

2. Our Data Protection and Data Privacy Principles 

3. Types of Personal Data We Collect 

4. How Do We Use Your Personal Data 

5. Retention of Personal Data 

6. Sharing of Personal Data 

7. Cookies 

8. Social Plugins, Social Media Widgets and Connecting via Social Networks 

9. Analytics 

10. Transactions 

11. Security 

12. Other Websites 

13. Children Under the Age of 13 

14. Online Tracking 

15. Mergers, Acquisitions, and Other Business Transactions 

16. California and Nevada Privacy Rights 

17. Canada Privacy Rights 

18. Visiting the Website from Outside the United States of America 

19. Contact Us 

20. Changes to Our Privacy Policy 


1. “Personal Data” Explained 

As used in this policy, “Personal Data” means information that would allow someone to specifically identify you or contact you physically or online (e.g., your name, physical address telephone number, email address, social security number, credit card information); and the term “Non-Personal Data”means any information other than personal information that we may collect from you. As described in more detail in section 3 below, the term “Personal Data” as used in this Privacy Policy includesDevice Information (defined below) and Order Information (defined below).


2. Our Data Protection and Data Privacy Principles 

We have implemented security features that are designed to prevent loss, misuse, alteration, or unauthorized release of, or access to, Personal Data provided to us. We have designed the Site to limit the collection and processing of Personal Data. The confidentiality of any communication or material transmitted to or from us on, through, or in relation to the Site (including any instant messaging feature made available or through the Site) or by e-mail or other electronic communication cannot be guaranteed. We are not responsible for the security of information transmitted via the Internet. If you do not want to communicate with us via the Internet, you may contact us by mail at the mailing address set forth in the “Contact” section below (see section 17below).


3. Types of Personal Data We Collect and How We Use that Data 

When you visit the Site, we might automatically collect certain information about you or your device, including, for example, information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we might collect information about the individual web pages, products, services, or content that you access, view, or listen to, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.As described in more detail in section 7 below, we might collect Device Information using the following technologies:-“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.- “Log files” track actions occurring on a website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.- “Web beacons”, “tags”, and “pixels” are electronic files or pieces of code used to record information about how you browse a website. Additionally, when you make a purchase or attempt to make a purchase on, through, or in relation to the Site, we collect certain information from you ,including, for example, your name, billing address, shipping address, payment information(including credit card numbers), email address, and phone number. We refer to this information as “Order Information”. Again, when we talk about “Personal Data” in this Privacy Policy, we are also talking about Device Information and Order Information. We use commercially reasonable efforts to maintain the confidentiality of the Personal Data that you provide to us. 


4. How Do We Use Your Personal Data 

We might use the Order Information that we collect generally to fulfill any orders placed on, through, or in relation to the Site (including, for example, processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we might use this Order Information to:- Communicate with you;- Screen our orders for potential risk or fraud; and- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.We might use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize the Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).We might also use the Personal Data in other ways. Examples of those uses might include, for example:- Operate, administer, maintain, and improve the Site and its content, features, products and services;- Facilitate your movement through the Site;- Facilitate and maintain your access and use of the Site and its content, features, products and services;- Facilitate and maintain your accounts and profiles with us or our affiliates;- Help place, fulfill, process, and track your purchases, orders, shipments, and requests;- Help provide customer service;- Send you communications like, for example, administrative e-mails, information and updates regarding any of your orders, answers to your questions, and updates about the Site;- Provide you with information about us, our affiliates, and their respective businesses, products, and services;- Provide you with information about third-party businesses, products, and services;- Provide you with customized content and services, including advertising and promotional information (e.g., targeted ads, retargeted ads), recommendations for content you might like, and cross-app or cross-site functionality across multiple third-party websites;- Conduct research and measurement activities for purposes of market research, product and service development, advertising claim substantiation, and similar activities by us or our affiliates;- Improve our or our affiliates’ products, services, marketing, and promotional efforts;- Create new products, services, marketing, and promotions for us or our affiliates;- Market our or our affiliates’ businesses, products, and services;- Administer our or our affiliates’ contests, tournaments, promotions, surveys, or similar activities;- Help personalize user experiences with the Site and its content, features, products, and services;- Analyze traffic, user behavior, and user activity to, on, and through the Site;- Monitor the activities of you and others on or through the Site;- Create consumer profiles, which may combine your personal or non-personal information from the Site with your personal and non-personal information from another source or service;- Protect or enforce the rights and properties of us or our affiliates; and/or- Protect or enforce the rights and properties of others (which may include you), assuming that we believe that we an obligation to do so.In addition to all of the foregoing, we reserve the right, for us and for those who we might share your personal and/or non-personal information with (including our affiliates), to use your personal and non-personal information when: (a) required by applicable law, court order or other governmental authority (including, without limitation and by way of example only, in response to a subpoena or other legal process; and/or (b) when we or those who we might share your personal and/or non-personal information with (including our affiliates) believe in good faith that such use is otherwise necessary or advisable (including, without limitation and by way of example only, to investigate, prevent, or take legal action against someone who may be causing injury to, interfering with, or threatening the rights, obligations, or properties of us, our affiliates, a user of the Site [which may include you], or anyone else who may be harmed by such activities, or to further the user’s legitimate business interests). 


