Please use the Glossary, in section 27, to understand the meaning of some of the terms used, particularly with reference to the European General Data Protection Regulations and the UK Data Protection Act 2018.
Our Contact Information
Full Name of Legal Entity
Starfish Technologies, LLC (dba Raven)
Attention: Compliance Department
11150 S Wilcrest Drive
Houston, Texas 77099
If you are based in the UK or Europe, you have the right to make a complaint at any time to your local Data Protection Authority. We would, however, appreciate the chance to deal with your concerns before you approach your local Data Protection Authority so please contact us in the first instance. If required, please see the below information as to how to contact your local Data Protection Authority.
- Where to Report Complaints
1.1. UK Residents
The UK Data Protection Authority and regulator for data protection issues is the Information Commissioner's Office (“ICO") (www.ico.org.uk).
1.2. European Residents
Each member state has a designated Data Protection Authority, more information about your national Data Protection Authority can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
1.3. United States Residents
If you have a complaint, please contact us at firstname.lastname@example.org or give us a call at the number listed above.
2. Important Information and Who We Are
2.2. Website Not Intended for Children
Our Website is not intended for children and we do not knowingly collect data relating to children. If you are under 18, do not register on the Website, make any purchases through the Website, use any of the interactive or public comment features on the Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us via the contact details below.
2.3. Other Privacy Policies
2.5. Data Privacy Manager
2.7. Third-Party Links
WE DO NOT PROVIDE ANY THIRD-PARTY LINKS TO EXTERNAL WEBSITES ON OUR WEBSITE.
3. The Type of Data We Collect About You
3.1. Personal Data - 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:
3.2. Identity Data - includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
3.3. Contact Data - includes billing address, delivery address, email address, and telephone numbers.
3.4. Financial Data - includes bank account and payment card details.
3.5. Transaction Data - includes details about payments to and from you and other details of products and services you have purchased from us.
3.6. 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.
3.7. Profile Data - includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
3.8. Usage Data - includes information about how you use our website, products, and services.
3.9. Marketing and Communications Data - includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- The Type of Data We Don’t Collect About You
4.1. Special Categories of Personal Data - 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 offenses.
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.
6. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through
6.1. Direct interactions - You may give us your Identity, Contact, and Financial 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, or purchase, our products or services;
● create an account on our Website;
● 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.
6.2. 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 also see our Cookie Notice below for further details.
6.3. Third Parties or Publicly Available Sources
We will receive personal data about you from various third parties as set out below:
6.4. Technical Data from the Following Parties
● Analytics providers, such as Google Analytics, based outside the UK and EEA;
● Email providers, such as Drip, based outside the UK and EEA; and
● Contact and Transaction Data from providers of technical, payment and delivery services, such as Shopify, Amazon, and PayPal, based outside the UK and EEA;
7. How We Use Your Personal Data
7.1. We will only use your personal data when the law allows us to.
7.2. Please see section 27 (Glossary) below to find out more about the types of lawful basis that we will rely on to process your personal data.
7.3. Most commonly, we will use your personal data in the following circumstances
● Where we need to perform the contract that we are about to enter, or have entered, into with you.
● 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.
● Where we need to comply with a legal obligation.
Consent Required Before We Send Third-Party Direct Marketing Communications 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 selecting unsubscribe on the communications we send, by going into your Raven Cloud account under the My Account section and selecting the unsubscribe button, or contacting us at email@example.com.
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, where appropriate, identified what our legitimate interests are. Please 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, where more than one ground has been set out in the table below, you need details about the specific legal ground which we are relying on to process your personal data.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer.
Performance of a contract with you.
To process and deliver your order (or to deliver our services to you), including
(a) Manage payments, fees, and charges; and
(b) Collect and recover money owed to us.
(e) Marketing and Communications
(a) Performance of a contract or purchase order with you.
(b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey.
(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 product reviews and/or to complete a survey.
(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 and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
(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 reorganization or group restructuring exercise).
(b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
(e) Marketing and Communications
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 Website, products/services, marketing, customer relationships, and experiences.
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.
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business).
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
10.1. 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”).
10.2. Requested Information/ Customer Who Has Not Opted Out - You will receive email marketing communications from us if you have requested information from us or purchased goods or services from us, and you have not opted out of receiving that marketing.
10.3. Third-party marketing - WE DO NOT SHARE YOUR PERSONAL DATA FOR ANY THIRD-PARTY MARKETING PURPOSES. If that ever changes we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us at firstname.lastname@example.org or giving us a call at 1-800-713-9009. Additionally, you can click the unsubscribe button in any marketing emails and/or text messages. Lastly, you can go into your Raven Cloud Account under the My Account section and select the unsubscribe button. When you opt-out of receiving these marketing messages, this will not apply to the personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions.
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 at email@example.com. 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.
14. Disclosures of Your Personal Data
We may share your personal data with the parties set out below for the purposes set out in the Purposes for which we will use your personal data table above.
14.1. Internal Third Parties - as set out in the Glossary.
14.2. External Third Parties - as set out in the Glossary.
14.3. Specific Third Parties - as set out in the Glossary.
14.5. Limited Purpose Use - 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 and applicable law.
15. International Transfers
15.1. US Servers - Raven, our networks and servers are based in the United States and so, if you are based outside of the United States, it is likely that providing you with our services will involve transferring your data internationally, specifically outside the UK and/or the EEA.
15.2. Third-Party Service Providers Outside of the UK/EEA - In addition, some of our external third parties are based outside the UK and/or EEA so, again, if you are based outside the United States their processing of your personal data will involve transferring your data internationally, specifically outside the UK and/or the EEA.
