Privacy Policy


Effective 2/1/2020

Welcome!

This is the Privacy Policy (“Policy”) of Starlight Software Solutions LLC (“Starlight,” “us,” “our,” or “we”), a Colorado limited liability company with offices at 7010 Broadway, Ste. 106, Denver, Colorado 80221. This Policy describes how we collect, process, and share your Personal Data. We also describe your rights and choices with respect to your Personal Data, and other important information. Please read this Policy carefully. 

Scope of the Policy

This Policy applies to our website at starlightsoftwaresolutions.com and other sites that link to/post this Policy, (including any subdomains or mobile versions the “Website(s)”), the Starlight client-server applications, web applications, and web portals (“Programs”), and the Starlight mobile applications (the “App(s)” and together with the Programs, the “Platform”).

This Policy applies only to the Personal Data we process in our role as a “controller” or a “Business” (as defined by applicable privacy laws). This Policy does not apply to our processing of Personal Data on behalf of our business customers (“Customers”) their users, or our Customers’ use of any Personal Data available through or produced by our Platform. This Policy also does not apply to information processed by other third parties, for example, when you visit a third-party website or interact with a third-party service, even if linked from our Platform or Website.

This Policy is incorporated into the Terms of Use governing your use of our Platform. Any capitalized terms not defined in this Policy will have the definitions provided in our Terms of Use. Your use of our Platform indicates your acknowledgement of the practices described in this Policy. 

About our Platform

The Platform allows our business customers (“Customers”) to manage inventory, dispatching, operations, billing, and other aspects of their business. Our Customers and their authorized users of the Platform can log into the Programs to view and set schedules, manage operations and billing, and use other tools to manage day-to-day operations. In addition, drivers and others can download our App to view and complete work orders, document vehicle inspections, and help manage jobs and deliveries. 

Processing of Personal Data

Personal Data We Process

We may process the following categories of data that relate to identified or identifiable individuals (“Personal Data”) (note, specific Personal Data elements listed in each category are only examples and may change):

Identity Data: Personal Data relating to an individual’s identity or representing that individual, such as your name, photo, username, unique ID, etc.

Contact Data: Personal Data used to contact an individual, e.g. email address(es) or phone number(s).

Financial Data: Personal Data relating to financial accounts or services, e.g. a credit card or other financial or billing account number, and other relevant information you provide in connection with a financial transaction.

Device/Network Data: Personal Data relating to your device, browser, or application e.g. IP addresses, MAC addresses, application ID/AdID/IDFA, identifiers from cookies, session navigation history and similar browsing metadata, and other data generated through applications and browsers, including cookies and similar technologies. 

Government ID Data Data relating to official government identification, such as driver’s license numbers, including similar Identity Data included in Cal Civ Code § 1798.80(e).

Location Data: Personal Data relating to your precise location, such as information collected from your device’s GPS, Wi-Fi network, cell towers, or other precise localization service active on your device. 

Inference Data: Personal Data inferred about personal characteristics and preferences, such as demographics, interests, behavioral patterns, psychological trends, predispositions, or behavior.

How We Collect Personal Data

The Personal Data we collect under this Policy comes from a variety of sources, which vary depending on the nature of processing and available technologies.  A summary is below, but for further detail, please see the table at the end of this Policy.

Data you provide to us: You may provide us with Personal Data directly, for example, when you provide your information and register for an account.

Data we create or infer: We (or third parties operating on our behalf) create and infer Personal Data (such as Inference Data or Aggregate Data) based on our observations or analysis of other Personal Data we process, and we may correlate this data with other data we process about you.

Data collected automatically: We (or third parties operating on our behalf) may collect certain Personal Data automatically, for example, Device/Network Data is typically collected automatically through the use of cookies and similar technologies used on our Websites and Platform.

Data we receive from others: We may receive Personal Data from third parties with whom we have a relationship. For example, we may receive the Personal Data we process from our third-party service providers.

How We Use Personal Data

When you use our Platform, we generally process your Personal Data in connection with the following activities and purposes, as well as for the general processing purposes described below.

Subscription & Account Registration

We generally collect and process Identity Data, Device/Network Data, and Contact Data when users of the Platform register and create an account on our Platform. Additionally, we may collect Financial Data when you subscribe to our Platform and use a credit card or other accepted method for payment. We generally use this as necessary to create, maintain, and provide your account and the service/features you request, or to process your payment. We may also use your Contact Data to contact you with information about your account or our Platform. 

