Privacy Policy

Effective Date: April 1, 2024

South Texas Accelerated Research Therapeutics, LP, together with its subsidiaries and controlled affiliates (collectively, “START” “us,” “we,” or “our”) is committed to protecting the privacy of Personal Data (i.e., information reasonably related to a specific individual). This Privacy Notice describes how we process Personal Data collected through our websites, social media accounts, and other online interactions and communications such as email (collectively, our “Digital Properties”); in-person events; and other online and offline interactions.

This Privacy Notice applies to information we collect about individual consumers, such as general website visitors (“Individuals”), as well as information we collect about the personnel of our business partners, including vendors and business customers, in business-to-business interactions (“Business Contacts”).  However, this Privacy Notice does not apply to information about our current/former employees, applicants, and other individuals who interact with us for employment-related purposes. This Privacy Notice also does not apply to data that we handle on behalf of and under the instructions of our business customers (as a processor) or data that is subject to research regulations (such as human subjects research regulations issued by the U.S. Food and Drug Administration).

Whenever you interact with us on behalf of another individual or entity, such as if you refer a friend to us, you must obtain their consent (or have the legal authority without consent) to share their Personal Data with us.

Changes to this Privacy Notice. We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this Privacy Notice periodically for updates. If required by law, we will contact you directly to provide you with an updated Privacy Notice.

1. Sources of Personal Data

We collect Personal Data about you from the following sources:

1. Directly from you. We may collect Personal Data you provide to us directly, such as when you contact us through our Digital Properties; interact with us in person; sign up for offers or newsletters; communicate with us; or sign up for an account or other services.
2. Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, including through cookies and other tracking technologies when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information.  For more information about cookies and other tracking technologies, please see our Cookie Policy.
3. From third parties. We may collect Personal Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, social media companies or other parties who interact with us.
4. From publicly available sources.  We may collect Personal Data about you from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use or disclose the combined information for the purposes identified below.

2. Types of Personal Data We Collect

We may collect the following types of Personal Data about you. Except as otherwise specified, we may collect this Personal Data from both Individuals and Business Contacts.

1. Identifiers, such as your name, email address, physical address, telephone number, business contact information, and device identifiers (e.g., cookie IDs and IP address).
2. Records about you, such as the content, timing and method of communications you have with us and information you share with or upload to our Digital Properties, such as reviews and comments. 
3. Demographic information, such as age (including birthdates) and gender.
4. Commercial information, such as information related to products or services purchased, obtained, or considered.
5. Internet or other electronic network activity information, such as your browsing history, search history, preference information (including marketing and purchasing preferences), and other information regarding your interactions with and use of the Digital Properties. For more information about cookies and other device data, please see our Cookie Policy.
6. Non-precise geolocation data, such as your location as derived from your IP address.
7. Audio, electronic, visual, or other sensory information, such as photographs and audio/video recordings.
8. Professional or employment-related information (for Business Contacts), such as job title; organization; professional licenses, credentials, or affiliations; and other professional information. 
9. Inferences drawn from any of the information we collect about your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and determine your preferred frequency for receiving offers.
10. Sensitive Personal Data, including Information about your health.

3. How We Use Personal Data

We may use Personal Data for the following purposes:

1. To provide you or your company products and services, making our Digital Properties, products and services available to you; providing customer service; communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); hosting informational webinars; and providing similar services or otherwise facilitating your relationship with us.
2. For our internal business purposes, such as operating our Digital Properties and customizing the content; maintaining internal business records, such as accounting, document management and similar activities; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
3. For our internal research and product improvement purposes, such as verifying or maintaining the quality or safety of our products or services; improving our products or services; designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
4. For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, our partners, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
5. In connection with a corporate transaction, such as if we acquire, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy or other forms of corporate change.
6. For marketing and targeted advertising, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use Personal Data we collect to personalize advertise to you (including by developing product, brand, or services audiences and identifying you across devices/sites); to analyze interactions with us or our Digital Properties; or to send you newsletters, surveys, questionnaires, promotions, or information. You can unsubscribe from our email marketing via the link in the email, or by contacting us using the information in the Contact Information section below.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

4. How We Disclose Personal Data

We may disclose Personal Data to third parties, including the categories of recipients described below:

1. Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
2. Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
3. Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
4. Vendors necessary to complete transactions you request, such as shipping companies and logistics providers.
5. Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce other agreements or policies; and to protect ours, our customers’, our partners’, or third parties’ safety, property, or rights.
6. Other entities in connection with a corporate transaction, such as if we acquire, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
7. Business partners that may use Personal Data for their own purposes, such as:

• Advertisers, ad platforms and networks, and social media platforms;
• Third parties whose cookies and tracking tools we use as described in our Cookie Policy; and
• Partners who work with us on promotional opportunities, including co-branded products and services.

Where required by law, we will obtain your consent prior to disclosing your Personal Data to our business partners. Where recipients use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those third-party services for details on their practices.   

1. 1. The public, such as when you have an opportunity to make comments regarding us or our products or services that we may share with the public, including testimonials. Any Personal Data in comments, reviews, or other content that you share in public areas of our Digital Properties may be read, collected, or used by other users or the public. 

• Entities to which you have consented to the disclosure.

5. Cookies and Other Tracking Technologies

We may collect technical information from and about your device (such as your browser type, operating system, IP address, and domain name) via cookies and other tracking technologies. Please see our Cookie Policy for further information.

6. Data Security and Data Retention

Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information. 

Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your Personal Data in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest. If you would like to know more about the retention periods applicable to your Personal Data, you can contact us using details provided in the Contact Information below.

7. Children’s Privacy

Our Digital Properties are intended for individuals 18 years of age and older. The Digital Properties are not directed at, marketed to, nor intended for, children under 18 years of age. As a general rule, we do not knowingly collect any information, including Personal Data, from children under 18 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 18, please contact us at the address in the Contact Information section below, and we will take prompt steps to delete the information.

8. External Links

Our Digital Properties may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.

9. Contact Information

If you have questions regarding this Privacy Notice, please contact us at: information@startresearch.com 

10. Supplemental Information for the EEA, Switzerland and the UK

The following terms supplement the above disclosures with respect to our processing of EEA, Swiss, and UK Personal Data, and only apply to the extent that EEA, Swiss, or UK data protection laws apply to our processing of your Personal Data. To the extent applicable, in the event of any conflict or inconsistency between the other parts of the Privacy Notice and the terms of this Section, this Section shall govern and prevail with regards to the processing of such EEA, Swiss and UK Personal Data. 

Data Controller

START entity responsible for the processing of your Personal Data as the controller is the entity that has the primary relationship with you. This may be the START group entity whose Digital Property you are viewing or using, that provides services to you, that markets or provides promotional materials to you, or the primary START group entity in the region where you interact with us. 

In some cases, more than one START group entity may make decisions on how your Personal Data is processed, such as when two START group entities co-sign a contract with you or multiple START group entities organize an event. In these situations, all such entities are jointly responsible for the lawfulness of the specific processing activities as joint controllers.

In other cases, different START group entities may independently determine how your Personal Data is processed as independent controllers, such as when one START group entity uses Personal Data received from another START group entity to market to you.

You can view START group companies’ locations here. For further details, please do not hesitate to contact us using the contact details in the Contact Information section above.

Legal Bases for Processing

We process the following categories of personal data for the following processing purposes based on the following legal bases: