Privacy Policy

Last Updated: May 27, 2023

StartSpace is aware of your concerns regarding the usage and sharing of your personal information, and we value your privacy. This Privacy Policy explains how we collect, use, and share your personally identifiable information ("Personal Information") through our website (startspace.com) and our services. We kindly ask you to read this policy attentively.

Please note that your use of StartSpace is always subject to the Terms of Use, which includes this Privacy Policy. Any terms used in this Privacy Policy without explicit definitions will have the same meanings as provided in the Terms of Use.

What does this Privacy Policy cover?

This Privacy Policy outlines how we collect, receive, use, store, share, transfer, and process your Personal Information. It also explains the choices you have regarding the use of your Personal Information, as well as your rights and how to exercise them.

This Privacy Policy applies solely to the processing of your Personal Information by StartSpace as a data controller. This means it pertains to the processing carried out by us for our own purposes.

Will StartSpace ever change this Privacy Policy?

As we continuously strive to enhance our services, there may be occasions where we need to modify this Privacy Policy. In such cases, we will notify you about the changes by prominently posting a notice on our website, sending you an email, or employing other appropriate means.

Kindly note that if you have opted out of receiving legal notice emails from us (or if you have not provided us with your email address), these legal notices will still apply to your use of StartSpace, and it remains your responsibility to read and comprehend them.

What Information does StartSpace collect?

We collect and process Personal Information about you when you interact with us and our services, including when you subscribe to any of our paid or unpaid services. This may encompass:

• Your first and last name;
• Your email address;
• Your phone number;
• Your payment details (such as billing address, credit card details, in case of a purchase);
• Your location and/or mailing address;
• Your photograph;
• Your marketing preferences, including any consents you have provided;
• Information related to the browser or device you utilize to access our website (including your IP address);
• Any information collected online from you and associated with your account, such as your username and password;
• Your subscription status with StartSpace newsletters;
• Public information about the social media accounts linked to your StartSpace account;
• Any other information you provide us during communication.

Additionally, we collect information about the usage of our website through cookies. For further details, please refer to the "Cookies" section below.

How does StartSpace use your Personal Information?

We process your Personal Information for the following purposes:

• To establish and fulfill a contract with you, such as when you subscribe to a subscription Service. This may involve verifying your identity, processing payments, communicating with you, and providing customer service.
• To enable our business operations and pursue our legitimate interests as required by StartSpace. Specifically, we utilize your Personal Information for the following purposes:
  • Providing the services you have requested and responding to any communications, comments, or complaints you send us.
  • Monitoring the use of our services to improve and protect our services, content, and website.
  • Allowing you to create, maintain, customize, and secure your account with us.
  • Personalizing our services for you.
  • Monitoring user accounts to prevent, investigate, and report fraud, misrepresentation, terrorism, security incidents, or crime in accordance with applicable law.
  • Inviting you to participate in surveys or market research.
  • Where the use of Personal Information is based on a balancing of our legitimate interests with your privacy interest, we will provide additional information about our balancing analysis and process upon request. Please send any such requests to info@startspace.com.
• Compliance with applicable laws and protection of StartSpace's legitimate business interests and legal rights. This includes the use of Personal Information in connection with legal claims, compliance, regulatory, and investigative purposes (including disclosure of such information in connection with legal process or litigation).
• Additionally, with your consent (if required), we may send you direct marketing communications related to our relevant services or other services provided by us, our affiliates, and carefully selected partners. You can withdraw your consent at any time ("opt-out"); please refer to the section "What are your rights?" below. In the case of electronic direct marketing, you can opt out by following the instructions in the communication.
• In certain circumstances, we may share some Personal Information with third parties, but only as described in this Privacy Policy.

How will StartSpace share the Personal Information it receives?

