Privacy Policy

PRIVACY POLICY Last updated: March 15, 2021

Thank you for choosing to be part of our community at STAR HARBOR Space Academy (“Company”, “we”, “us”, “our”). We are committed to protecting your privacy. We firmly believe that electronic security and privacy are necessary for the continued success of the Internet. In support of this, we only use the personally identifiable information (personal information or personal data) that you provide in accordance with the terms outlined below.

This Privacy Policy covers any personal information we obtain when you visit us, use our services, or access the features on the websites that we own or control (today or in the future), including Starhaboracademy.com (the “Site”). You can access the Site in many ways, including from a computer or mobile phone, and this Privacy Policy will apply regardless of the means of access. This Privacy Policy also governs the use of personal information we obtain from you from any third party site or application where we post content or invite your feedback or participation, including, but not limited to, Twitter, Facebook, Instagram, YouTube, Pinterest, and Google+ (“Third Party Sites”). We cannot control the privacy policies or practices of Third Party Sites or of companies we do not own or control, and cannot control the actions of people we do not employ or manage. You should always check the privacy policies of Third Party Sites and your privacy settings.

Please read this Privacy Policy carefully.

YOUR CONSENT TO THIS POLICY. By continuing to use the Site, you are consenting to the practices described in this Privacy Policy.

PERSONAL INFORMATION WE COLLECT. We may collect or may have collected the following categories of information about you. In some cases, the information we collect may fall within more than one category.

Contact information and personal identifiers, such as your name, address, email address, telephone number, and username or social media handle. Device identifiers, such as information about your device like your IP address, or other online identifiers. Identity verification information, in order to verify you when you request information about your data. Online or network activity information, such as information regarding your interaction with the Site, digital properties, and advertisements, information about your browsing and search history on the Site, and log file information, which includes, but may not be limited to, your browser type, webpages you visit, and other electronic network activity. In addition, we may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. User Content, such as your communications with us and any other content you provide (including photographs, videos, reviews, articles, survey responses, emails, and comments). Inferences drawn from or created based on any of the information identified above.

HOW WE COLLECT YOUR PERSONAL INFORMATION. We may collect or may have collected personal information about you from various sources. The categories of sources from which we may collect personal information are:

Directly from you, such as when you contact us with a question or complaint, respond to a survey, or sign-up to receive information or marketing communications from us. Cookies and automatic collection methods, such as when you visit the Site or use one of our mobile applications, and when you open or click on emails we send you, we (and third parties we work with) may automatically collect information from your browser or device using technologies such as cookies, web beacons, pixel tags, and similar technologies. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Web beacons or pixel tags are small images which are embedded into the Site or emails that provide us with information about your browser or device, or whether you open or click on the emails we send you. These technologies enable us, or the third parties who place such technologies, to collect information such as device identifiers and online or other network activity information. Our Cookie Policy describes what we do in that regard. Through other technologies, such as call recording technology when you speak to customer support. From our business partners and service providers, such as analytics providers, advertising companies and networks, third-party retailers, and other third parties that we choose to collaborate or work with. From social media platforms and networks, such as Facebook, Twitter, Pinterest, and Instagram. For example, we may obtain your information from a social media platform or network if you interact with us on social media or choose to log-in to the Site using your social media credentials. From our affiliates that you have interacted with.

HOW WE USE YOUR PERSONAL INFORMATION. We may use or may have used the information we have about you:

To provide information, products and services to you. To communicate with you, including to respond to your inquiries or complaints. For marketing and advertising, such as to send you marketing and advertising materials via postal mail, text message or email, and to show you advertisements for products and/or services tailored to your interests on social media and other websites. For analytics purposes, such as to understand how you use the Site; determine what browser and devices you use to visit the Site; and to evaluate and improve our products, services, advertisements, and website and mobile applications. To operate and improve our business, including to provide quality assurance, conduct research and development to develop new products and services, and perform accounting, auditing and other internal business functions. For legal and security purposes, such as to detect, prevent, and prosecute harmful, fraudulent, or illegal activity, loss prevention, identify and repair bugs on the Site or mobile applications, and to comply with applicable legal requirements, relevant industry standards and our policies.

We also may use or may have used the information in other ways for which we provide specific notice at the time of collection.

