Updated October 4, 2013
Please review the following statement to understand how the information you provide to Starfish through the Services will be treated.
1. Information Starfish Collects
The Starfish Services work in tandem with an existing course management system and/or student information system. Therefore, certain personally identifiable information from these existing systems will be presented within the Starfish Service. This personally identifiable information consists of, but is not limited to, contact information, such as your name, city and state, and e-mail address as well as demographic information such as your age, gender and interests. This information better enables us to provide you with content relevant to your interests and provides us with aggregate data that Starfish uses to improve the Services. We may also ask you for information about your system or how you use Starfish products and services. Please see Section 5, below, for information on how to access or update this information.
Starfish gathers information about all users collectively, such as what areas users visit most frequently and what services users access most often. Starfish automatically logs the users’ domain name, IP addresses, browser type, language and other data which tracks users’ access to the Services. We analyze these logs for sales and marketing purposes as well as system performance monitoring. These logs are analyzed for the aggregate trends they reveal about our customers and how the customers use the Services, not for the behaviors of individual users.
2. Purposes of Data Collection
Starfish requests personal information including email address and telephone number for purposes such as student success, the provision of customer service and support, billing, network management, customer surveys, sales management, support, newsletter subscriptions, user group memberships, event registration and sponsorship, offers of related services, and other exchanges of information.
3. What Starfish Does with the Information It Collects
Starfish may use aggregated personal information to determine the demographic composition of our user base and to distribute statistics and general marketplace information and analysis about Starfish. This aggregate information does not identify specific users.
Certain non-personal information regarding users is recorded by the standard operation of the Internet servers hosting the Services. This information is primarily used to provide users of the Services with an enhanced online experience. Starfish may disclose aggregated user statistics in order to describe the Services to prospective partners, and other third parties, and for other lawful purposes.
Starfish utilizes other companies to provide limited services on its behalf, including but not limited to customer support, Web analytics, coordination of mailings and event management. These companies are permitted to access only the information they require to perform those services. Starfish requires these companies to maintain the confidentiality of any personal information and prohibits them from using the information for any other purpose than the purpose for which it was collected.
4. Users Options: Opt-Out
Users may opt out of receiving future promotional electronic mailings from Starfish by following the unsubscribe procedures indicated in the mailing. Individual end users of Starfish software should contact their educational institution or other organization licensing the software for questions about access to the personal information collected by that institution. Please contact us at the address below if you have other questions about the information you receive from us or the information that we collect from you.
5. Access Your Information
Starfish offers users the ability to correct or change the information collected during registration. Users may change this information at any time and as often as necessary by choosing the “Profile” option or other similar functionality offered in the Services. To access or change your personal information, log in to your account through the Services. For data not available through such an account, please contact the system administrator at your institution or contact Starfish at the address listed below.
All of your personal information is stored on servers at a location designed specifically to ensure that no unauthorized individuals have access to the server or its data.
7. European Union Data Protection
If you reside in the European Union, upon registration you will be indicating your explicit consent that the personal information you have provided may be transferred and stored in countries outside the EU, including the United States. If you fail to provide your consent, you will not be permitted to access the Services for which registration is required. Starfish complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Starfish has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Starfish’s certification, please visit http://www.export.gov/safeharbor/.
In order to comply with the European Union’s Safe Harbor Principles, Starfish commits to the resolution of complaints about your privacy and our collection or use of your personal information. We have committed to resolve any complaints by European Union citizens relating to this policy, which cannot be resolved directly with our company, through the EU Safe Harbor Dispute Resolution Procedure administered by the Council of Better Business Bureaus, Inc.
If you have any questions regarding this policy, please contact:Chris Kottke
Vice President of Finance & Administration
Starfish Retention Solutions, Inc.
1400 Key Boulevard, Suite 1050
Arlington, VA 22209
If you do not receive acknowledgement of your complaint or your complaint is not satisfactorily addressed by Starfish Retention Solutions, Inc., please visit the BBB EU SAFE HARBOR Web site at http://www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
9. Contact Starfish
If you have any questions about this privacy statement, the information that we collect from you, or the Services, please contact us at email@example.com or write to:Starfish Retention Solutions, Inc.
1400 Key Boulevard, Suite 1050
Arlington, VA 22209
In the event that you are concerned about how data you have provided Starfish through the Services has been used, please contact us at the address listed above. Starfish takes all concerns about privacy and use of data very seriously, and shall endeavor to reply to you within two business days to commence its investigation of your concerns.