SECTION 1 – WHAT INFORMATION DO WE COLLECT?
TTSA collects two types of information from you: a) non-personal information, and b) personally identifiable information.
Personally Identifiable Information. We also collect information from you when you subscribe or send us an email through the Site, which may enable us to identify you personally, with information such as your email address, name, phone number, state of residence, birthday, age, Social Security number, and/or tax identification number, investment amount, assets and income, information obtained from others, physical address such as home or business address, or internet protocol (“IP”) address, which may also be contained on server logs, or other information you provide to the Site, such as answers to questionnaires or surveys, or responses filled in on blank forms made available on the Site (“Personally Identifiable Information” and together with the Non-Personal Information, the “Data”). We may also collect and store information, which could include Non-Personal Information or Personally Identifiable Information, locally on your computer or device using mechanisms such as browser web storage or application data caches.
We use analytics programs and service providers, such as Google Analytics, which can use first party cookies to report on your interactions with the Site. Such firms collect information including, but not limited to, the time of each of your visits to the Site, whether you have visited the Site before, what website or advertisement referred you to the Site, and what pages you viewed on the Site. For more information about how data is collected and processed in connection with the Google Analytics service, visit: https://www.google.com/policies/privacy/partners/
For EU Residents Only: If you are a resident of the European Union, we will only collect and share information via cookies and other online tracking tools if you agree to its collection.
SECTION 2 - WHAT DO WE DO WITH YOUR INFORMATION?
TTSA will use Non-Personal Information and Personally Identifiable Information a) to market our products and services to you, b) to provide products and services requested by you, c) to enable our business partners to provide and assist us in the marketing, operation, troubleshooting and analysis of our Site and other services, d) to meet any regulatory requirements for the offer or sale of securities required by law, rules or regulations to our affiliates, e) to engage in any other lawful activities we believe are consistent with the foregoing, and f) to protect against legal liability. We may provide any of these services through third parties, which may necessitate sharing Non-Personal Information and Personally Identifiable Information with them.
If you provide Data for a certain reason, we may use the Data in connection with the reason for which it was provided. For instance, if you contact us by email or through our ‘Contact Us’ form on the Site, we will use the Data you provide to answer your question or resolve your problem. We may also use your Data and other Personally Non-Identifiable information collected through our Site to help us improve the content and functionality of our Site, to better understand our users and to improve our products and services. We may use this information to communicate with you or to tell you about the products and services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing list, please select ‘unsubscribe’ from an email mailing or contact us at email@example.com. Note however that if you invest in TTSA, we will send you administrative communications that are reasonably necessary, such as shareholder-related notifications, and you cannot opt out of these communications.
We have access to the Personally Identifiable Information you provide to our third-party service provider FundAmerica and its affiliated escrow company PrimeTrust. We use this information to complete investor verifications, process your investment transaction and initiate/maintain our shareholder records. We are legally required to obtain and in some cases maintain sensitive Personally Identifiable Information, which we securely store and strictly limit access (see Section 7).
TTSA employs or contracts with third parties, companies, or individuals to perform certain functions or services on its behalf. Examples of these services from such third parties, companies, or individuals, may include ID verification, accreditation/financial/credit verification, electronic document signing, payment storing and processing, share management, sending postal mail and email, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service. As such, these third parties, companies, or individuals may have access to your information, including Non-Personal Information or Personally Identifiable Information, as needed to perform their functions or services, and may not use it for other purposes.
We do not and will not sell any of your information, including Non-Personal Information or Personally Identifiable Information, to any third party for purposes of advertising, soliciting or telemarketing.
SECTION 3 - UPDATING YOUR INFORMATION
If any of your information has changed (name, address, telephone number, email address), please contact us at firstname.lastname@example.org. To protect your privacy, we will need to validate your identity before we update your information.
