Privacy - Starcity Coliving

Privacy

Privacy

Starcity Properties, Inc.

Privacy Policy

This is the privacy policy (“Policy”) for Starcity Properties, Inc. and/or its affiliates, including Starcity Management, Inc., Starcity International, LLC, and Starcity Ventures, LLC, (a.k.a. “Starcity”, “we”, “our”, or “us”) online services.

Your privacy is important to us. We understand and share your concerns about the privacy of information and data you may provide to store or manage through the Services (as defined below). In this Policy, we attempt to explain what we do with your information, and, if applicable, how we collect it. Please read this Policy carefully as it also explains how you may verify the accuracy of any Personal Information (as defined below) we have concerning you and how you may request that we delete or update your Personal Information. By using the Services you consent to this Policy.

Starcity complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  Starcity has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Starcity is subject to investigatory and enforcement powers of the U.S. Federal Trade Commission.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. Starcity commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to HR Data transferred from the EU in the context of the employment relationship. Please contact us to be directed to the relevant DPA contacts.

Starcity adheres to the Privacy Shield Principles including the Privacy Shield Principles for Personal Information received from entities in the European Economic Area.

CLIENT CONSENT

By submitting or making available Personal Information through the Services, you agree to the terms of this Policy and you expressly consent to the processing of your Personal Information in accordance with this Policy. Your Personal Information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Information and data may be less stringent than the laws in your country.

INTERNATIONAL USERS

WE PRIMARILY STORE DATA ABOUT YOU, INCLUDING PERSONAL INFORMATION, ON SERVERS LOCATED AND OPERATED WITHIN THE UNITED STATES. IF YOU RESIDE OUTSIDE OF THE UNITED STATES, IN ORDER TO PROVIDE AND OPERATE THE SERVICE, WE MAY SEND AND STORE YOUR PERSONAL INFORMATION OUTSIDE OF THE COUNTRY WHERE YOU RESIDE OR ARE LOCATED, TO THE UNITED STATES. THEREFORE, OUR COLLECTION AND USE OF YOUR PERSONAL INFORMATION IS SUBJECT TO THE UNITED STATES’ LAWS RELATED TO PRIVACY AND USE OF PERSONAL DATA AND INFORMATION. THESE LAWS, INCLUDING WHAT IS DETERMINED TO BE “PERSONAL DATA AND/OR INFORMATION,” ARE DIFFERENT AND MAY BE LESS PROTECTIVE THAN THOSE  APPLICABLE TO YOU IN YOUR COUNTRY OF RESIDENCE. BY ACCEPTING THE TERMS OF THIS PRIVACY POLICY, YOU ACKNOWLEDGE, AGREE AND CONSENT TO (1) THE TRANSFER TO AND PROCESSING OF PERSONAL INFORMATION ON SERVERS LOCATED OUTSIDE OF THE COUNTRY WHERE YOU RESIDE, (2) OUR COLLECTION AND USE OF YOUR PERSONAL INFORMATION AS DESCRIBED HEREIN AND IN ACCORDANCE WITH THE LAWS OF THE UNITED STATES THAT MAY BE DIFFERENT AND MAY BE LESS PROTECTIVE THAN THOSE IN YOUR COUNTRY AND (3) THAT YOU ARE TAKING A RISK BY USING THE SERVICE.

  • What This Policy Covers: This Policy pertains specifically to the way we collect, use, and store information from www.starcity.com (the “Site”) and the services, features, content or applications we offer (collectively with the Site, these are the “Services”).

Specifically, we put this Policy together to tell you about how we treat the personally identifiable information (“Personal Information”) that is either gathered when you use our Services or provided to us by our third-party partners that help our Services work more efficiently (“Partners”).While we seek out Partners that share our respect for your privacy, you should note that this Policy does not cover the practices of our Partners,s ince we do not own or control them. Even though you may engage with our Partners while interacting with our Services, such as payment processors, you should review the privacy policy of each Partner independently and carefully. Starcity does not take responsibility for the policies held by our Partners.

