Privacy policy.

Last updated: December 2023

Our Commitment to You

Starfish Connection, Inc and its affiliated companies (“Starfish Connection” or “we”) are dedicated to providing its users with transparency and control over the use of their data. In order for us to provide you with our services we may collect and process certain personal information about you and your activity.

By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken measurable steps to protect the confidentiality, security and integrity of this Information. We encourage you to review the following information carefully.

(1) Grounds for data collection

Your “Personal Data” (meaning any information which may potentially allow your identification with reasonable means) will be processed as necessary for the performance of our contractual obligations towards you and providing you with our services and products (including, without limitation, any content therein) and the operation of our websites and mobile apps and delivery of emails to you (collectively the “Services”, and the “Websites”), to protect our legitimate interests and for compliance with legal and regulatory obligations to which we are subject.

When you use our Services, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

(2) How do we receive data about you?

We receive your Personal Data from various sources:

  1. Registration information – When you voluntarily provide us your personal details in order to create an account or register to our Services (for example, your name and email address).

  2. When you communicate with us – For example when you send us a message, or apply to be a content provider/editor, we collect the Personal Data you provided us with.

  3. When you submit content to or through the Services.

  4. When you respond to or participate in one of our polls, surveys, votes, rankings, quizzes, contests, sweepstakes, games, forums or by otherwise expressing an opinion.

  5. When you click on links included in our Services that lead to third party products and/or services offered on third party sites by business partners we are affiliated with (“Affiliate Link/s”; please see our Terms for additional information in this respect).

  6. When you purchase, return, or exchange products offered through the Services.

  7. Technical information – When operating our Services, we use various technological tracking tools to collect information regarding your use of the Services. Along with our partners, we may use tracking technologies such as cookies, JavaScript, beacons and Local Storage, which are used to store content information and preferences. You can learn more about the tracking tools we use by visiting our Cookie Policy.

  8. Third party information – We may receive your data from third party providers who help us with the provision and maintenance of our Services, such as social networks (for example your name and user name, when you register or log-in to our Services), traffic analytics vendors, fraud prevention agencies and others. We also receive your data from publishers and advertisers who use our platform and other services.

(3) What types of data do we collect?

PERSONAL DATA

In the course of using the Services, we may ask you to provide us with certain Personal Data to provide and improve the Services, to contact or identify you, to enable you to access certain parts of the Websites, and as otherwise indicated in this Policy. We may collect the following Personal Data about you:

  • Identifiers:

  • When you sign up to an event or receive our newsletter, when you send us a message (or submit a support ticket), or otherwise communicate with us in relation to the Services, we may receive certain identifiers, such as: your name, email address or other information included in such communications.

  • If you create an account or register to our Services, or connect your account and log-in to our Services via to a social network (for example: if you log in via Facebook), we may also collect certain identifiers, such as your associated credentials, profile name, email address, profile photo, age and country/state of residence.

  • Payment data such as your payment instrument number (such as a credit card number) and billing information, collected in order to process your payments for purchases, fulfill your requests for refunds, returns, or exchanges, and process the redemption of discounts. This data is usually processed by our relevant service providers, and not retained by us.

  • In the framework of one of our polls, surveys, votes, rankings, quizzes, contests, sweepstakes, games, forums, content publishing, and when you choose to provide it, we may also collect information about your personal or professional interests, favorites and opinions about various products, programs and services.

  • Internet or other electronic network activity information – our Services may use your IP-address and UDID and other information regarding your interaction with our Services and with advertisements displayed on our Services.

  • Geolocation data – our Services may use information regarding your general location.

NON-PERSONAL DATA

We also collect data about the use of our Services and the characteristics and activities of users, in order to operate it and improve it. We may collect the following non-Personal Data:

  • Technical information – this includes data such as website visits, the browser you are using and its display settings, your operating system, device type, session start/stop time, time zone, network connection type (e.g., Wi-Fi, cellular), and non-identifiable cookie information.

  • Information from third parties – this includes information we receive from our business partners. This may include pseudonymous advertiser identifiers that some advertisers or other third party ad platforms choose to share with us. This information is also used to enhance data points about a particular unique browser or device.

