Privacy policy

Privacy Policy

Last modified: March 31, 2023

Introduction

Starface World, Inc. (“Starface World,” “Company” or “We”) respects your privacy and is committed to protecting it through compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit www.starface.world or one of our other websites, applications or use other services from Company (each referred to herein as a “Site” and collectively, the “Sites”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On the Site(s).
• In email, text, and other electronic messages between you and the Sites.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any means other than through a Site; or 
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Sites.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Sites. By accessing or using the Sites, you agree to this privacy policy. This policy may change from time to time. Your continued use of the Sites after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Sites, including information by which you may be personally identified, such as name, postal address, email address, telephone number and any other identifier by which you may be contacted online or offline ("personal information") or that is about you but individually does not identify you, such as the following: 

• Payment Information

If you purchase Products through the Services, we require that you provide our third party payment vendors, including Shopify and Carthook, with certain billing information, which may include your credit card number, expiration date, bank account information, billing address, activation code, and similar information (collectively, “Payment Information”).  You authorize our third party payment vendors to collect, process, and store your Payment Information in accordance with their respective privacy policies.  We reserve the right to change our payment vendor at any time, or to use additional payment vendors, at our discretion, and will update this Privacy Policy from time to time accordingly.  

• Server Log Information  

Our servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and the pages you’ve clicked on while on our Site, and details regarding your activity on the Site such as time spent on the Site and other performance and usage data. We may use these log files for purposes such as assisting in monitoring and troubleshooting errors and incidents, analyzing traffic, or optimizing the user experience.

• Cookies

We may collect information using “cookies” and other similar technologies. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your use. We use both 1st and 3rd-party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.

• Session Cookies: We use session cookies to make it easier for you to navigate our Services. A session ID cookie expires when you close the Services.
• Persistent Cookies: A persistent cookie remains on your device for an extended period of time or until you delete them. You can remove persistent cookies by following directions provided in your web browser’s “help” file. To the extent we provide a log-in portal or related feature on our Site, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our visitors to personalize the experience on our Site.  

If you do not want us to place a cookie on your device, you may be able to turn that feature off on your device. Please consult your browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, certain aspects of the Site may not function properly or as intended.

• Third-Party Analytics Providers

We use one or more third–party analytics services to evaluate your use of the Services, as the case may be, by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Services you visit, number of links clicked, search terms and other similar usage data) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data.  

By accessing and using the Services, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Services.

For Google Analytics, please see: https://support.google.com/analytics/answer/6004245?hl=en and https://tools.google.com/dlpage/gaoptout

• Geolocation Information

We may automatically collect geolocation information from your device via your browser’s location services. You may provide permission for this collection on the device level (e.g., you have consented to location services generally through your browser’s settings) or by accepting our request for geolocation access on the Site. Please consult your browser’s documentation regarding how to turn off location services. If you disable location services, you may not be able to use the full array of features and functionalities available through our Site.

We collect this information:

• Directly from you when you provide it to us (as further described below).
• Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

Information You Provide to Us  

The information we collect on or through our Sites may include:

• Information that you provide by filling in forms on our Sites. This includes information provided at the time of registering to use our Site, subscribing to our service, posting a review or material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Sites.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys or questionnaires that we might ask you to complete.
• Details of transactions you carry out through our Sites and of the fulfillment of your orders. You may be required to provide financial information before placing an order through or subscribing to our Sites.
• Your search queries on the Sites.
• You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Sites, such as product reviews (collectively, "User Contributions"). Your User Contributions are posted at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Sites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Site and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account/subscription, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Sites or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Sites.
• To protect the security or integrity of the Sites and our business.
• To share your Personal Information with third parties for our marketing, commercial and advertising purposes, subject to any opt-out rights you may have.
• To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA or CPRA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users is among the assets transferred.
• With your permission, we may send you emails about our store, new products and other updates.
• With your permission, we may send text messages about our store, new products, and other updates. Updates include Checkout Reminders. Webhooks will be used to trigger the Checkout Reminders messaging system. 
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may share or receive information about you with/from third parties, including, but not limited to, advertising and remarketing providers, or similar partners, for purposes of personalizing or otherwise understanding how you engage with ads or other content. These third parties may use cookies, pixel tags, or other technologies to collect information in furtherance of such purposes, including to tailor, target (i.e., behavioral, contextual, retargeting, and remarketing), analyze, report on, and/or manage advertising campaigns or other initiatives. For example, when a browser visits a site, pixel tags enable us and these third-parties to recognize certain cookies stored within the browser to learn which ads or other content bring a user to a given site. Information that we may receive from these third parties, including through their service providers, may include advertising identifiers, IP addresses, reports, and campaign data.