HOW WE SHARE YOUR PERSONAL INFORMATION. In general, we do not share personal information about you with third parties for such third-parties’ own marketing or advertising purposes. We do share personal information with third parties for other purposes. For example, we share personal information with:

The STAR HARBOR Space Academy family of brands and companies, such as our affiliates, parents, and subsidiaries; Service providers that provide products or services to us, that help us market or advertise to you (including co-branded marketing and advertising), or that provide products or services to you (such as delivering packages to you). Even with this access to personal information necessary to perform these functions, those third parties are not authorized by us to disclose your information for any other purposes; Social media platforms and networks, such as Facebook, Twitter, Pinterest, and Instagram that offer functionalities, plugins, widgets, or tools in connection with the Site or mobile application (e.g., to log into an account, or to share inspiration, finds, purchases, and other content with your friends and followers on social media). If you choose to use these functionalities, plugins, widgets, or tools, certain information may be shared with or collected by those social media companies—for more information about what information is shared or collected, and how it is used, see the applicable social media company’s privacy policy; Parties to business transactions, such as those we deal with in mergers, acquisitions, joint ventures, sales of assets, reorganizations, divestitures, dissolutions, bankruptcies, liquidations, or other types of business transactions. In these types of transactions, personal information may be shared, sold, or transferred, and it may be used subsequently by a third party; and Online third-party companies for advertising purposes, including to: serve advertisements across the Internet; track and categorize your activity and interests over time on the Site and mobile application, and on third-party websites and mobile applications; and to identify the different device(s) you use to access websites and mobile applications. We share information with these companies, and these companies may collect information—including automatically collected information when you use the Site or mobile application. These third-party companies also may possess or obtain information about you from your interactions: directly with the third-party companies; with other websites, mobile applications, or companies that the third-party companies work with; or from your interactions with advertisements the third-party companies help to display to you. The information that these companies collect or that we share may be used to customize or personalize the advertisements that are displayed to you. We may share personal information with the third-party companies we work with for our purposes, though in general we do not share personal information about you with third parties for third-party marketing or advertising purposes. We may also share other information at our discretion, including automatically collected information, which may be used by third parties for third-party marketing, advertising, and other purposes. Additional third parties such as law enforcement, government entities, courts, or other third parties as required or allowed by applicable law, or otherwise to help prevent harm or fraud to us, you, our customers, or other third parties. We also may share personal information with third parties upon your request or with your approval, though we may not be able to accommodate all requests.

SOCIAL COMMERCE AND THIRD PARTY SITES. We work with third parties, including social network sites like Twitter, Facebook, YouTube, Instagram, Pinterest, and Google+, and with application developers who specialize in social commerce so we can connect to your social networks. All of these companies operate Third Party Sites. We provide access to the Site by third parties and business partners so we can generate interest in our products among members of your social networks and to allow you to share your interests with friends in your network.

The use of any features made available to you on the Site by a third party may result in information being collected or shared about you by us or by the third party. Information collected or shared through any such third party features is considered public information by us because the Third Party Sites made it publicly available. If you do not want us to be able to access information about you from Third Party Sites, you must instruct Third Party Sites not to share the information. We are not responsible for how these third parties may use information collected from or about you so be sure to review the privacy policies and privacy settings on your social networking sites to make sure you understand the information they are sharing. If you do not want a Third Party Site to share information about you, you must contact that site and determine whether it gives you the opportunity to opt out of sharing such information.

CHILDREN. The Site is not intended for or directed to children under the age of thirteen and we do not knowingly collect personal information from children under the age of thirteen on the Site. If we become aware that a child under the age of thirteen has provided us with personal information, we will delete the information from our records.

INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA. We are a global business and we and our service providers conduct business in countries such as the European Union (EU). As a result, it may be necessary for the personal information that we collect from you to be transferred to or accessed from outside the EU in order for us to provide the Services. If we do this, we have procedures in place to ensure your data receives the necessary protections. Any transfer of your personal data will follow applicable laws and we will treat the information according to the principles set out in this Privacy Policy.

EU USER’S RIGHTS WITH RESPECT TO PERSONAL INFORMATION. Depending on your local law, you may have certain rights with respect to your personal information, including the right to object to, restrict and/or withdraw your consent to the processing of your personal information, the right to access your personal information, and the ability to receive a machine-readable copy of your personal information. You may also have the right to ensure that we correct or delete any inaccurate or out of date personal information which we have about you.

If you believe that any personal information which we have about you is inaccurate or out of date and you would like us to correct or delete it, or you wish to exercise any other of your rights or have any questions or concerns about your personal information, please contact us at info@starhaboracademy.com.

If you have a complaint about how we handle your personal information or respond to your request, you may be able to complain to your data protection authority. We ask that you kindly contact us first, so that we have an opportunity to resolve your complaint.

CALIFORNIA PRIVACY RIGHTS. Under the California Consumer Privacy Act (“CCPA”), California residents have certain rights regarding the personal information that businesses collect about them. This includes the rights to request access or deletion of your personal information, as well as the right to direct a business to stop selling your personal information.