5. Retention of Personal Data 

We may retain your personal information and non-personal information for as long as we believe necessary. We may also dispose of or delete any such personal information or non-personal information at any time, except as set forth in any other agreement or document executed by both you and us concerning the same or as required by law.


6. Sharing of Personal Data 

We may share your Personal Data with our employees, agents, administrators, accountants ,financial advisors, and legal advisors for use in connection with the work they may perform on our behalf. We may share your Personal Data in the manner set forth in the potential examples listed in section 4, above. We also reserve the right to share your Personal Data with our affiliates, business partners, or third party service providers: (a) acting on our behalf or with our permission to provide you with our content, products, or services; (b) acting on our behalf or with our permission to fulfill your requests; (c) acting on our behalf or with our permission to send you marketing and event materials, newsletters, surveys, polls, e-mails, instant messages, or other communications;(d)supporting our operations through software, system, and platform assistance, cloud hosting, data analytics, payment processing, or the like; and/or (e) acting on our behalf or with our permission to provide, manage, administer, maintain, improve, monitor, distribute, operate, or facilitate the Site or the content, products, and services offered or made available on, through, or in relation to the Site.For example, we use Shopify to power our online store – you can read more about how Shopify uses your Personal Information at https://www.shopify.com/legal/privacy. We may share aggregate date on website users’ home servers with third parties, such as marketing and data analytics firms. We may also use your Personal Data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example, we frequently promote various events in conjunction with Eventbrite. Accordingly, you may receive emails from Eventbrite relating to events that may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page athttp://www.networkadvertising.org/understanding-online-advertising/how-does-it-work/.You can opt-out of certain targeted advertising by using the links below:- Facebook: https://www.facebook.com/settings/?tab=ads.- Google: https://www.google.com/settings/ads/anonymous.- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads.In certain cases, we are required to disclose Personal Data to investigate, prevent, or take action concerning: (1) legal requests; (2) the enforcement of our Terms of Service or Return Policy; (3) the protection of our rights, property, or personal safety or the rights, property, or personal safety of our users and the public; (4) our exercise of legal rights; and (5) any other disclosure required by law. 


7. Cookies 

A “cookie” is a small text file that is stored on computers, tablets, mobile phones, and any device used to browse the Internet, capable of storing navigation information for statistical or functional purposes. Some cookies may be used to recognize the user viewing a particular website, make navigation easier, and customize the content. For example, cookies allow us to remember your actions and preferences so that you do not have to re-enter information each time you visit or use the Site or navigate to another page. Cookies also allow us to keep track of items you add to your shopping cart. There are several types of cookies, including, for example, browser cookies, session cookies, and persistent cookies. While browsing on the Site, we may collect information about traffic flow and visits to the pages of our domain. This information, obtained through cookies, will be treated in a secure manner. We use different types of “cookies” on the Site. We use session cookies and cookies that remember your language and time zone preferences. You can set your browser to accept or reject the setting of all or certain cookies, or to request to be notified when a cookie is set.Each browser has specific configuration instructions. However, please be aware that the blocking of cookies may have the effect that you will not be able to use all of the Site’s functions.


8. Social Plugins, Social Media Widgets, and Connecting via Social Networks 

The Site may include different types of “social plugins” and social media widgets.These features may collect your IP address and information on which pages you are visiting on the Site, and they may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy policy of the company providing it.The Site may include social media widgets from Instagram, Facebook, YouTube, Pinterest and TikTok that use cookies to track users and advertise to them when they visit those platforms.If you do not want to be tracked by social media widgets, log out of all social networks you’re logged in to before visiting the Site.If you choose to log in to the Site using a social networking service, we may receive and store authentication information from that service to allow you to enable your log in and other information you may choose to share when you connect with those services.


