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Freestartr LLC

Privacy Policy

Effective July 2, 2017.

FreeStartr takes privacy and the protection and security of your personal information seriously. This Privacy Policy (the “Policy”) governs your use of this website (the “Site”) and the services (together with the Site, the “Services”) offered by Freestartr LLC, a Nevada limited liability company (together with its affiliates, agents, representatives, consultants, and employees, , “FreeStartr”, “we”, and “us”). Please read the Policy carefully before interacting with the Site or using any of the Services.

By using the Services in any way, you acknowledge that you have read, understood, and agree to be bound by our Terms of Use and this Privacy Policy.

Your use of the Services is at all times subject to the Terms of Use, which adopts and incorporates this Policy by reference.

Modification of this Policy

We reserve the right to amend this Policy at any time by posting a revised version of the Policy on the Site. You agree to be bound by any changes to the Policy when you continue to use the Services after those changes have been posted. If due to such changes, you decide that you want to remove any portion of your personal information from the Site or our servers, please contact us at [email protected].

Information that FreeStartr Collects

We collect and retain two types of information: (i) Personal Identifying Information that individual users voluntarily provide when interacting with the Site or using of the Services (through any means of communication with FreeStartr); and (ii) Computer Tracking Data, which is automatically collected from every visitor and recorded in our log files. The Personal Identifying Information and Computer Tracking Data are sometimes jointly referred to in this Policy as Information. The Personal Identifying Information that we retain may include your account user name, password, name, address, telephone number, email address, birth date, and credit card number, as well as other personal information.

The Computer Tracking Data that we retain may include, without limitation, information regarding the number and frequency of visits to the Site, your activities on the Site, the websites that you access before and after you visit the Website, the software used to access the Site, your IP address and other Internet Service Provider related information. We may also record the location of your computer or mobile device at the time that you are interacting with the Site. FreeStartr may also use uses session “cookies” (text files such as html files, Flash files or other technology) to enhance the security and functionality of the Site. Web browsers often automatically accept cookies but you retain the ability to adjust your preferences through the settings on your browser.

COPPA Compliance
The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personal identifiable information online from children who are under 13 years of age. As noted in the Terms of Use, we comply with COPPA and we do not knowingly collect or solicit personal identifiable information from children under 13 years of age.

How FreeStartr Uses Your Information

FreeStartr will only use the Personal Identifying Information or Computer Tracking Data internally in connection with the Services, including to personalize, provide, and improve the Services, to allow you to register and create a user account, to contact you, to allow other users to contact you, to fulfill your requests for certain services, to offer you information about upgrades, policy changes or other operational information, to analyze how you use the Services, and in the course of security analysis or routine maintenance. In certain cases, we may also share some of the Information with third parties, but only as described below.

Sharing of Non-Personal Identifiable Information

We may aggregate and/or anonymize information collected through the Service so that the information does not identify you. We may use this aggregated, anonymized, and other non-Personal Identifiable Information for any purpose, including for research and marketing purposes, including for providing targeted advertising to Site users, and our use and disclosure of such information is not subject to any restrictions under this Policy.

Sharing of Personal Identifiable Information; No Commercial Disclosure

We do not rent, sell or otherwise distribute any Personal Identifying Information in identifiable form to anyone. However, we may share your Personal Identifying Information with third parties as described in this section:

a. Affiliated Businesses: In certain situations, businesses or third party websites with which FreeStartr is affiliated may offer products or services to you through or in connection with the Services (either alone or jointly with us). If you do not wish to receive such communications, please submit your request in an email to [email protected].

b.  Agents: We may employ other people or companies to perform tasks on our behalf in the course of normal and routine operation of FreeStartr, and we may share your information with them in order to offer the Services to you. For example, we may use one or more payment processing companies (like Coinbase or Stripe) to receive and process your credit card transactions for us. Please see other specific terms relating to third-party payment processing which are set out in our Terms of Use. Unless we tell you differently, our agents do not have any right to use the Information we share with them beyond what is necessary to assist us. That is, our agents cannot sell or rent your information to others.

c. Personal Identifying Information Disclosed in User Content: Any Personal Identifying Information that you voluntarily disclose online in a manner that other users can view (on discussion forums, in messages, and chat areas, etc.) may be displayed to other users. Your user name may also be displayed to other users if and when you send messages or comments on the Site, and other users may be able to contact you through messages and comments. Any Information posted to the Site in connection with the publication of any Campaign will be displayed to other users.

d. Business Transfers: If FreeStartr (or substantially all of its assets) is acquired, or if we cease business operations, commence bankruptcy, or experience some other change of control, Information could be one of the assets transferred to or acquired by a third party.

Identifying Information; Subpoenas and Legal Process

PLEASE READ THIS SECTION CAREFULLY: IT MAY SUBSTANTIALLY AFFECT YOUR LEGAL RIGHTS.