Using the Platform and App

We generally process Identity Data, Contact Data, Device/Network Data, and Inference Data when you use our Platform. We generally use this as necessary to create, maintain, and provide your account and the service/features you request. For example, we may use this information to log you in, authenticate your access, and provide you with the Programs modules and features for which you are subscribed. 

We generally process Identity Data, Contact Data, Device/Network Data, and Inference Data when you use our App. We may also process Location Data if you or our Customer enable location services when you use the Platform. Similarly, if you provide it or our Customer requires it, we may process Government ID Data. We generally use this as necessary to create, maintain, and provide your account and the service/features you request. We may process Location Data, Inference Data, Government ID Data, and Device/Network Data in order to track your location on behalf of the relevant Customer, and at the Customer’s request, to generate metrics regarding activity, productivity, and other metrics as part of our business analytics services, and this processing is performed solely on the Customer’s behalf.

Note: Our Customers can use our Platform to create analytics regarding the performance of their business, including for example, financial reports, operations management, scheduling, fulfillment, and reports relating to customer satisfaction or employee effectiveness and efficiency. Some of these analytics require the processing of Personal Data. For example, Customer’s users of the App may be monitored, and their performance evaluated using statistics made available through the Platform at the Customer’s request. These analytics are performed on behalf and at the discretion of our Customer, and their use of Personal Data and any actions they may take are solely within the discretion of that Customer.

Communications

You may contact us through our Websites or Platform or sign up for certain communications from us. In each case, we generally collect Contact Data and any Identity Data that you provide in the registration form, as well as any information you send to us as part of your communication. This information is primarily used to respond to your request, but where you consent, or if relevant to your request and permitted by law, we may send you marketing communications as described further below. 

Cookies and Similar Technologies 

When you use the Websites or Platform you may interact with cookies and similar technologies that we operate on or allow access to our Platform. We, and certain third parties, may automatically collect and process Device/Network Data and Inference Data when you interact with these cookies and similar technologies. In cases where these cookies and similar technologies are controlled by third parties, we may receive this data from third parties to the extent allowed by the applicable service provider or partner. Please note, some of these technologies can be used by third parties to identify you across platforms, devices, websites, and services. The privacy policies of third parties may apply to these third-party technologies and their own use of any Personal Data they collect. 

Subject to users’ rights and choices, we use this data as follows: 

  1. for “essential” or “functional” purposes, such as to enable various features of the Platform such as remembering passwords, or staying logged in during your session; and
  2. for “analytics” purposes, consistent with our legitimate interests in understanding how the Platform is used or performs, how users engage with and navigate through the Platform, in providing and improving the user experience and efficiency of our Platform, understanding information about the devices and demographics of visitors to our Platform, what sites refer visitors to our Platform, how often they visit our Platform, and other similar purposes.

Purposes of Processing

We process Personal Data for numerous purposes in connection with our business, including the following:

Platform Provision and Contractual Obligations

We process any Personal Data as is necessary to provide the Platform, authenticate users and their rights to access the Platform, and as otherwise necessary to fulfill our contractual obligations to you, and provide you with the information, features, and services you request.  Additionally, we may provide analytics of data at your requests, including information about productivity, profitability, financial returns, or similar information.

Internal Processes and Platform Improvement

We may use any Personal Data we process through our Platform as necessary in connection with our legitimate business interests in improving the design of our Platform, understanding how our Platform is used or function, for customer service purposes, in connection with logs and metadata relating to service use, and for ensuring the security and stability of the Platform. 

Additionally, we may use Personal Data to understand what parts of our Platform are most relevant to users, how users interact with our Platform, how our Platform performs, etc., or we may analyze use of the Platform to determine if there are specific activities that might indicate an information security risk to the Platform or our users. This processing is subject to your rights and choices under applicable law.

Aggregate Analytics

We process Personal Data (including Location Data in pseudonymized or de-identified form) as necessary creating aggregate analytics about how our Platform is used and performs, and to understand which aspects of our products and Platform are most relevant to users (“Aggregate Data”). The resulting aggregate data will not contain information from which an individual may be readily identified. This processing is subject to users rights and choices applicable to processing performed in accordance with our legitimate business interests. 

Marketing Communications

We use Personal Data as necessary to provide marketing communications, and consistent with our legitimate business interests, we may send you marketing and promotional communications if you sign up for such communications or subscribe to the Platform. We may also process Device/Network Data and Contact Data when you interact with our communications in connection with our legitimate business interest in understanding communication response and open rates.