9. Analytics 

Google Analytics (Functional Cookies). We use Google Analytics, a web analysis service of Google, to improve the user experience. Google Analytics helps us determine the number of visitors to theSite and helps us understand how users find the Site. Google Analytics may record your geographical location, device, internet browser, operating system, and IP address. We are not provided with information allowing us to link an individual to an IP address. More information aboutGoogle Analytics can be found at https://marketingplatform.google.com/about/analytics/. We useGoogle Ads conversion tracking cookies to measure and optimize the performance and user experience related to our ads in Google Search or selected Google Display Network websites. More information about Google’s Privacy Policy can be found at https://policies.google.com/. We may use other web analytics services in the future to help us improve the user experience.


10. Transactions 

In connection with setting up your account and/or any transaction that you conduct through the Site, you may be asked to supply certain information relevant to the transaction, including, without limitation, your credit card number and expiration date, your billing address, your shipping address, your phone number and/or your email address. By submitting such information, you grant us without charge the irrevocable, unencumbered, universe-wide and perpetual right to provide such information to third parties (e.g., payment processing companies)for the purpose of facilitating the transaction. All credit card, debit card and other monetary transactions on or through the Site occur through an online payment processing application(s) accessible through the Site. This online payment processing application(s) is provided by our third-party online payment processing vendor,Shopify. Additional information about Shopify, its privacy policy and its information security measures (collectively, the “Shopify Policies”) should be available on the Shopify website located athttps://www.shopify.com/legal/privacy or by contacting Shopify directly. Reference is made to theShopify Policies for informational purposes only and are in no way incorporated into or made a part of this Privacy Policy. Our relationship with Shopify, if any, is merely contractual in nature, as Shopify is nothing more than a third-party vendor to us, and is in no way subject to our direction or control; thus, their relationship is not, and should not be construed as, one of fiduciaries, franchisors-franchisees, agents-principals, employers-employees, partners, joint venturers, or the like.


11. Security 

We implement security measures to help protect the Personal Data collected through the Site. For example, we encrypt the transmission of information through the Site by using secure socket layer(SSL) technology. Regardless of the foregoing, please observe that “perfect” or “100%” security does not exist on the Internet. Therefore, your access and use of the Site, and your opening of any communications sent through or as a function of the Site, are done at your own risk.


12. Other Websites 

This Privacy Policy only applies to the Site and any websites of our affiliates which may link to thisPrivacy Policy. The Site may contain links to other websites. Please be aware that we are not responsible for the privacy practices of those websites. When visiting other websites, you should read those websites’ privacy policies.


13. Children Under the Age of 13 

The Site is not intended for children. No one under age 13 may provide any Personal Data on theSite. We do not knowingly collect Personal Data from children under 13. If you are under 13, do not use or provide any information on the Site. If we learn we have collected or received Personal Data from a child under 13, we will use reasonable efforts to refrain from further using such Personal Data or maintaining it in retrievable form. If you believe we might have information from or about a child under 13, please contact us at starttoday@thehollisco.com. Furthermore, if you are under 18 years of age, then you (or your parent or legal guardian) may at any time request that we remove content or information about you that is posted on the Site. Please submit any such request (“Request forRemoval of Minor Information”) to start@thehollisco.com, with a subject line of “Removal of MinorInformation”. For each Request for Removal of Minor Information, please state “Removal of MinorInformation” in the e-mail or letter subject line, and clearly state the following in the body: (a) the nature of your request; (b) the identity of the content or information to be removed; (c) whether such content or information if found on the Site; (d) the location on content or information on the Site (e.g.,providing the URL for the specific web page the content or information is found on);e. that the request is related to the “Removal of Minor Information”; (f) your name, street address, city, state, zip code, and e-mail address; and (g) whether you prefer to receive a response to your request by mail or e-mail. We are not responsible for failing to comply with any Request for Removal of MinorInformation that is incomplete, incorrectly labeled, or incorrectly sent. Please note that the aforementioned removal does not ensure complete or comprehensive removal of such content or information posted on the Site. Also, please note that we are not required to erase or otherwise eliminate, or to enable erasure or elimination of, such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule, or regulation requires us to maintain the content or information; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished, or reposted by the third party); when we anonymize the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information. The foregoing is a description of our voluntary practices concerning the collection of personal information through the Site from certain minors, and is not intended to be an admission that we are subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s OnlinePrivacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.


