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PRIVACY POLICY

The Effective Date of this Privacy Policy is October 9, 2017.

This “Privacy Policy” explains how To The Stars Academy of Arts and Science Inc. (collectively “TTSA,” “us” or “we”) collects and protects your personal information.  We collect information from you when you interact with our website, tothestarsacademy.com (together with any mobile services, the “Site”).  By using the Site, you consent to our collection and use of your information as explained in this Privacy Policy and agree to be bound by our Terms of Use.  Please note that if you choose to invest in TTSA’s offering as advertised on this Site, you will be required to agree to separate agreements as part of the investment process, including, but not limited to, new or additional privacy policies or terms of use. 

SECTION 1 – WHAT INFORMATION DO WE COLLECT?

TTSA Collects two types of information from you: a) non-personal information, and b) personally identifiable information. 

Non-Personal Information.  When anyone uses the Site, whether they join our mailing list, click the ‘Invest Now’ button or just browse, we collect “Non-Personal Information,” including without limitation, website pages viewed, clickstream data, presentation and videos viewed, time spent using certain features, demographic data such as server locations, cookies existing on your computer, search criteria used and results, date, time, connections feed and other information that does not specifically identify you.  We collect this information using various technologies, including, but not limited to, cookies and server logs, and JavaScript (see below in Section 8 for more details). 

Personally Identifiable Information.  We also collect information from you when you 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 taxpayer 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 devise 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/

This Privacy Policy does not cover the collection of information by cookies or any other methods by third parties, including our business partners.  We do not control how such third parties collect information about you.

SECTION 2 - WHAT DO WE DO WITH YOUR INFORMATION?

We will use information you provide consistent with this Privacy Policy.  TTSA will use information you provide to use, including Non-Personal Information or Personally Identifiable Information, to better serve you and enhance your experience on our Site, among other things. As such, you consent to our use and disclosure of any information submitted to us via our Site, our contact form, or information collected when you access the Site in any manner, and you acknowledge that you have no expectation of privacy, confidentiality or privilege in such information.

TTSA will use Non-Personal Information and Personally Identifiable Information a) to market our products and services to you, b) to provide services and products 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 or members, 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’ link 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 services.  We may use this information to communicate with you regarding our services or to tell you about the 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 contact us as indicated below.  Note however that if you invest in TTSA, we will send you administrative communications that are reasonably necessary, such as shareholder-related notifications.

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 may also use and disclose Non-Personal Information and Personally Identifiable Information: to investigate and help prevent potentially unlawful activity or activities that threaten the integrity of our Site or network; to protect and defend our rights or property or the rights or property of others; as required by courts or administrative agencies; and in connection with a financing, sale, merger, or reorganization of TTSA’s business or assets.  Any successor in interest to our business would acquire the information we maintain, including Personally Identifiable Information, and may alter the terms of this Privacy Policy.

In the event of a corporate sale, merger, reorganization, dissolution or similar event, Data may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.  We may also share your Data with our affiliates for purpose consistent with this Privacy Policy.

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 – 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:  investorrelations@tothestarsacademy.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.

SECTION 4 – EXCLUSIONS

This Privacy Policy does not apply to any Data collected by TTSA other than Data collected through the Site.  This Privacy Policy shall not apply to any unsolicited information you provide to us through the Site or any other means.  This includes, but is not limited to information posted to any public areas of the website, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”).  All Unsolicited Information shall be deemed to be non-confidential and TTSA shall be free to reproduce, use, disclose, distribute and exploit such Unsolicited Information without limitation or attribution.

SECTION 5 - 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.

Once you click on the “Invest Now” button to make an investment in TTSA, you will be sent to FundAmerica’s platform to complete the transaction.  FundAmerica and its affiliated escrow company, PrimeTrust, have their own privacy policy and terms of use, which can be accessed on their site.  We recommend that you review their privacy policies so you can understand the manner in which your personal information will be handled by these providers. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

SECTION 6 - 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.  Payments are processed through our third-party provider, FundAmerica and its affiliated company PrimeTrust (see above in Section 5). 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 7 – 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. 

SECTION 8 - 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:  investorrelations@tothestarsacademy.com.

SECTION 9 - CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, so please review it frequently.  You can determine if changes have been made by checking the Effective Date above. Changes and clarifications will take effect immediately upon their posting on the Site. If we make material changes to this Privacy Policy, we will notify you here that it has been updated.  Your continued use of our Site following the posting of any changes to this notice means you accept such changes.

SECTION 10 - QUESTIONS AND CONTACT INFORMATION

If you have any questions that this Privacy Policy doesn’t address, please contact us at the information below. If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact our Privacy Compliance Officer at investorrelations@tothestarsinc.com or by mail at:

To The Stars Academy of Arts and Science Inc.
Attn: Privacy Compliance Officer
1051 South Coast Highway 101, Suite B 
Encinitas, California, USA 92024

CALIFORNIA PRIVACY RIGHTS

TTSA is a Delaware public benefit corporation headquartered in Encinitas, California.  DO NOT TRACK Disclosures: Your web browser may allow you to send a ‘do not track’ request with your browsing traffic so you can browse anonymously.  TTSA doesn’t recognize automated browser signals regarding tracking mechanisms, which may include ‘do not track’ instructions. Do Not Track is a standard that is still under development, so TTSA will continue to develop its Privacy Policy in accordance with best business practices. To learn about Do Not Track, please click here.

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 3.

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. 

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