Compliance, Health, Safety & Public Interest

Note that we may, without your consent or further notice to you, and to the extent required or permitted by law, process any Personal Data subject to the Policy for purposes determined to be in the public interest or otherwise required by law. For example, we may process information as necessary to fulfil our legal obligations, to protect the vital interests of any individuals, or otherwise in the public interest or as required by a public authority. Please see the data sharing section for more information about how we disclose Personal Data in extraordinary circumstances.

Other Processing of Personal Data

If we process Personal Data in connection with our Platform in a way not described in this Policy, this Policy will still apply generally (e.g. with respect to users’ rights and choices) unless otherwise stated when you provide it. 

Data Sharing

Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally share Personal Data with the following categories of recipients:

Business Purposes: In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests or other business purposes, we may share your Personal Data with service providers or subprocessors who provide certain services to us or process data on our behalf. For example, we may use cloud-based hosting providers to host our Platform or may disclose information as part of our own internal operations, such as security operations, performance/stability analytics, internal research, etc.) 

Affiliates: We may share your Personal Data with our current or future affiliated entities, subsidiaries, and parent companies, for example, in order to streamline business operations, develop products and services that better meet the interests and needs of our customers, or to improve our Platform. 

Successors: Your Personal Data may be shared if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process.

Lawful Recipients: In limited circumstances, we may, without notice or your consent, disclose your Personal Data, any communications sent or received by you, and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms of Use, in the vital interests of us or any person, or in such other circumstances as may be required or permitted by law. Note, these disclosures may be made to governments that do not ensure the same degree of protection of your Personal Data as your home jurisdiction. We may, in our sole discretion (but without any obligation), object to the disclosure of Personal Data to such parties.

Users’ Rights and Choices

Users’ Rights

Applicable law may grant you rights in your Personal Data. These rights vary based on your location, state/country of residence, and may be limited by or subject to our or our Customers’ own rights in your Personal Data. In cases where we process Personal Data on our own behalf, you may exercise rights you have by contacting us at admin@starlightsoftwaresolutions.com. 

Note: When we process Personal Data on behalf of a Customer, you will be required to submit your request to the Customer and exercise your rights through that party, and we will cooperate with that Customer as necessary.

All rights requests we receive directly must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data. We may require that you log in to your account or verify that you have access to your account or the email on file in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

For information regarding your California Privacy Rights (if you are a California resident), please see below.

Users’ Choices

It is possible for you to use portions of our Platform or Websites without providing any Personal Data, but you may not be able to access certain features or view certain content. To the extent required under applicable law, and subject to our rights under applicable law, you may have the following choices regarding the Personal Data we process. 

Location Data: Depending on Customer account settings, the collection and processing of Location Data may be required for you to use the App, or certain location based features of the Platform. You may disable our use of location services through the settings menu of certain applications or your operating system, unless disabled by the Customer. If you choose to disable location services, you may be unable to use certain features of the Platform, such as navigation or operational tracking.

Consent: If you consent to processing, you may withdraw your consent at any time, to the extent required by law.

Notifications If you do not want to receive push notifications from our App, you can change your notification preferences using your operating system’s notification setting functionality. To disable location services that may affect the notifications you receive, see above.

Direct Marketing: You have the choice to opt-out of or withdraw your consent to processing related to direct marketing communications. You may have a legal right not to receive such messages in certain circumstances, in which case, you will only receive direct marketing communications if you consent. You may exercise your choice via the links in our communications or by contacting us re: direct marketing using the information below. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

Cookies & Similar Tech: If you do not want information collected using cookies and similar technologies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu, or any menus we may make available to you. You must opt out of third-party services directly via the third party. For example, to learn more about or opt-out of Google’s analytics Platform, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out. Please note, currently our Platform does not respond to your browser’s do-not-track request.

Information Security

We implement and maintain reasonable security measures to safeguard the Personal Data we process. However, we sometimes share Personal Data with, or process data on behalf of third parties, as noted above. We do not have control over and will not be liable for third parties’ security processes. We do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure. 

Use by Minors 

Our Platform and Websites are not directed to or intended for use by individuals under the age of 18. Do not access or use the Platform or Websites if you are not of the age of majority in your jurisdiction.

Changes to Our Policy

We may change this Policy from time to time. Changes will be posted on this page with the effective date. Please visit this page regularly so that you are aware of our latest updates. Your acknowledgement of these changes or use of the Platform following notice of any changes (as applicable) indicates your acceptance of any changes.

Contact Us

Feel free to contact us with questions or concerns using the appropriate address below.