By accessing and using the Site, you consent to the processing of data about you by these advertisers/remarketing providers in the manner and for the purposes set out in this Privacy Policy. For more information about digital targeting and advertising, and how you can opt out, you can visit the sites below, and http://optout.aboutads.info and www.networkadvertising.org/consumer/opt_out.asp.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. 

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To data partners for the purposes set forth in this Privacy Policy.
• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.  The types of companies that may receive personal information and their functions are: technical assistance, database management/back-up services, use analytics, email marketing platforms, customer service, and our hosting provider, Shopify. For more information about Shopify please see their terms of use and privacy policy: https://www.shopify.com/legal/terms and https://www.shopify.com/legal/privacy, respectively.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Starface World, Inc.'s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Starface World, Inc. about our Site’s users is among the assets transferred.
• To auditors and professional advisers like bankers, lawyers, accountants and insurers.
• To fulfill the purpose for which you provide it. 
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• When you contribute to a publicly available area or feature of the Sites, the information and content that you post may be made available to the general public, depending on your settings (which is why we recommend that you do not submit or post any sensitive personal information, such as your full name, home address, phone number or other information that would enable others to contact or locate you);

We may, from time to time, share and/or license personal information to other companies who may provide you information about the products and services they or their partners offer.  However, to the extent required by law, you will be given the opportunity to opt out of such sharing. We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms and Conditions [INSERT AS LINK] and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to hello@starfaceworld.com or by clicking on the “Unsubscribe” link located on the bottom of any Starface World marketing email and following the instructions found on the page to which the link takes you. Please allow us a reasonable time to process your request. You cannot opt out of receiving transactional e-mails related to the Site. 

We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional personal information rights and choices.

Your State Privacy Rights

If you are a California, Nevada, Colorado, Connecticut, Virginia, or Utah resident, your state's laws may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see the section below titled “For California Users Only”. 

Colorado, Connecticut, Virginia and Utah each provide their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability.
• Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut and Virginia also provide their state residents with rights to:

• Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. 

To exercise any of these rights please email us at hello@starfaceworld.com. 

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to hello@starfaceworld.com.  However, please know we do not currently sell data triggering that statute's opt-out requirements.

GDPR and UK Rights

If you are a resident of the European Union or the United Kingdom, EU or UK laws may provide you with additional rights regarding our use of your personal information. To learn more about your these rights, see the section below titled “For UK Users Only”.

Children Under the Age of 13

We do not knowingly collect personal information from children under the age of 13 through the Services. If you are under 13, please do not give us any personal information.  We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information without their permission.  If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at hello@starfaceworld.com, and we will endeavor to delete that information from our databases.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see the section below titled “For California Users Only”.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls and any payment transactions are encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Sites. The information you share in public areas may be viewed by any user of the Sites.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Sites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.

To use certain aspects of our services, such as making a purchase or subscribing we may require credit or debit card account information. By submitting your credit or debit card account information through the Services, you expressly consent to the sharing of your information with third party merchants, subscription and billing processors, and payment processors. These third parties may store your credit or debit card account information so you can use our Services in the future. We do not have your complete credit or debit card account information, store your credit or debit card account information, or have direct control over or responsibility for your credit or debit card account information. While we require that such third party merchants, billing processors, and payment processors use reasonable procedures to help protect your credit or debit card information, we cannot guarantee that transmissions of your credit or debit card account information or Personal Information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third-party service providers. We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.

Governing Law/Dispute Resolution/Arbitration

All matters relating to the Site and this Privacy Policy and any dispute or claim arising therefrom or related thereto (in each case, including non-contractual disputes or claims), shall be governed by and construed in accordance with the choice of law, dispute resolution and class action waiver provisions of our Terms of Service [INSERT HYPERLINK].

For California Users Only: 

This section applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and the California Privacy Rights Act of 2020 (CPRA) and any terms defined in the CCPA or CPRA have the same meaning when used in this policy. Any other capitalized terms used in this policy will have the same meaning as defined in our Terms and Conditions or our general privacy policy.