We may disclose your Personal Information to third parties as outlined below:

• Affiliates: We may share your Personal Information with our subsidiaries and/or corporate affiliates for the purposes described above.
• Publishers: When you subscribe to the content of a Publisher, we provide them with the necessary information (including your name and email address) to deliver their content(s) to you. Please note that Publishers have control over their own content. Therefore, when you engage with a Publisher's content in a way that requires your personal information, such as commenting on content to which you are not subscribed, that personal information is directly provided to the Publisher.
• Service Providers: We collaborate with third-party service providers who perform services on our behalf. These service providers include, but are not limited to, providers of website hosting, maintenance services, email services, security services, content delivery networks, customer support operations, artificial intelligence services and software services, traffic and usage analytics services, and cloud storage and computing services.
• Other users: Depending on your user profile settings, you may choose to share certain user profile information, such as your name, subscriptions, publications, location, and images, with other users. This facilitates user interaction within the services, including commenting on posts or uploading images or videos. Your account privacy settings enable you to restrict other users' access to your Personal Information in your user profile and determine the visibility of specific information. Your username and user profile may also be visible to other users when you interact with a newsletter post, such as "liking" the post or leaving a comment. You may have the option to allow StartSpace to share your reading activities on StartSpace with the public or with other socially connected accounts, such as your social media followers.
• Prospective sellers or buyers: In the event of a sale or merger of our business or assets, we may share and/or transfer customer information. This also applies if we undergo bankruptcy, change of control, or any other form of corporate restructuring.
• Government authorities and/or law enforcement officials: If necessary for the purposes stated in this Privacy Policy, as mandated by law, or for the legal protection of our legitimate interests in compliance with applicable laws, we may share Personal Information with competent regulatory, prosecuting, tax, or governmental authorities, courts, or other tribunals in any jurisdiction or markets, domestic or foreign.

In certain cases, we may anonymize your Personal Information in a way that prevents your identification as an individual. We reserve the right to use and share such anonymized information with trusted partners not explicitly mentioned here. However, we never disclose aggregated or de-identified information that could identify you as an individual.

Where will we send your Personal Information?

StartSpace, as an entity established in The Netherlands, engages service providers located both within The Netherlands and in other countries to process Personal Information in accordance with this Privacy Policy. Consequently, your Personal Information may be transferred internationally.

Is Personal Information about you secure?

To ensure your privacy and security, your account is safeguarded by a password. It is essential to choose a password that provides adequate protection and to restrict access to your computer or device and browser by logging out after each session.

We make every effort to protect the privacy of your account and other Personal Information stored in our records. However, it is important to note that complete security cannot be guaranteed. Unauthorized access or use, service failures, or other circumstances may compromise the security of user information at any time.

What are your rights?

In accordance with applicable local laws, you have certain rights regarding your Personal Information held by StartSpace. These rights may include:

• The right to request a copy of your Personal Information, and to rectify, erase, or restrict its processing.
• The right to request the transfer of your Personal Information to other organizations.
• The right to object to certain processing activities and request the restriction of such activities.
• The right to withdraw your consent, where applicable, if we have obtained your consent to process your Personal Information.
• Please note that these rights may be subject to limitations imposed by applicable law. For instance, we may be unable to delete your Personal Information if we have a legal obligation to retain it. In certain situations, we may retain data even if you withdraw your consent or delete your account.

When the provision of Personal Information is necessary to fulfill legal or contractual obligations, it is mandatory to provide such information. Failure to do so may prevent us from managing our contractual relationship or meeting our obligations. In all other cases, the provision of requested personal data is optional. We will inform you whether the provision of your Personal Information is mandatory or optional.

We aim to address any queries or concerns you may have about the processing of your Personal Information. If you have concerns or wish to opt out of marketing communications, please contact us at info@startspace.com.

You can access, edit, or delete certain personal information on your own

By accessing your account settings, you can view, edit, or delete certain information you have provided to us, including:

• Name and password
• Email address
• User profile information, such as uploaded images

Please note that the availability of information for viewing, updating, and deleting may vary as our services evolve. To delete your account, you can do so directly from your account page.