VOICE PROCESSING TECHNOLOGIES

If you choose to use Amazon Alexa Skills or Google Assistant in connection with the Services, Amazon and Google will process your personal data via their voice processing technologies, by which they collect audio through the microphone on your device(s) to effectuate an instruction or request by you using Amazon Alexa Skills or Google Assistant. Please be aware that your use of Amazon Alexa Skills or Google Assistant may provide Amazon and Google with access to and use of information associated with your use of their device, including the audio you provide, and you should carefully review their privacy policy and terms of use (to learn more about their data processing, please visit Google’s policies, here and here; and Amazon’s policies: here and here).

* If we combine Personal Data with non-Personal Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.

TRACKING TECHNOLOGIES

When you visit or access our Services (including, without limitation, if you open an email we have delivered to you) we use (and authorize 3rd parties to use) pixels, cookies, events and other technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Websites’ performance, perform analytics and customize your experience on it. In addition, we may merge information we have with information collected through these tracking technologies with information we may obtain from other sources and, as a result, such information may become Personal Data.

To learn more about our Tracking Technologies please visit our Cookie Policy page.

(4) How do we use the data we collect?

  • Provision of service – for the provision and improvement of our Services, including for support, responding to your queries, and processing of payments as stated in Section 3 above.

  • Service announcements – we will use your Personal Data to communicate with you and to keep you informed of our latest updates to our Services and offer you service offers.

  • Marketing and advertising purposes – by subscribing to our newsletter you will receive tips and announcements straight to your email account. We may also use your Personal Data in the following ways: we may send you promotional material concerning our Services, or our partners’ services, which we believe might interest you; we may also display certain adverts on our Services, which we believe will be relevant for you. We make our best efforts to make sure you see only relevant ads and receive relevant communications from us, including but not limited to, by building an automated profile based on your Personal Data.

  • Opt-out of retargeted advertising – You may object to the use of your Personal Data for advertising purposes by disabling your cookies, as described in our Cookie Policy.

  • Opt out of receiving marketing materials – if you do not want us to use or share your Personal Data for marketing purposes, you may opt-out in accordance with this “Opt-out” section. You may choose not to receive our promotional or marketing emails by clicking on the “unsubscribe” link in the emails that you receive from us, or contact our DPO at dpo@ourstoryconnection.com [note] (kindly specify the name of the relevant product from which you wish to unsubscribe). Please note that even if you unsubscribe from our newsletter, we may continue to send you service-related updates and notifications, or reply to your queries and feedback you provide us. Also note that even if you opt-out, we may still use and share your Personal Data with third parties for non-marketing purposes (for example to fulfill your requests, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Data are authorized to use your Personal Data only as necessary to provide these non-marketing services. If you subscribed to any of our partners’ service, please note we will have no control over our partners’ communications, and in order to unsubscribe from it please contact the relevant partner, or use the “unsubscribe” link in its emails.

  • Push Notifications – if you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our relevant app.

  • Analytics, surveys and research – from time to time, we may conduct surveys or test features, and analyze the data we have to develop, evaluate and improve these features, all in order to improve our Services and think of new and exciting features for our users.

  • Protecting our interests – we may use your Personal Data when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Services and protect the rights and property of Our Story, its users and/or partners.

  • Enforcing of Policies – we may use your Personal Data in order to enforce our policies, including but not limited to our Terms.

  • Compliance with legal and regulatory requirements – we may use your Personal Data to investigate violations, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

(5) With whom do we share your Personal Data?

  • Internal concerned parties – we share your information with companies in our group, as well as our employees, in order to provide you with our Services.

  • Business partners – we share your information with business partners, such as SaaS, storage and analytics providers who help us provide you with our Services. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf, but they are obligated to comply with the applicable terms of this Policy and may not use your Personal Data for any other purpose. Please also note, that usually, when you click on an Affiliate Link the “3rd Party Affiliate” (as such term is defined in our Terms) will use a tracker (e.g., a cookie) on the your device that may collect Personal Data and will enable to confirm (for example) if you made a purchase from a retailer’s website which is linked via the corresponding Affiliate Link.

