Privacy Policy

1. HOW WE COLLECT AND USE INFORMATION ABOUT YOU

Information StartNoobs provide us directly:

We ask for certain information from current and former students seeking volunteer opportunities with nonprofits in exchange for repayment of their education loans ("StartNoobs"), such as your first and last name, date of birth, student identification number, e-mail address, school name, student loan account information, tuition account information, and location. For certain purposes, we may also request the last four digits of your social security number, and other private information provided through your university's Learning Management System (LMS) provider, which will be encrypted and stored securely in compliance with applicable data protection laws. We may also request information concerning your interests and work experience. Please note that it is always your choice whether or not to provide us with information about yourself. Please do not do so unless you consent to our Terms of Use, including this Privacy Policy. You must not submit information about any other person without their explicit prior written consent. By submitting information about another person, you hereby represent and warrant to us that you have obtained such person's express consent, including their acknowledgment and acceptance of this Privacy Policy and our Terms of Use.

We use the information you provide to us in order to operate, maintain and provide the Service to you, including for the purpose of communicating with you, verifying that you are eligible to access and use the Service, facilitating connections between you and non-profit users for the purpose of enabling StartNoobs to find service opportunities, conducting internal research and analysis about the Service and the Site, and disbursing funds to the appropriate academically related accounts upon satisfactory completion of services provided to our nonprofit users. If we approve your application to become a StartNoob and you participate in service opportunities, we may also keep records of the service projects that you have been matched with through the Service in order to suggest additional service opportunities that may be of interest to you.

Information we collect from donors and nonprofits:

We (or our third party service providers) also collect certain information from donors and nonprofit users that is necessary to provide the Service. For example, in order to submit payments, our donors are asked to provide our third party payment processor with credit card information, and they may also be asked to provide tax identification numbers. We request that nonprofit users provide documentation that we need in order to verify their active 501(c)(3) status.

Retaining or discarding your information:

We retain your information in accordance with our data retention policy and applicable laws. Personal data is retained for 7 years after account closure for user accounts, 7 years for financial records, and 3 years for communications. You should maintain your own records of any information submitted to us.

Legal basis for processing:

We process your personal information based on one or more of the following legal grounds: (1) your consent; (2) contractual necessity (i.e., processing that is necessary for the performance of a contract with you, such as your agreement to use our services); (3) compliance with a legal obligation; and (4) our legitimate interests, provided that such processing does not outweigh your rights and freedoms. We may also process your personal information where necessary to protect your vital interests or those of another person.

Information we collect:

We collect various categories of personal information from you and third parties. This includes, but is not limited to: contact information (such as name, email address, and phone number), demographic information, educational information (such as enrollment status and loan details), device information (such as IP address, browser type, and operating system), usage data, and any other information you choose to provide. We also collect analytics data and log file information as detailed below.

Analytics information:

We may directly collect analytics data (such as page views, session duration, bounce rates, device information, browser type, IP address, referral sources, and user interaction metrics), or use third-party analytics tools, to help us measure traffic and usage trends for the Service and Site. These tools collect information sent by your browser or device, including the pages you visit and other information that assists us in improving the Service and Site. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.

Location Information:

When you visit StartNoo.com using a mobile device, we may use technology that determines your location in order to assist in notifying you of nearby service opportunities. We will not share your location with any third parties, without your consent or affirmative choice to share your location. You can disable location services for our website through your device settings at any time.

Use of certain service type information we collect about you:

We use or may use cookies, log files, web beacons (clear gifs), and device identifier information (each described further below). You can manage your cookie preferences through your browser settings and opt out of non-essential cookies at any time through our Cookie Management Tool to: (a) provide, monitor, and improve the effectiveness of our Service and Site; (b) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; and (c) diagnose or fix technology problems.

Cookie Information and Your Choices:

When you first visit the Service and Site, you will be presented with a cookie consent banner allowing you to accept or decline non-essential cookies. We may send one or more cookies – small text files containing strings of alphanumeric characters – to your computer that uniquely identify your browser to enhance your navigation through this Site or the Service. A cookie may also convey information to us about how you use the Service and Site (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service and Site over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to this Site. Persistent cookies can be removed by following your web browser's directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Service may not function properly if the ability to accept cookies is disabled.

Log file information:

Log file information is automatically reported by your browser or device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

Clear gifs/web beacons information:

When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

Device identifiers:

When you access the Service by or through a mobile device (including smart-phones or tablets), we may access, collect, monitor or remotely store one or more "device identifiers," such as a universally unique identifier ("UUID"). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by StartNoo. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device to enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

Commercial and marketing communications:

You may receive communications from StartNoo in connection with the Service and Site. Communications could include contracts, notices, records, and other written communications. By using this Site or the Service, you consent to receive such communications electronically. StartNoo is not responsible for any automatic filtering you or your network provider may apply to email communications that we send to the email address you provide us. Further, by using this Site and registering for an account, you consent to receive electronic communications for all notices required by law or regulation to be received in paper written form. You may not opt out of Service-related communications (e.g., purchase and billing confirmations and reminders, changes/updates to features of the Service, and technical and security notices).

