For purposes of the EU’s General Data Protection Regulation 2016 (the “GDPR”) the data controller is Estrella LLC, with an office at 182 Howard Street #826, San Francisco, California 94105 USA. Please see Section 12 below for additional disclosures applicable only to users based in the European Union (the “EU”).
1. What types of information do we collect and how do we collect it?
2. How do we use information collected about you?
3. How long do we maintain your personal data?
4. To whom do we disclose information collected about you?
5. What are our policies for cookies and similar technologies?
6. How do we secure information collected about you?
7. Do our platforms support “DO NOT TRACK” signals?
8. Do we share information about you with third parties for their own direct marketing purposes?
9. What are the policies of linked websites and other third parties?
10. What is our policy on use of our platforms by children?
11. How can you correct, update or make choices about the information collected about you that we are storing?
12. Additional disclosures for users based in the European Union.
15. How can you contact us?
1. WHAT TYPES OF INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?
When you use or access any of our Platforms, we may collect a variety of information about you and others, as described below. Such information includes, but is not limited to, information about you which is in a form that permits us to identify you (your “personal data”).
A. Personal Data About You That You Provide.
When you use or access any of our Platforms, we may ask you to provide us with certain personal data, including but not limited to some or all of the following: your name, username, email address, telephone number, current and previous mailing addresses, credit or debit card or PayPal account information, payment address, other financial account number, social security number or tax identification number, driver’s license number or other government issued identification number (or a copy of your driver’s license or other government issued identification card), date of birth, time of birth, birth location, login, PIN, password, account preferences, and time zone. You may be asked for this information at various times when interacting with our Platforms, such as when registering to be a user of any of our services, when making a purchase through any of our Platforms, or when filling out a form or survey or participating in a promotion through our Platforms.
B. Personal Data About You That We Collect Via Technology.
When you use or access any of our Platforms, we may also collect certain personal data through automated means, including but not limited to some or all of the following: your mobile phone number, unique device ID, device type, machine ID, geolocation information, computer and connection information, browser type, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and date and time stamps for your visits. We also may collect any telephone number from which you contact us, or from which you place a call to another user through our calling feature on any of our Platforms. (If you call any user or other person directly – that is, not through the calling feature on any of our Platforms – your telephone number may be obtained by the person called.)
We may monitor or record your live telephone conversations with other users through the Platform for operational purposes, including for quality assurance purposes and in furtherance of making certain services available to you.
C. Information About You That We Collect From Others.
When you use or access any of our Platforms, we may also collect your name and email address from your friends who suggest to us that you may wish use one of our Platforms. If we receive this personal data about you in this way, we will contact you to let you know that you have been recommended to us. If you do not respond to our outreach or you ask us to delete your personal data, we will do so.
When you use or access certain of our Platforms, we may also collect your name, address, phone number, and geolocation information from other third parties, such as identity verification vendors which we engage.
D. Information About Others That We Collect From You.
When you use or access any of our Platforms, you may decide to provide us with information about a third party, such as your friends’ names and email addresses in connection with our “tell a friend” features.
E. Information Provided to Social Networking Sites.
F. Other Information That We Collect Via Technology.
When you use or access our Platforms, we also may collect certain information through automated means associated with your activities on our Platforms, including information about the way you interact with any of our Platforms or any content thereon, statistics regarding your page views and traffic to and from our Platforms, and the number of bytes transferred, hyperlinks clicked, and other actions you take on our Platforms. Each of our Platforms may also track information such as the URL that you visited before you come to the Platform and the URL to which you next go. As with most websites and other digital platforms, we also employ cookies, pixel tags, web beacons, and similar technologies on our Platforms to collect and store certain information about visitors to our Platforms, to improve our services, and to help us remember you and your preferences when you revisit our Platforms. For more information about our practices in this area for a particular Platform, please see our Cookies Policy linked in the footer of such Platform.
G. Information in Your Inquiries and Posts.
We also collect any information you send to us or other users through any of our Platforms, including information about you in correspondence, mail, and chats conducted through a Platform, and responses to our customer satisfaction surveys or customer service communications. We also collect information from content you post in online reviews, comments, forums, or blogs on our Platforms.
