Privacy Policy
Importance of Your Privacy. At StartFresh, your privacy is of great importance to us. We understand that you entrust us with your private information to help us match you with a credit counseling agency (an "Agency"), offer access to various products or provide other services described at the web site located at www.startfreshtoday.com (the "Web site"). In exchange for your trust, you expect and deserve our commitment to treat your information with respect and in accordance with this Privacy Policy. Rest assured that we protect your privacy. Under no circumstances will StartFresh sell or share any personal information about you to or with any person or organization except (i) as authorized by you, (ii) with Agencies, (ii) with Provider to the extent you purchase access to a debtor education course, (iv) as may be required by law or court order, or (v) as otherwise set forth in this Privacy Policy. The Privacy Policy below describes the standards we adhere to in handling information about you and any personal information you submit through the Web site.
PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING ANY OF STARTFRESH'S SERVICES. BY USING ANY SUCH SERVICES YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND UNDERSTAND THIS POLICY AND THAT YOU AGREE TO BE BOUND BY ITS TERMS. IF YOU DO NOT AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY, SIMPLY EXIT THIS PAGE WITHOUT ACCESSING OR USING OUR WEB SITE OR ANY OF OUR SERVICES.
A Special Note About Children. Children are not eligible to use our service and we ask that minors (under the age of 13) do not submit any personal information to us or use the service. StartFresh does not collect or maintain information from those actually known to be under the age of 13, and no part of the Web site is structured to attract anyone under the age of 13.
Important Categories of Information for you to Know:
- Who we are
- Information we may collect at the Web site
- How your information is used
- Altering the information you submit through the Web site
1. Who We Are. StartFresh owns and operates the Web site, the purpose of which is to connect consumers to Agencies and to provide other services in connection the bankruptcy process. Based on the information you supply at the Web site (a "Submission") and based on the services you have selected, StartFresh will make your data available to an Agency or Provider assigned to you or otherwise use such information to provide the requested services. In addition, depending on the products or services selected by you, we may make information submitted by you at the Web site available to third party vendors to the extent you have purchased any services or products from such vendors through the Web site. This Agency or Provider, if applicable, will likely contact you after reviewing your Submission or information submitted in connection with the Course.
2. Information We Collect. There are several areas on the Web site where you may be asked to enter both personal and non-personal information. We DO NOT sell or share any personal information about you to or with any person or organization except (i) as authorized by you, (ii) to participating Agencies, (iii) as set forth herein, or (iv) as may be required by law or court order.
(a) Information we receive from you via Submissions. To use StartFresh's services, when you come to the Web site you'll need to provide personal information such as your name, phone number, Social Security Number, e-mail address, income, information regarding assets and liabilities and other financial information.
(b) Technical information we collect. In order for StartFresh to ensure that we are providing the best possible consumer experience on the Web site, we collect and track certain user information. When you visit the Web site, our Web server sends a cookie to your computer. This cookie stores a limited amount of information about your site visit. The cookie tracks aggregate information on how our site is being used, including session counts, navigation patterns, pages visited, etc. These cookies, however, do not store any personally identifiable information such as your name, email address or phone number as you browse the site. When you complete a Submission, we store your cookie identification in our system. This cookie allows our site to recognize you when you return. StartFresh also utilizes Web Logs to track aggregate information about how our site is being used. Web Logs track anonymous user information, including the number of visitors to the Web site, operating systems, Internet Provider addresses (if publicly available), and browser type. Unlike cookies, Web Logs are maintained only on StartFresh servers and do not store or place anything on the user's computer. If you come to the Web site from an online banner ad, an anonymous identification number may be passed to the Web site. This information cannot be used to gather any personally identifiable information about you. It will only allow us to track the overall effectiveness of our online advertising, marketing and banner advertisement campaigns.
(c) Information from surveys. You may have the option of completing an online survey at the Web site from time to time. Participation in surveys is completely voluntary and it is your choice whether or not you wish to disclose your personal information to us in connection with any such survey.
(d) Information from the "Contact Us" section of the Web site. You may contact StartFresh through the "Contact Us" feature. Participation in this area is completely voluntary and it is your choice whether or not you wish to disclose your personal information to us.
(e) Information collected on other sections of the Web site. StartFresh may, from time to time, make various resources available to you at the Web site to help educate you about the bankruptcy and/or credit counseling industry. At times we may collect personal information in connection with providing such services.
3. How your information is used. We use the information you provide in your Submission or other submission of information to match you with an Agency or Provider, and, to the extent attorney due diligence products are purchased at the Web site, provide other services to you as described throughout the Web site. StartFresh may also share certain aggregated data with our Agencies and other third parties for general reporting and demographic purposes; however, this data does not include any of your personal identifying information. As the Agencies and Providers may keep and use your information whether or not you work with them on a transaction, we recommend that you contact them directly for more information about their specific privacy policies. Some of our services may be offered in conjunction with partner companies, affiliates or other companies or web sites with which we work. In order for us to provide these services to you, it may be necessary for us to share your personal information with one of such entities (subject to any limitations set forth in the Terms and Conditions and elsewhere in this Privacy Policy). In addition, again subject to the limitations described in the preceding parenthetical, personal information entered by you in various sections of the Web site may be shared with software partners to assist licensees of such software programs, to the extent such licensees are also working with you, to complete forms in a more expeditious manner. These parties are not allowed to use personally identifiable information except for the purpose of providing these services. If you do not want your data to be shared, you can choose not to allow the transfer by not using that particular service.
In addition, StartFresh may disclose account or other personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with StartFresh's rights or property, other Web site users or anyone else that could be harmed by such activities.
4. Altering Information You Submit Through a StartFresh Web Site. You may be able to review and change personal information in an active Submission that you completed through StartFresh at the Web site. If you are unable to complete this online, you may contact our customer care department at info@startfreshtoday.com.
(a) Deleting your information. Federal and state regulations may require that we store completed Submissions for various periods of time. In order to comply with these regulations, we may be unable to delete information from our databases.
(b) Request to stop receiving emails from us. Periodically, StartFresh may send you emails to alert you to money saving tips or special offers. If you do not wish to receive any of these offers, please send an e-mail to optout@startfreshtoday.com to remove yourself from our mailing list.
Security
StartFresh uses extensive and sophisticated secure technology to protect your data and transmissions between you, StartFresh and Agencies participating in the Web site. Transmission between browsers and our web server is implemented using Secure Sockets Layer (SSL) technology. This technology requires an SSL-capable browser. Our database is physically separated from our web server and is protected by a physical firewall. Although StartFresh has taken these reasonable and appropriate measures to ensure that your personal information is delivered and disclosed only in accordance with your instructions, StartFresh cannot and does not guarantee that the personal information you provide will not be intercepted by others and decrypted.
Changes to Privacy Policy
If we make a change to our Privacy Policy in the future that will affect how we treat your information, we will notify you by e-mail of the change to the extent such change is material. Otherwise, we will post such change at the Web site, and such change will be deemed to be effective 10 days from the date of such posting. In that case, your ability to opt out of the new policy will be determined by applicable laws.
This Privacy Policy was last updated on April 6, 2006.
PLEASE PRINT AND RETAIN A COPY OF THIS AGREEMENT FOR YOUR RECORDS.