14. Online Tracking 

We do not respond to “do not track” (DNT) signals.


15. Mergers, Acquisitions, and Other Business Transactions 

We may decide to sell, buy, merge, or otherwise reorganize its business. If that occurs, you will be notified via email or a prominent notice on the Site of any ownership We may decide to sell, buy, merge, or otherwise reorganize its business. If that occurs, you will be notified via email or a prominent notice on the Site of any ownership change and any changes in the use of your Personal Data. These types of transactions may involve the disclosure of Personal Data to prospective or actual purchasers, or receiving it from sellers. We seek appropriate protection forPersonal Data in these types of transactions.


16. California & Nevada Privacy Rights 

If you are a California resident, California law may provide you with additional rights regarding ouruse of your personal information. To learn more about your California privacy rights, visit the CCPAPrivacy Notice.If you are a Nevada resident, Nevada law gives consumers in Nevada the right to restrict certainbusinesses from selling certain Personal Data to third parties if those third parties will license or sellsuch personal information to additional third parties. To exercise this right, please click here, followthe instructions and provide the requested information (e.g., your complete name, street address,city, state, zip code, and email address).


17. Canada Privacy Rights 

If you are a Canadian Citizen and we have an established business relationship with you, then, pursuant to Principle 9 of the Model Code for the Protection of Personal Information, you have the right to request the existence, use and disclosure of your Personal Data and be given access to that information. You are further able to challenge the accuracy and completeness of the information and have it amended as appropriate. Specifically, you are entitled to obtain free of charge, information from us regarding whether or not we have any of your Personal Data, an account of the use that has been made of that information, and an account of the third parties to which it has been disclosed.Please submit any such request (“Canada Privacy Rights Request”) to any one of the following: By mail: Start Today via The Hollis Company, LLC, Attn. Canada Privacy Agent, P.O. Box 151885, Austin, TX 78715, with a subject line of “Your Canada Privacy Rights”. By email: starttoday@thehollisco.com, with a subject line of “Your Canada Privacy Rights – Attn. Canada Privacy Agent”. For each Canada PrivacyRights Request, please state “Your Canada Privacy Rights” in the email or letter subject line, and clearly state the following in the body: (a) the nature of your request; (b) that the request is related to“Your Canada Privacy Rights;” (c) your name, street address, city, state, zip code and email address; and (d) whether you prefer to receive a response to your request by mail or email. If you send a Canada Privacy Rights Request by mail, then please do so by U.S. Certified Mail, ReturnReceipt Requested to allow for confirmation of mailing, delivery and tracking. We will not accept aCanada Rights Request via telephone or fax; and are not responsible for a Canada Privacy RightsRequest that is incomplete, incorrectly labeled or incorrectly sent. Finally, as explained further above, we do not authorize third parties to collect your personal information when you use the Site, except as expressly stated in this Privacy Policy. To the fullest extent permitted by law, we are not responsible for, and you hereby release us from, any and all liability which may arise from, such third parties’ unauthorized collection of your personal information.


18. Visiting the Website from Outside the United States of America 

If you are accessing the Site from outside of the United States of America or otherwise contacting or visiting us from outside of the United States of America and Canada, please be aware that yourPersonal Data may be transferred to, stored or processed in the United States of America, where our servers are located and our database is operated. The data protection and other laws of theUnited States of America and other countries might not be as comprehensive as those in the country from which you are accessing the Site. By providing your Personal Data, you understand that it maybe transferred to our facilities and to those third parties with whom we share it as described in thisPrivacy Policy.


19. Contact Us 

Should you have any further questions or suggestions regarding the protection of your PersonalData processed in connection with the use of the Site, please contact us at starttoday@thehollisco.com, or via the Bot on the right. 


20. Changes to Our Privacy Policy 

This Privacy Policy is effective as of the date set forth at the end of this document. We may regularly review and revise our Privacy Policy as we deem appropriate. We will make changes to the PrivacyPolicy available on this Site and note that this Privacy Policy has been updated, in which case the updated of this Privacy Policy is effective immediately after it appears on this Site. This PrivacyPolicy was last updated on January 1, 2020.