SECTION 4 – OPT-OUT POLICY
TTSA may at times send you email communications with marketing or promotional materials. If you prefer not to receive such marketing or promotional emails from us, you may unsubscribe completely by clicking on the unsubscribe link in the email or emailing us at: email@example.com. Please note that opt-out requests make take up to ten (10) business days to process. Please also note that at times we may need to send you email communications that are transactional in nature such as shareholder notifications or payment confirmations, which are communications you will not be able to opt out of.
We are not responsible for removing your Personally Identifiable Information from the lists of any third party who has previously been provided your information in accordance with this notice.
For EU Residents Only: If you are a resident of the European Union and you would like to take advantage of any of your rights under the EU General Data Protection Regulation (GDPR), such as your Right to Erasure (aka Right to be Forgotten) please contact us at firstname.lastname@example.org and we will be happy to assist you. For additional information related to EU residents, please see the EU Residents section of this policy.
SECTION 5 - EXCLUSIONS
SECTION 6 - THIRD-PARTY SERVICES
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
The Site contains links to other websites and services not maintained by TTSA. In addition, other websites and services may also reference or link to the Site. We encourage you to be aware when you enter or leave our website, or surf the Internet, and to read the privacy statements of each website and service that you visit. We do not endorse, screen, or approve, and are not responsible for the privacy practices or the content of other websites or services.
SECTION 7 - SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed, such as restricting access and data encryption. ACH, check and wire payments are processed through our third-party provider, FundAmerica and its affiliated company PrimeTrust (see above in Section 5) and credit card payments through third-party provider Vantiv. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
It is important for you to protect against unauthorized access to your password and to your computer. Be sure to log off when finished using a shared computer.
SECTION 8 – COOKIES, SERVER LOGS
“Cookies” are pieces of information that may be placed on your computer by a website for the purpose of facilitating and enhancing your communication and interaction with that website. “Server Logs” can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server.
For EU Residents Only: If you are a European Union resident, a banner will appear allowing you the option to consent before proceeding to use our website.
SECTION 9 - AGE OF CONSENT
Our Site is not intended for use by children, especially those under thirteen (13) years of age. No one under age 13 is allowed to use the Site, provide any personal information or receive our email distributions. We do not knowingly solicit or collect Personally Identifiable Information from children or teenagers under the age of 13. If you believe that a minor has disclosed Personally Identifiable Information to us, please report this to us immediately by emailing: email@example.com.
SECTION 11 - QUESTIONS AND CONTACT INFORMATION
To The Stars Academy of Arts and Science Inc.
Attn: Privacy Compliance Officer
315 South Coast Highway 101, Suite U38
Encinitas, California, USA 92024
CALIFORNIA PRIVACY RIGHTS
Residents of the State of California have the right to request certain details about how their information was shared with third parties during the preceding year for direct marketing purposes from companies that conduct business in California. Alternately, a company can comply with the law by providing clear opt-out capability to users. TTSA has elected to comply with the law by allowing California resident to opt-out of having their information shared with third parties for direct marketing purposes. To opt-out, please follow the process described above in Section 4.
Keep in mind if you opt-in to the Site by using a different email address, you may still receive materials from us at that different email address.
EUROPEAN UNION RESIDENTS
- We will use the personally identifiable information you provide us only as necessary to fulfill the purpose (e.g. verifying your investment, sending shareholder notices, responding to questions).
- We will only collect your information from non-essential cookies if you consent to that use.
- We will use the information you provide to us, such as the information you provide when investing, submitting a question, posting a comment or for our own marketing purposes if you consent to that use.
- If you wish to take advantage of any of your rights under the European Union Data Protection Regulation (GDPR), such as the Right to Erasure (aka Right to be Forgotten) or Portability, please contact us at firstname.lastname@example.org and we will be happy to assist you.
- If you feel our customer service department has not appropriately responded to your request pursuant to the GDPR, you may contact our Data Protection Officer directly. Please send all correspondence to our Privacy Compliance Officer (see Section 11 above).