(Last Updated August 16, 2021)
For the purpose of the processing personal data, Press Start Leadership may engage data processors and/or, at its sole discretion, hire other persons to perform certain functions on behalf of Press Start Leadership. In such cases, Press Start Leadership shall take necessary measures to ensure that such data is processed by the personal data processors in accordance with instructions of Press Start Leadership and applicable legislation. Press Start Leadership shall also require personal data processors to implement appropriate measures for the security of personal data. In such cases, Press Start Leadership shall ensure that such persons will be subject to the non-disclosure obligation and will not be able to use this information for any other purpose, except to the extent necessary to perform the functions assigned to them.
The following is general Information on Press Start Leadership privacy practices. Please read our privacy statement and let us know if you have any questions.
- Personal information we collect about you PIPEDA
- Types of data collected
- Sweepstakes and other promotion
- Online surveys
- How we collect your data
- Cookies and other technologies
- How we use your information.
- Transfer of Information to Malta and Other Countries
- California / Delaware Do Not Track Disclosures
- Where we store your information
- How we secure information we collect
- Additional EU Disclosures
- Provision of Personal Data and failure to provide Personal Data
- How is personal information disclosed?
- How long we keep information
- EU-US and Swiss-US Privacy Shield
- Marketing information:
- How to access and control your information
- Consent to provide personal information
- Transfer to third parties
- Your rights as a data subject
- Privacy shield
- Legal bases for processing (for EEA users):
- Our COPPA policy towards children
- How we protect your information
- Residents of California
- Your right to withdraw consent
- Opting out
- GDPR Data Privacy User Rights
- Data portability
- About security and personal information
- Complaints to a data protection authority
- Contact us
2. Personal information we collect about you (PIPEDA)
According to the personal information protection and electronic documents act, 2000 (PIPEDA), “personal information” means information about an identifiable individual. The information you provide to Press Start Leadership is considered personal data it is possible to relate it back to you through your name, address, e-mail address, telephone number and any other information that can identify you.
If information cannot be related to an identifiable individual it is considered anonymous information. Whenever possible, Press Start Leadership works with anonymous information. This privacy statement does not apply to anonymous information.
3. Types of data we collect from you
Personally Identifiable Information (PII). We collect information you provide directly to us. For example, we collect information when you participate in any interactive features of the Services, fill out a form, make a purchase, participate in a contest or promotion, communicate with us via third party social media sites, interact with a message board, request customer support, use our Platform or otherwise communicate with us. The types of information we may collect include:
- Identifiers, such as your full name, email address, unique personal identifier, online identifier, internet protocol address,
- Payment and Billing information
- any other information you choose to provide
Sensitive PII. In certain circumstances, such as when you purchase our service, you may provide a credit, debit, or payment account number, or other payment information to our payment gateway provider which we recognize as more sensitive than other PII.
Anonymous Data. Some of the Data that we acquire cannot identify, distinguish or trace you or your Device, even if combined with other identifying information, and some Data that could be considered PII when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your Device, but is instead used in an anonymous way, often aggregated with other anonymous Data about other users.
Additionally, we may also collect certain other types of information that, along with Identity Data and Contact Data, may be considered and specifically named “Non-Public Information” or “Personal Data” in certain jurisdictions, including the European Union (“EU”).
In addition to the above, we may collect information, and/or use the information we collect, in the following specific ways:
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW
4. Sweepstakes and Other Promotions
From time to time, we may offer sweepstakes or other promotions on our website and Platform. If you enter a sweepstakes or promotional contest, we will ask you to provide information about yourself (such as your name, phone number, address, date of birth, and email address). Among other things, we will use this information to contact you if you win, and we may also use this information for marketing purposes. We may share this information with any co-sponsor of the contest or sweepstakes; we will identify the co-sponsor in the contest rules. If you do not want us to collect the information requested in the contest or sweepstakes registration form or to provide it to co-sponsors, please do not enter the contest or sweepstakes.
5. Online Surveys
From time to time, we survey our users to measure their satisfaction with our website and Platform and other sites and to help us learn more about our audience and how they interact with our website and Platform. Third-party research firms often conduct these surveys on our behalf. We use the survey results to help us improve the services we offer to you. We will take the information you provide and aggregate it on an anonymous basis with data collected from other survey participants. We may use and disclose that pool of anonymous information as we see fit, without identifying you personally.
