Last updated: October 06, 2020
information when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection
Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The
following definitions shall have the same meaning regardless of whether they appear in singular or in
Collecting and Using Your Personal Data
Types of Data Collected
Account means a unique account created for You to access our Service or parts of
Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the
Company as the legal entity that collects Consumers’ personal information and determines the purposes
and means of the processing of Consumers’ personal information, or on behalf of which such information
is collected and that alone, or jointly with others, determines the purposes and means of the processing
of consumers’ personal information, that does business in the State of California.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this
Agreement) refers to Starling Growth Advisory, 100 Park Ave. 16th Floor, New York New York.
For the purpose of the GDPR, the Company is the Data Controller.
Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a
natural person who is a California resident. A resident, as defined in the law, includes (1) every
individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual
who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Cookies are small files that are placed on Your computer, mobile device or any
other device by a website, containing the details of Your browsing history on that website among its
Country refers to: New York, United States
Data Controller, for the purposes of the GDPR (General Data Protection Regulation),
refers to the Company as the legal person which alone or jointly with others determines the purposes and
means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a
cellphone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatory
authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop
and implement a mechanism for allowing internet users to control the tracking of their online activities
Personal Data is any information that relates to an identified or identifiable
For the purposes for GDPR, Personal Data means any information relating to You such as a name, an
identification number, location data, online identifier or to one or more factors specific to the
physical, physiological, genetic, mental, economic, cultural or social identity.
For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes
or is capable of being associated with, or could reasonably be linked, directly or indirectly, with
Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling,
renting, releasing, disclosing, disseminating, making available, transferring, or otherwise
communicating orally, in writing, or by electronic or other means, a Consumer’s Personal information to
another business or a third party for monetary or other valuable consideration.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on
behalf of the Company. It refers to third-party companies or individuals employed by the Company to
facilitate the Service, to provide the Service on behalf of the Company, to perform services related to
the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR,
Service Providers are considered Data Processors.
Third-party Social Media Service refers to any website or any social network
website through which a User can log in or create an account to use the Service.
Usage Data refers to data collected automatically, either generated by the use of
the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Pietential, accessible from www.pietential.com
You means the individual accessing or using the Service, or the company, or other
legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the
User as you are the individual using the Service.
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can
be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser
type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent
on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically,
including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address
of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device
identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the
Service by or through a mobile device.
Tracking Technologies and Cookies
information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to
improve and analyze Our Service.
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You
do not accept Cookies, You may not be able to use some parts of our Service.
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile
device when You go offline, while Session Cookies are deleted as soon as You close your web browser. Learn more
about cookies: All About Cookies
We use both session and persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These Cookies are essential to provide You with services available through the Website and to
enable You to use some of its features. They help to authenticate users and prevent fraudulent use of
user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We
only use these Cookies to provide You with those services.
Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
Type: Persistent Cookies
Administered by: Us
Purpose: These Cookies allow us to remember choices You make when You use the Website, such as
remembering your login details or language preference. The purpose of these Cookies is to provide You
with a more personal experience and to avoid You having to re-enter your preferences every time You use
For more information about the cookies we use and your choices regarding cookies, please visit our Cookies
Use of Your Personal Data
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The
Personal Data You provide can give You access to different functionalities of the Service that are
available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of
the purchase contract for the products, items or services You have purchased or of any other contract
with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent
forms of electronic communication, such as a mobile application’s push notifications regarding updates
or informative communications related to the functionalities, products or contracted services, including
the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other
goods, services and events which we offer that are similar to those that you have already purchased or
enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
We may share your personal information in the following situations:
Retention of Your Personal Data
With Service Providers: We may share Your personal information with Service
Providers to monitor and analyze the use of our Service, to contact You.
For Business transfers: We may share or transfer Your personal information in
connection with, or during negotiations of, any merger, sale of Company assets, financing, or
acquisition of all or a portion of our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case
any other subsidiaries, joint venture partners or other companies that We control or that are under
common control with Us.
With Business partners: We may share Your information with Our business partners
to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the
public areas with other users, such information may be viewed by all users and may be publicly
distributed outside. If You interact with other users or register through a Third-Party Social Media
Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and
description of Your activity. Similarly, other users will be able to view descriptions of Your activity,
communicate with You and view Your profile.
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this
obligations (for example, if we are required to retain your data to comply with applicable laws), resolve
disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a
shorter period of time, except when this data is used to strengthen the security or to improve the functionality
of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company’s operating offices and in any other
places where the parties involved in the processing are located. It means that this information may be
transferred to — and maintained on — computers located outside of Your state, province, country or other
governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in
a country unless there are adequate controls in place including the security of Your data and other personal
Disclosure of Your Personal Data
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We
will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by
law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Security of Your Personal Data
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability
The security of Your Personal Data is important to Us, but remember that no method of transmission over the
Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means
to protect Your Personal Data, We cannot guarantee its absolute security.
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
Consent: You have given Your consent for processing Personal Data for one or more
Performance of a contract: Provision of Personal Data is necessary for the
performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a
legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your
vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried
out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests: Processing Personal Data is necessary for the purposes of
the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing,
and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a
requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise
Exercising of Your GDPR Data Protection Rights
Request access to Your Personal Data. The right to access, update or delete the
information We have on You. Whenever made possible, you can access, update or request deletion of Your
Personal Data directly within Your account settings section. If you are unable to perform these actions
yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data
We hold about You.
Request correction of the Personal Data that We hold about You. You have the right
to to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying
on a legitimate interest as the legal basis for Our processing and there is something about Your
particular situation, which makes You want to object to our processing of Your Personal Data on this
ground. You also have the right to object where We are processing Your Personal Data for direct
Request erasure of Your Personal Data. You have the right to ask Us to delete or
remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a
third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format.
Please note that this right only applies to automated information which You initially provided consent
for Us to use or where We used the information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your
Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain
specific functionalities of the Service.
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note
that we may ask You to verify Your identity before responding to such requests. If You make a request, We will
try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal
Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data
protection authority in the EEA.
Your Rights under the CCPA
Exercising Your CCPA Data Protection Rights
The right to notice. You must be properly notified which categories of Personal
Data are being collected and the purposes for which the Personal Data is being used.
The right to access / the right to request. The CCPA permits You to request and
obtain from the Company information regarding the disclosure of Your Personal Data that has been
collected in the past 12 months by the Company or its subsidiaries to a third-party for the third
party’s direct marketing purposes.
The right to say no to the sale of Personal Data. You also have the right to ask
the Company not to sell Your Personal Data to third parties. You can submit such a request by visiting
our “Do Not Sell My Personal Information” section or web page.
The right to know about Your Personal Data. You have the right to request and
obtain from the Company information regarding the disclosure of the following:
The categories of Personal Data collected
The sources from which the Personal Data was collected
The business or commercial purpose for collecting or selling the Personal Data
Categories of third parties with whom We share Personal Data
The specific pieces of Personal Data we collected about You
The right to delete Personal Data. You also have the right to request the deletion
of Your Personal Data that have been collected in the past 12 months.
The right not to be discriminated against. You have the right not to be
discriminated against for exercising any of Your Consumer’s rights, including by:
Denying goods or services to You
Charging different prices or rates for goods or services, including the use of discounts or
other benefits or imposing penalties
Providing a different level or quality of goods or services to You
Suggesting that You will receive a different price or rate for goods or services or a different
level or quality of goods or services.
In order to exercise any of Your rights under the CCPA, and if you are a California resident, You can email or
call us or visit our “Do Not Sell My Personal Information” section or web page.
The Company will disclose and deliver the required information free of charge within 45 days of receiving Your
verifiable request. The time period to provide the required information may be extended once by an additional 45
days when reasonable necessary and with prior notice.
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner with (for example, our
advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA
If you wish to opt out of the use of your personal information for interest-based advertising purposes and these
potential sales as defined under CCPA law, you may do so by following the instructions below.
Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that
You can opt out of receiving ads that are personalized as served by our Service Providers by following our
instructions presented on the Service:
From Our “Cookie Consent” notice banner
Or from Our “CCPA Opt-out” notice banner
Or from Our “Do Not Sell My Personal Information” notice banner
Or from Our “Do Not Sell My Personal Information” link
The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change
browsers or delete the cookies saved by your browser, you will need to opt out again.
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order
to serve you ads that are targeted to your interests:
“Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
“Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from Your mobile device by changing the preferences on
your mobile device.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third party websites do keep track of Your browsing activities. If You are visiting such websites,
You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can
enable or disable DNT by visiting the preferences or settings page of Your web browser.
The Service may contain content appropriate for children under the age of 13. As a parent, you should know that
through the Service children under the age of 13 may participate in activities that involve the collection or
use of personal information. We use reasonable efforts to ensure that before we collect any personal information
from a child, the child’s parent receives notice of and consents to our personal information practices.
We also may limit how We collect, use, and store some of the information of Users between 13 and 18 years old.
In some cases, this means We will be unable to provide certain functionality of the Service to these Users. If
We need to rely on consent as a legal basis for processing Your information and Your country requires consent
from a parent, We may require Your parent’s consent before We collect and use that information.
We may ask a User to verify its date of birth before collecting any personal information from them. If the User
is under the age of 13, the Service will be either blocked or redirected to a parental consent process.
Information Collected from Children Under the Age of 13
The Company may collect and store persistent identifiers such as cookies or IP addresses from Children without
parental consent for the purpose of supporting the internal operation of the Service.
We may collect and store other personal information about children if this information is submitted by a child
with prior parent consent or by the parent or guardian of the child.
The Company may collect and store the following types of personal information about a child when submitted by a
child with prior parental consent or by the parent or guardian of the child:
For further details on the information We might collect, You can refer to the “Types of Data Collected” section
collected from and about children.
A parent who has already given the Company permission to collect and use his child personal information can, at
Review, correct or delete the child’s personal information
Discontinue further collection or use of the child’s personal information
Your California Privacy Rights (California’s Shine the Light law)
Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an
established business relationship with us can request information once a year about sharing their Personal Data
with third parties for the third parties’ direct marketing purposes.
If you’d like to request more information under the California Shine the Light law, and if you are a California
resident, You can contact Us using the contact information provided below.
California Privacy Rights for Minor Users (California Business and Professions Code Section
California Business and Professions Code section 22581 allow California residents under the age of 18 who are
registered users of online sites, services or applications to request and obtain removal of content or
information they have publicly posted.
To request removal of such data, and if you are a California resident, You can contact Us using the contact
information provided below, and include the email address associated with Your account.
Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted
online and that the law may not permit or require removal in certain circumstances.
Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link,
site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third
party sites or services.
Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective
effective when they are posted on this page.