  • User Profiles and Submissions – certain user profile information, including your name, location, and any related video or image content you uploaded to the Services for publication, may be displayed to other users as part of the Services, to facilitate user interaction within the Services or address your request for our Services. Your account privacy settings may allow you to limit other users from seeing the Personal Data in your user profile and/or what information in your user profile is visible to others. Please remember that any content you upload to your public user profile, along with any Personal Data or content that you voluntarily disclose online in a manner other users can view (e.g., on your published content,  forums, discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your name/username may also be displayed to other users if and when you send messages or comments or upload images, content or videos through the Services, and other users can also contact you through messages and comments.

  • Compliance with laws and law enforcement entities – we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.

  • Merger and acquisitions – we may share your data if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Policy.

(6) How we protect your information

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners on a “need to know” basis, in order to enable the carrying out of the agreement between us.

While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Services, and you do so at your own risk.

(7) Retention

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.

(8) Rights and Information for Residents of Specific Jurisdictions

A. EUROPEAN USERS’ RIGHTS

If you reside within the European Union, you may request to:

  1. Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.

  2. Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.

  3. Request rectification of your Personal Data that is in our control.

  4. Request erasure of your Personal Data.

  5. Object to the processing of Personal Data by us.

  6. Request to restrict processing of your Personal Data by us.

  7. Lodge a complaint with a supervisory authority.

However, please note that these rights pertain to EU residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

TRANSFER OF DATA OUTSIDE THE EEA

EU users, please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

B. California Residents

In the preceding 12 months, we have collected, disclosed, and/or sold the following categories of Personal Data:

We may share or transfer Personal Data to third parties as assets that are part of a merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of Our Story. Such transfer will be handled according to the requirement of the California Consumer Privacy Act (“CCPA”) and shall not be regarded as a sale of Personal Data under the CCPA.

SOURCES OF PERSONAL DATA

In the 12 preceding months, we have collected the above-mentioned categories of Personal Data from either of the following categories of sources:

  • Consumer directly;

  • Social media;

  • Fraud prevention service providers;

  • Analytics Providers;

  • Ad networks.

CALIFORNIA CONSUMERS’ RIGHTS

The CCPA provides consumers with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.

ACCESS TO PERSONAL DATA

You may request, up to two times in a 12 months period, that we disclose to you the categories and specific pieces of Personal Data that we have collected about you, the categories of sources from which your Personal Data is collected, the business or commercial purpose for collecting your Personal Data, the categories of Personal Data that we disclosed for a business purpose, any categories of Personal Data about you that we sold, the categories of third-parties with whom we have shared your Personal Data, and the business or commercial purpose for selling your Personal Data, if applicable.

DELETION REQUESTS

You have the right to request that we delete any Personal Data collected from you and retained, unless an exception applies.

Once we receive and confirm your verifiable consumer request, we will delete (and where necessary and relevant, direct our service providers, subcontractors, and consultants to delete) your Personal Data, unless an exception applies.

RIGHT TO OPT-OUT OF THE SALE OF PERSONAL DATA

In the event that we sell your Personal Data, you have the right to submit a request to opt-out of the sale of your Personal Data. You may change your decision at any time and permit us to sell your Personal Data.

If you do not want us to sell your Personal Data to third parties, please click on the “Do Not Sell My Personal Information” link located in our homepage for residents located in California.

After you opt-out, we may continue to share some Personal Data with our partners (who will function as our service providers in such instance) to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud. If you access this site (or app) from other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to the Personal Data collected when you use those devices or browsers.

Additionally, although clicking the “Do Not Sell My Personal Information” link will opt you out of the sale of your Personal Data for advertising purposes, it will not opt you out of the use of previously collected and sold Personal Data or all interest-based advertising. If you would like more information about how to opt-out of interest-based advertising in desktop and mobile browsers on a particular device, please visit https://optout.aboutads.info/ and https://optout.networkadvertising.org/. You may also download the AppChoices app at http://www.aboutads.info/appchoices to opt-out in connection with mobile apps, or use the platform controls on your mobile device to opt-out.  [insert referenced hyperlinks]

EXERCISING YOUR RIGHTS

You can exercise your rights to access to your Personal Data or request deletion of your Personal Data, by submitting a verifiable consumer request to our email address: dpo@ourstoryconnection.com (please provide the required details as per Section 12 below).

