Effective Date: 21 Jan, 2021

Updated: 21 Jan, 2021

STARFISH, a registered Trademark of Satco Products, Inc. and subsidiaries (“we”, “us”, “our”, “STARFISH”, “Satco”) are committed to protecting your privacy. This Privacy Policy (“Policy”) describes how we collect, use and disclose your Personal Data through your individual use of the following services, products, and related mobile applications (collectively, the “Products”):

STARFISH Mobile Application (“STARFISH App” or “App”).

BY INSTALLING, ACTIVATING OR USING THE STARFISH APP, YOU ARE AGREEING TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AS SET OUT IN THIS PRIVACY POLICY, DO NOT PROCEED WITH DOWNLOADING, ACCESSING OR USING ANY OF THE PRODUCTS AND REMOVE AND DELETE THE APP FROM YOUR DEVICE.

In this Privacy Policy:

“Personal Data” means information that can be used to identify an individual, either from that information alone, or from that information and other information we have access to about that individual.
“Smart Devices” refers to those nonstandard computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart lighting, smart wearable devices, smart air cleaning devices, etc.

The platform for the STARFISH App is powered by one of our service providers, Tuya Inc. (“Tuya”) and Tuya has access to the Personal Data we collect from you. Tuya’s privacy policy can be viewed here . We only collect, use or disclose the personal information of our clients with their consent and as such, the processing of your personal information by Tuya shall be limited to the purposes set out in this privacy policy and of providing the services for which you have engaged us.

If you are located in California, please consult our California Privacy Statement at the bottom of the within document for supplemental information concerning to the collection, use and disclosure of your Personal Data as key differences exist.

If you are located in Canada, please consult our Canada Privacy Schedule for additional information concerning to the collection, use and disclosure of your Personal Data as key differences exist.

What Personal Data do we collect?

In order to provide our Products to you, we will ask you to provide necessary Personal Data that is required to provide you with our Products. If you do not provide your Personal Data, we may not be able to provide you with our Products. We collect the following Personal Data from you:

Information You Voluntarily Provide Us

Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, username, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.
Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

Information We Collect Automatically

Device Information: When you interact with our Products, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.
Usage Data: During your interaction with our Products, we automatically collect data relating to your use of the Products, including, for example, data concerning visits, clicks, downloads, and messages sent/received.
Log Information: When you use the Products, the system and exception log may be uploaded. The log information includes personal information such as your account information that may be included as part of the logs.
Location Information: We may collect information about your real-time precise or non-precise geo-location when you use our Products when the “Geo-Fence” service is turned on. Geo-location information includes: your access SSID (which is a unique ID that is a set of characters used for naming wireless networks) when your device is paired with wifi to set location for family, and where certain settings such as “Geo-fence” are turned on. “Geo-Fence” may be turned on and off in Settings. When “Geo-Fence” is turned off certain features of the app may be unavailable.

Smart Devices Related Information:

Basic Information of Smart Devices: When you connect your Smart Devices with our Products, we may collect basic information about your Smart Devices, such as device name, device ID, online status, activation time, firmware version, and upgrade information.
Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with our Products, we may collect different information reported by your Smart Devices such as but not limited to energy source monitoring information (i.e. socket, lighting).

Purposes and legal basis for processing Personal Data

If you are located in Canada, please consult our Canada Privacy Schedule for additional information about the purposes for which we collect and use your Personal Data as key differences exist.

The purposes for which we may process your Personal Data are as follows:

Provide Our Products: We process your account and profile data, device information, usage data, location information, and information related to your Smart Devices to provide you with our Products that you have requested or purchased. The legal basis for this processing is to perform our agreement with you according to our Service Agreement and Terms of Use.
Improve Our Products: We process your device information, usage data, location information and information related to your Smart Devices to ensure the functions and safety of our Products, to develop and improve our Products, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our agreement with you according to our Service Agreement and Terms of Use.
Non-marketing Communication: We process your Personal Data to send you important information regarding the Products, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications. The legal basis for this processing is to perform our agreement with you according to our Service Agreement and Terms of Use.
Marketing Communication: We will ask you when you first log in to the STARFISH App whether you would like to receive any special offers or promotions relating to our Products. We collect your Personal Data to send you these communications, depending on the options you choose. If you would like to receive updates and offers related to the Products, please log in to your STARFISH account and select “marketing message”. You can unsubscribe to receiving these communications anytime by visiting your “Communication Preferences” in your STARFISH App account, or by clicking “unsubscribe” and/or “update your email preference” at the bottom of any promotional email you receive from us. Please consult the “Managing Your Preferences” section in the Privacy Policy for additional information about unsubscribing to these communications
Personalization: We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of our Products. The legal basis for this processing is your consent.
Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Who do we share Personal Data with?