Right to Notice. You have the right to be properly notified of the following:

Personal Information We Collect: Please review the section of this Privacy Policy titled “PERSONAL INFORMATION WE COLLECT” for more information about the personal information we collected about you in the past 12 months.

Why We Collect Personal Information: Please review the section of this Privacy Policy titled “HOW WE USE YOUR PERSONAL INFORMATION” for more information on why we collect personal information about you in the past 12 months.

How We Collect Personal Information: Please review the section of this Privacy Policy titled “HOW WE COLLECT YOUR PERSONAL INFORMATION” for more information on how we collect personal information about you in the past 12 months.

With Whom We Share Your Personal Information: Please review the section of this Privacy Policy titled “HOW WE SHARE YOUR PERSONAL INFORMATION” for more information on how we share personal information about you in the past 12 months.

Right to Access Your Information: You have the right to request the following covering the 12 months preceding your request:

The specific pieces of personal information we have collected about you The categories of personal information that we have collected about you The categories of sources from which we collected the personal information The purpose for collecting or selling the personal information The categories of personal information that we have disclosed about you, the purpose for disclosing such personal information and the categories of third parties with whom we disclosed such personal information The categories of personal information that we have sold about you, as well as the categories of third parties to whom we sold such personal information

If you would like to exercise your right to request access, please submit your request by emailing us at info@starhaboracademy.com.

Right to Deletion: You have the right to request that we delete any personal information about you that we have collected from you. Please note that there are exceptions where we do not have to fulfill a request to delete information, such as when the deletion of information would create problems with the completion of a transaction or compliance with a legal obligation. If you would like to exercise your right to request deletion, please submit your request by emailing us at info@starhaboracademy.com.

Right to Non-Discrimination: We will not discriminate against you (e.g., through denying goods or services, or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.

How to Exercise Your Rights: To exercise your rights described above, please submit a verifiable consumer request to us by emailing us at info@starhaboracademy.com.

Verifiable Consumer Requests: Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may only make a verifiable consumer request for access to your personal information twice within a 12-month period. The verifiable consumer request must: 1) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative of that person; and 2) Describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We cannot respond to your request to exercise your access and/or deletion rights if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. 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 a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format: We attempt to respond to a verifiable consumer request within 45 days after we receive it. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing within 45 days after we receive your initial request. 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 prior to the date we receive the verifiable consumer request. The response we provide will also provide the reasons we cannot comply with a request, if applicable. For access 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.

Complaints. In compliance with the CCPA, we commit to resolve complaints about your privacy and our collection or use of your personal information. California residents with inquiries or complaints regarding this Privacy Policy should contact us at info@starhaboracademy.com.

California’s Shine the Light law. California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties’ direct marketing purposes. If you would like to request more information under the California Shine the Light law, and if you are a California resident, you can email us at info@starhaboracademy.com.

CONTROLS FOR DO-NOT-TRACK FEATURES. Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

OPT-OUT FROM MAILINGS. From time to time, you may receive periodic mailings, telephone calls, e-mails or other communications from us with news or other information on events, products, discounts, special promotions, or other offers from or on our behalf. If at any time you wish to stop receiving communications from us please send us an email to info@starhaboracademy.com with the phrase “Privacy Opt-out: Mailings” in the subject line, or write to us at the address provided below, and we will remove you from our mailing list. Alternatively, for email communications, you may opt out of receiving such communications by following the unsubscribe instructions set forth at the bottom of most promotional e-mail messages from us.

TEXT, SMS, AND CALLS. If you have provided us with your prior express consent to receive communications via an automatic telephone dialing system (auto-dialer), artificial or prerecorded voice messages, or text messages, we may use your information to send text messages to any mobile device connected to your cell phone number, until you opt out from future text messages by texting STOP. Once you cancel, we will send one additional confirmation message stating that you’ve opted out.

CORRECTION OF DATA. It is your responsibility to provide us with accurate personal information about yourself and to inform us of any changes. (e.g. new home address or change of name). If, however, you discover any information previously provided to us is inaccurate or incomplete, you may request that the data be corrected or amended by sending us an email at info@starhaboracademy.com.

SECURITY. While no service is completely secure, we have a security team dedicated to keeping personal information safe. We maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing, of the personal information in our possession. We employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities.

DATA RETENTION. We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

UPDATES TO THIS PRIVACY POLICY. This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our personal information practices. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will post a prominent notice on the Site to notify you of any significant changes to our privacy practices and indicate at the top of the Privacy Policy when it was most recently updated.

HOW TO CONTACT US. If you have any questions about your privacy or security on the Site, please email us at info@starhaboracademy.com and include your name and address in the message.