Effective Date: February 10, 2017
The Cloud Security Alliance, Inc. (“CSA” “we” or “us”) abides by the following principles when handling personal information in electronic form:
This Privacy Notice provides detailed information on how CSA puts these principles into practice when collecting, processing, transmitting, or disposing of personal information through its website located at star.watch and the services provided through the Starwatch Site (“Starwatch Service”). (Starwatch Site and Starwatch Service, separately or collectively designated as “Starwatch Platform”). This Privacy Notice also describes the choices that are available to users and visitors of the Starwatch Platform.
"Device" means desktop computer, laptop, tablet, smartphone and the like.
"Personal information" means any information that relates to an identified or identifiable individual.
"Subscriber" means a person or entity who has purchased a Subscription to the Starwatch Service.
"User" means any individual who uses the Starwatch Platform as (a) a subscriber, or (b) an employee, representative or agent of a subscriber.
"Visitor" means any individual who accesses or uses the Starwatch Platform and who is not a user.
"You" means a user or visitor.
Please read this Privacy Notice before you visit the Starwatch Site or use the Starwatch Service or provide personal information on or through the Starwatch Platform. When you provide your Personal Information to register to use the Starwatch Platform, you signify that you agree with all terms of this Privacy Notice. If you disagree with any part of this Privacy Notice, please do not use the Starwatch Site or Starwatch Service.
This Privacy Notice applies solely to personal information that CSA collects through the Starwatch Platform or through electronic communications that it receives at the addresses indicated on the section “How to Contact Us.”
It does not apply to the websites of third parties to which the Starwatch Platform may link. CSA does not endorse, and is not responsible for the content of these websites, their policies or practices, or any product or service that they may offer.
Any activity you perform on these third-party websites, including, but not limited to, the provision of personal information will be subject to the privacy policies and other terms and conditions of these third parties. We recommend that you review these third-party terms before providing any personal information to them.
The Starwatch Platform is designed to allow you to browse through it as a visitor without providing any contact information. However, certain areas of the Starwatch Platform may require, or allow for the voluntary submission of, personal information.
When you use or interact with the Starwatch Platform, or click on a link that directs the user to our Starwatch Platform, your browser automatically provides, and we automatically collect and store, certain information about your device and activities. This includes, for example:
When you interact with the Starwatch Platform to register as a user, to request information, or otherwise, you may submit certain information that is directly tied to your identity, including:
Subscribers provide payment card or bank account information used for the payment of a Subscription Fee for the StarWatch license. This information is collected and processed directly by our payment processor. We have no access to such information.
When we send a communication to a user, or when the user accesses, responds to, or declines to open a communication from us, or when a user completes a form to subscribe to the Starwatch Service, or when a user contacts us, we automatically collect and store certain information about the user, the user’s device, and the user’s activities, such as:
When a user is signed in to the user’s account, the user’s activities on the Starwatch Platform are tracked and are associated with the user’s account.
The Starwatch Platform is not directed to children. CSA does not knowingly collect personal information from children. If you are younger than thirteen (13) years old, please do not provide any personal information while using the Starwatch Platform.
We (and our service providers) collect information in a variety of ways, such as through the methods identified below:
CSA uses the information that it has collected or received from visitors and users as follows:
Starwatch Service - We use the information that you provide to subscribe to or use the Starwatch Service to provide each user with access to the Starwatch Platform and to interact with the user about the Starwatch Platform.
Fulfillment of requests - We record and use your personal information to respond to your inquiries, and send you the information or documents that you request.
Administrative communications - We may send you important administrative information regarding the Starwatch Platform, for example, notices that the license to use the Starwatch Service is to be renewed.
Other communications - We may use your personal information to send you mailings relating to CSA activities or events that we think may be of interest to you (for example training), in accordance with applicable law. You may opt-out from receiving these communications as indicated in the communication itself or in section “Your Choices” below.
Internal business purposes - We may use the collected information for internal business purposes, such as for data analysis, audits, fraud monitoring and prevention, or to track usage.
Statistical analysis - We use aggregated data to develop statistics about Starwatch Platform usage (which do not identify a specific user), such as the number of users who have visited certain pages or used a certain feature or functionality, or how long users spend on a particular page. We use this information for research and development purposes to understand how our users interact with the Starwatch Platform, to develop features that appear to better meet users’ needs, or to enhance, improve or modify our Starwatch Platform.
Starwatch service providers - Entities that provide services to us, such as communications, database management, hosting, or mailing may have access to personal information when they provide service to us related to the operation of the Starwatch Site or Starwatch Service.
Business transfers - We may transfer personal information to third parties as part of the sale, transfer or disposition of CSA’s assets.
Law enforcement; compliance - We may use or disclose personal information to any third party (a) if we believe that we are required to do so by law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from governmental or public authorities; (d) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our Starwatch Platform or network; (e) to enforce our Terms of Starwatch Service; (f) to protect our operations or those of any of our affiliates; or (g) to protect the rights, privacy, safety, property, business, or safety of CSA, its employees, members, Starwatch Platform subscribers, users, or visitors, or the public; and (h) to allow us to pursue available remedies or limit the damages that we may sustain.