We may share your Personal Data with the following recipients for the following purposes:

To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.
To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our Products. For instance, your device ID may be shared with Google Assistant for voice control.
To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). Such third party will only be permitted to use your Personal Data for the purposes for which it was collected, as outlined in this Privacy Policy, unless your consent is otherwise obtained.
As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
To subsidiaries or affiliates within our corporate family, to carry out regular business activities.

International Transfers of Personal Data

To facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence.

If you are located in Canada, please consult our Canada Privacy Schedule for information about the circumstances in which we may transfer your Personal Data outside of Canada, the countries outside Canada that may receive your Personal Data and the purposes for which your Personal Data is transferred.

Your Rights Relating to Your Personal Data

If you are located in Canada, please consult our Canada Privacy Schedule to better understand your rights with respect to your Personal Data as a Canadian user as they differ from the below.

We respect your rights and control over your Personal Data. You may exercise any of the following rights via the “Profile – Personal Center” in the STARFISH App:

Request access to the Personal Data that we process about you;
Request that we correct inaccurate or incomplete Personal Data about you;
Request deletion of Personal Data about you;
Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you;
Request transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; and
Opt-out or object to our use of your Personal Data where our use is based on your consent or our legitimate interests.

You do not have to pay a fee and we will aim to respond you within 30 days. If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

Managing Your Preferences:

In this section, we explain how you can manage your preferences relating to some of your Personal Data.

As explained above, we will ask you when you first log in to the STARFISH App whether you would like to receive any special offers or promotions relating to our Products. These communications will be sent to you by Satco. To unsubscribe from any of these communications, and to opt out of sharing certain Personal Data with us, please consult the following: the unsubscribe link and/or “update your email preference” on the bottom of each email, or by selecting “communication Preferences” in your STARFISH, which allows you to adjust the types of notifications you receive.

Do Not Sell My Information:

With your consent, we may share your Personal Data with third parties who use your information for marketing purposes. You can opt out of sharing this information at any time by:

visiting your “Communication Preferences” in your STARFISH App;
sending us an email at starfish@satco.com; or
writing to us at: Satco Products, Inc. 110 Heartland Blvd, Brentwood, New York 11717

Unsubscribe from EMAILS:

You can unsubscribe from receiving our marketing emails by clicking “unsubscribe” and/or “update your email preference” on the bottom of our email page, or by selecting “Communication Preferences” in your STARFISH App account.

Unsubscribe from App Notifications and Text Messages:

You can unsubscribe from receiving notifications from STARFISH, including any text messages from STARFISH, by selecting “Communication Preferences” in your STARFISH App account and turning “Notifications” off.

If you have any questions, concerns or complaints concerning the management of your communication preferences, please contact us at the information provided below under “Contact Us”.

WE DO NOT DISCRIMINATE AGAINST ANY CONSUMER EXERCISING THEIR PRIVACY RIGHTS. IF YOU ARE NOT ABLE TO USE SOME FEATURES OF THE STARFISH APP BASED ON YOUR PRIVACY SETTINGS, IT IS PURELY DUE TO TECHNICAL LIMITATIONS. HOWEVER, CERTAIN PERSONAL DATA IS REQUIRED FOR THE PROVISION OF THE PRODUCTS. IF YOU DO NOT AGREE TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AS SET OUT IN THIS PRIVACY POLICY, DO NOT PROCEED WITH DOWNLOADING, ACCESSING OR USING ANY OF THE PRODUCTS AND REMOVE AND DELETE THE APP FROM YOUR DEVICE.

Security

We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. STARFISH provides various security strategies to effectively ensure data security of user and device. As for device access, STARFISH’s proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization. As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported. As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you should immediately notify us of the problem by emailing starfish@satco.com.

Data Retention

We process your Personal Data for a reasonable period necessary for the purposes set out in this Privacy Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destroy your Personal Data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.

