Privacy Policy

Starthub.org respects your privacy and is committed to protecting it. This Privacy Policy describes the policies and procedures that govern the collection, use and disclosure of your personal information when you use Starthub.org. We will not use or share your confidential information with anyone except as described in this Privacy Policy. This Privacy Policy does not apply to information we collect from other sources. Information that you submit to Starthub.org may be publicly available and disclosed. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in Starthub.org’s Terms of Service.

Scope of this Privacy Policy

This Privacy Policy applies only to your relationship with “the Covered Parties” as defined in the Starthub.org Terms of Service. It does not apply to the interactions that you have with any other individual, entity, investor or other group on or through Starthub.org.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you use Starthub.org, and our practices for collecting, using, maintaining, protecting and disclosing that information. This Privacy Policy applies to information we collect:

  • On Starthub.org;
  • In e-mail, text and other electronic messages between you and Starthub.org, on the site or otherwise; and
  • When you interact with our links and applications on third-party websites and services if they include a link to this Privacy Policy.

It does not apply to information collected by:

  • Us offline or through any other means; or
  • Any third party (including our partners, affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on Starthub.org.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use Starthub.org. By accessing or using Starthub.org, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of Starthub.org after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

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Definitions

This Privacy Policy is a part of the Terms of Service for Starthub.org. The terms “Covered Parties,” “Starthub.org,” “Gust,” and “Starthub.org Content,” as well as all other capitalized terms not otherwise defined in the Privacy Policy have the same meaning set forth in the Starthub.org Terms of Service.

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What is "Personal Data"?

"Personal data" is any data that (1) is recorded in any form, (2) is about or pertains to a specific individual and (3) can be linked to that individual. For example, and without limitation, your first and last names, address, email address, telephone number, and other contact information are "personal data." Personal data does not include website data, aggregated data,  uploaded documents, or profile information about a commercial business or not-for-profit organization.

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What kind of Personal Data is Collected?

We collect personal data at different stages of your use of Starthub.org.

  • When you visit Starthub.org: If you visit Starthub.org or use an interface which interacts with Starthub.org, we collect your IP address, the location of your Internet Service Provider, the type and version of Internet browser that you are using, and the website from which you came. We also collect information regarding your site usage, such as the time spent on a page and the number of pages you viewed.

  • When you interact with Starthub.org: We also collect personal data that you provide when you interact with Starthub.org such as, for example, by sending a message or uploading documents, or when exchanging correspondence with us such as through support emails.

  • When you use submit User Content:

    • If you submit content as an Investor, you may record in your profile within your Organization’s information about yourself, such as your contact information, picture, biography, experience, or other groups to which you belong.  While the Organization’s name will be name public, no investor information will be publicly disclosed.

    • If you are a Startup, you may record information about yourself, your company, and your company’s management team. You may also include a video recording or picture.  All information you put onto Starthub.org is considered to be intended for publication and may published on Starthub.org and other websites, except the submitter’s name and email address, as well as the email addresses of any management team members included in the submitted profile.

If you provide any information about or personal data of a third party (such as a person's name or photograph), you are representing to the Covered Parties that you have all necessary authority and/or have obtained all necessary consents from such individual to enable the Covered Parties to collect, use and disclose his or her personal data as set forth in this Privacy Policy.  If we receive a written complaint or direction from the person, we will take down his or her information and notify you that we have done so.

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How is Personal Data Collected?

We collect personal data directly from you when you provide it through your use of Starthub.org, such as in emails or when you fill out forms that are displayed on Starthub.org. We also use cookies that are sent to your computer, or action tags that are placed on Starthub.org. For additional explanation on cookies and action tags, see Cookies and Action Tags.

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For what Purpose will my Personal Data be Used?

The Covered Parties use your personal data to respond to requests that you make of us, and to contact you and to provide you with information that we believe may be of interest to you. We may also use your name and contact information to make queries to social networking and other sites, such as LinkedIn, for a variety of purposes, including, but not limited to, verifying your identity.

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With Whom may the Covered Parties Share Personal Data?

Under certain business or legal conditions, Gust may have to disclose your personal data to others as follows:

  • Within the Gust Family: Gust may now or in the future have a parent, subsidiary or related company or companies within the Gust family of companies.  Gust has the right to share all personal data with all such affiliated companies.

  • Service Providers: Gust may engage other companies and individuals to perform necessary business functions on behalf of Gust (e.g. outside contractors or service providers). If it is necessary to perform these functions, these companies or individuals may have access to personal data of our users. These service providers have agreed not to use the personal data for any other purpose other than providing the required services.