If you have any questions about accessing or updating the information we hold about you, please contact us at info@startspace.com.

You can unsubscribe from our marketing communications

To unsubscribe from our marketing communications, you can click on the "unsubscribe" link located at the bottom of our emails, update your communication preferences, or contact us at info@startspace.com.

You have the right to lodge a complaint with your local data protection authority

If you have unresolved concerns regarding the processing of your Personal Information, you have the right to lodge a complaint with a data protection authority. Contact details for data protection authorities in the EEA, Switzerland, and certain non-European countries can be found here.

How long will StartSpace retain your data?

We will retain your information for a duration that is reasonably necessary to fulfill the purposes for which it was collected. In certain cases, we may retain your Personal Information for a longer period if there is a complaint or a reasonable expectation of litigation relating to our relationship with you.

Automated individual decision-making, including profiling

We do not engage in the automated processing of your Personal Information for individual decision-making, including profiling.

Cookies

We utilize cookies on our website. Cookies are small text files that are sent by a web server to your web browser and stored locally on your computer. These cookies enable the server to uniquely identify your browser on each page. They do not cause any harm to your computer and are free from viruses.

Our website employs the following categories of cookies:

Category 1: Strictly Necessary Cookies

These cookies are indispensable for allowing you to navigate the website and utilize its features. Without these cookies, services that you have requested, such as remembering your login details or data provided for a purchase, cannot be provided.

Category 2: Performance Cookies

These cookies gather information about how individuals utilize our website. The data collected by these cookies never reveals personal details from which your individual identity can be determined.

Category 3: Functionality Cookies

These cookies retain the choices you make, such as the country you visit our website from, language preferences, and search parameters. This information is used to offer you an experience that is more suitable to your selections and to make your visits more personalized and enjoyable.

• Cookie Name: startspace_session
• Cookie Type: Persistent
• Cookie Purpose: Session identifier (login, etc)
• Cookie Lifetime: 365 days max
• Cookie Domain: .startspace.com

• Cookie Name: startspace_id
• Cookie Type: Persistent
• Cookie Purpose: Unique page visit count
• Cookie Lifetime: 365 days max
• Cookie Domain: .startspace.com

• Cookie Name: cookie_consent
• Cookie Type: Persistent
• Cookie Purpose: Allow cookies or not
• Cookie Lifetime: 365 days max
• Cookie Domain: .startspace.com

Disabling and opting-out of cookies

Current versions of web browsers provide users with enhanced controls over the placement and duration of both first-party and third-party cookies. You can find information on cookie management features available to you by searching for "cookies" in your web browser's "Help menu". You can enable or disable cookies by adjusting the settings in your browser. For more information on cookies and how to manage them, you can also visit www.allaboutcookies.org. However, please note that if you choose to disable cookies in your browser, you may not be able to complete certain activities on our websites or access certain parts of them correctly. If you would like more information about interest-based advertising and how to opt-out of these cookies, please visit https://youronlinechoices.eu.

Information Collected From Other Websites and Do Not Track Policy

Through the cookies we place on your browser or device, we may collect information about your online activity after you leave our website. This information, like any other usage information we collect, allows us to improve our services and personalize your online experience, as described in this Privacy Policy. Your browser may offer a "Do Not Track" option, which enables you to indicate to website operators and service providers (including behavioral advertising services) that you do not want them to track certain online activities of yours over time and across different websites. At this time, our services do not support Do Not Track requests. This means that we collect information about your online activity both while you are using our services and after you leave our services.

Questions about this policy?

The data controller for this processing is StartSpace.

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to info@startspace.com or contact us at:

StartSpace
Roosje Vechtstraat 36
8081 BZ, Elburg
The Netherlands
E: info@startspace.com
T: +31 646413862

We will try to resolve your concerns.