Privacy Policy

    Effective as of February 17, 2023

    This Privacy Policy describes how (“StarTree”, “we”, “us” or “our”) handles personal information that we collect through our website at (the “Website”).

    The Website and our self-service StarTree Cloud (the “StarTree Cloud”) is intended exclusively for use by business customers in their professional capacity (each a “business customer”). We do not offer products or services for use by individuals for their personal, family, or household purposes. Accordingly, we treat all personal information we collect in connection with the Website as pertaining to individuals in their capacities as representatives of the relevant business and not their individual capacities.

    This Privacy Policy does not apply to information that StarTree processes on behalf of business customers while providing the StarTree Cloud. Our use of information that we process on behalf of our business customers is governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that business customer.

    NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.


    Personal Information We Collect

    Information You Provide to Us
    Personal information you may provide to us through the Website or otherwise includes:

    • Contact data, such as your first and last name, email address, professional title and company name, and phone number.

    • Communications data based on our exchanges with you, including when you contact us through the Website, social media, or otherwise.

    • Research data, such as your responses to surveys that we might ask you to complete for research purposes related to our business.

    • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

    • Profile data, such as the username and password that you may set to establish an online account on the Website, links to your profiles on social networks, and any other information that you add to your account profile.

    • Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.

    • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

    Third-Party Sources
    We may combine personal information we receive from you with personal information we obtain from other sources, such as:

    • Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.

    • Data providers, such as information services and data licensors that provide demographic and other information that we use to provide the Website.

    • Marketing partners, such as joint marketing partners and event co-sponsors.

    • Third-party services, such as social media services, that you use to log into, or otherwise link to, your Website account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to usbased on your account settings on that service.

    Automatic Data Collection
    We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Website, our communications and other online services, such as:

    • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or general geographic area.

    • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Website, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

    • Communication interaction data, such as your interactions with our email, or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

    Cookies and Similar Technologies
    Some of the automatic collection described above is facilitated by the following technologies:

    • Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.

    • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.

    • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

    **How We Use Your Personal Information**

    We may use your personal information for the following purposes or as otherwise described at the time of collection:

    Service Delivery and Operations
    We may use your personal information to:

    • provide, operate and improve the Website and our business;

    • personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Website;

    • establish and maintain your user profile on the Website;

    • enable security features of the Website, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;

    • communicate with you about the Website, including by sending announcements, updates, security alerts, and support and administrative messages;

    • understand your needs and interests, and personalize your experience with the Website and our communications; and provide support for the Website, and respond to your requests, such as for newsletters and other communications, questions and feedback.

    Research and Development
    We may use your personal information for research and development purposes, including to analyze and improve the Website and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Website and promote our business.

    We, our service providers and our third-party partners may collect and use your personal information for marketing purposes:

    • Direct marketing. We may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

    • Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Website, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.

    Service Improvement and Analytics
    We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

    Compliance and Protection
    We may use your personal information to:

    • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

    • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

    • audit our internal processes for compliance with legal and contractual requirements or our internal policies;

    • enforce the terms and conditions that govern the Website; and

    • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

    With Your Consent
    In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

    Cookies and Similar Technologies
    In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

    • Technical operation. To allow the technical operation of the Website.

    • Functionality. To enhance the performance and functionality of our services.

    • Advertising. To help our third-party advertising partners collect information about how you use the Website and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.

    • Analytics. To help us understand user activity on the Website, including which pages are most and least visited and how visitors move around the Website, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. To provide this service, Google Analytics may collect certain information about you from your computer using cookies. You can learn more about Google Analytics and how it collects and processes data by visiting: You can opt-out of the use of Google Analytics here:

    How We Share Your Personal Information

    We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.  

    Service Providers
    Third parties that provide services on our behalf or help us operate the Website or our business (such as hosting, information technology, customer support, email delivery, customer research, marketing, and website analytics). 

    Advertising Partners
    Third-party advertising companies for the interest-based advertising purposes described above. 

    Third Parties Designated by You
    We may share your personal data with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested. 

    Business and Marketing Partners
    Third parties with whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you. 

    Linked Third-Party Services
    If you link your Website account to a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

    Professional Advisors
    Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

    Authorities and Others
    Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. 

    Business Transferees
    Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, StarTree, our parent, our affiliates, or our subsidiaries (including, in connection with a bankruptcy or similar proceedings).

    Your Choices

    In this section, we describe the choices available to you.

    Access or Update Your Information
    If you have registered for an account with us through the Website, you may review and update certain account information by logging into the account.

    Opt-Out of Marketing Communications
    You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, by contacting us, or by filling out this form. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

    Do Not Track
    Some Internet browsers may be configured to send a specific “Do Not Track” signal to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit

    Declining to Provide Information
    We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

    Other Sites and Services

    The Website may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.


    We employ technical, organizational, and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

    International Data Transfer

    We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.


    The Website is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Website from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

    Changes to this Privacy Policy

    We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Website or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Website after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

    How to Contact Us

    To exercise your choices or if you have questions about this Privacy Policy or our privacy practices, please contact us at

    Notice to European Users

    Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

    Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.   

    Controller. Starree is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the ‘How to contact us’ section above for our contact details.

    Our Legal Bases for Processing 
    In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use. 

    Our legal bases for processing your personal information described in this Privacy Policy are listed below.

    • Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).

    • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.

    • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

    • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).  

    We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’.

      Personal information legal bases table

      We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes.  

      To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements. 

      When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

      Other Info
      No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

      No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. 

      Your Rights
      General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

      • Access. Provide you with information about our processing of your personal information and give you access to your personal information.

      • Correct. Update or correct inaccuracies in your personal information.

      • Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). 

      • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

      • Restrict. Restrict the processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing it.

      • Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.

      • Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.  

      Exercising These Rights. You may submit these requests by email to or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part), we will let you know our grounds for doing so at the time, subject to any legal restrictions.  

      Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence. 

      • For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here:

      • For users in the UK – the contact information for the UK data protection regulator is below:

      The Information Commissioner’s Office
      Water Lane, Wycliffe House
      Wilmslow - Cheshire SK9 5AF
      Tel. +44 303 123 1113

      Data Processing Outside Europe  
      We are a U.S.-based company, and many of our service providers, advisers, partners, or other recipients of data are also based in the U.S. This means that if you use the Service, your personal information will necessarily be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.  

      It is important to note that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws. 

      You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.