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Select Start Privacy Notice for California Residents

Effective Date: August 03, 2020

Last reviewed: August 03, 2020

This Privacy Notice for California Residents supplements the information contained in Select Start’s General Privacy Notice and applies solely to 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). Any terms defined in the CCPA have the same meaning when used in this Notice. Throughout this policy, the terms “we”, “us” and “our” refer to Select Start.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, our Website has collected personal information found in the following categories in the last twelve (12) months:

Category

Examples

Collected

  1. Identifiers.

A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, Social Security number, driver's license number, passport number, or other similar identifiers.

Yes

  1. California Customer Records Personal Information categories. (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

  1. 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

  1. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

  1. 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

  1. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Yes

  1. Geolocation data.

Physical location or movements.

Yes

  1. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

  1. Professional or employment-related information.

Current or past job history or performance evaluations.

No

  1. 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

  1. Inferences drawn from other Personal Information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No

 

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) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

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

  • Directly from you. For example, by visiting the website, filling in forms on the website, when you make or attempt to make a purchase on our site, or by corresponding by phone, email, or otherwise.
  • Indirectly from you. For example, from observing your actions when you browse pages on our Website.
  • From third-party business partners such as social media sites, ad networks, and analytics providers.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • Purpose for Providing: To fulfill or meet the reason you provided the information. For example, if you ask a question about our products, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase, we will use that information to process your payment information, arrange for shipping, and provide you with invoices and or order confirmations. We may also save your information to communicate with you, facilitate new product orders, or process returns.
  • Website: To provide, support, personalize, and develop our Websites, products, and services, including the delivery of content, product and service offerings and targeted offers via email or text message (with your consent, where required by law). 
  • Fraud and Security Purposes: To create, maintain, customize, and secure your account with us and to process your requests, purchases, transactions, and payments and prevent transactional fraud. To also help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business.
  • Service and Support: To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • Legal and Regulatory Requirements: 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.
  • To provide services and information.
  • To manage day to day business needs including, but not limited to, payment processing and financial account management, business planning and forecasting, security and fraud prevention, and compliance with legal and regulatory obligations.
  • To gather broad demographic information and to monitor the level of activity on the Site.

Select Start 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

Select Start may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Select Start has disclosed the following categories of personal information for a business purpose:

Category

Collected

  1. Identifiers

Yes

  1. California Customer Records Personal Information categories.

Yes

  1. Protected classification characteristics under California or federal law.

No

  1. Commercial information.

Yes

  1. Biometric information.

No

  1. Internet or other similar network activity.

Yes

  1. Geolocation data.

Yes

  1. Sensory data.

Yes

  1. Professional or employment-related information.

No

  1. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

No

  1. Inferences drawn from other Personal Information.

Yes

 

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with our Services.

Sales of Personal Information

In the preceding twelve (12) months, Select Start has not sold personal information.

Your Rights and Choices

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

Access to Specific Information and Data Portability Rights

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. Once we receive and confirm your verifiable consumer request, 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.
  • The specific pieces of personal information we collected about you (also called a data portability request).

 

Deletion Request Rights

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. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception 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, 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 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.

Exercising Access, Data Portability, and Deletion Rights

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

    • Calling us at (415) 290-3193
    • Emailing us at info@select-start.com 
  • Download, complete, and submit a verifiable California Consumer Request Form. Please email completed request form to info@select-start.com
  • If you have multiple requests, please note that you will have to submit a separate form for each request.

    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 also make a verifiable consumer request on behalf of your minor child.

    You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

    • Provide sufficient information 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 understand, evaluate, and respond to it properly. 

    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.

    Making a verifiable consumer request does not require you to create an account with us.

    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 endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 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 the verifiable consumer request’s receipt. 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.

    Non-Discrimination

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

    Other California Privacy Rights

    California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Websites 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 info@select-start.com 

    Changes to Our Privacy Notice

    Select Start reserves the right to amend this privacy Notice at our discretion and at any time. When we make changes to this privacy Notice, we will post the updated Notice on the Website and update the Notice’s effective date. Your continued use of our Websites 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 Select Start collects and uses your information described above, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

    Phone: (415) 290-3193

    Website: https://select-start.com/

    Email: info@select-start.com

    Postal Address:

    309 E 8th St. Ste. 404A 

    Los Angeles, CA 90014

     

    INTRODUCTION

     

    Select Start Privacy Policy.