You can choose to stop receiving promotional email communications from us by clicking on the "unsubscribe" link provided in such communications. We make every effort to promptly process all unsubscribe requests. If you have any questions about Service-related communications or unsubscribing from StartNoo communications, you can contact us directly at privacy@StartNoo.com.

StartNoo still reserves the right, in our sole discretion, to communicate with you via U.S. Postal Service and other third-party mail or courier services using the address under which your account is registered. For this reason, it is important that you keep all contact information up to date, including your physical address, mailing address, and electronic mail address.

You may withdraw your consent to receive electronic communications, by mailing a notarized letter to StartNoo, LLC, 7901 4th Street N, St. Petersburg, Florida 33702. Should you withdraw, you will no longer be able to use the Service. Such withdrawal will not apply to any communications sent by us prior to our receipt of your notice of withdrawal.

2. SHARING AND VISIBILITY OF YOUR INFORMATION

We will not rent or sell your information to third parties outside StartNoo and its group companies (including any parent, subsidiaries and affiliates) without your consent, except as noted below.

Who we may share your information with:

We may share your information with third parties to the extent necessary for the purpose of providing the Service, including integration within your university's Learning Management Systems (LMS). This may include sharing service-learning data, service opportunity participation data, assessment information from nonprofits or students, as required for the functioning of the Service, and information needed to process tuition payments or payments towards student loan lenders. For example, we may share information that you provide to us with loan servicers and universities for the purpose of verifying the accuracy of the information you provide or to confirm your eligibility to participate in the Service or to have funds disbursed toward your accounts. Access to your information by these third parties will be limited to what is reasonably necessary to enable us to deliver, or facilitate our delivery of, the Service.

Your user profile:

Other users will have access to the information displayed on your public profile. You will have the ability to determine which information about you is publicly displayed.

What happens in the event of a change of control:

We may sell/divest/transfer StartNoo or any of its holding companies (including any shares in StartNoo or any of its holding companies), or any combination of its products, services, assets or businesses. Your information such as your name and email address and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, and other similar transactions or proceedings involving all or a portion of StartNoo or any of its holding companies. You acknowledge and agree that your personal data may be transferred in connection with any of the aforementioned events, subject to applicable law and appropriate safeguards for data protection. We will notify users of any such transfer and provide details about the new data controller in accordance with applicable privacy laws.

Instances where we are required to share your information:

StartNoo will disclose your information if we reasonably believe that such action is necessary to (a) comply with the law (including any subpoena, court order, or discovery request) and the requests of law enforcement; (b) to enforce our Terms of Use (including this Privacy Policy) or to protect the security or integrity of our Service; or (c) to exercise or protect the rights, property, or personal safety of StartNoo, our users or others.

Sharing certain service type information we collect about you:

We may share certain service type information, including information obtained through tools such as cookies, log files, device identifiers and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with our third-party business partners for the purposes described in the section above entitled "How We Collect and Use Information About You." We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.

Important Note Regarding SMS Opt-In Data: The above data sharing practices exclude text messaging originator opt-in data and consent. Your phone number and SMS opt-in consent information will not be shared with any third parties for marketing purposes or any other purpose except as required to deliver SMS messages through our SMS service provider (AWS SNS/End User Messaging) in accordance with our SMS Terms of Service.

3. HOW WE STORE AND PROTECT YOUR INFORMATION AND COMPLIANCE WITH PRIVACY LAWS

Location of Storage and Processing:

StartNoo.com is hosted on servers located in the United States. StartNoo.com is intended for use in the United States and has been designed with the United States audience in mind. Your information collected through the Service will be stored and processed in the United States. StartNoo may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders to other countries or jurisdictions around the world, subject to appropriate safeguards and in compliance with applicable laws.

Additional Clarity for International Users:

If you are a user accessing StartNoo from outside of the United States, please note that you are transferring your personal data to the United States which does not have the same data protection laws (governing personal data collection, use and disclosure) as the EU and other regions. By providing your personal data you consent to:

• the use and disclosure of your personal data as set out above in this Privacy Policy; and
• the transfer of your personal data to the United States or any other country in which StartNoo or its parent, subsidiaries, affiliates or service providers maintain facilities as indicated above.

