Privacy Policy

Last updated: May 14, 2022

Types of Information We Collect

The following provides examples of the type of information that we collect from you and how we use that information.

Cookies and first-party tracking

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. We have a legitimate interest in making our website operate efficiently.

Cookies and third-party tracking

We participate in behavior-based advertising, this means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. Where required by law, we base the use of third-party cookies upon consent.

 

Demographic information

We collect personal information, such as your location. We have a legitimate interest in understanding our users and providing tailored services.

Email interconnectivity

If you receive an email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and makes purchases. We have a legitimate interest in understanding how you interact with our communications to you.

 

Content Contributors / Independent Contractors

If you are engaged as an independent contractor to contribute content for our website, we collect the information necessary for the engagement. This may include, among other things, your Social Security Number. Providing this information is required for the engagement. We use information about our independent content contributors to perform our independent contractor agreements. In some contexts, we are also required by law to collect information about our independent contractors. We also have a legitimate interest in using your information to have efficient workforce operations.

 

Feedback/Support

If you provide us feedback or contact us for support we will collect your name and email address, as well as any other content that you send to us, in order to reply. We have a legitimate interest in receiving and acting upon your feedback or issues.

 

Newsletters

When you sign up for one of our mailing lists we collect your email address. We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.

 

Marketing Panel

If you are selected to participate in a consumer marketing panel, we will collect your shipping address. We have a legitimate interest in facilitating our consumer marketing panel with individuals that consent to participate.

 

Mobile Devices

We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website. We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.

 

Partner Promotion

We collect information that you provide as part of a program or event that we co-sponsor or co-market with another organization. We have a legitimate interest in fulfilling our promotions.

 

Social Media and Share Links

When you “like” or “follow” us on Facebook, Instagram, Pinterest or other social media sites, we may collect your information. This information may include your name, e-mail address, and any comments or content you post that are relevant to us. We may also collect your information if you submit information to us through Facebook, Pinterest, Instagram or another social media site. These links may include the use of so-called “share links.” A “share link” is a button and/or text link appearing on our website that launches a sharing mechanism that allows you to post links to, and content from, our website onto other websites. We have a legitimate interest in understanding our users and providing tailored services. Our use is also based upon your consent.

 

Surveys

When you participate in a survey we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information. We have a legitimate interest in understanding your opinions and collecting information relevant to our organization.

 

Sweepstakes or contests

When you participate in sweepstakes or contests we collect information about you which includes contact information to notify you if you are selected. We have a legitimate interest in operating the sweepstakes. In some contexts, we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws.

 

Website interactions

We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. We have a legitimate interest in understanding how you interact with our website to better improve it and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.

 

Weblogs

We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors. We have a legitimate interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.

 

In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.

 

Use and processing of information

In addition to the purposes and uses described above, we use information in the following ways:

  • To identify you when you visit our websites.

  • To improve our services and offerings.

  • To conduct analytics.

  • To respond to inquiries related to support, employment opportunities, or other requests.

  • To send marketing and promotional materials including information relating to our services, sales, or promotions, or those of our business partners.

  • For internal administrative purposes, as well as to manage our relationships.

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. As a result, our collection and processing of your information are based in different contexts upon your consent, our need to perform a contract, our obligations under the law, and/or our legitimate interest in conducting our business.

 

Sharing Of Information

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

  1. Acquisitions. If another company acquires or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.

  2. Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.

  3. Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, the safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.

  4. Public. Our website may provide the opportunity to post comments in chat rooms, message boards, bulletin boards or similar public forums where you and other users of our website can communicate. If you decide to submit information on these pages, that information may be publicly available.

  5. Partner Promotion. We may offer contests, sweepstakes, or other promotions with third-party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third-party partner the information that you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy. When you use our website, we share information that we collect from you, such as your email (in hashed form), IP address or information about your browser or operating system, with our identity partners/service providers, including LiveRamp Inc. LiveRamp returns an online identification code that we may store in our first-party cookie for our use in online and cross-channel advertising and it may be shared with advertising companies to enable interest-based and targeted advertising.

  6. Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of orders.

Your Choices

You can make the following choices regarding your personal information:

Access to your personal information

You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.

Changes to your personal information

We rely on you to update and correct your personal information. If our website does not permit you to update or correct certain information, you contact us at the address described below in order to request that your information be modified. Note that we may keep historical information in our backup files as permitted by law.

 

Deletion of your personal information

Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.

 

Objection to certain processing

You may object to our use or disclosure of your personal information by contacting us at the address described below.

Online tracking

We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.

Newsletters

You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. When you sign up for our emails, you are agreeing not only to receive our content delivered to you but also to receive these occasional advertorial emails from our advertisers/sponsors. If you would prefer not to receive these emails, you can unsubscribe by following the unsubscribe instructions in the emails that you receive and we will not send you any additional content or advertorial emails.

 

Revocation of consent

If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

 

Please address written requests and questions about your rights to hello@starling.nyc or call us at 1 (929) 699-6742.

 

Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name, email address, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity with us.

 

 

How we protect personal information

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach of your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Other Important Information

The following additional information relates to our privacy practices:

Transmission of information to other countries

By submitting your personal information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.

 

Third-party applications/websites

Our websites may include links to websites or applications that are owned or operated by third parties. Please note, that we have no control over the privacy practices of websites or applications that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or shared.

Changes to this privacy policy

We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes a “last updated” date. The last updated date refers to the date that the current version was last substantively modified.

Accessibility

If you are visually impaired, you may access this notice through your browser’s audio reader.

Children

We do not knowingly sell the personal information of minors under 16 years of age.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

 

hello@starling.nyc

Gowanus Hospitality Group, LLC

452 Union Street

Brooklyn, NY 11231

Attn: Privacy Request

1 (929) 699-6742