     

    Select Start respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Throughout this policy, the terms “we”, “us” and “our” refer to Select Start.

  • IMPORTANT INFORMATION AND WHO WE ARE

  •  

    Purpose of This Privacy Policy

     

    This privacy policy aims to give you information on how we collect and process your personal data through your use of this website.

     

    This website is not intended for children and we do not knowingly collect data relating to children.

     

    It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

     

    Controller

    Select Start is the controller and responsible for your personal data.

     

    If you have any questions about this privacy policy, including any requests to exercise your legal rights under the GDPR, please contact our team using the details set out below.

     

    Contact Details

    If you have any questions about this privacy policy or our privacy practices, please contact our privacy support in the following ways:

    • Select Start
    • Email address: info@select-start.com
    • Postal address: 309 E 8th St. Ste. 404A, Los Angeles CA 90014, United States
    • Phone Number: (415) 290-3193

     

    You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

     

    Changes to The Privacy Policy and Your Duty to Inform Us of Changes

    We keep our privacy policy under regular review. This version was last updated on August 3, 2020.

     

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

     

    Third-Party Links

    This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

  • THE DATA WE COLLECT ABOUT YOU

  •  

    Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

     

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

    • Identity Data includes first name, last name, username or similar identifier, date of birth and gender.
    • Contact Data includes billing address, delivery address, email address and telephone numbers.
    • Financial Data includes payment information such as credit card details.
    • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
    • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
    • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    • Usage Data includes information about how you use our website, products and services.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

     

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

     

    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

     

    If You Fail to Provide Personal Data

    Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

     

  • HOW IS YOUR PERSONAL DATA COLLECTED?

  •  

    We use different methods to collect personal information from and about you including through:

    • Direct interactions: You may give us your name, billing address, shipping address, payment information, including credit card numbers, email addresses, and phone numbers. 
    • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.  

     

    Third parties or publicly available sources. We may receive analytics and advertising data about you from the sources listed below. Please use the following links for more information about how these third parties collect and use personal data: Google - Shopify

  • HOW WE USE YOUR PERSONAL DATA

  •  

    We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

    • Where we need to perform the contract, we are about to enter into or have entered into with you.
    • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    • Where we need to comply with a legal obligation.

     

    Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

     

    Purposes for Which We Will Use Your Personal Data

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

     

    Purpose/Activity

    Type of Data

    Lawful Basis for Processing 

    To register you as a new customer

    1. Identity
    2. Contact

    Performance of a contract with you

    To process and deliver your order including:

    1. Manage payments, fees and charges
    2. Collect and recover money owed to us
    1. Identity
    2. Contact
    3. Financial
    4. Transaction
    5. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary for our legitimate interests (to recover debts due to us)

    To manage our relationship with you which will include:

    1. Notifying you about changes to our terms or privacy policy
    2. Asking you to leave a review or take a survey
    1. Identity
    2. Contact
    3. Profile
    4. Marketing and Communications

    1. Performance of a contract with you
    2. Necessary to comply with a legal obligation
    3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)


    To allow you to complete a survey

    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing and Communications

    1. Performance of a contract with you
    2. 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)

    1. Identity
    2. Contact
    3. Technical

    1. 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)
    2. 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

    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing and Communications
    6. Technical

    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

    1. Technical
    2. 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

    1. Identity
    2. Contact
    3. Technical
    4. Usage
    5. Profile
    6. Marketing and Communications

    Necessary for our legitimate interests (to develop our products/services and grow our business)

     

    Marketing

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

     

    Promotional Offers From Us

    We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

     

    You will receive marketing communications from us if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing.

     

    Third-Party Marketing

    We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

     

    Opting Out

    You can ask us or third parties to stop sending you marketing messages at any time. 

     

    Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, other transactions.

     

    Cookies

    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

     

    Change of Purpose

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

     

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

     

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

     

  • DISCLOSURES OF YOUR PERSONAL DATA

  •  

    We may share your personal data with the parties set out below for the purposes set out in the table above.

