Contact us
Contact us
Last Updated: 27 October, 2024
Starti Limited (“Company,” “we,” “us,” or “our”) operates starti.tv (the “Platform”), a connected television demand-side platform enabling advertisers to purchase, manage, and optimize ad campaigns across streaming TV environments. This Privacy Policy (“Policy”) describes how we collect, use, disclose, and protect Personal Data (as defined below) in compliance with applicable laws, including the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”), and other global privacy frameworks.
By accessing or using the Platform, you acknowledge that you have read and understood this Policy. For questions, contact us at contact@starti.tv
1. DEFINITIONS
- “Personal Data”: Information that identifies, relates to, or could reasonably be linked to an individual or household, directly or indirectly.
- “CTV Device Data”: Non-personally identifiable information associated with connected TV devices (e.g., IP addresses, device IDs, viewing patterns).
- “Service Providers”: Third parties engaged to process data on our behalf under contractual obligations.
- “Data Controller”: The entity determining the purposes and means of processing Personal Data (typically advertisers using the Platform).
- “Data Processor”: The entity processing data on behalf of the Data Controller (the Company, in certain contexts).
2. TYPES OF DATA COLLECTED
2.1 Data Provided Directly
- Advertiser Account Data: Full name, business email, company name, billing address, payment information, and tax IDs.
- Campaign Data: Targeting parameters (e.g., demographics, geographic regions), budget details, and creative assets.
2.2 Data Collected Automatically
- CTV Device Data:
- Device identifiers (e.g., Roku Advertising ID, Samsung Tizen ID, Vizio ID).
- IP address, inferred geolocation (city/state level), and network carrier.
- Content interaction data (e.g., ad impressions, skip rates, view-through conversions).
- Technical Data:
- Browser/device type, operating system, timestamps, and cookie/pixel data.
- Mobile Advertising IDs (MAIDs) for cross-device targeting (e.g., IDFA, GAID).
2.3 Data from Third Parties
- Audience Segments: Aggregated interest-based or demographic data from data partners (e.g., purchase intent, household income brackets).
- Fraud Detection Data: Signals from third-party vendors to identify invalid traffic (IVT).
3. LEGAL BASIS AND PURPOSES OF PROCESSING
We process Personal Data under the following legal bases:
- Contractual Necessity: To fulfill obligations to advertisers under our Terms of Service.
- Legitimate Interests: To improve Platform functionality, prevent fraud, and deliver targeted advertising.
- Legal Compliance: To meet regulatory, tax, or law enforcement requirements.
- Consent: Where required by law (e.g., for cookies or sensitive data processing).
Specific Use Cases Include:
- Delivering, measuring, and optimizing CTV ad campaigns.
- Generating performance reports for advertisers (e.g., reach, frequency, conversion metrics).
- Debugging technical errors and enhancing Platform security.
- Conducting internal research and development.
4. DATA SHARING AND DISCLOSURE
We may share Personal Data with:
4.1 Advertisers and Publishers
- Aggregated campaign performance data, excluding individual viewer identities.
4.2 Service Providers
- Ad Tech Vendors: DSPs, SSPs, ad exchanges, and attribution partners.
- Infrastructure Providers: Cloud hosting services (e.g., AWS, Google Cloud). - Analytics Tools: Platforms for monitoring ad delivery and user engagement.
4.3 Legal and Regulatory Obligations
- In response to subpoenas, court orders, or governmental requests.
4.4 Corporate Transactions
- During mergers, acquisitions, or asset sales, with confidentiality safeguards. We do not sell Personal Data as defined under the CCPA.
5. COOKIES AND TRACKING TECHNOLOGIES
5.1 Technologies Used
- First-Party Cookies: Session management and user authentication.
- Third-Party Cookies/Pixels: Ad performance tracking and retargeting.
- Device Fingerprinting: Detection of fraudulent activity.
5.2 Opt-Out Mechanisms Users may:
- Adjust browser settings to block cookies (see [All About Cookies](https://www.allaboutcookies.org/)).
- Opt out of interest-based advertising via:
- [DAA Opt-Out Tool](https://optout.aboutads.info/)
- [NAI Consumer Opt-Out](https://www.networkadvertising.org/choices/)
- Device-specific settings (e.g., [Google’s Ad Settings](https://adssettings.google.com/)).
6. DATA SUBJECT RIGHTS
Depending on jurisdiction, you may:
- Access: Request a copy of Personal Data we hold about you.
- Rectification: Correct inaccurate or incomplete data.
- Erasure: Delete Personal Data, subject to legal exceptions.
- Restriction: Limit processing under certain conditions (e.g., disputed accuracy).
- Portability: Receive data in a structured, machine-readable format.
- Objection: Object to processing based on legitimate interests or direct marketing.
- CCPA Opt-Out: Opt out of the “sale” or “sharing” of Personal Data (as defined by CCPA).To exercise rights, submit a verifiable request to contact@starti.tv. We will respond within [30 days] and may require proof of identity (e.g., government-issued ID).
7. DATA RETENTION AND SECURITY
7.1 Retention Periods
We retain Personal Data only as long as necessary for:
- Fulfilling contractual obligations to advertisers.
- Compliance with legal, tax, or audit requirements.
- Resolving disputes or enforcing agreements.
7.2 Security Measures
- Technical Safeguards: AES-256 encryption, firewalls, and intrusion detection systems.
- Administrative Controls: Role-based access, employee training, and incident response plans.
- Physical Safeguards: Secured data centers with 24/7 monitoring.
8. INTERNATIONAL DATA TRANSFERS
Data may be transferred to and processed in countries outside your residence, including the United States, European Economic Area (“EEA”), and Asia-Pacific (“APAC”). We ensure adequate protections via:
- Standard Contractual Clauses (SCCs) for GDPR-compliant transfers.
- Binding Corporate Rules (BCRs) for intra-organization transfers.
9. CHILDREN’S PRIVACY
The Platform is not intended for individuals under the age of 16 (or 13 under the U.S. Children’s Online Privacy Protection Act (“COPPA”)). We do not knowingly collect Personal Data from minors.
10. UPDATES TO THIS POLICY
We reserve the right to amend this Policy at our discretion. Material changes will be communicated via:
- Email notification to registered users.
- A prominent banner on the Platform’s login page. The “Last Updated” date at the top of this Policy will reflect the effective date of revisions.
11. CONTACT INFORMATION
For questions, complaints, or to exercise your rights:
Starti Limited Unit 225-22, 2/F Mega Cube 8
Wang Kwong Rd Kln Bay
Hong Kong
Email: contact@starti.tv
Phone: +1 778 266 3600
Phone: +86 159 2997 2924
12. SEVERABILITY
If any provision of this Policy is deemed unenforceable, the remaining provisions shall remain in full force.
13. GOVERNING LAW
This Policy is governed by the laws of Hong Kong, without regard to conflict-of-law principles.
Starti.tv Copyright © 2024 Starti Limited. All Rights Reserved.