2. HOW DO WE USE INFORMATION COLLECTED ABOUT YOU?
Our primary purpose in collecting information about you in connection with your use of our Platforms is to provide you or connect you with our products, services, information, and users that match your interests and preferences. However, we may use such information collected about you for a variety of commercial purposes. Without limitation, we may use such information to:
enable your participation in activities on our Platforms;
provide our offerings and services to you;
confirm your identity;
enforce our Platform policies and terms of service, and investigate potential violations of such policies or terms;
fulfill an order that you place through any of our Platforms, including to process payment for any purchase made through any of our Platforms;
respond to inquiries that you may have about any of our Platforms or services;
administer your account on any of our Platforms;
display our content based upon your interests;
enable you to search information on our Platforms;
list in our search and directory services any users who provide services through one of our Platforms;
contact you regarding customer service and customer surveys;
assess your needs and interests in our products and services in order to better tailor our offers and/or advertising;
improve our Platforms;
inform you of changes made to our Platforms;
organize or carry out promotional activities, games or promotional events;
inform you of products, services, promotions, offers, and competitions which you may find interesting, provided you have not opted out of receiving such information or, where required, we have your express consent;
understand general customer trends and patterns so we can develop and support existing and ongoing marketing strategies for our products and services; and
conduct other marketing and commercial activities.
We may also use information about you that we collect in connection with your use of our Platforms for security, administrative, and legal purposes (including to detect, prevent, or otherwise address fraud, security or technical issues).
Also, we may combine information about you that we collect in connection with your use of our Platforms with other records (such as those obtained from third parties) to develop a customer profile relating to you.
3. HOW LONG DO WE MAINTAIN YOUR PERSONAL DATA?
We will store your personal data for no longer than is necessary for the purpose for which such personal data is processed. Please note, however, that we may retain and use your personal data as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements and rights, or if it is not technically and reasonably feasible to remove such information from our databases, which means that we may retain and use your personal data as necessary after you stop using our Platforms. Subject to the foregoing, we will endeavor to delete your personal data promptly upon your written request.
4. TO WHOM DO WE DISCLOSE INFORMATION COLLECTED ABOUT YOU?
We may share or disclose information about you to third parties in the following situations:
A. Other Users.
In connection with making the Platforms available to our users, we may disclose certain information about you (including your name, username, and date of birth) to other users of the Platforms, solely as directed by you or as authorized under our terms of service for the applicable Platform.
B. Our Affiliates.
We may disclose information collected about you to our affiliates who act as service providers for us. By “affiliates”, we mean any entity that controls, or is controlled by, or is under common control with Estrella, LLC, including, but not limited to, companies doing business under any of the following brands: Estrella. Our affiliates provide us with various services, including fraud detection and marketing services. Personal data collected about you by one entity in our corporate family will not be disclosed to any affiliate (i.e., to any other entity in our corporate family) for their direct marketing purposes, without your consent.
C. Third-Party Service Providers.
We also disclose information collected about you to our third-party service providers and other partners who perform services on our behalf in connection with any of the Platforms. The services provided by such third parties and partners include services in the following categories:
processing payments on our behalf;
helping us to provide products or services that you request;
sending marketing communications on our behalf;
authenticating identities on our behalf;
helping us to create or maintain our databases;
helping us to research or analyze the people who use our Platforms; and
testing our Platforms.
D. Social Networking Sites.
E. Co-Branded Service Providers.
We may enter into agreements with certain third-party businesses pursuant to which we provide such third party with a URL and a customer registration page co-branded with, or private labeled by, the third party, which distributes and promotes the URL to its customers. If you register on a website with a third party with which we have such a co-branded arrangement, we may provide information we have collected about you through our Platforms to such third party acting as such third party’s service provider.
F. General Public.
We may share with the general public via our Platforms, or re-publish on a third-party website, any information that you post as a user of one of our Platforms, such as information in a listing, online review, comment, forum, or blog posting on any of our Platforms. This may include information that identifies you (by username or otherwise).
G. Third Parties Involved in Business Transition.
H. Our Advisors.
We may also share information collected about you with our auditors, legal advisors, and similar third parties in connection with our receiving their professional services, subject to standard confidentiality obligations.
I. Law Enforcement.
We may disclose information about you to the government or to third parties under certain circumstances when legally obligated to do so, such as in connection with suspected illegal activity in connection with the Platforms, or to respond to a subpoena, court order or other legal process, or that we believe may aid a law enforcement investigation. We reserve the right to release information collected through the Platforms to law enforcement or other government officials, as we, in our sole discretion, deem necessary or appropriate.