6. How we collect your data
When you access or use our Services, we automatically collect information about you, including:
- Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
- Clickstream Data: As you use the Internet, a trail of electronic information is left at each website and Platform you visit. This information, sometimes referred to as “Clickstream Data,” can be collected and stored by a website and Platform’s server. For example, Clickstream Data can tell the type of computer and browsing software you use and the address of the website and Platform from which you linked to the website and Platform. The Website and Platform may collect and use Clickstream Data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our website and Platform, how visitors navigate throughout the Website and Platform and how we may tailor our website and Platform to better meet the needs of visitors. This information often will be used to improve our Website and Platform and our services. Any collection or use of clickstream data will be anonymous and aggregated and will not intentionally contain any Personal Information.
Be Careful Publicly Posting PII. Please be aware that Content and PII that you disclose in publicly accessible portions of the Service may be available to other users, and may also be made available outside the Service by third parties, so you should be mindful of all PII, especially sensitive PII, that you may wish to post.
7. Cookies and other technologies
Most browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen will tell you how to do this. We also give you information about disabling cookies. However, you may not be able to take full advantage of our web site if you do so.
A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser or exit the site. Others are used to remember you when you return to the Platform and will last for longer. Please see our cookies policy page
8. How we use your information
We use the information we collect to provide, maintain and improve our Services, such as to administer your account and to provide you with insights to help you optimize your use of our Platform.
We may also use the information we collect to:
- Provide and deliver the services you request, process transactions and send you transaction-related information, including confirmations and invoices,
- Send you technical notices, updates, security alerts and support and administrative messages;
- Respond to your comments, questions and requests and provide customer service;
- Communicate with you about products, services, offers, promotions, rewards and events offered by Press Start Leadership and others, and provide news and information we think will be of interest to you;
- Monitor and analyze trends, usage and activities in connection with our Services;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
- Debug to identify and repair errors impairing existing intended functionality;
- Undertake internal research for technical development and demonstration;
- Undertake activities to verify or maintain the quality or safety of a service owned, manufactured, manufactured for, or controlled by Press Start Leadership, and to improve, upgrade, or enhance the service owned, manufactured, manufactured for, or controlled by Press Start Leadership;
- Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Press Start Leadership and others;
- Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests; and
- Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards; and
Please keep in mind that Press Start Leadership does not trade or sell your personal information.
9. Transfer of Information to and Other Countries
In order to provide you with the Services you purchased or that you request from us, information about you may be transferred to Press Start Leadership locations in Malta as well as countries where our service providers may be based. In some cases, information about you may be transferred to or accessed from other countries, including when you consent and allow us to do so, where it is required in order for us to provide Services to you and when we need to do so to provide functions like product support, troubleshooting and gaining insights into the usage patterns of our Services. When information about you is transferred to countries other than your home country, you may not have the same rights and protections as you do under local law. Any international transfers of such information will be done in accordance with applicable law.
10. California / Delaware Do Not Track Disclosures
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, Press Start Leadership do not monitor or take any action with respect to these signals or other mechanisms.
11. Where we store your information
Press Start Leadership has a data privacy officer who is responsible for ensuring that your personal information is collected, used, disclosed (shared) and retained in compliance with applicable privacy regulations.
However, the data that we collect from you may be transferred to, and stored at, a destination outside the European economic area (“EEA”) that may not be subject to equivalent data protection law.
12. How we secure information we collect
Information storage and security
We use industry standard technical and organizational measures to secure the information we store.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the internet, we cannot guarantee that data, during transmission through the internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
If you use our server or data center services, responsibility for securing storage and access to the information you put into the services rests with you and not Press Start Leadership. We strongly recommend that server or data center users configure SSL to prevent interception of data transmitted over networks and to restrict access to the databases and other storage points used.
13. Additional EU Disclosures
If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to address your concerns before you approach your Supervisory Authority so please contact us in the first instance. If you are situated in the EU and have a complaint, please contact our privacy team at Christopher@pressstartleadership.com
14. Provision of Personal Data and failure 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 our services). In this case, we will not be able to provide services to you
15. How is personal information disclosed?
The site may use your Personal Information for any purpose which the site may deem fit in its sole discretion.