We maintain written contracts with these Partners and require that these Partners provide at least the same level of privacy protection and security as required by the Privacy Shield Principles. To the extent provided by the Principles, Starcity remains responsible and liable under the Privacy Shield Principles if a Partner that it engages to process Personal Information information on its behalf does so in a manner inconsistent with the Privacy Shield Principles, unless Starcity proves that it is not responsible for the matter giving rise to the damage.

For example, before you apply to live in a Starcity community, you should
also read Plaid’s privacy policy, since they are one of our Partners and the information you provide to them through our Services will be treated in accordance with their privacy policy.

  • How We Collect Your Information: We receive information about you in a number of ways, including: (i) the information you provide when you create an account through the Services (your “Account”); (ii) your answers to the Starcity membership application questions (a “Membership”); (iii) the information you provide through your use of the Application (the “App”); (iv) your use of the Services generally; and (iv) from third party websites and services. By using our Services, you consent to letting us collect, transfer, manipulate, store, disclose and otherwise use your information as described in this Policy.
  • What Information We Collect, Why We Collect It, and How we Use it: We collect Personal Information and other data so we can personalize, improve and operate our Services. The following are types of information we gather from our users:
    • Account Information: When you create an Account, you are asked to provide some Personal Information, such as your name, password and email address. By doing so, you understand that you are sharing information with others that may be personal to you. This means your Account may not be anonymous. We may use your contact information to send you information about our Services, but only rarely when we feel such information is important. Of course, you have the option to unsubscribe from these messages through your Account settings. There may be other circumstances where we determine contacting you is necessary, such as recovering your account.
    • Starcity Membership Application Information: Prospective members who would like to apply to live in Starcity must complete an application (“Member Application”). The Member Application is broken into three parts: Logistics, Background Check, and Community Fitness.