Changes to this Privacy Policy

Our Privacy Policy applies only to STARFISH and not to other companies' or organizations' sites to which we link or to which you otherwise provide your information. Accessing third party websites or sources requires you to leave our website. We do not control those third party websites or any of the content contained therein and you expressly acknowledge and agree that we are in no way responsible or liable for any of those third party websites, including, without limitation, their content, policies, failures, promotions, products, services on or actions of those websites and/or any damages, losses, failures or problems caused by, related to or arising from those websites. STARFISH encourages you to review all policies, rules, terms and regulations, including the privacy policies, of each website that you visit.

STARFISH reserves the right to change this Privacy Policy at any time. We may update this Privacy Policy from time to time to reflect changes to our information practices based on your comment, changes in the law and our need to accurately reflect our data collection and disclosure practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice in the STARFISH App prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued viewing of or use of our website and/or App and your continued transaction of business with STARFISH following the posting of any changes to this Privacy Policy will signify your assent to any such changes or amendments. This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

STARFISH is committed to treating your Personal Data in a confidential manner. We have put in place appropriate physical, electronic, and managerial procedures to safeguard and maintain data security, and correctly use the information we collect.

Dispute Resolution

If you are located in Canada, this section does not apply to you. Please consult our Canada Privacy Schedule if you have any questions, complaints or concerns about our practices or the Canada Privacy Schedule.

Any dispute between you and us regarding the privacy of your personal information is subject to this Privacy Policy and the Service Agreement and Terms of Use applicable to our product or service you use, including limitation on damages, resolution of disputes, and application of the law of the State of New York in a Court of competent jurisdiction located in the Tenth Judicial District of the State of New York.

If you have any questions about our practices or this Privacy Policy, please contact us as follows:

STARFISH

Postal Mailing Address: Satco Products, Inc. 110 Heartland Blvd. Brentwood, New York 11717

Email: starfish@satco.com

How do we use cookies and other tracking technologies?

STARFISH is committed to make your online experience and interaction with our STARFISH Mobile Application as informative, relevant and supportive as possible. One way of achieving this is to use cookies and/or similar techniques, which store information about your visit to our App. We feel that it is very important that you know what cookies and/or other tracking technologies our App uses and for what purposes. This will help protect your privacy, while ensuring our App’s user-friendliness as much as possible. This is a statement about privacy and our use of cookies and/or other tracking technologies – not a contract or agreement.

Please consult our STARFISH Service Agreement and Terms of Use Service Agreement and Terms of Use of STARFISH .

STARFISH uses cookies and/or other tracking technologies to ensure that the App functions properly. Without these cookies and/or other tracking technologies, such functions may not be possible. The App uses cookies and/or other tracking technologies in the following manner: for location purposes to identify, inter alia, the correct server region and to store preferences such as which language should be applied/utilized in the App.

Do we collect data from children?

Protecting the privacy of young children is especially important to us. The Products are not directed to individuals under the age of thirteen (13), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from anyone under the age of thirteen (13) unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from anyone under the age of thirteen (13) without permission from that child’s parent or legal guardian, we will make commercially reasonably efforts to delete that information. If you notice we have collected or processed the Personal Data of anyone under the age of thirteen (13) in error, please contact us at starfish@satco.com.

California Privacy Statement

This California Privacy Statement is for California Residents only and supplements the STARFISH Privacy Policy hereinabove. This policy describes the personal information that STARFISH (“we,” “our,” or “us”) collects in the course of its business, explains how this information is collected, used, shared, and disclosed, describes rights provided by the California Consumer Privacy Act of 2018 (“CCPA”; Effective January 1, 2020) to California Residents (“consumers” or “you”) regarding their personal information, and explains how consumers can exercise those rights.

This Statement reflects our good faith interpretation of the law and its regulations as of the Effective Date, but the CCPA's regulations are not yet complete, and as such, differing interpretations of the law may occur.

With a limited exception, and as noted in other sections of this privacy policy, certain provisions of the CCPA do not apply to:

Certain personal information covered by or collected under industry-specific federal and state privacy laws including, but not limited to, the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, and the Driver's Privacy Protection Act of 1994.
Personal information we receive from you reflecting a communication or transaction between us and another business when you are acting as an employee, owner, director, officer, or contractor of such company, partnership, sole proprietorship, nonprofit, or government agency and you are seeking a product or service from us for the company, partnership, sole proprietorship, nonprofit, or government agency (Business Consumer). We have outlined the limited rights afforded to Business Consumers below.

