Privacy & Terms

We respect your privacy and process personal data in accordance with applicable laws and regulations, including the European Union’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA/CPRA). This Policy explains what personal data we collect, how we use it, and the rights you have regarding your data.

1. Personal Data We Collect

We collect personal data in the following categories, which are necessary to provide and improve our services, and to comply with legal obligations:

Account and Contact Information: Personal data you voluntarily provide when creating an account or interacting with our services, such as your full name, email address, and other contact details.
Order and Payment Data (for Affiliates): Information related to orders and payments made by users referred by you, including transaction amounts, payment methods, and order status (to calculate commissions and process payments).
Referral Attribution Data: Data related to referral activities, such as referral codes, discount codes, and information about how users access our services through your referral links (to track attribution and calculate commissions).
Technical Data: Automatically collected data when you use our services, including device type, operating system, browser type, IP address, basic usage events (e.g., page views, session duration), and other technical information necessary for the proper operation of our services.

2. Cookies & Local Storage

We use cookies, local storage, and similar technologies to support referral attribution, service functionality, and user experience. By using our services, you consent to the use of these technologies in accordance with this Policy. You may manage your cookie preferences through your browser settings, but disabling certain cookies may affect the functionality of our services.

aff_ref Cookie: Stores your referral code to track referrals and attribute conversions. This cookie has a maximum validity period of 30 days from the date of placement.
aff_policy_read Local Storage: Records that you have read and agreed to our Privacy Policy and Terms of Service, to avoid repeated consent prompts.
Session Storage: Temporarily caches your eligibility status (e.g., commission eligibility, referral qualification) during your browsing session. This data is deleted once you close your browser.

For users in the European Union: We use both necessary cookies (required for service operation) and non-necessary cookies (for attribution and functionality). You have the right to refuse non-necessary cookies, and we will not use them without your explicit consent.

3. How We Use Your Personal Data

We use your personal data only for the following legitimate purposes, and we will not use it for any unstated purposes without your prior consent:

Provide, maintain, and improve our services, including tracking referrals, calculating commissions, and processing payments to affiliates.
Prevent fraud, abuse, and unauthorized use of our services, and ensure the integrity and security of our referral program.
Comply with applicable legal, regulatory, and tax obligations (e.g., retaining records for tax reporting, responding to legal requests).
Communicate with you about our services, including updates to this Policy, changes to the referral program, and important service notifications (you may opt out of non-essential communications).

4. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including: (i) the duration of your participation in our referral program; (ii) compliance with legal and tax retention requirements (e.g., retaining payment and transaction data for the period required by tax laws); (iii) resolving disputes, enforcing our terms, and preventing fraud. After the retention period expires, we will securely archive or delete your personal data in a way that prevents unauthorized access or recovery.

5. Legal Basis for Processing (GDPR Compliance)

For users in the European Union, we process your personal data based on the following legal bases, as required by the GDPR:

Consent: Where required (e.g., for non-necessary cookies), we process your data with your explicit, freely given, and revocable consent.
Performance of a Contract: Processing your data to fulfill our obligations under the contract between you and us (e.g., providing the referral program, paying commissions).
Legitimate Interests: Processing your data for our legitimate business interests, which do not override your privacy rights. These interests include: tracking referral attribution, preventing fraud and abuse, and improving our services.

6. Your Rights (GDPR & CCPA/CPRA Compliance)

You have the following rights regarding your personal data, and we will respond to your requests in accordance with applicable laws (usually within 30 days):

Right to Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request correction of any inaccurate or incomplete personal data we hold about you.
Right to Erasure (Right to be Forgotten): Request deletion of your personal data, where we no longer have a legal basis to retain it.
Right to Restriction of Processing: Request that we restrict processing of your personal data (e.g., if you dispute the accuracy of the data).
Right to Object: Object to processing of your personal data based on our legitimate interests (we will stop processing unless we have compelling legitimate grounds to continue).
Right to Withdraw Consent: If processing is based on your consent, you may withdraw your consent at any time (this does not affect the legality of processing before withdrawal).
Right to Data Portability (GDPR): Request a copy of your personal data in a structured, machine-readable format, or request that we transfer it to another data controller.
Right to Opt-Out of Data Sale (CCPA/CPRA): For users in California, you have the right to request that we do not sell your personal data (we do not sell personal data to third parties, but this right is explicitly acknowledged per CCPA/CPRA requirements).

To exercise any of these rights, please contact us at: support@startTower.com.

7. Data Security

We take appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include: encrypted data transmission (via HTTPS), secure storage systems, access controls (limiting access to personal data to authorized personnel only), and regular security audits. While we strive to protect your data, no security measure is 100% secure, and we cannot guarantee absolute security. We will notify you promptly if a data breach occurs that is likely to result in a high risk to your rights and freedoms.

8. Children’s Privacy

Our services are not intended for children under the age of 13 (in compliance with the Children’s Online Privacy Protection Act (COPPA) in the U.S.) and 16 (in compliance with the GDPR in the EU). We do not intentionally collect personal data from children under these ages. If we become aware that we have collected personal data from a child without parental/guardian consent, we will promptly delete that data.

9. Third-Party Disclosure

We do not sell, rent, or share your personal data with third parties for marketing purposes. We may share your personal data with third-party service providers who assist us in providing our services (e.g., payment processors like PayPal/Stripe, hosting providers), but these providers are contractually obligated to protect your data and only process it in accordance with our instructions. We may also disclose your data if required by law (e.g., in response to a court order, subpoena, or regulatory request) or to protect our rights, property, or safety, or the rights, property, or safety of others.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, legal requirements, or best practices. We will notify you of any material changes by posting the updated Policy on our website and updating the "Last Updated" date at the end of this document. Your continued use of our services after the update constitutes your acceptance of the revised Policy.

Privacy Policy