Information We Collect

We and our Sites collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
• health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data;
• personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, within the last twelve (12) months we have collected or may in the future collect the below categories of personal information from consumers and we keep this information only for so long as we need it to perform a contract or transaction with you or maintain an ongoing customer relationship with you, comply with any legal obligations and/or to bring or defend any legal claims: 

 

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	NO
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES, for potential employees only
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES
L. Sensitive Personal Information.	Sensitive personal information” means: (1) personal information that reveals (A) a consumer’s social security, driver’s license, state identification card, or passport number; (B) a consumer’s account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) a consumer’s precise geolocation; (D) a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a consumer’s mall, email and text messages, unless the business is the intended recipient of the communication; (F) a consumer’s genetic data; and (2)(A) the processing of biometric information for the purpose of uniquely identifying a consumer; (B) personal information collected and analyzed concerning a consumer’s health; or (C) personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.	NO

 

We and our Site obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase, or when you register on our site or provide information to us.
• Indirectly from you. For example, from observing your actions on our Site.

Use of Personal Information

We may use, share, sell, or disclose the personal information we collect for one or more of the purposes listed in the general privacy policy in the section titled “How We Use Your Information.”

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months and/or in the future, Company has disclosed or may disclose personal information for a business purpose to the categories of third parties indicated in the table above.

 

Each of the categories of personal information listed above may be shared with the following categories of third parties for the purpose of cross-context behavioral advertising:

• Advertising publishers that place advertisements on our behalf, such as Google or Meta;
• Advertising partners that place advertisements on the Lyft Platform on behalf of other advertisers; and
• Parties that provide statistical and analytic information regarding the effectiveness of our marketing

Your Rights and Choices 

The CCPA and/or CPRA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and 
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 
• The specific pieces of personal information we collected about you (also called a data portability request).
• If personal information was shared for cross-context behavioral advertising.

Right to Delete 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. 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 the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action. 

Right to Correct

You have a right to correct data that we hold about you that is inaccurate.

Right to Limit Use of Sensitive Personal Information

You have the right to limit our use of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services as well as other specified legitimate business purposes.  “Sensitive personal information” is defined above.  Any of the above information that is already publicly available is not considered to be sensitive personal information.

Exercising Your Rights to Know, Delete or Correct

To exercise your rights to know, correct or delete described above, please submit a request by emailing us at hello@starfaceworld.com.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. 

You may also make a request to know, correct or delete on behalf of your child by emailing us at hello@starfaceworld.com. 

You may only submit a request to know twice within a 12-month period. Your request to know, correct or delete must:

• Provide sufficient information, at our request, that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor's identity or authority to make it. 

For instructions on exercising your sale, sharing and sensitive personal information use opt-out or opt-in rights, see Personal Information Sales or Sharing Opt-Out and Opt-In Rights and Limitation of Use of Sensitive Personal Information Rights.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at hello@starfaceworld.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. 

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Personal Information Sales and Sharing Opt-Out and Opt-In 

We do not sell the personal information of our consumers in exchange for monetary consideration. We may share your personal information with certain third parties as disclosed in the “How We Use Your Information” section in the general privacy policy for non-monetary consideration, which may be considered a “sale” under California law. 

If you are age 16 or older, you have the right to direct us to not sell or share your personal information at any time (the "right to opt-out"). We do not sell or share the personal information of consumers we actually know are less than 16 years old, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 15 years old, or the parent or guardian of a consumer less than 13 years old. 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA or CPRA rights. Unless permitted by the CCPA or CPRA, we will not:

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

We currently do not offer any financial incentive programs that can result in different prices, rates, or quality levels in exchange for which we ask you to submit your personal information.  However, we may in the future offer you such programs. Any permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. 

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to hello@starfaceworld.com.

For UK Users Only:

Introduction

This GDPR Privacy Addendum supplements the information in the Starface World Privacy Policy and applies to Personal Data about individuals located in the European Economic Area and the United Kingdom. 

We adopt this GDPR Privacy Addendum to comply with the General Data Protection Regulation (2016/679) and any implementing acts of the foregoing by any of the member states of the European Economic Area, the United Kingdom, or Switzerland (“GDPR”) and any terms defined in the GDPR or our Privacy Policy have the same meaning when used in this GDPR Privacy Addendum. For applicable users, this GDPR Privacy Addendum takes precedence over anything contradictory in our Privacy Policy.

For purposes of this GDPR Privacy Addendum, “Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.  

Data Controller, Data Protection Officer, and Representative

Starface World, Inc. is the data controller of the Personal Data you provide on or through our Site. We may be contacted in any manner set forth below in the “Contact Information” section of this GDPR Privacy Addendum.

Lawful Basis for Processing Your Personal Data

We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when balanced against your rights and freedoms), as required by law, and with your consent. 