  • Legally Required Disclosure: Under certain circumstances, disclosure of your personal data may be required by law. Gust may disclose your personal data (1) if, in its own best judgment, it is required to do so in order to comply with a facially valid judicial or governmental subpoena, warrant, or other order, or (2) to a government institution that has asserted its lawful authority to obtain the information, or (3) in connection with the exercise or defense of its rights.

  • Change of Ownership: If ownership of Gust changes as a result of a merger, acquisition, or transfer to another company, your personal data may be transferred to the successor entity. If such transfer takes place, you will be notified of any material changes to the Privacy Policy and provided with the ability to opt-out of the transfer of your personal data to the successor entity.

  • With Partners: Gust may share the organization’s contact information provided by you when you submit User Content. You may opt-out of communications from such Partners by unsubscribing at Starthub.org or the Partner websites or by emailing support@Starthub.org.

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Can I Access or Change my Personal Data?

All users of Starthub.org can access the personal data that Gust holds about them and can see it listed in their profiles, by logging into Gust.com with the login credentials provided when the data was submitted through either Starthub.org or Gust.com. They can correct, amend, or delete this data at their convenience.

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Can I have my Personal Data Deleted?

You can contact support@Starthub.org to delete any personal data that is recorded in the profile that you create for yourself as an investor or for your company, or as an entrepreneur.

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What is Aggregated Data, and how is it used?

Data aggregation is a process in which information is gathered and expressed in a summary form for purposes such as statistical analysis, in order to obtain information about a particular group based on specific variables. Data used for aggregation purposes are collected in a form that removes all identifiers, and may be combined with other data for which all identifiers have also been removed. Aggregated data may be packaged and licensed to third parties such as governments, economic development agencies and financial institutions. Examples of aggregated data may include:

  • Data about the startup industry in Boston, such as number of companies , number of times a job posting has been viewed, number of times investors have requested information about a company, and so forth.

  • Data about industries and geographies related to companies seeking investors and those successfully obtaining investments.

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What is Website Data, and how is it used?

Website data is aggregated data about the overall traffic to, and usage of Starthub.org. Examples include the number of visitors to the website and the number of content submissions. Gust may extract and use website data for internal purposes, in order to analyze the performance of Starthub.org and applications. For example, we may use these data for traffic analysis and business decision making, in order to determine how we can improve our site or its functionalities.  Gust may share this website data with partners, in order to analyze the performance of Starthub.org and the content thereon.

The statistics generated in this manner contain no personal data and cannot be used to gather any information about individual visitors to the site.

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Cookies and Action Tags?

  • Cookies Starthub.org uses 'cookies.' A cookie is a small amount of data sent to a user's web browser from a web server, which is then stored on the user's hard drive. Cookies are used to make site navigation easier, and can help recognize a returning visitor. Starthub.org’s cookies do not generate any personal data, do not read personal data from your computer, and are not tied to any personal data. Most browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies, or to prompt you before accepting cookies from the sites that you visit. If you decide not to accept our cookies, some or all features of the site may not be available because navigation on the site is facilitated by cookies. You can delete cookies from your computer at any time. You can learn more about cookies by visiting: www.allaboutcookies.org or www.networkadvertising.org.

  • Action Tags Starthub.org uses action tags. An action tag is a small piece of code that is placed on a webpage or in an email in order to track the pages viewed or the messages opened, the date and time when someone visited our website, the website from which the visitor came, the type of browser used, and the domain name and address of the user's Internet Service Provider. Action tags allow us to better understand how users and visitors use our site or browse through our pages, so that we can improve access to and navigation through the site, add or modify pages, according to our user's patterns. Action tags cannot be removed or deleted by our users, because they are part of the programming of a webpage.

  • Log Files Log file information is automatically reported by your browser each time you access a web page. When you use Starthub.org, our servers automatically record certain information that your web browser sends out whenever you visit any website. These server logs may include information such as your web request, ip address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other similar information.

  • Web Beacons When you use Starthub.org, we may employ web beacons, which are used to track the online usage patterns of Users anonymously. No personally identifiable information from your account is collected using these beacons. In addition, we may also use web beacons in HTML-based emails sent to Users to track which emails are opened by recipients.

  • Do Not Track Signals Starthub.org does not track or use Do Not Track signals

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What Security Measures are in Place to Protect my Personal Data?

Gust uses physical, technical, and administrative procedures in order to safeguard and protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, while we do our best to implement reasonable security measures, we do not guarantee that our safeguards will always work.