If You are a California resident, You may have some additional privacy rights, a list is provided below for your reference:

You have the right to know what personal information is collected, used, shared or sold, both as to the categories and specific pieces of personal information.
You have the right to opt-out of STARFISH's sale of your personal information. Consumers are able to direct a business that sells personal information to stop selling that information. Children under the age of 16 must provide opt in consent, with a parent or guardian consenting for children under the age of 13.
You have the right to request the deletion of your personal information.
You have the right to non-discrimination in terms of price or service when you exercise a privacy right under the CCPA.
You have the right to request us to disclose to you, no more than twice in a 12-month period, the personal information about you that STARFISH collects, uses, discloses, and sells during the preceding 12 months, which shall include as follows:

The categories of personal information that we've collected and sold about you or shared for a business purpose with our service providers.
The sources from which we collected such information.

The third parties with whom we've shared that personal information and to whom we've sold that personal information.

The business or commercial purpose for collecting or selling that personal information.
The specific pieces of personal information we've collected about you.

We will not discriminate against you because you exercised your rights under this section of the Privacy Policy.

For purposes of exercising your rights above, please note the following regarding how we collect and use your personal information as described in this policy:

We collect the following categories of personal information: Identifiers; payment information; characteristics of protected classifications under California or federal law; Internet of other electronic network activity information; geolocation data; audio, electronic or visual information.
- Identifiers. This may include a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
- Personal information described in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)). This may include a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
- Characteristics of Protected Classification under California or Federal Law. This may include age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
- Commercial information. This may include records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Geolocation data. This may include physical location or movements.
- Inferences drawn from other personal information. This may include information, data, assumptions, or conclusions derived from facts, evidence, or another source of information or data reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
We may have collected personal information from one or more the following categories of sources:
- You, with respect to both online and offline interactions you may have with us;
- The devices you use to access our websites, mobile applications, and online services;
- Public sources (i.e., databases);
- Social Media Platforms;
- Marketing data from third parties;
- Identify verification and fraud prevention services; and
- Marketing and analytics providers.
We disclose the following categories of personal information for a business purpose: Identifiers; payment information; Internet of other electronic network activity information; geolocation data; audio, electronic or visual information.
We may collect your personal information for the following business or commercial purposes:
- Account Services: We use personal information to offer our account services, including: (1) establishing, maintaining, supporting, and servicing an account you may have opened with us and for which you provided the information or that you may have applied for or established with us; (2) providing services, products, or information you may have requested from us; and (3) performing services such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, or providing similar services on our own behalf or on the service provider's behalf.
- Security and Fraud Detection: We use personal information for our security and fraud detection services including: detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity.
- Improvement of Products and Services: We use personal information to verify, maintain, and improve our products and services.
- Internal Research: We use personal information for our internal research related to technological development and demonstration.
- Advertising and Marketing Services: We use personal information to provide advertising or marketing services.
- Legal Obligations: We use personal information to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- Audits: We use personal information to audit current interactions with you and related transactions (e.g., counting and verifying ad impressions, auditing compliance).
- Commercial/Economic Interests: We use personal information to advance our commercial or economic interest.

We may also use or disclose your personal information as otherwise described to you when collecting your Personal Information or as otherwise set forth in the CCPA.

Disclosing Your Personal Information for a Business or Commercial Purpose

We may disclose and/or exchange your personal information to service providers and third parties in order to carry out specific business or commercial purposes, which may be defined as a sale of information. In the preceding 12 months, we have disclosed the following categories of consumer personal information for business or commercial purposes to service providers and the following categories of third parties: Identifiers; Internet or other electronic network activity; geolocation data.
With respect to each of the categories of Personal Information listed immediately above, we may disclose such Personal Information for a business purpose to the following categories of third parties:
- Affiliates of STARFISH and Satco Products, Inc.
- Service providers
- Select Business Partners
- Third Party Ad Service providers
- Such third parties as our customers or consumers may direct us to disclose their personal information

Selling Your Personal Information for a Business or Commercial Purpose

Do not sell?

We do not respond to “Do Not Sell” requests as we do not track your data across third party websites, nor do we sell your data to third parties to provide targeted advertising. Nonetheless, we aim to make your online experience and interaction with our websites as informative, relevant and supportive as possible. One way of achieving this is to use cookies or similar techniques, which store information about your visit to our site on your computer. For more information on how we use cookies and other tracking technologies, read our Cookie Notice.