If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the applicable data protection laws. We have a lawful basis for each of our processing activities as set forth more fully below:

 

Purpose/Activity	Type of data	Lawful basis for processing
To register you as a new User	Identity Contact	Performance of a contract with you
To process your materials	Identity Contact Financial Transaction Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy; Communicating with you regarding your submission	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To deliver direct marketing to you	Identity Contact Profile Usage Marketing and Communications Tracking Technical	For most direct marketing communications, we rely on consent based on our privacy policy, however there are situations in which it is in our legitimate interests to use your personal data in this way
To enable you to take part in a prize draw, competition or complete a survey	Identity Contact Profile Usage Marketing and Communications	Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical Tracking	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical Tracking	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Tracking Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)
To prevent and detect unlawful acts	Identity Contact Financial Transaction Technical Tracking	Necessary for our legitimate interests (to protect our business and our customers by way of undertaking fraud monitoring and suspicious transaction monitoring) Necessary to comply with a legal or contractual obligation to share personal data for the purposes of law enforcement
In order to resolve legal claims or disputes involving you or us	All relevant data categories, depending on the nature of the allegation or claim	Necessary to bring or defend a claim

 

Automated Decision Making

We do not use your Personal Data with any automated decision making process.

Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may have certain rights under applicable data protection laws, including the right to access and update your Personal Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any time, and the right to have us erase certain Personal Data about you. You may also have the right to complain to a supervisory authority about our processing of your Personal Data. 

Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data.

 

• Access and Update. You may notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
• Restrictions. You may have the right to restrict our processing of your Personal Data under certain circumstances. In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing but we have retained it as permitted by law.
• Portability. To the extent the Personal Data you provide us is processed based on your consent and that we process it through automated means, you may have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in structured, commonly used and machine-readable format. You also have the right to request that we transmit this Personal Data to another controller, when technically feasible.
• Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent, you may withdraw your consent at any time by contacting us through emailat hello@starfaceworld.com. You may also withdraw your consent to send you legal updates by clicking the unsubscribe link at the bottom of a legal update that you receive from us. Note that unsubscribing from one of our newsletters in this way only unsubscribes you from that newsletter; you may need to unsubscribe from additional newsletters separately. Withdrawing your consent will not, however, affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness of our continued processing that is based on any other lawful basis for processing your Personal Data.
• Right to be Forgotten. You may have the right to request that we delete all of your Personal Data. We will only delete your Personal Data when we no longer have a lawful basis for processing your Personal Data or after a final determination that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth in our disaster recovery policies.
• Complaints. You may have the right to lodge a complaint with the applicable supervisory authority in the country you live in, the country you work in, or the country where you believe your rights under applicable data protection laws have been violated. However, before doing so, we request that you contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

How You May Exercise Your Rights. You may exercise any of the above rights (when applicable) by contacting us through any of the methods listed under Contact Information below. If you contact us to exercise any of the foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee subject to a maximum set by applicable law.

Consent to Processing of Personal Data in the United States

We may process your Personal Data outside of your home country, including to the United States. We only do this when we are legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data. 

If you are a resident of the European Economic Area (“EEA”), in order to provide our Site and legal updates to you, we may send and store your Personal Data outside of the EEA, including to the United States. Accordingly, your Personal Data may be transferred outside the country where you reside or are located, including to countries that may not or do not provide an equivalent level of protection for your Personal Data. Your information may be processed and stored in the United States and United States federal, state, and local governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of the United States. By using our Site, you represent that you have read and understood the above and hereby consent to the storage and processing of your Personal Data outside the country where you reside or are located, including in the United States. 

Your Personal Data is transferred by us to another country only if it is required or permitted under applicable data protection law and provided that there are appropriate safeguards in place to protect your Personal Data.

The Sites are not directed to children under the age of thirteen (13). If you are under thirteen (13), do not provide your Personal Information on or to the Site. We do not knowingly collect on the Site any Personal Information from children under thirteen (13). If a parent or guardian becomes aware of his or her child has provided us with Personal Information without their consent, please contact us at: hello@starfaceworld.com. 

Data Retention Periods

We may retain your Personal Data for as long as you have an account or profile with us.  In some instances, we may keep it after you no longer have an account or profile with us, for example we may keep it:

• on our backup and disaster recovery systems;
• for as long as necessary to protect our legal interests; 
• to comply with other legal requirements; and
• for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable, indefinitely.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by email to the email address specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this privacy policy to check for any changes. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under the law, please do not hesitate to contact us at hello@starfaceworld.com.