General inquires: info@starlightsoftwaresolutions.com

Physical address: Starlight Software Solutions, LLC

7010 Broadway

Ste. 106

Denver, CO 80221

Your California Privacy Rights

Under the California Consumer Privacy Act (“CCPA”) and other California laws, California residents may have the following rights in addition to those set forth in the Rights & Choices section above, subject to your submission of an appropriately verified request (see below for verification requirements): 

Privacy Rights

Right to Know 

You may request any of following, for the 12 month period preceding your request: (1) the categories of Personal Data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the business or commercial purpose for which we collected or sold your Personal Data; (4) the categories of third parties to whom we have sold your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you. 

Right to Delete

You have the right to delete certain Personal Data that we hold about you, subject to exceptions under applicable law.

Right to Non-Discrimination

You have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA.

Direct Marketing

You may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes (if any) during the preceding calendar year. 

Opt-Out of Sale

If we engage in sales of data (as defined by applicable law), you may direct us to stop selling or disclosing Personal Data to third parties for commercial purposes. At this time, we do not sell Personal Data.

Submission of Rights Requests

You may submit requests by emailing us at admin@starlightsoftwaresolutions.com. Please provide your email address, phone number and address we have on file for you along with the type of request you are submitting.

Verification of Rights Requests

All rights requests must be verified to ensure that the individual making the request is authorized to make that request, to reduce fraud, and to ensure the security of your Personal Data. We may require that you provide additional information in order to verify your identity. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf. 

Supplemental Data Processing Disclosures

Categories of Personal Data Disclosed for Business Purposes

For purposes of the CCPA, we may disclose to Service Providers for “business purposes” the following categories of Personal Data: Identity Data; Contact Data; Financial Data; Government ID Data; Device/Network Data; Location Data; Inference Data.

Data Sale

For purposes of the CCPA, we do not “sell” your Personal Data. 

Right to Know 

Category of Data:  Identity Data

Category of Sources: Data you provide to us; Data we create or infer; Data collected automatically; Data we receive from others

Business and Commercial Purposes: Platform Provision and Contractual Obligations; Internal Processes and Platform Improvement; Aggregate Analytics; Marketing Communications; Compliance, Health, Safety & Public Interest; Other Processing

Category of Recipients: Customers; Service Providers; Affiliates; Successors; Lawful Recipients

Category of Data:  Contact Data

Category of Sources: Data you provide to us; Data we create or infer; Data collected automatically; Data we receive from others

Business and Commercial Purposes: Platform Provision and Contractual Obligations; Internal Processes and Platform Improvement; Aggregate Analytics; Marketing Communications; Compliance, Health, Safety & Public Interest; Other Processing

Category of Recipients: Customers; Service Providers; Affiliates; Successors; Lawful Recipients

Category of Data:  Financial Data

Category of Sources: Data you provide to us; Third parties 

Business and Commercial Purposes: Platform Provision and Contractual Obligations; Internal Processes and Service Improvement; Personalization; Compliance, Health, Safety & Public Interest

Category of Recipients: Service Providers; Affiliates; Successors; Legal Disclosures; Other

Category of Data:  Device/ Network Data

Category of Sources: Data collected automatically; Data we receive from others

Business and Commercial Purposes: Platform Provision and Contractual Obligations; Internal Processes and Platform Improvement; Aggregate Analytics; Marketing Communications; Compliance, Health, Safety & Public Interest; Other Processing

Category of Recipients: Customers; Service Providers; Affiliates; Successors; Lawful Recipients

Category of Data:  Government ID Data

Category of Sources: Data you provide to us; Third parties

Business and Commercial Purposes: Platform Provision and Contractual Obligations; Internal Processes and Platform Improvement; Aggregate Analytics; Marketing Communications; Compliance, Health, Safety & Public Interest; Other Processing

Category of Recipients: Customers; Service Providers; Affiliates; Successors; Lawful Recipients

Category of Data:  Location Data

Category of Sources: Data you provide to us; Data we create or infer; Data collected automatically

Business and Commercial Purposes: Platform Provision and Contractual Obligations; Internal Processes and Platform Improvement; Aggregate Analytics; Marketing Communications; Compliance, Health, Safety & Public Interest; Other Processing

Category of Recipients: Customers; Service Providers; Affiliates; Successors; Lawful Recipients

Category of Data:  Inference Data

Category of Sources: Data you provide to us; Data we create or infer; Data collected automatically; Data we receive from others

Business and Commercial Purposes: Platform Provision and Contractual Obligations; Internal Processes and Platform Improvement; Aggregate Analytics; Marketing Communications; Compliance, Health, Safety & Public Interest; Other Processing

Category of Recipients: Customers; Service Providers; Affiliates; Successors; Lawful Recipients

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