California privacy rights - CSA does not disclose any personal information to third parties for their direct marketing purposes. Should this practice change, we will allow all users to opt-out from such disclosures.
The Starwatch Platform provides the ability to make online payments for the Subscription Fee. All credit card information and other customer details that are required to process credit card payments are collected directly by our payment processing service provider (“BrainTree Payments,” a PayPal service), in accordance with its data handling practices (see https://www.paypal.com/us/webapps/mpp/ua/privacy-full). CSA is not responsible for the handling of this data by BrainTree Payments.
Marketing Communications - We may from time to time send you mailings relating to events that we think may be of interest to you. If you prefer not to receive marketing mailings from us, you may unsubscribe from these mailings by following the unsubscribe instructions in these messages or by contacting us as indicated in the section “How to Contact CSA about STARWatch.”
Cookies - Cookies enable a website to store information on the user’s device and then later read it again. A cookie may contain a unique identifier of a user’s device and browser. Session cookies are erased when a user closes his/her browser. Persistent cookies are stored for a longer period. When a user returns, and uses the device and browser on which a persistent cookie is stored, the cookie allows us to recognize the device and browser that were used in a prior session.
We use “session” cookies and “persistent” cookies on the Starwatch Platform. These cookies are strictly necessary for the provision of the Starwatch Service.
These cookies originate from the following sources:
However, please note that if certain cookies are blocked, some features of the Starwatch Platform may not operate as intended.
If you have questions about cookies and other technologies, please visit http://www.allaboutcookies.org/ or http://networkadvertising.org/ or contact us as indicated in “How to contact CSA about STARWatch.”
We will retain personal information about you for so long as necessary to fulfill the purposes outlined in this Notice unless a longer retention period is required by law and/or regulations or our data retention policy.
CSA seeks to adopt commercially reasonable security measures consistent with industry practice to protect personal information under its control against loss, misuse, and alteration. However, we cannot guarantee the security of our servers, the means by which personal information is transmitted between your device and our servers, or any personal information that we receive through or in connection with the Starwatch Platform. If you believe that your connection to our Starwatch Platform is no longer secure, please notify us as soon as possible.
We attempt to strike a reasonable balance between security and convenience. Emails are usually sent as unencrypted text. If misrouted or intercepted, an unencrypted email could be read easily. If there is a matter that requires high security or confidentiality, please do not send the related information through email. Contact us first about that matter without providing confidential details, and we will decide with you on a more secure means of communicating.
We ask that you do not send us, and you do not disclose to us, any Social Security numbers, credit card or other payment card information, driver’s license, passport or similar information, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership, or any other sensitive information, on or through the Starwatch Services or otherwise to us or our employees or representatives.
By using the Starwatch Platform, you acknowledge and agree that (a) the personal information that you provide to us or that we collect through our Starwatch Platform may be stored and processed in the United States or abroad, which may provide a different level of data protection than that which is provided by your country of residence; and (b) we may, at our discretion, store and process such data in the United States or other countries.
The Starwatch Service is operated by us from the United States, is subject to US laws, and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.
We may limit access to the Starwatch Platform to any person, geographic area, or jurisdiction that we choose, in our sole discretion.
If you have any question, comment or complaint about this Privacy Notice, or the use, management or disclosure of personal information collected on or through our Starwatch Platform, please contact us as set forth in the section “How to contact CSA about STARWatch.”
Do Not Track - California law requires that website operators that collect personal information about California residents disclose how they respond to a “Do Not Track” signal. However, because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to Do Not Track signals that we might receive, if any, from browsers. We will continue to work with the online industry to define a common understanding of how to treat Do Not Track signals. You can also contact us as indicated in “How to contact CSA about STARWatch” for more information.
Our website contains Google Analytics cookies. For more information see the Section “Cookies and Other Technologies.”
We do not share with these third parties any information that would readily identify you, such as an email address, but these third parties may have access to information about your device, such as an IP or MAC address. We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests.
We update this Privacy Notice from time to time. If the changes are significant, we will post a prominent notice on the Starwatch Platform for a reasonable time to notify you of these changes. Unless, and until, you object in writing, by contacting us as indicated in “How to contact CSA about STARWatch,” all changes will apply to the existing information about you that CSA already holds, and the personal information collected from the effective date of the revised Privacy Notice.
We encourage you to periodically review this webpage to ensure that you are aware of the current Privacy Notice. Your use of our Starwatch Platform following the effective date of any revision will constitute your acceptance of the terms of the updated Privacy Notice.
If you have any questions, comments, or complaints regarding this Privacy Notice, or our privacy, security or data protection practices, please contact us by email at [email protected] or by mail at 2212 Queen Anne Avenue N, Seattle, WA 98109.