Individuals and/or organizations to which we may disclose personal information include:
- the public if you advertise with Press Start Leadership or use publicly available Communications Services
- Individuals and organizations that advertise with Press Start Leadership if you submit an enquiry with Press Start Leadership. If you do not want Press Start Leadership to disclose your personal information to these individuals and organizations, please do not submit enquires.
Depending on your enquiry these may include:
- private advertisers
- operators of Linked Sites
- outsourced service providers who assist Press Start Leadership to provide its services including:
- information technology providers
- marketing and market research advisers
- professional advisers
- organizations involved in a sale/transfer of Press Start Leadership assets, business, or shares
- government and regulatory authorities as required by law
Except as provided herein and as required by law, your Personal Information will not be made available to third parties without your consent.
16. How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
17. EU-US and Swiss-US Privacy Shield
In connection with Press Start Leadership’s processing of personal data (as defined by European law) it receives from the European Union (“EU“) or Switzerland, we comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (together “Privacy Shield“) with respect to personal data we process from the EU or Switzerland and transfer to Malta. For more information about the Privacy Shield, and to view our certification, please visit the Privacy Shield website. We remain responsible and liable under the Privacy Shield for any personal data that we share with third parties for external processing on our behalf, as described in the “Sharing of Information” section above, unless we prove we are not responsible for the event giving rise to the damage. If you have an inquiry regarding our adherence to the Privacy Shield, we encourage you to contact us at Christopher@pressstartleadership.com. We are subject to the investigatory and enforcement authority of the Malta. You may also refer your complaint free-of-charge to our designated Privacy Shield dispute resolution provider. In certain circumstances, the Privacy Shield provides the right to invoke binding arbitration to resolve complaints.
18. Marketing information:
if you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our services, such as when you last opened an email from us or ceased using your Press Start Leadership materials. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
19. How to access and control your information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.
20. Consent to provide personal information
We inform you when we need to collect your personal information and why we are collecting it.
Press Start Leadership only collects information from you after you give us your consent. The only exception is when the law requires the collection, use or disclosure of a person’s information without consent.
Providing us with personal information is entirely voluntary. By giving us your personal information, you consent to allow us to use and disclose your personal information as described to you. If you do not agree with the use and disclosure of your information, please do not provide us with your personal information. Some of our services can only be offered if you provide personal information so, if you choose not to provide your information, we may not be able to provide you with those services.
You may withdraw consent at any time. You will be informed of the effect that withdrawing your consent will have.
Your withdrawal of consent will only apply from the point that you withdrew consent. Your withdrawal of consent is not retroactive.
This means we will not remove information that has already been disclosed.
21. Transfer to third parties
To facilitate the purposes of Web related Service, personal data may be shared in the normal course and scope of business with third parties to whom Press Start Leadership has chosen to outsource work. In the event that personal data is transferred to a third party, Press Start Leadership requires in its agreements with third parties that adequate privacy precautions are taken that provide the same level of privacy protection as is required by the principles of the privacy shield. In certain circumstances, Press Start Leadership may remain responsible and liable under privacy shield principles if such third parties process the personal data in a manner inconsistent with the privacy shield principles
22. Your rights as a data subject
In some jurisdictions (for example, the member states of the European Union) you may be entitled to certain rights in and to your personal data, subject to certain conditions and exceptions contained in applicable law. These rights may include the following:
- Request us to confirm whether your personal data is processed by us, and if we do, to obtain access to your personal data and certain information about it.
- Require the correction of your personal data if it is inaccurate or incomplete.
- Direct us to stop processing your personal data under certain circumstances.
- Erase or delete your personal data, for example, where the data is no longer needed to achieve the purpose for which it was collected.
- Restrict the further processing of personal data
- Request us not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (we currently do not engage in such processing and will notify you prior to doing so).
- Request to receive your personal data for transmission to, or to directly transmit to, another data controller in a structured, commonly-used and machine-readable format.
To protect your privacy and the security of your personal data, we will take reasonable steps to verify your identity before complying with such rights requests.