You acknowledge that the laws of the United States treat your information in a manner that may be substantially different from, and less protective than, the treatment required under the laws of other countries and jurisdictions. If you do not want your information transferred to the United States, you should not share your information with us, or make use of this website.

Keeping your information safe:

StartNoo cares about the security of your information and uses commercially reasonable administrative, technical, and physical safeguards to preserve the integrity and security of all information collected through the Service. However, no security system is impenetrable, and StartNoo cannot ensure or warrant the absolute security of any information you transmit to StartNoo or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed by unauthorized parties. You provide information to us at your own risk. You are responsible for controlling access to your password and email communications from StartNoo at all times. While StartNoo implements reasonable security measures, to the fullest extent permitted by applicable law, StartNoo disclaims all liability for any damages, losses or claims of any kind relating to any information that you provide to us or others through this Site, except where such disclaimer is prohibited by law.

4. COMPLIANCE WITH PRIVACY LAWS AND DATA SUBJECT RIGHTS

FERPA Compliance:

StartNoo complies with the Family Educational Rights and Privacy Act ("FERPA") regarding educational records. Students have rights to access their educational records, request amendments, and control disclosure of personally identifiable information from education records.

CCPA/CPRA Compliance:

California residents have rights to know what personal information we collect, delete personal information, opt-out of sale/sharing, correct inaccurate information, and limit use of sensitive personal information. We do not sell personal information to third parties. To exercise rights, contact privacy@startnoo.com.

New York SHIELD Act:

We maintain a data security program, including other applicable data security laws, which we implement and maintain reasonable security procedures and practices, including administrative, technical, and physical safeguards. In the event of a data breach affecting New York residents, we will provide notification as required by law.

Florida Privacy Laws:

We comply with Florida's data protection requirements, including breach notification within 30 days of discovery and implementation of reasonable security measures.

COPPA Compliance:

We do not knowingly collect information from children under 13 without verifiable parental consent. If we discover such collection, we will promptly delete the information.

Data Retention:

We retain personal information only as long as necessary for the purposes outlined in this Privacy Policy or as required by law. Upon request or account termination, we will delete or anonymize personal information, except where retention is required for legal compliance.

GDPR Compliance:

As of these Terms of Use, StartNoo is only available in the United States of America. If at any point StartNoo expands to offering services in the European Union, for users in the European Union, we will process personal data based on lawful bases including consent, legitimate interests, and legal obligations. EU data subjects have rights to access, rectify, erase, restrict processing, data portability, and object to processing. To exercise these rights, contact us at privacy@startnoo.com. We will respond within one month, which may be extended by up to two additional months, where necessary, taking into account the complexity and number of requests.

5. CHILDREN'S PRIVACY AND AGE RESTRICTIONS

StartNoo does not knowingly collect or solicit any information from anyone under the age of 18 or knowingly allow such persons to register as users of this Site. The Service and Site and its content are not directed at children under the age of 18. Students between the ages of 13 and 17 may only use the Service with express written consent from both a legal guardian and an authorized administrator of an educational institution partnered with StartNoo, and only for educational purposes. StartNoo reserves the right to terminate access immediately if these requirements are not met. Do not provide us with any information for any reason unless you are at least 18 years of age, and do not provide us with any information about any other person who is under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information within 72 hours in accordance with COPPA and other applicable laws. If you believe that we might have any information from or about a child under 13, please contact us at privacy@startnoo.com.

6. HOW TO CONTACT US

Contact Information: If you have any questions about this Privacy Policy, the Terms of Use, or the Service, please contact us at legal@StartNoo.com or by mail at StartNoo, LLC, 7901 4th Street N, St. Petersburg, Florida 33702.

Legal Notices: This Privacy Policy is governed by Florida law without regard to conflict of law principles, except where preempted by federal law or where other state laws mandatorily apply to specific data processing activities. If any provision is found unenforceable, the remainder shall remain in effect. Our failure to enforce any provision does not waive our right to enforce it later. This Privacy Policy constitutes the entire agreement regarding privacy practices and supersedes all prior agreements. Any amendments must be in writing and signed by authorized representatives.

7. CHANGES TO OUR PRIVACY POLICY

StartNoo may modify or update this Privacy Policy from time to time to reflect changes in our business, practices, or legal requirements. We will review this page periodically and update the Effective Date when changes are made. We reserve the right to modify this Privacy Policy at any time, and will notify users of material changes as appropriate under the circumstances by email to registered users and/or prominent notice on our website, in accordance with applicable law. Your continued use of the Service after the effective date of such changes constitutes acceptance of the updated Privacy Policy. For material changes to this Privacy Policy, we will seek to obtain your explicit consent where required by applicable law. If you do not agree to the changes, you must discontinue use of the Service and may request deletion of your personal information, subject to legal retention requirements.