15.3. Personal Data Safeguards - Whenever we transfer your personal data out of the UK and/or the EEA, we ensure a similar degree of protection is afforded to it as would be by the European General Data Protection Regulations and the UK Data Protection Act 2018, by ensuring at least one of the following safeguards is implemented:
15.3.1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
15.3.2. 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.
15.4. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
16. Data Security
16.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized 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.
16.2. 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.
16.3. For example, we encrypt your personal information when it is stored in our data centers. In addition, sensitive information such as credit card number and password information that we request from you to register for our services is protected with encryption, such as Secured Socket Layer (SSL) protocol, during transmission over the Internet. The servers on which personal information is stored are kept in a controlled environment with limited access.
16.4. You may access your account information and our service only through the use of an individual user ID and password. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. Extra precautions may be taken by enabling two-factor authentication (2FA) for your account. We ask you not to share your password with anyone. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.
17. Data Retention
17.1. How Long Will You Use My Personal Data For? - We will only retain your personal data for as long as reasonably necessary to fulfill 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 of our relationship with you.
17.2. To determine the appropriate retention period for personal data, we consider the jurisdiction, amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized 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.
17.3. By law, for any UK data, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
17.4. In some circumstances you can ask us to delete your data: see the section called, Your Legal Rights in the UK and Europe, below for further information.
17.5. In some circumstances we will anonymize 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.
18. Your Legal Rights in the UK and Europe
If you are based in the UK or within the EEA, under certain circumstances, you have rights under data protection laws (European General Data Protection Regulations and the UK Data Protection Act 2018) in relation to your personal data, including the right to:
18.1. Request Access to Your Personal Data - (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.
18.2. Request Correction of Your Personal Data - that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
18.3. Request Erasure of Your Personal Data - This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local laws. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which we will tell you about, when and if applicable, at the time of your request.
Object To Processing Your 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 want to object to processing on this ground, as you feel it impacts 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 Your Personal Data
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
20.1. If you want us to establish the data's accuracy.
20.2. Where our use of the data is unlawful but you do not want us to erase it.
20.3. 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.
20.4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request Transfer Of Your Personal Data
If you would like to request a transfer of your personal data to you or to a third party we will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please 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.
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 certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
22.1. If you wish to exercise any of the rights set out above, please contact us using the details in the section titled, Our Contact Information.
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.
26.1. Lawful Basis -
26.2. Legitimate Interest - means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
26.3. Performance of Contract - means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
26.4. Comply with a Legal Obligation - means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- External Third Parties
27.1. Service providers acting as processors based in the United States who provide IT, Website, and system administration services.
27.2. HM Revenue & Customs, regulators, and other authorities acting as processors based in the United Kingdom or other foreign countries who require reporting of processing activities in certain circumstances.
28. Cookie Notice
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
● Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
● Information about your computer and internet connection, including your IP address, operating system, and browser type.
28.2. Behavioral Tracking - We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For information on how you can opt-out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking please contact us at firstname.lastname@example.org or give us a call at 1-800-713-9009.
28.3. De-Identified Information - The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
● Estimate our audience size and usage patterns.
● Store information about your preferences, allowing us to customize our Website and products according to your individual interests.
● Optimize product performance for your needs.
● Recognize you when you return to our Website.
28.4. Technologies We Use - The technologies we use for this automatic data collection may include:
● Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see the section below, titled, Choices About How We Use and Disclose Your Information.
● Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.
29. California Consumer Privacy Act of 2018 (“CCPA”) & California Consumer Privacy Rights Act of 202 (“CPRA”)
29.1. California Consumers Rights and Choices
● Right to Know
● Right to Delete
● Right to Opt-Out
● Right to Opt-In
● "Do Not Sell My Personal Information"
29.2. Right to Know - California Consumers have the right to request that we disclose certain information to them about our collection and use of their personal data over the past 12 months (the “right to know”). Once we receive a request from a California Consumer we will confirm their identity, after which time we will go forward with processing their request.
29.3. Right to Delete - California Consumers have the right to request that we delete any of their personal information that we collect from them, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies.
29.4. *We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
29.5. Exceptions to Right to Delete Requests - We may deny your deletion request if retaining the information is necessary for us or our service providers to:
● Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
● Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
● Debug products to identify and repair errors that impair existing intended functionality.
● Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
● Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
● Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement if you previously provided informed consent.
● Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
● Comply with a legal obligation.
● Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
29.6. Exercising Your Rights to Know or Delete - To exercise your rights to know or delete described above, please fill out the attached CCPA Consumer Request Form for California Residents then submit a copy of it to us at email@example.com.
29.7. How to Designate an Authorized Agent - Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. To designate an authorized agent, please contact us at firstname.lastname@example.org.
29.8. You may also make a request to know or delete on behalf of your child by contacting us at email@example.com.
29.9. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
● Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
● Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
29.10. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You do not need to create an account with us to submit a request to know or delete.
29.11. We will only use personal information provided in the request to verify the requestor's identity or authority to make it.
29.12. Response Timing and Format - We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at firstname.lastname@example.org.
29.13. We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
29.14. We will deliver our written response by mail or electronically, at your option.
29.15. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
29.16. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
- Personal Information Sales Opt-Out and Opt-In Rights
30.1. *We do not sell your personal information.
30.2. Right to Opt-Out - If that ever changes California Consumers would have the right to direct us to not sell their personal information at any time by contacting us at email@example.com (the "right to opt-out").
30.2.1. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us at firstname.lastname@example.org.
30.2.2. Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by emailing us at email@example.com.
30.2.3. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with that request.
30.3. Right to Opt-In - Likewise, California Consumers would also have the right to give us their affirmative authorization to sell their personal information (the "right to opt-in").
We will not discriminate against you for exercising any of your CCPA or CPRA rights.
- Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write us at 11150 S Wilcrest Drive, Ste 200, Houston, TX 77099.