J. Legal Processes.
We may share all types of information with others as required by, or permitted by, law. This may include sharing all types of information with governmental entities, or third parties in response to subpoenas, court orders, other legal process, or as we believe is necessary to exercise our legal rights, to defend against legal claims that have been brought against us, or to defend against possible legal claims that we determine in our sole discretion might be brought against us.
K. Other Third Parties.
We may share information with other third parties that are not described above. When we do so we will endeavor to either aggregate or de-identify the information so that a third party would not be likely to link data to you, your computer, or your device. Aggregation means that we combine the information of numerous people together so that the data does not relate to any one person. De-identify means that we remove or change certain pieces of information that might be used to link data to a particular person.
We may also share any information with other third parties that are not described above if you give us consent to do so.
5. WHAT ARE OUR POLICIES FOR COOKIES AND SIMILAR TECHNOLOGIES?
Please see our Cookies Policy linked in the footer of the applicable Platform.
6. HOW DO WE SECURE INFORMATION COLLECTED ABOUT YOU?
We have implemented and follow technical and procedural measures (including encryption of certain information) intended to protect against unauthorized access and use of information collected in connection the use of our Platforms. HOWEVER, PLEASE NOTE WE CANNOT FULLY ELIMINATE THESE RISKS AS, DESPITE OUR BEST INTENTIONS, NO TECHNOLOGY IS COMPLETELY SECURE. OUR PLATFORMS ARE OPERATED ON SOFTWARE, HARDWARE, AND NETWORKS, ANY COMPONENT OF WHICH MAY, FROM TIME TO TIME, EXPERIENCE BREACHES OF SECURITY OR OTHER ISSUES BEYOND OUR CONTROL.
Accordingly, we cannot guarantee that any information collected about you, whether during transmission or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others who do not have your authorization. Any such transmission or sharing of that information is done at your own risk.
You also play a role in protecting your personal information. Please do not share your user name or password with others.
7. DO OUR PLATFORMS SUPPORT “DO NOT TRACK” SIGNALS?
At this time, our websites do not support “Do Not Track” preferences that may be available in your browser for letting websites know that you do not want them collecting certain kinds of information. If you turn on the “Do Not Track” setting on your browser, our websites are not currently capable of following whatever Do Not Track preferences you set. For more information about Do Not Track, visit donottrack.us.
8. DO WE SHARE INFORMATION ABOUT YOU WITH THIRD PARTIES FOR THEIR OWN DIRECT MARKETING PURPOSES?
No. We do not disclose your personal data to third parties for their own direct marketing purposes without your consent.
9. WHAT ARE THE POLICIES OF LINKED WEBSITES AND OTHER THIRD PARTIES?
10. WHAT IS OUR POLICY ON USE OF OUR PLATFORMS BY CHILDREN?
None of our Platforms are designed or intended to be attractive to use by children under the age of 18, and we do not knowingly collect personally identifiable information from children under 18. IF YOU ARE UNDER 18 YEARS OF AGE, PLEASE DO NOT USE ANY OF OUR PLATFORMS AT ANY TIME OR IN ANY MANNER.
11. HOW CAN YOU CORRECT, UPDATE OR MAKE CHOICES ABOUT THE INFORMATION COLLECTED ABOUT YOU THAT WE ARE STORING?
If any of your personal data that we are storing changes, or if you no longer desire our services, you may correct, update, or delete information about you, or ask that it be removed from public forums (such as directories, blogs, or testimonials) on our Platforms, by calling us at (877) 533-6435 or emailing us at privacy@Estrella.com, or (for some information) by logging into your profile on the applicable Platform and making changes in your account settings. We will attempt to respond to your request within 30 days. In some cases, we may not be able to remove your personal data, in which case we will endeavor to let you know that we are unable to do so and why. For example, we may be required (by law or otherwise) to keep certain information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).
B. Disconnecting a SNS.
If you decide at any time that you no longer wish to have your Facebook, Twitter, or other SNS account linked to your Platform account, you must de-link the SNS from the applicable Platform by logging into your profile for such SNS and changing your preferences. You may also manage the sharing of certain personal information with us when you connect with us through an SNS, such as through Facebook Connect. Please refer to the privacy settings of the SNS to determine how you may adjust our permissions and manage the interactivity between our Platforms and your social media account.
