Privacy Statement - StarStar Mobile

Our Privacy Statement

StarStar Mobile provides consumers a way to easily connect with products and services they may want – anytime, anywhere, on any mobile phone. We are committed to providing a consumer driven experience as we enable consumers to explore and discover businesses with whom we partner to serve consumer needs in their local area, just when they need it.

This privacy statement describes how we collect and use the information you provide when you choose to use our service.

Introduction

StarStar Mobile (“we,” “us,” or “our,”) respects your privacy and we are committed to protecting it.

We require our business customers to adhere to all applicable privacy laws, and to provide appropriate privacy protections and transparency for consumers as to the personal information they collect. For more information, please see our Customer Code of Conduct.

Our Services

We provide our customers who are typically local businesses (“Brands”) with the ability to offer consumers an abbreviated dialing code – a StarStar Mobile number – that a consumer can enter into their mobile phone. Upon entering the number, the consumer is then routed to the desired Brand’s business location or customer service center for a live call with the business whose “StarStar” number they entered. In some instances, the consumer may also receive a text message (SMS) response that can include additional information regarding the Brand sought by the consumer or a landing page where the consumer can further engage with the Brand. For example, fictional customer “Pizza Corporation” invites consumers to dial **Pizza on their mobile phones to be routed to a Pizza Corporation representative for information on their retail outlets or for an enhanced customer service experience.

This can be done on a national level in which case a large business will offer consumers a nation wide product or service through StarStar Mobile or on a more localized level for small businesses with local offerings. In these instances, the caller is routed to a local business or receives a customer experience specific to their local area. StarStar Mobile uses the nearest cellular tower site identification and location information (“Cellular Tower Site”) to route the caller to a business nearest to where they initiated the call. StarStar Mobile does not track or receive a consumer’s location based on exact location of their mobile device.

Information We Collect and Use

StarStar Mobile services are designed with privacy protections embedded into our offerings and we take steps to use the minimum necessary data to provide the services our consumers require.

StarStar Mobile is not a mobile application that is downloaded on a mobile device and we do not use or access the precise geo-location of a consumer’s mobile device. Similarly, StarStar Mobile does not look up the location of a consumer’s mobile device and does not access the location information that a consumer’s mobile network carrier may have. Nor does our service rely on cell tower triangulation which is a more precise estimation of a consumer’s location.

When a consumer chooses to connect with a StarStar customer Brand they see advertised, we connect the consumer with their requested business using the StarStar dialing code the consumer enters. In many cases, a Brand will provide nationwide services, while in other instances, the Brand will be more local. Our most granular location based offering is limited at the county level location based on a Cell Tower Site as noted above. Moreover, since our localization capabilities occur only when a consumer’s call is initiated, StarStar Mobile does not track whether or when a consumer may move between Cell Tower Sites.

StarStar Mobile does not require consumers to provide any personal information beyond that which is necessary for us to connect them to the Brand they have initiated. As a function of the service call a consumer initiates, we may see a public listing appear in our systems similar to a name or “unknown caller” identification that may appear when a consumer receives a call. We do not request a consumer’s name, address or other unnecessary information to complete a StarStar call.

Where appropriate and to better protect consumers’ privacy, StarStar Mobile uses de-identification measures, including anonymization or aggregation of data. When we do, we apply both technological measures and contractual terms with our Brand customers designed to prevent re-identification of anonymous data. If one customer purchases multiple StarStar Mobile numbers for a series of related campaigns, we may share aggregate anonymous information across those groupings of StarStar Mobile numbers to provide metrics about the campaigns’ overall success.

In some cases Brand customers’ advertising campaigns that utilize StarStar Mobile may deliver recurring messages to consumers, and we may partner with advertisers and/or their partner companies to deliver these messages. In these cases, we will securely provide the mobile phone numbers of StarStar Mobile consumers for a given campaign to an advertiser or their partner for the execution of a specific campaign. We only do this under explicit conditions of the MMA, CTIA, our own, and wireless carriers’ policies so that consumers must be made aware that they will receive recurring advertising messages and they will always have the right to opt-out of such messages.

Log Information: The StarStar Mobile platform records certain information each time a consumer uses our platform to call a StarStar Mobile number. These StarStar Mobile call logs may include a person’s mobile telephone number, the number called, as well as information provided by the cellular carrier to process the call, including Cell Tower Site and mobile device identification number. This information is not stored or shared with any third party.

Mobile Landing Page Information: In some cases StarStar Mobile may host a mobile web landing page for a Brand whereby consumers may choose to access a link that will direct them to a Brand page and if the consumer chooses, they could request or provide more specific location information, e.g., clicking on a more precise spot on a map to help find the nearest retail location for the Brand. In such cases, StarStar Mobile may collect additional analytics information related to the consumer’s use of and interaction with the Brand’s landing page(s) using standard mobile analytics tools.

When our Brand customers choose to obtain more precise location information from a consumer’s through their landing page(s) interaction, we require our Brand customers to provide a clear and transparent indication to the consumer including a second “opt in” action to reveal the consumer’s location, similar to what is described in the MMA’s Mobile Advertising Guidelines, available here: https://www.mmaglobal.com/policies/global-mobile-advertising-guidelines.

Information We Share

With Brand customers. For each Brand, StarStar Mobile enables analytics and reporting of the calls that are initiated by consumers and connected to that specific Brand so they have a list of StarStar activity from consumers that chose to connect with them by using the Brand’s StarStar dialing code. This information may include: date/time-stamp of the call; the mobile number used for the StarStar connection; county or national-level market; carrier name; and the Brand customer’s campaign name.

With carrier partners: We share information collected from StarStar Mobile numbers calls with carriers for the purposes of revenue determination and service troubleshooting.

For Legal Process: We may disclose information we maintain in our systems if we reasonably believe the disclosure is required by law, if we reasonably believe the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of StarStar Mobile or our customers.

Text Messages And Opt-Ins: No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Security

StarStar Mobile applies appropriate administrative, technical, and physical safeguards throughout our systems and organization designed to protect the information within our systems from loss, theft, or compromise. However, no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee the security of your information.

If you have any questions about the security of your information, please contact us as described below.

Retention

We retain information for a variety of operational and regulatory purposes, and properly delete and destroy data when it is no longer necessary for one of our business functions.

Children’s Privacy

StarStar Mobile’s services are not designed for children under the age of 13, and we do not knowingly collect any personal information from children under the age of 13. If you become aware of a child under the age of13 having provided our website or services with personal information, please contact us as described below so that we may promptly delete the child’s information from our records.

Changes to this Statement

We will update this Privacy Statement from time to time in response to legal, business or operational changes. We encourage you to periodically review this Privacy Policy to be informed of how we are collecting and using your information.

Contact Us

For any questions regarding privacy and StarStarMobile, please contact us:

StarStar Mobile
Corporate HQ
7495 W. Atlantic Avenue
Suite 200-324
Delray Beach, FL 33446
From your Cell: **MOBILE
Phone: 954-607-6153
Email: privacy@StarStarMobile.com