      • Logistics: In order to apply for a Starcity Membership, you have to provide Personal Information, such as your name, phone number and email address. We use the information to contact you regarding your application process for a Starcity Membership.
      • Personal Information: Starcity pre-qualifies applicants on the basis of criminal and financial background checks. Certain Personal Information may be required to ascertain your background, including information you provide to us directly and information provided to our Partners. This information is not shared with existing members of the Starcity community.
      • Community Fitness: Since Starcity properties are designed as community housing, it is important that new members are a good cultural fit for their House. Starcity does not use information provided in this section to qualify applicants. 
      • Financial Information: While we collect financial account information (e.g. bank checking or routing numbers; debit or credit card processing information), we never transmit or store. All financial data is transmitted to and stored by our third party payment processing company (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy policy. We may, from time to time, request and receive some of your financial information from our Payment Processor for the purposes of completing transactions you have initiated through the Services, enrolling you in discount, rebate, and other programs in which you elect to participate, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage our business. In addition t performing a credit check during the Background Information phase of the Member Application, which can negatively impact your credit score, our Partners may provide us with a snapshot of certain portions of banking history, such as your income, their sources, and your income history for the prior year (“Financial Snapshot”). Your Financial Snapshot is stored in a secure server where access is limited to a few select employees. 
      • IP Address Information and Other Information Collected Automatically: We automatically receive and record information from your web browser when you interact with our Services, including your IP address and cookie information. This information is used to fight malware and facilitate data collection concerning your interaction with the Services (e.g., what links you have clicked on). Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site. We and our Partners use the aggregated data to analyze how often individuals use parts of the Services so that we can improve them.
      • Email Communications: We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service. If you provide us feedback or contact us via e-mail or the Services, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply, and any information that you submit to us. If we conduct a survey in which you participate, we may collect additional profile information.
      • Information Collected Using Cookies: Your browser likely stores cookies (tiny text files) that most websites send to you, including our Site. Cookies let our servers recognize your web browser and tell us how and when you use some of our Services. Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage the most attractive features of the Services. This Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.
      • DO NOT TRACK. Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA): Without a common industry or legal standard for interpreting Do Not Track (DNT) signals, Starcity does not respond to browser DNT signals. We will continue to monitor further development of a DNT standard by the privacy community and industry. 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.
      • Aggregate Information: We may also collect non-personally identifiable information and aggregate and anonymize such information (“Aggregate Information“), for example, tracking the number of visitors to the Services, where visitors enter the Services, how long they remain, etc., in connection with the operation of the Services. This statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser.
  • How We Share Your Information: The Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with third parties.
    • Information You Elect to Share: Some features of our Services may prompt you to access our Partners’ services, such as a link to a Partners’ website from within our Site. In doing so, you may elect to share Personal Information with Partners. Again, you should review the privacy policies of the Partners if you choose to use their services. Certain aspects of your Member Application, discussed above, may be shared with other members. Your Background Information and Financial Snapshot are never shared with other members. We strongly advise you to use the utmost caution before sharing any Personal Information with others, including other members. You should not, under any circumstances, provide your financial information (for example, credit card or bank account numbers) to other individuals.
    • Financial Information: As described above, we collect but never transmit or store financial information. Financial data is only transmitted and stored by our Partners.
    • IP Address Information: We do not make information about your IP Address public. However, sometimes we share this information with our Partners and as otherwise specified in this Privacy Policy.
    • Aggregate Information: We share some Aggregate Information with our Partners. This anonymous data lets us and our Partners understand how, and how often, users interact with our Services and our Partners’ services. In addition, these third parties may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.
    • Email Communications with Us: As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to your Account. Communications relating to your Account will only be sent for purposes important to the Services, such as password recovery.
    • Information Shared with Our Agents: We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order for us to provide our Services. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. By using our Services, you consent to our sharing of Personal Information with our Agents.
    • Information Shared with Our Partners: We may share your Personal Information with our Partners to provide technical support or to provide specific services, such as hosting of your applications, maintenance services, database management or payment processing. Partners will have access to your Personal Information only to perform these services on our behalf and are obligated not to disclose or use it for any other purpose.
    • Information Disclosed Pursuant to Business Transfers: At some point, we may choose to sell some or all of our assets. In these types of business transactions, user information is typically one of the transferred assets. Moreover, if we or substantially all of our assets were acquired by another company, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. By using our Services, you acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.
    • Information Disclosed for Our Protection and the Protection of Others: We reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Policy, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety or our users, Members or the public (such as when harm or violence against any person is threatened). This includes exchanging information with other companies and organizations for fraud protection, copyright infringement, and spam/malware prevention. Notwithstanding any other provision of this Policy, we reserve the right, but have no obligation, to disclose any information that you provide through the Services if in our sole opinion we suspect or have reason to suspect that the information involves a party who may be the victim of abuse in any form. Abuse may include, without limitation, elder abuse, child abuse, spousal abuse, animal abuse, neglect or domestic violence. Information may be disclosed to authorities that we, in our sole discretion, deem appropriate to handle such disclosure. Appropriate authorities may include, without limitation, law enforcement agencies, child protection agencies or court officials. Notwithstanding the foregoing, we will disclose Personal Information where required to the extent necessary to meet a legal obligation to which Starcity is subject, including a lawful request by public authorities and national security or law enforcement obligations and applicable law, rule, order, or regulation.
    • Information We Share With Your Consent: Except as laid out above, we will notify you when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.
  • How We Secure Your Information: We take the security of the information we collect through the Services seriously and in response implement a variety of security measures designed to reduce the risk of unauthorized disclosures and accidental destruction or loss of

Personal Information and to maintain the safety of your Personal Information using methods appropriate to the nature of the data and information provided to us by you.

Personal Information collected via the Services is securely transmitted and stored on servers located in the United States, and these servers are subject to our IT security policies and procedures.

While security is always a priority, we do not guarantee or warrant these techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.

Your Account information is protected by a password for your privacy and security. You need to prevent unauthorized access to your Account andPersonal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.

We protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

 To discuss the security programs, procedures and policies that we utilize to reasonably secure your Personal Information, please contact security@starcity.com. We are happy to discuss our security program with you.