C. Stopping Certain Communications From Us.
1. Emails. We may communicate with you by email at various times about your account and transactions, as well as regarding various customer service matters, customer surveys, and promotions, including special offers and updates about new products and services. You can choose to stop receiving promotional emails from us at any time simply by following the “Unsubscribe” or “Manage Email Preferences” link at the bottom of any promotional email, or by logging into your profile on the applicable Platform and changing your account preferences. Please note that you may not opt out of receiving non-promotional emails regarding your account or your transactions with us.
2. Service-Only Telephone Calls or Text Messages. If you voluntarily provide your telephone number to us, you will be agreeing that we (including our affiliates and agents) can call or text you at that number (including via an automated dialing system or prerecorded message) to respond to your request for our services and to communicate with you regarding your account or a transaction with us. Please note that standard message and data rates may apply. If you wish to stop receiving such service-only calls or texts at any time, you may do so by logging into your account and clicking the “Personal Information” link under the menu icon, and changing your account preferences; by calling us at (877) 533-6435; by emailing us at privacy@Estrella.com; or (for texts only) by responding “STOP” to any such text message.
3. Telephone Marketing Calls. If we have provided you the option to consent to receive telephone marketing calls from us (including via an automated dialing system or prerecorded messages), please note that your decision to consent to receive such promotional calls or messages is voluntary and is not required to purchase or use any of our products or services. If you have provided consent to receive telephone marketing calls from us, but you wish to revoke such consent, you may do so by any reasonable means, including by calling us at (877) 533-6435 or emailing us at privacy@Estrella.com and stating that you wish to revoke such consent.
4. Text Message Marketing. If we have provided you the option to consent to receive promotional text messages from us (including via an automated dialing system), please note that your decision to consent to receive such promotional text messages is voluntary and is not required to purchase or use any of our products or services, and that standard message and data rates may apply. If you have provided consent to receive promotional text messages from us, but you wish to revoke such consent, you may do so by any reasonable means, including by calling us at (877) 533-6435 or emailing us at privacy@Estrella.com and stating that you wish to revoke such consent, or by responding “STOP” to any such message.
12. ADDITIONAL DISCLOSURES FOR USERS BASED IN THE EUROPEAN UNION.
We are headquartered in the United States. By using any of our Platforms from outside the United States, you acknowledge that your personal data may be accessed by us or transferred to us in the United States and to our affiliates, partners, and service providers who are located around the world; and that your personal data will be transferred to, and stored and processed in, the United States or elsewhere in the world where our servers are located.
B. Rights Under the GDPR.
If you are based in the EU, in certain circumstances you have rights under data protection laws in relation to your personal data that we hold about you – specifically:
1. Request access to your personal data. You may have the right to request access to any personal data we hold about you as well as related information, including the purposes for processing the personal data, the recipients or categories of recipients with whom the personal data has been shared, where possible, the period for which the personal data will be stored, the source of the personal data, and the existence of any automated decision making.
2. Request correction of your personal data. You may have the right to obtain without undue delay the rectification of any inaccurate personal data we hold about you.
3. Request erasure of your personal data. You may have the right to request that personal data held about you be deleted.
4. Request restriction of processing your personal data. You may have the right to prevent or restrict processing of your personal data.
5. Request transfer of your personal data. You may have the right to request transfer of your personal data directly to a third party where this is technically feasible.
You can exercise any of these rights by calling us at (877) 533-6435 or by emailing us at privacy@Estrella.com.
C. Restrictions on Use of Your Personal Data to Promote Third-Party Products and Services.
If you are based in the EU, we will only send you direct marketing communications related to third party products and services, if you have given your consent to receiving such marketing. We will generally ask for your consent to receive such marketing when you first provide your personal data.
You can choose to stop receiving any direct marketing communications from us at any time simply by following the “Unsubscribe” or “Manage Email Preferences” link at the bottom of any promotional email, or by logging into your profile on the applicable Platform and making changes in your account settings. Please note that you may not opt out of receiving non-promotional emails regarding your account or your transactions with us.
15. HOW CAN YOU CONTACT US?
Email address: privacy@Estrella.com
Telephone number: (877) 533-6435
© 2020 Estrella, LLC. All rights reserved.