FreeStartr will not disclose without your consent, any Personal Identifying Information about you that we retain. FreeStartr will not automatically disclose information demanded by third parties solely because Freestartr might receive a subpoena. FreeStartr will comply with its legal obligations and with its policy regarding subpoenas. Our policy regarding our compliance with any subpoenas and/or legal process is as follows:

a. A third party seeking Personal Identifying Information about you must serve FreeStartr with a subpoena issued by an appropriate state or federal court with valid jurisdiction over the matter.;

b. On receipt of any such subpoena, FreeStartr will use commercially reasonable efforts to provide you with notice of the subpoena, so that you may seek legal counsel. Freestartr will not act as your attorney, and Freestartr will not “fight the subpoena” for you. It will be incumbent upon you to exercise your legal rights and defenses in connection with any such subpoena, and to do so in a timely manner.

c. In the event that you do not wish FreeStartr to disclose or turn over the requested information set forth in a subpoena, it is solely your responsibility to intervene or challenge the validity and/or enforcement of the subpoena by taking the applicable legal action. It will not suffice for you to simply instruct Freestartr not to comply with the subpoena. You must initiate and proceed with proper legal action. Freestartr advises you that you should contact an attorney immediately to obtain advice and counsel as to any such subpoena. You must timely notify FreeStartr of the legal actions that you take and provide proof of any such actions.

d. IN THE EVENT THAT YOU OR YOUR ATTORNEY DO NOT IN A TIMELY MANNER PROVIDE FREESTARTR WITH PROOF THAT YOU HAVE INITIATED THE APPROPRIATE LEGAL ACTIONS IN RESPONSE TO ANY SUCH SUPOENA, FREESTARTR WILL BE OBLIGATED TO COMPLY WITH THE SUBPOENA.

Court Orders

FreeStartr is obligated to and shall comply with any court order arising from any legal action brought against FreeStartr or in which FreeStartr is a party, including the disclosure of Personal Identifying Information.

Law Enforcement

FreeStartr may in its sole discretion, unilaterally provide Information in compliance with a law enforcement agency’s demand or request if such disclosure will materially aid in the prevention of imminent and serious harm to others’ physical safety or property. Participants will receive a notification from FreeStartr of such disclosure, unless the law enforcement agency making the demand or request notifies FreeStartr in writing that such notification to Participants would be illegal, or would unreasonably interfere with or otherwise jeopardize their investigation and/or increase the risk of harm to a person’s physical safety.

FreeStartr is Not Your Lawyer

BY AGREEING TO THE TERMS OF THIS PRIVACY POLICY, YOU ACKNOWLEDGE THAT FREESTARTR IS IN NO WAY OBLIGATED TO ACT AS A LEGAL REPRESENTATIVE ON YOUR BEHALF IN ANY MATTER, NOR TO SUPPLY YOU WITH LEGAL COUNSEL IN THE EVENT OF A THIRD PARTY REQUEST FOR PERSONAL IDENTIFYING INFORMATION, AND THAT IT IS SOLELY YOUR RESPONSIBILITY TO SEEK LEGAL REPRESENTATION AT YOUR SOLE COST AND EXPENSE. YOU FURTHER AGREE TO HOLD FREESTARTR HARMLESS, NOT TO SEEK INDEMNITY FROM FREESTARTR, AND NOT TO ASSERT ANY CLAIM OR BRING ANY ACTION AGAINST FREESTARTR IN THE EVENT OF FREESTARTR’S DISCLOSURE OF PERSONAL IDENTIFYING INFORMATION..

California Privacy Rights

Pursuant to California Civil Code Sections 1798.83-1798.84, California residents are permitted to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Identifiable Information (if any) for their direct marketing purposes in the prior calendar year, as well as the types of Personal Identifiable Information disclosed to those parties. Please note that Freestartr is not a California company, and it is unclear whether the foregoing California laws apply to Freestartr in any given situation. If you are a California resident and would like to request this information, please submit your request in an email to [email protected]. Freestartr reserves the right to determine that it is not subject to such California legislation in any given instance.

Information Security

Some of the Information affiliated with your account is protected by a password for your privacy and security. You are responsible for your password and for maintaining a password that is not easily hackable. As noted in the Terms of Use, for your security, we recommend that you use a long, unique password consisting of a mix of upper- and lower-case letters, numbers, and symbols. You are also responsible for keeping your password confidential. You should not share your user name and password with anyone. You should limit access to your computer or mobile device by signing out of the Site after you have finished accessing your account.

We take reasonable precautions to protect your Information from loss, misuse or alteration. We maintain reasonable physical, electronic and procedural safeguards for your Information. You should recognize, however, that there is no such thing as “perfect security” on the Internet, and we cannot guarantee the security of your Information.

In addition, because Internet communication is potentially insecure, it is also possible that the information you supply to us while using the Site or via email may be intercepted during transmission. We are not liable for any breach of our systems or interception of our transmissions, and we hereby disclaim, to the fullest extent provided under all applicable laws, any liability associated with any claim relating to a breach of security, data or information.

User Choices Regarding Collection and Storage of Information

You may decline to provide any Personal Identifiable Information, but as a result you may be unable to register and create an account on the Site or to use certain of the Services. You may update or correct your account information and email preferences at any time by logging in to your account. When logged in, you may be able to add, update, or delete certain information. When you make any such changes, however, we may maintain a copy of the unrevised information in our records.

Links to Other Web Sites

We are not responsible for the practices employed by websites linked to the Site, nor the information or content contained therein. Please remember that—when you use a link to go from the Site to another website—this Policy is no longer in effect. Your browsing and interaction on any other website, including those that are linked to on the Site, is subject to that website’s own rules and policies.

Questions
If you have any questions, comments, or concerns regarding this Policy, please contact us at [email protected].