Your Rights?

“Right to Know”: You have the right to request that we disclose to you what personal information of yours that we collect, use, and/or disclose.

You have the right to request that we provide you with certain information about the personal information we collect, use, or disclose about you as well as the categories and specific pieces of information that we have collected about you in the 12 months before your submission of a verifiable consumer request.
A household may request to know aggregate household personal information by submitting a verifiable consumer request. Also, unless the household has a password-protected account, if all consumers in a household jointly request access to specific pieces of information for the household, we can individually verify the identity of all the members of the household, and we can verify that each member is a current member of the household, then we will comply with the request.
However, there is certain information that we will not disclose to you. This information includes but is not limited to your Social Security number, driver's license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answer, or unique biometric data generated from measurements or technical analysis of human characteristics. However, if we have collected this type of information about you, we will inform you of that fact and provide you with enough information to determine what was collected.
This right does not apply to Business Consumers.

“Right to Delete:” You have the right to request the deletion of your personal information collected or maintained by us.

You have the right to request that we delete any personal information that we have collected from you and maintained about you. Once we receive and confirm your verifiable consumer request, if we determine that we must comply with a deletion request and delete your personal information from our records, we will also direct any service providers we work with to also delete your personal information from their records. If we store any of your personal information in our archived or back-up systems, we will delete your information once the systems are accessed, restored, and/or used.
A household may request the deletion of aggregate household personal information by submitting a verifiable consumer request. In addition, unless the household has a password-protected account, if all consumers in a household jointly request deletion of household personal information, we can individually verify the identity of all the members of the household, and we can verify that each member is a current member of the household, then we will comply with the request.
Please note that we may deny your deletion request for a number of different reasons, which are identified in the CCPA.
This right does not apply to Business Consumers.

Exercising Your Rights under the CCPA

If you have questions about the foregoing or how to execute your Right to Know and/or Right to Delete in our Privacy Notice or specifically with regard to categories and specific pieces of data processed, categories of sources from which your data is collected by us, categories of third parties with whom we share your data in the preceding 12 months of its collection and the business or commercial purpose for collecting please contact via email at starfish@satco.com. You may also make a verifiable request to exercise your rights by contacting us via the toll-free telephone 1-800-257-2826.

If we cannot verify if you are the California consumer making the request is the consumer about whom we have collected information (or is authorized to act on your behalf) we have the right to deny requests. While verifying your identity we shall generally avoid requesting additional information from you for purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information from you, which shall only be used for the purposes of verifying your identity while you are seeking to exercise your rights under the CCPA, and for security or fraud-prevention purposes. We shall delete any new personal information collected for the purposes of verification as soon as practical after processing your request, except as required to comply with applicable legislation.

An “Authorized agent” means a natural person or a business entity registered with the Secretary of State that a consumer has authorized to act on your behalf and upon the following conditions:

1. You have provided the authorized agent written permission to do so and we could verify this; and

2. You have verified your own identity directly with the business.

Subsection 1 does not apply when you have provided the authorized agent with a valid power of attorney.

We endeavor to timely respond to a verifiable individual, free of charge and in a portable format unless it is excessive, repetitive or material unfounded. If we require more time, we will inform you of the reason thereof and extension period in writing.

Please note that we are only required to respond to your request for access to your personal information twice within a 12-month period.

Non-Discrimination

We will not discriminate against you for exercising your rights under the CCPA. Unless permitted by applicable regulations, we will not charge different prices or rates, deny products or services, provide different products or services or level of quality and/or suggest you may receive the foregoing mentioned.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your data’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to Our California Privacy Statement

We are required by law to update this California Privacy Statement at least once each year. This California Privacy Statement was last updated on 15 Jan,2021 .

Additional California Privacy Rights

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal information we have shared with our third-party providers for their marketing purposes and a list of the third-party providers that have received your information.

If you are a California resident and want a copy of this notice, please submit a written request specifying that you want a “California Privacy Rights Notice” to the following address:

STARFISH

Satco Products, Inc.

110 Heartland Blvd.

Brentwood, New York 11717

Please allow 30 days for a written response.

If you are a minor under 18 and have an account with us, you may ask us to remove reviews or other content that you posted on the site by writing to starfish@satco.com. We will begin to process your request within 30 days. Please note that processing your request does not ensure complete or comprehensive removal of content that you posted.