In addition, you can exercise your rights (such as access and deletion) via our webform located at https://ourstoryconnection.com/contact/ , where you can submit a verifiable user request.

Only you or a person legally authorized to act on your behalf may make a consumer request related to your Personal Data.

The request must:

  • Provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Data or an authorized representative.

  • Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

  • We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

If you have any general questions about the Personal Data that we collect about you how we use it, please contact us at dpo@ourstoryconnection.com (please provide the required details as per Section 12 below).

RESPONSE TIMING AND FORMAT

Our goal is to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the first 45 days period. We will deliver our written response, electronically. Any disclosures we provide will cover the 12-month period preceding the request. If reasonably possible, we will provide your Personal Data in a format that is readily useable and should allow you to transmit the information 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.

In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.

Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.

DESIGNATING AGENTS

You can designate an authorized agent to make a request under the CCPA on your behalf if:

  • The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and

  • You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

NON-DISCRIMINATION

Unless permitted by the CCPA, in connection with you exercising your aforementioned rights, 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.

REQUESTS METRICS

We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median number of days in which we responded to such requests, in the previous year, as applicable to the time period in which the CCPA was in effect. As of the date of publishing this Policy, such yearly data has yet to have been received. Once such data is received, it will be published in a dedicated Consumer Requests Metrics page which will be available within this Policy.

C. Brazilian Residents

The following part of this Policy complements the general part of the Policy and addresses the specific disclosure requirements under the Brazilian Data Protection Law (Lei Geral de Proteção de Dados, “LGPD”).

Processing of Personal Data

The processing of your Personal Data is not a condition for the use our Services. However, parts of our Services may not be available without registration and/or payment, which involve the processing of Personal Data.

Brazilian Users’ Rights:

If you reside in Brazil, you have the following rights under LGPD:

  • Receive confirmation as to whether or not Personal Data concerning you is being processed;

  • Access your Personal Data;

  • Correct incomplete, inaccurate or outdated Personal Data;

  • Request anonymization, blocking or deletion of unnecessary, excessive Personal Data;

  • Request data portability to another service provider or product, upon express request, as may be provided by the appropriate law;

  • Request deletion of Personal Data processed with your consent;

  • Obtain information about the public or private entities with which we share your Personal Data;

  • Request information on the possibility of you not providing consent, as well as being informed about the consequences should consent not be given;

  • Revoke your consent.

Contact information: dpo@minutemedia.com (please provide the required details as per Section 12 below).

(9) Other Jurisdictions

Under certain jurisdictions, some of the aforementioned rights may apply as well. Please contact us using the contact details provided below and we would make our best efforts to assist with any questions or requests.

(10) Our Policy toward Children

We understand the importance of protecting children’s privacy, especially in an online environment. The Services are not designed for or directed at children under the age of 18 [confirm age with age verification service] years old (“Minors”). We do not knowingly collect Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided below.

(11) Updates to this Policy

This Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our Websites (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. In the event of material changes, we may also provide you with a notice. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Privacy Policy.

Notwithstanding the forgoing, as of January 1st 2022, this Policy will be updated at least once every 12 months.

(12) How to contact us?

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below.

Kindly specify: (a) the nature of your request, (b) your country of residence, and (c) the name of the Services (website/product/application) subject of your request.

Email: dpo@ourstoryconnection.com

Please be advised that dpo@minutemedia.com is designated solely for privacy related inquiries of our users, and we reserve the right not respond to any non-privacy inquiries that are sent via the DPO email address. For any non-privacy inquiries, please see the email addresses listed our Terms.

Upon receiving your request, and according to legal obligations to which we are subject, we will first need to verify your request and therefore we may ask you to provide us with additional verification details, as needed. Following our verification process, we will respond to your request within the timeframe required under applicable laws.