23. Privacy shield
24. Legal bases for processing (for EEA users):
If you are an individual in the European economic area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the services, including to operate the services, provide customer support and personalized features and to protect the safety and security of the services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, and this may mean no longer using the services
25. Our COPPA policy towards children
The services are not directed to individuals under the age of 13. We do not knowingly collect personal information from children under 13. Press Start Leadership complies with both the Children’s Online Privacy Protection Act of 1998 (COPPA) and, with regard to EU data subjects, with GDPR. While children under the age of (13) may use the site only with the consent of his or her parent or legal guardian, please be advised that this site is not directed or otherwise promoted for use by children under the age of (13).
26. How we protect your information
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using TLS 1.3 (a strong protocol), x25519 (a strong key exchange), and aes_128_gcm (a strong cipher). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our platforms; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
27. Residents of California
If you are a resident of California, you have certain rights and protections under the California Consumer Privacy Act (“CCPA“).
28. Your right to withdraw consent
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. You can also change your marketing preferences at any time as described in ‘our promotional updates and communications’ section.
You can also exercise the rights listed above at any time by contacting us at Christopher@pressstartleadership.com. If your request or concern is not satisfactorily resolved by us, you may contact our data protection officer, at Christopher@pressstartleadership.com
He can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
29. Opting out of messages from us
To opt-out of any future promotional messages from us, you should unsubscribe in the body of the promotional message that was sent to you (found at the bottom of the email) or send an unsubscribe request to us at Christopher@pressstartleadership.com. We will process your request within a reasonable time after receipt.
30. GDPR Data Privacy User Rights
If you are an EU resident and Press Start Leadership is processing, and/or transmitting your personal data, then you – as an “EU data subject” – benefit from the following rights and privileges under the General Data Protection Regulation (GDPR):
- Right of Access: you have the right to obtain from us, as controllers, confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the following personal data and information:
- the purposes of the processing;
- the categories of personal data concerned; i.e name, email, phone number etc
- the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations’;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing; (f) the right to lodge a complaint with a supervisory authority (for a list of supervisory authorities, see https://edpb.europa.eu/about-edpb/board/members_en);
- where the personal data are not collected from you, any available information as to their source;
- The existence of automated decision-making, including profiling, along the lines indicated by Article 22(1) and (4) GDPR, and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
- Right to Rectification: you have the right to obtain from us without undue delay the rectification of inaccurate personal data concerned, provided during registration by him or her. Taking into account the purposes of the processing, the user have the right to have request his incomplete personal data be completed, including by means of providing a supplementary statement.
- Right to Erasure (“Right to be Forgotten): you have the right to obtain from us the erasure of your personal data without undue delay, and we have the obligation to erase personal data without undue delay when: a) your data are no longer necessary for the purposes for which they were collected; b) you had consented to the processing; c) you have objected to the processing, as per below; d) your persona data had been unlawfully collected; e) your personal data need to be erased as a matter of compliance with a legal obligation.
- Right to Restriction of Processing: you have the right to obtain from us the restriction of processing if you: a) contest the accuracy of the personal data, until this is verified; b) the processing is unlawful but you don’t want erasure; c) we no longer need the personal data, but you require them to establish, exercise to defend a legal claim; d) you have objected to processing but there is a need to verify whether our legitimate grounds override your rights to object.
- Right to Data Portability: where your personal data have been provided on the basis of your consent or for the performance of a contract, and their processing occurs in an automated way, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data– or have directly transmitted – to another controller.
Right to Object: you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data based on a legitimate ground point (e) or (f) of Article 6(1), including profiling based on those provisions. In this case, we can no longer process your personal data unless we show that there is a compelling legitimate ground for the processing which override your interests, rights and freedoms or for our establishment, exercise or defense of legal claims.
31. Data portability
Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create on the spaces you under your sole control, like your personal bitbucket repository
32. Security and personal information
The site uses its best endeavors to store all Personal Information on servers with restricted access, and all electronic storage and transmission of Personal Information are secured with appropriate security technologies. Not to withstand the foregoing, the site cannot guarantee that such precautions would render the site and its servers immune to security breaches.
33. Complaint to a data protection authority
You have the right to submit a complaint concerning our data processing activities to our data protection officer
34. Contact us
If you have any queries regarding our data collection and protection practices or your rights, please do not hesitate to contact our data protection officer, at Christopher@pressstartleadership.com