Privacy Policy

1.1. Important information and who we are

Welcome to the Privacy and Data Protection Policy (“Privacy Policy”) of StartIn Lab Ltd. Our website address is: https://startin.in

We are a registered UK company as StartIn Lab Ltd. We provide an app-based incubator for students and start-ups in UK.

At StartIn Lab Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the law and guidelines of the EU General Data Protection Regulation (“GDPR”).

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Customers (including students, researchers, alumni, and founders)
• Third parties connected to your customers

and any other people that the organisation has a relationship with or may need to contact (e.g. the university our members are attending).

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2. Who is Your Data Controller

StartIn Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at privacy[at]startin.in.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority 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 at privacy[at]startin.in.

1.3. Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2.1. Types of Data / Privacy Policy Scope

“Personal Data” 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 below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Profile/Identity Data: first name, last name, gender, date of birth.
• Contact Data: phone number, addresses, email addresses.
• Contact List Data: your address book or contact list, used for things such as helping you and others find people you may know.
• Marketing and Communications Data: your preferences in receiving marketing information and other information from us.
• Billing Data: debit/credit card information such as the name attached to your payment details and your billing address.
• Transactional Data: details and records of all payments you have made for our services or products.
• Technical Data: IP address, browser type and version, app version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
• Customer Support Data: feedback and survey responses.
• Usage Data: information about how you use our website, app, products and services.

If you contact us directly, we may receive additional information about you such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other information you may choose to provide.

We also collect, use and share Aggregated Data such as the number of (active) users per month or number of (active) users grouped by university each member is part of. 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. 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 may also aggregate data to enable research or analysis so that we can better understand and serve you and others. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

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.

2.2. The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
• “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests — this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests.

2.3 Data Collection when using our website

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

3.1. Our Uses

We will only use your Personal Data when the law allows us to. Examples of how we use your data include:

• Provide, operate, and maintain our website and app
• Improve, personalize, and expand our website and app
• Understand and analyse how you use our website and app
• Develop new products, services, features, and functionality
• Communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes
• Send you emails and push notifications
• Find and prevent fraud

3.2. Marketing and Content Updates

You will receive marketing and new content communications from us unless you specifically request that you would not like to receive these communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3. 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.

4.1. What Control Do I Have Over StartIn Lab Ltd’s Use Of My Personal Data?

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access: You have the right to request copies of your personal data.
• The right to rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
• The right to erasure: You have the right to request that we erase your personal data, under certain conditions. You may delete your account at any time. If you would like us to delete/correct personally identifiable data, let us know and we will action your request within 30 days.
• The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us (privacy[at]startin.in).

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes. If you are a California resident and would like a copy of this notice, please submit a written request to privacy[at]startin.in.

4.2. How Does StartIn Lab Ltd Protect Customers’ Personal Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality.

If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, no transmission of data over the internet is guaranteed to be completely secure. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk.

4.3. Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages (including emails) at any time by changing the communication preferences in your account settings or sending an email to privacy[at]startin.in.

Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.4. How to Request your Data and the Process for Obtaining it

There will be no charge to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

5.1. Will We Share Your Data With Third Parties?

We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors (only when necessary and with your consent) or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).

We may also share Personal Data with interested parties in the event that StartIn Lab Ltd. anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If StartIn Lab Ltd. is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data.

We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

You must not use StartIn Lab Ltd unless you are aged 18 or older. If you are under 18 and you access StartIn Lab Ltd by lying about your age, you must immediately stop using StartIn Lab Ltd.

The website, products and services are not intended for children and we do not knowingly collect data relating to children.

Your information may be stored and processed in the US or other countries or jurisdictions outside the US where StartIn Lab Ltd has facilities (UK). We are currently storing data in the EU and US, so by using StartIn Lab Ltd., you are permitting and consenting to the transfer of information, including Personal Data, also outside of the EU and US.

We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 20 October 2022. By using StartIn Lab Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of StartIn Lab Ltd. will constitute your express acceptance of any modifications to this Privacy Policy.

All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored.

Our staff are not authorised to contract on behalf of StartIn Lab Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a StartIn Lab Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the StartIn Lab Ltd legal department.

Please also see our Terms of Use which set out the terms, disclaimers, and limitations of liability governing your use of StartIn Lab Ltd.