Privacy Policy

Effective date: August 1st, 2020

StarkWare Industries Ltd. (“us”, “we”, or “our”) operates the https://starkware.co website (hereinafter referred to as the “Service”).

This Privacy Policy applies to data collected by us from users of the Service, subscribers to our mailing list and persons that contact us offline.

This Privacy Policy does not apply to data owned and/or collected by our customers, that we may process as part of our provision of services to such customers. Data owned or collected by our customers shall be governed solely by their respective privacy policies.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

Definitions

* Service
Service means the https://starkware.co website operated by StarkWare Industries Ltd.

* Personal Data
Personal Data means data 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.

* Usage Data
Usage Data is data collected automatically that is either generated by use of the Service or by the Service infrastructure (for example, the duration of a page visit).

* Cookies
Cookies are small files stored on your device (computer or mobile device), which store certain information that allows us to understand and save your preferences for future visits and to compile aggregate data about site traffic and site interaction.

* Data Controller
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which, and the manner in which, any Personal Data are to be processed.
For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

* Data Processor (or Service Provider)
Data Processor (or Service Provider) means any natural or legal person who processes Personal Data on behalf of the Data Controller.
We may use the services of various Service Providers in order to operate the Service and process your data more effectively.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain Personal Data that can be used to contact or identify you. Such Personal Data includes:

  • Email address
  • Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Usage Data

While you use our Service we may collect Usage Data on how the Service is accessed and used. Such Usage Data may include information such as your browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, device details (such as manufacturer and model) and other diagnostic data. Usage Data is aggregated and is not kept per individual.

Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and to collect and compile aggregate data about site traffic and site interaction. We do not use cookies to collect Personal Data.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used, such as beacons, tags and scripts, to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
  • Opting Out of Collection

    You can prevent collection of your data by not providing us such data, by ceasing to use the Service and to interact with us, or by contacting us as mentioned below.

    Use of Data

    We use collected data for various purposes:

    • To provide and maintain our Service
    • To notify you about changes to our Service
    • To allow you to participate in interactive features of our Service, when available
    • To provide customer support
    • To gather analysis or valuable information so that we can improve our Service
    • To monitor the usage of our Service
    • To detect, prevent and address technical issues
    • To provide you with news and general information about goods, services and events which we offer, unless you have opted not to receive such information

    Legal Basis for Processing under the EU General Data Protection Regulation (GDPR)

    If you are from the European Economic Area (EEA), our legal basis for collecting and using the Personal Data as described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

    If we obtain your Personal Data through your use of the Service, subscription to our mailing list or other interaction with us, our legal basis for processing your Personal Data is that it is necessary for our legitimate interest in providing and developing the Service and other services and meeting the requirements of our current and prospective customers.

    If we contact you with marketing materials, our legal basis for processing your Personal Data is that it is necessary for our legitimate interests in conducting direct marketing of the Service and other services to current and prospective customers.

    Retention of Data

    We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy and to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.Email addresses will be retained for a period of 12 months, after which they will be reconfirmed by the Data Subject or deleted. Usage Data is aggregated and retained for internal analysis purposes. Usage Data will be retained for a period of 3 months, except if it is required to strengthen the security or to improve the functionality of our Service, or if we are legally obligated to retain it for longer periods.

    Transfer of Data

    Your data, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

    If you are located outside Israel and choose to provide data to us, please note that we transfer the data, including Personal Data, to Israel and process it there.

    Your consent to this Privacy Policy followed by your submission of such data represents your agreement to that transfer.

    We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. Transfer of your Personal Data will take place in accordance with the requirements of applicable law.

    Disclosure of Data

    Disclosure for Law Enforcement

    Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

    Legal Requirements

    We may disclose your Personal Data in the good faith belief that such action is necessary to:

    • To comply with a legal obligation
    • To protect and defend our rights or property or that of a third party
    • To prevent or investigate possible wrongdoing in connection with the
      Service
    • To protect the personal safety of users of the Service or the public
    • To protect against legal liability

    Security of Data

    We use reasonable and appropriate efforts, applying administrative, physical, electronic and procedural safeguards, to maintain and protect the confidentiality and security of all data collected by us, including your Personal Data. We allow only authorized personnel to access your data, on a need-to-know basis.

    Although we make good faith efforts to store your data in a secure operating environment, we cannot guarantee security. You understand and agree that all data collected through the Service or otherwise is subject to the provisions and disclaimers of this Privacy Policy.

    In the event that we become aware of any accidental or unauthorized access to your data, we will notify you of such data breach in accordance with applicable laws.

    Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

    Our Service does not support Do Not Track signals (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

    You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

    Your Rights under the EU General Data Protection Regulation (GDPR)

    Subject to any local or national law exceptions, if you are in the EEA and your Personal Data is processed by us, you have the rights to:

    • withdraw your consent to the processing of your Personal Data if such processing is based on consent (this will not affect our right to process your Personal Data up until such time as you provide us with notice that you no longer consent);
    • access your Personal Data;
    • receive or ask that we provide you with (or transfer to a third party) your Personal Data in a structured, commonly used and machine readable format;
    • request us not to process your Personal Data for marketing purposes (including profiling to the extent that it is related to our marketing activities). We will provide you with appropriate choices to opt-in or opt-out as set out above. You can also exercise the right at any time by contacting us at the contact details set out below;
    • request us to rectify any inaccurate Personal Data that we may hold;
    • request us to erase Personal Data where: (a) it is no longer necessary for us to hold such Personal Data; (b) you no longer consent to the processing of your Personal Data; (c) your Personal Data has been unlawfully processed; or (d) we are otherwise required by law to erase your Personal Data;
    • make a complaint with the national data protection authority in the country where you are based. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us using the contact information provided below.

    You may contact us on our contact details below at any time to exercise any of the rights which apply to you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights).

    Your Rights under Applicable Privacy Laws

    You may have rights in relation to your Personal Data under applicable privacy laws in other jurisdictions. If you wish to exercise any such rights, please contact us using the contact information below.

    Service Providers

    We may employ Service Providers, third party companies and individuals, to facilitate our Service, provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.

    These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

    Analytics

    We may use third-party Service Providers to monitor and analyze the use of our Service.

    • Google Analytics

    Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

    You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add- on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

    For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:
    https://policies.google.com/privacy?hl=en

    Links to Other Sites

    Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site. We encourage you to review the privacy policy of such third party before you submit to it any information.

    We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

    Minors’ Privacy

    Our Service is not designed or intended for individuals under the age of 18 (“Minors”).

    We will not knowingly collect any Personal Data concerning Minors. If you are a parent or guardian and you are aware that a Minor under your care has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data concerning Minors, we take steps to remove that information from our servers.

    Changes to This Privacy Policy

    We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

    We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.
    You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

    Contact Us

    If you have any questions about this Privacy Policy, please contact us: