STAR2STAR COMMUNICATIONS, LLC PRIVACY POLICY

Star2Star Communications, LLC respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy describes the information Star2Star Communications, LLC or any of its affiliated entities (“Star2Star”) may collect from you while using any Star2Star hardware, software and/or any Star2Star website (hereinafter collectively referred to as (“the Products”). This Privacy Policy also describes how Star2Star may use such information and how it may be protected.

What information does Star2Star collect?

Star2Star collects and stores personally identifiable information when it is voluntarily provided. Personally identifiable information is any information that may reasonably be used to identify you and may include any name, address, phone number, fax number, e-mail address, or any other information transmitted by you when registering or using the Products. Additionally, Star2Star may collect copies of correspondence and personally identifiable information if you directly contact us.

Star2Star may also passively collect information from you that is not personally identifiable as a result of your registration or use of the Products. For example, Star2Star may track, log, and/or record information about the date and time you registered or used the Products, the type of browser used, and your Internet Protocol (IP) address. Star2Star may collect this information by depositing certain bits of information called “cookies” in your computer. A cookie is a small file placed on the hard drive of your computer. This technology does not collect your personally identifiable information, but rather, this information is collected in an aggregate form.

How does Star2Star use the information it collects?

When Star2Star receives personally identifiable information, Star2Star may use it for reasonable business purposes as determined by Star2Star. For example, Star2Star may use this information to contact you via e-mail, mail, and/or telephone in order to provide you with information Star2Star believes may be of interest. It may also be used for compiling data and analyses to understand and serve Star2Star’s customer needs. Additionally, we may use information that we collect about you or that you provide to us, including any personally identifiable information, to evaluate the use and utility of the Products.

What information may Star2Star disclose and/or share?

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. However, Star2Star only shares personally identifiable information for business purposes and only on a need-to-know basis. Such information may be shared with: (a) Star2Star employees and affiliates; (b) the customer from which Star2Star received the information; (c) Star2Star consultants and/or third-parties that have agreed to safeguard such information in a like manner to the way that Star2Star safeguards such information and that have signed confidentiality agreements with Star2Star; and (d) other entities authorized to have access to such information under applicable law or regulation, such as law enforcement. Star2Star does not share non-public personally identifiable information with third party marketers.

Star2Star may disclose personally identifiable information: to comply with any court order, law or legal process,including to respond to any government or regulatory request; to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes and; if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Star2Star, our customers or others.

Star2Star will not use or share information in ways unrelated to those described above without first notifying youand offering you a choice as to whether or not Star2Star may use your data in this different manner.

Choices About How We Use and Disclose Your information

While using the Products you can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our website may then be inaccessible or not function properly.

Correction and Deletion of Information

Star2Star will make every effort to maintain the accuracy and confidentiality of any personally identifiable information supplied by you to Star2Star. If you wish to make additions or other corrections to the information that has been sent to Star2Star, please contact Star2Star at support@Star2Star.com

Additionally, Star2Star may store personally identifiable information even after you are no longer a customer or user of the Products. If you wish to stop receiving e-mails or other communications from Star2Star in the future, or if you have submitted personally identifiable information through the use of a Product and would like to have that information deleted from Star2Star’s records, please contact Star2Star at support@Star2Star.com Please note, Star2Star may be required to indefinitely maintain certain records that may contain personally identifiable information.

Links to Other Websites

As a resource to its visitors, Star2Star may provide links to third party websites from its Products. Such links are covered by the Terms of Use that accompany the Products. Star2Star tries to carefully choose websites that it believes are useful and accurate. However, because website design and content can quickly change, Star2Star does not guarantee the standards of the websites to which it links. Star2Star also does not control the privacy policies of these third party websites; therefore you should directly check the privacy policies of those websites and make your own determination of how those sites collection and use personally identifiable information.

Children’s Privacy Protection

Star2Star’s website is a general audience site that is not designed nor intended to collect personally identifiable information from children under the age of 13. Star2Star does not knowingly collect personally identifiable information from anyone under the age of 13, and does not use such information if it discovers that it is has been provided. To respect the privacy of children and to comply with the Children’s Online Privacy Protection Act, children under the age of 13 should not provide any personally identifiable information to Star2Star through the use of the Products or otherwise. Star2Star asks that parents supervise their children while online and contact Star2Star at support@Star2Star.com if it is discovered that any personally identifiable information has been transmitted to Star2Star by a child under the age of 13.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of Star2Star Products that are California residents to request certain information regarding Star2Star’s disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@Star2Star.com or write Star2Star at: Star2Star Communications, LLC, Attention Legal Department, 600 Tallevast Road, Suite 202, Sarasota, FL 34243.

International Users

If you are located outside of the United States and Canada, please note that the Products are for use solely within the United States and Canada and may be subject to certain laws governing prohibiting its export or use outside the United States and Canada. You agree to abide by and hold harmless Star2Star from all violations of United States or Canadian export laws. Additionally, any personally identifiable information collected when registering or using the Products may be transferred to the United States and other countries that might not provide an equivalent level of protection as the data protection laws in your home country. Use of the Products or submission of any personally identifiable information whether in connection with the use or registration of the Products will therefore constitute your consent to the transfer of personally identifiable information outside of your home country.

Data Security

Star2Star will make commercially reasonable efforts to store personally identifiable information in a secure environment that is designed to prevent public access. However, Star2Star cannot guarantee complete security from unauthorized sources accessing such information. If Star2Star takes commercially reasonable efforts to secure the information, it shall have no liability to you for any unauthorized access or subsequent use of the information.

Changes to Our Privacy Policy

This Privacy Policy may be wholly or partially changed, modified, added to or reduced at any time, with or without notice by Star2Star in its sole discretion. Changes and updates to our Privacy Policy will be posted on our website. Please check this Privacy Policy periodically to review any changes that may have been made.

Contact

If you have any questions regarding this Privacy Policy or Star2Star’s privacy practices, please contact Star2Star at: support@Star2Star.com

If a complaint or dispute remains unresolved after having contacted Star2Star, please contact the Better Business Bureau Online at: www.bbb.org

Your Consent to These Terms

By registering or using the Products, you consent to the information collection, use and disclosure practices described in this Privacy Policy. This Privacy Policy may be modified, changed or updated at any time by Star2Star. Your continued use of the Products after we make changes to this policy is deemed to be acceptance of those changes, so please check the policy periodically for updates. Changes and updates to our Privacy Policy will be posted on our website.

Last Modified: July 2012