Gust uses industry-standard technological means to protect your personal data while in transit through the Internet. We use encryption and a comprehensive authentication protocol to provide reasonable security. However, please remember that no security system on the Internet is perfect.

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What about Uploaded Documents?

Documents that are uploaded to Starthub.org for sharing are stored at a third party data-storage service. All uploads and downloads are transmitted through the web between users and the data storage service using the same encryption techniques as those that are used with personal data. However, uploaded documents are neither stored redundantly, nor backed up. Therefore, we recommend that users keep back-up copies of their documents if they upload them to Starthub.org.

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When will StartHub.org, Gust, or anyone else Contact Me?

Starthub.org will communicate with you in response to your inquiries regarding content partnerships, website support, business development, or existing content on Starthub.org. We will contact you by phone or by email, according to your preference. Starthub.org may also send you an email in order to notify you of new services or features, or updates to the Privacy Policy or Terms of Service. If you proactively opt-in to receive periodic news or digests from the site, Starthub.org will also send you such news or digest emails until such time as you proactively opt-out.

Gust will send you service-related emails if it becomes necessary to do so. Gust may also send you an email in order to notify you of new services or features, or updates to our Privacy Policy, Terms of Service, or other agreement(s) that you have with Gust.

The public information you provide in company or organization profiles, including contact information for the organization such as a mailing or email address, may also be shared with a limited number of partners/sponsors of Starthub.org, the City of Boston, Venture Cafe, and IBM. All partners will safeguard such information subject to the terms of their own Privacy Policies, and you may opt out of sharing any information with any such partners by emailing support@Starthub.org, or through other means provided on the Starthub.org web site.

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Links to Other Websites

Starthub.org may provide links to other websites. We are not responsible for the privacy practices or content of these sites. In order to safeguard your privacy, please review the privacy policies of any sites that you may visit before providing any personal data to these third party sites.

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Limitation of Liability

The Covered Parties exercise reasonable efforts to safeguard the security and confidentiality of your personal data; however, transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure. The Covered Parties will not be liable for unauthorized disclosure of personal data that occurs through no fault of the Covered Parties including, but not limited to, errors in transmission, access to your account by anyone uses your user ID and password, your failure to comply with your security obligations, and the unauthorized acts of the Covered Parties’ employees.

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Minors

Gust does not provide products or services for individuals under the age of 18. We do not intentionally collect nor maintain information from users actually known to be under the age of 18, and we will not use that information if we learn that it has been provided by someone under 18.

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Choice

If at any time Gust wishes to disclose, or use your personal data in a way, or for a purpose other than as described in this Privacy Policy, Gust will give you the opportunity to choose (opt out) whether your personal data (1) may be disclosed to a third party and (2) may be used for a purpose other than the purposes that are set forth in this Privacy Policy.

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California Privacy Rights

California Civil Code Section § 1798.83 permits users of Starthub.org that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@Starthub.org or write us at: Starthub.org, c/o Gust, 158 West 29th Street, New York, NY 10001-5300 USA.

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Changes to the Privacy Policy

From time to time, this Privacy Policy may be updated in order to reflect changes in practices. Whenever such changes are made, an updated Privacy Policy will be posted on Starthub.org and users who have shared their contact information may be emailed. All changes will apply to the personal data that are already collected, and to personal data that are collected after the effective date of the revised Privacy Policy, and will become effective when posted. You will have the right to delete your profile at any time.

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Dispute Resolution

If you have any concerns or claims with respect to our Privacy Policy, please contact us at support@Starthub.org. We will investigate and attempt to resolve any complaints and disputes regarding our use and disclosure of personal data. If the complaint or dispute cannot be resolved through our internal process, and/or we do not adequately respond to your question, please contact the New York office of the American Arbitration Association, which will serve as a liaison with Gust to resolve your concerns.

If arbitration is necessary, it will be conducted by telephone and email, and if it must be done in person, it will be conducted in New York, NY. The arbitration will be conducted by one arbitrator member of the American Arbitration Association, and under the rules of commercial arbitration of the American Arbitration Association. Both parties will bear equally the cost of arbitration (exclusive of legal fees and expenses). All decisions of the arbitrator(s) will be final and binding on both parties and enforceable in any court of competent jurisdiction.

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Contacting StartHub.org

Starthub.org is operated by Gust. Our mailing address is 158 West 29th Street, New York, NY 10001-5300, USA.

If you have any questions about this Privacy Policy, or believe that its terms have not been complied with, please email us at:support@Starthub.org

Effective Date: October 15, 2015.