Privacy Policy

Last updated: 12^th March 2023

Welcome to the StartIn Lab’s privacy policy.

StartIn Lab Ltd. (collectively referred to as “we”, “us” or “our”) is committed to protecting and respecting your privacy. This policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our services or our applications (apps). The policy also tells you about your privacy rights and how the law protects you.

1. Important information and who we are

1.1 Purpose of this privacy policy

This privacy policy aims to give you information on how StartIn Lab collects and processes your personal data through your use of our website, applications, our app (StartIn UK on AppStore and Google PlayStore) or when you interact with us by any other means, including any data you may provide through the website when you sign up to our newsletter, make an enquiry orprovide feedback.

Our service is designed for adults above the age of 18 years, users below 18 years are prohibited from using our services as stated in our Terms & Conditions. This website and app is not intended for children and minors and we do not knowingly attempt to solicit or receive data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1.2 Controller

StartIn Lab Ltd. is the “data controller” for the purposes of data protection legislation. We are responsible for your personal information and, by law, we are required to provide you with information about us, about how and why we use your data and about the rights you have over it.

We are not required by law to appoint a data protection officer (DPO), so any questions about this policy or our privacy practices, including any requests to exercise “your legal rights”, shall be addressed to the contact details set out below.

1.3 Changes to this privacy policy

We may review this privacy policy from time to time and we will notify you of any changes by uploading the new version of it on our website [or on our applications]. We will send you an e-mail or post an update notice on our website or applications so that you become aware of the updated version of this policy. The “Last updated” date at the top of this policy will also be adjusted accordingly.  

You are advised to review this privacy policy periodically for any changes. Changes to this policy are effective when they are posted on our website and/or applications.

1.4 Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.5 Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes [first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, profile picture, previous professional experience, universities you studied or study at, and information regarding your character and work style that we use to improve our matching algorithm (e.g. are you pushing deadlines to the last minute or not].
• Contact Data includes [billing address, delivery address, email address and telephone numbers].
• Financial Data includes [bank account and payment card details].
• Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
• Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website]. This may also include information about your visit, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methosd used to browse away from the page
• Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses]. 
• Usage Data includes [information about how you use our website, app, and services].
• Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].

We also collect, use and share Aggregated Data such as statistical or demographic data for industry and market analysis, our marketing and advertising strategy or for any other business purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your identiy, contacts, and personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our services;
  • create an account on our app;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies[, server logs] and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:
  • analytics providers (such as Google based outside UK)
  • advertising networks (such as LinkedIn, TikTok, and Instagram based outside the UK), and
  • search information providers (such as Google, LinkedIn based ourside the UK

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from data brokers or aggregators
• Identity and Contact Data from publicly available sources

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use (this is, process) your personal data in the following circumstances:

• Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we are about to enter into or have entered into with you.
• Necessary for the purposes of legitimate interests. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Our legitimate interests include responding to enquiries from you or third parties, optimising our website, applications and the overall user experience, informing you about our services/ products and ensuring that our operations are conducted in an appropriate and efficient manner.
  • Ahead of processing your personal data for our legitimate interests, we consider and balance any potential impact on you (both positive and negative) and your rights. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.
• Consent. In some circumstances, we may ask for your consent to process your information in a particular way (for example, we will get your consent before sending you direct marketing communications via email or text message, or any third party marketing. You have the right to withdraw consent to marketing at any time by contacting us).

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new user	(a) Identity (b) Contact	Performance of a contract with you
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business, app, and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant app and website content as well as advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our app, website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

We may send you marketing communications from time to time about our new products and offers, provided that we obtain your consent to do so. If you no longer wish to receive marketing messages from us, you have the right to opt-out at any time by following the instructions in the “Opting-out” section below.

If you have already purchased goods or services from us, we may send you electronic marketing communications about products we feel may interest you (based on your prior experience with us) if you have not opted out from that marketing messages.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosure of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table [Purposes for which we will use your personal data] above.

• Internal Third Parties:
  • Other companies in the StartIn Lab Group acting as joint controllers or processors and who are based United Kingdom, Germany, Israel, and United States and provide IT and system administration services and undertake leadership reporting.
• External Third Parties:
  • Service providers [acting as processors] based United Kingdom who provide IT and system administration services.
• • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in United Kingdom, Germany, Israel, or United States who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based in the United Kingdom [who require reporting of processing activities in certain circumstances].
• Specific third parties listed in the table “Purposes for which we will use your personal data” above
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within the StartIn Lab Group. This will involve transferring your data outside the UK.

Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.]

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see 9. Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

• Request access (commonly known as a “data subject access request”) – you have the right to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction – you have the right to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure (“right to be forgotten”) – you have the right to ask us to delete or remove the personal data we hold about you from our records. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons – for example, where we are legally obligated to keep the information or if it is impossible or unproportionate for us to erase the data. In this case, we won’t delete it but we will only keep it for as lomg as it is needed and we have time limits on our data systems.
• Object to processing – you have the right to object to processingyour personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you feel such processing impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing – you have the right to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer – you have the right to ask us to transfer the personal data we hold about you, either to you or a third party you have chosen, in a structured, commonly used, machine-readable format. 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 consent at any time (where we are relying on consent to process your personal data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with certain products or services. We will advise you if this is the case at the time you withdraw your consent.
• Object to automated processing, including profiling – in some circumstances you can ask us not to reach decisions that produce legal or similarly significant effects on you using automated decision-making, including profiling. Note, however, that the use of algorithms or machine learning techniques in ways that don’t have significant privacy implications on you is unlikely to render you with the right to object such automated processing.

If you wish to exercise any of the rights set out above, please contact us on the contact details set out below.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

Full name of legal entity: StartIn Lab Ltd.

Email address: privacy[at]startin.in

Postal address: 80 Woodlane, W12 0BZ London

Telephone number: +44 7742 7177 66

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.