  • What Information of Mine Can I Access and Change?:We offer you choices regarding the collection, use, and sharing of your Personal Information. We may periodically send you free newsletters and emails that directly promote the use of the Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information below). Should you decide to opt-out of receiving future mailings, we may share your email address with third parties to ensure that you do not receive further communications from third parties. Despite your indicated email preferences, we may send you notice of any updates to our Privacy Policy.

If you are a registered user, you may access and change any of your Personal Information in your associated Account by logging into the Services. Unregistered users can access and delete cookies through their web browser settings.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84,California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address:

Starcity Properties, Inc, 1020 Kearny St., San Francisco, CA 94133 or security@starcity.com

  • How Can I Delete My Account?: You may request deletion of your account information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete account information, it will be deleted from the active database, but may remain in our archives

You can delete your Account by emailing Securitywelcome@starcity.com with the subject line “Terminate My Account”. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account.

  • What Choices Do I Have Regarding My Information:
    • You can limit the information we collect by using some of our Services
      without registering for an Account.
    • Although some of our Services require you to provide Personal Information, you can always opt not to engage our Services.
    • You can delete your Account. Please note that we will need to verify
      that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us and may be publicly accessible.
  • What Happens When There Are Changes to this Privacy Policy?: We may amend this Privacy Policy occasionally. The way we use the information we collect is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

A Note About Children: We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

  • GENERAL DATA PROTECTION REGULATION (GDPR)
    • Legal Basis: If you are from the European Economic Area (EEA), Starcity’s basis for collecting and using the personal information described in this Policy depends on the Personal Information we collect and the specific context in which we collect it.
    • Starcity may process your Personal Information because:
      • Your use of the Services
      • You have given us permission to do so
      • The processing is in our legitimate interests and it is not overridden by your rights
      • To comply with the law
    • 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 information are, or are to be, processed. Data collected may be used directly or by one of our wholly owned subsidiaries: 

Starcity Management, Inc., Starcity International, LLC,  and Starcity Ventures, LLC. 

For the sake of clarity the “covered entities” under this Privacy Policy shall be: Starcity Properties, Inc., Starcity Management, Inc, Starcity International, LLC, and Starcity Ventures, LLC. 

For the purpose of this Policy, we are a Data Controller of your Personal Data.

    • Data Processor: Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may process your Data internally or use the services of various Partners in order to process your data more effectively.
    • Data Subject: Data Subject is any living individual who is using our Service and is the subject of Personal Information.
    • Your Data Protection Rights under the General Data Protection Regulation (GDPR): If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Starcity  aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Information. If you wish to be informed about what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

      • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
      • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete. 
      • The right to object. You have the right to object to our processing of your Personal Data.
      • The right of restriction. You have the right to request that we restrict the processing of your personal information.
      • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
      • The right to withdraw consent. You also have the right to withdraw your consent at any time where Starcity relied on your consent to process your personal information.
    • Please note that we may ask you to verify your identity before responding to such requests.
    • You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).
    • We have offices and facilities in United States and the EEA. The United States is outside the EEA and any international transfer within our group of companies will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by Privacy Shield certification (www.privacyshield.gov) if the transfer is to the United States. For EEA personal data transferred to the United States, Starcity commits to complying with Privacy Shield Principles.
  • CALIFORNIA PRIVACY RIGHTS. Our members who are California residents may request and obtain from us once a year, free of charge, certain information about the Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Data that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to security@starcity.com.
  • What if I Have Questions or Concerns?: If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to securitywelcome@starcity.com. We will make every effort to resolve your concerns.
    Enforcement. In compliance with the Privacy Shield Principles, Starcity commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Starcity at: 

Starcity

Attn: Stephen Ripley, 1020 Kearny St.San Francisco, CA 94133

security@starcity.com

Starcity  has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.

You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances.  For further information, please see the Privacy Shield website. To learn more about the Privacy Shield Framework, and to view Starcity’s certification, please visit https://www.privacyshield.gov.