    • Internal Third Parties
    • Other companies in the Select Start Group acting as joint controllers or processors
    • External Third Parties such as service providers acting as processors, including:
      • Shopify: We use Shopify to sell, ship, and manage our products.
      • Google Analytics: We use Google Analytics to help us understand how our customers user the site.

     

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  • INTERNATIONAL TRANSFERS

  •  

    We share your personal data within the Select Start Group. This will involve transferring your data outside the European Economic Area (EEA).

     

    Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

     

    Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

     

    • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. 

     

    Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  • DATA SECURITY

  •  

    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. 

     

    They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

     

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  • DATA RETENTION

  •  

    How Long Will You Use My Personal Data For?

    We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

     

    To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

     

    By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for six years after they cease being customers for tax purposes.

     

    In some circumstances you can ask us to delete your data: see your legal rights below for further information.

  • YOUR LEGAL RIGHTS

  •  

    Under certain circumstances, you have rights under data protection laws in relation to your personal data.

    • Request access to your personal data.
    • Request correction of your personal data.
    • Request erasure of your personal data.
    • Object to processing of your personal data.
    • Request restriction of processing your personal data.
    • Request transfer of your personal data.
    • Right to withdraw consent.

     

    If you wish to exercise any of the rights set out above, please contact complete a Data Subject Request Form and email it to info@select-start.com

     

    Your California Privacy Rights. 

    If you are a California resident, please visit our Privacy Notice for California Residents for additional information about our processing of personal information and your California privacy rights.

     

     

    No Fee Usually Required

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

     

    What We May Need From 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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

     

    Time Limit to Respond

    We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  • GLOSSARY

  •  

    Lawful Basis

     

    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

     

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

     

    Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

     

    Third Parties

     

    Internal Third Parties

     

    Other companies in the Select Start Group acting as joint controllers or processors and provide IT and system administration services and undertake leadership reporting.

     

    External Third Parties

    • Service providers acting as processors, including: 
      • Shopify: We use Shopify to sell, ship, and manage our products.
      • Google Analytics: We use Google Analytics To help us understand how our customers use the site.

     

    Your Legal Rights

     

    Lawful Basis

    Legitimate Interest


    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

    Performance of Contract


    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    Comply with a Legal Obligation


    Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

    Third Parties

    Internal Third Parties


    Other companies in the Select Start Group acting as joint controllers or processors and provide IT and system administration services and undertake leadership reporting.

    External Third Parties


    Service providers acting as processors, including: 

    • Shopify: We use Shopify to sell, ship, and manage our products.
    • Google Analytics: We use Google Analytics To help us understand how our customers use the site.

    Your Rights

    Request access


    Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    Request correction


    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    Request erasure


    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    Object to processing


    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    Request restriction of processing


    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    • If you want us to establish the data's accuracy.
    • Where our use of the data is unlawful, but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

    Request the transfer


    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time


    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

     

     

     

    SMS/MMS MOBILE MESSAGING MARKETING PROGRAM

    We respect your privacy. We will only use information you provide through the Program to transmit your mobile messages and respond to you, if necessary. This includes, but is not limited to, sharing information with platform providers, phone companies, and other vendors who assist us in the delivery of mobile messages.  WE DO NOT SELL, RENT, LOAN, TRADE, LEASE, OR OTHERWISE TRANSFER FOR PROFIT ANY PHONE NUMBERS OR CUSTOMER INFORMATION COLLECTED THROUGH THE PROGRAM TO ANY THIRD PARTY. Nonetheless, We reserve the right at all times to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect Our rights or property. When you complete forms online or otherwise provide Us information in connection with the Program, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If, in Our sole discretion, We believe that any such information is untrue, inaccurate, or incomplete, or you have opted into the Program for an ulterior purpose, We may refuse you access to the Program and pursue any appropriate legal remedies.

    California Civil Code Section 1798.83 permits Users of the Program that are California residents to request certain information regarding our disclosure of the information you provide through the Program to third parties for their direct marketing purposes.  To make such a request, please contact us at the following address:

    Select Start

    309 E 8th St, 404A, Los Angeles, CA 90014

    info@selectstart.com

    This Privacy Policy is strictly limited to the Program and has no effect on any other privacy policy(ies) that may govern the relationship between you and Us in other contexts.