Privacy Policy

Privacy Policy, effective as of 6th May 2018

Startle International (“Startle,” “we,” “us,” “our,” or the “Company”) is committed to protecting the privacy of individuals who visit the Company’s Web sites (“Visitors”) and individuals who register to use the Services as defined below (“Customers”). This Privacy Policy describes Startle’s privacy practices in relation to the use of the Company’s Web sites and the related applications and services offered by Startle (collectively, the “Services”), as well as individuals’ choices regarding use, access and correction of personal information.

If you have questions or complaints regarding Startle’s Privacy Policy or associated practices, please contact us here.

1. Web Sites covered

This Privacy Policy covers the information practices, including how the Company collects, uses, shares and secures the personal information you provide, of Web sites and applications that link to this Privacy Policy (collectively referred to as “Startle’s Web sites” or “the Company’s Web sites”).

Startle’s Web sites may contain links to other Web sites. The information practices or the content of such other Web sites is governed by the privacy policies of such other Web sites. The Company encourages you to review the privacy policies of other Web sites to understand their information practices.

2. Information collected

When expressing an interest in obtaining additional information about the Services, or registering to use the Web sites or other Services, Startle requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Services, Startle may also require you to provide the Company with billing information, such as billing name and address, debit debit details, and delivery address that will be using the Services (“Billing Information”).

Required Contact Information, Billing Information, Optional Information and any other information you submit to Startle to or through the Services are referred to collectively as “Data”.

As you navigate the Company’s Web sites, Startle may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Web Site Navigational Information”). Web Site Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked). For additional information about the collection of Web Site Navigational Information by Startle and others, please click here.

When you provide us with personal information about third parties, we will only use this information for the specific reason for which it is provided, such as to add new user logons to your Startle account.

3. Use of information collected

The Company uses Data about Startle Visitors and Customers to perform the services requested. For example, if you fill out a Web form, the Company will use the information provided to contact you about your interest in the Services.

Startle may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding the Company, its affiliates, and its partners.

Startle may also receive information about Customers from other sources, including third parties such as affiliates and resellers, and combine this information with Data we already have about you. This helps us to update, expand and analyse our records, identify new customers, and create more tailored advertising to provide products and services that may be of interest to you.

Startle uses financial information solely to collect payment from Customers.

Startle uses Web Site Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Site Navigational Information alone or in combination with Data about Startle Customers to provide personalised information about the Company. For additional information about the use of Web Site Navigational Information, please click here.

Startle partners with third parties to display relevant advertising on other sites. Our third-party partners may use cookies or similar technologies to provide you with advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here. Please note you will continue to receive generic ads.

4. Web Site Navigational Information

Cookies, Web Beacons and IP Addresses

Startle uses commonly-used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Web sites (“Web Site Navigational Information”). As described more fully below, we and our partners use these cookies or similar technologies to analyse trends, administer Web sites and Services, track users’ movements around our Web sites and Services, serve targeted advertisements and gather demographic information about our user base as a whole. This section describes the types of Web Site Navigational Information used on the Company’s Web sites and Services, and how this information may be used.


Startle uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit one of the Company’s Web sites, Startle’s servers send a cookie to your computer or device. Standing alone, cookies do not personally identify you; they merely recognise your Web browser. Unless you choose to identify yourself to Startle or have previously identified yourself to Startle, you remain anonymous to the Company.

Startle uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer or device when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Web sites or Services.

The following sets out how uses different categories of cookies and your options for managing cookies’ settings:

Required cookies

Required cookies enable you to navigate the Company’s Web sites and use its features, such as accessing secure areas of the Web sites and using Startle Services.

If you have chosen to identify yourself to Startle, the Company may place on your browser cookies containing an encrypted, unique identifier. These cookies allow the Company to uniquely identify you when you are logged into the Web sites and Services and to process your requests.

Because required cookies are essential to operate the Company’s Web sites and the Services, there is no option to opt out of these cookies.

Functionality cookies

Functionality cookies allow the Company’s Web sites and Services to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimise your use of Startle’s Web sites and Services after logging in.

Functional cookies may also be used to improve how the Company's Web sites and Services function and perform, to enhance and customise your interactions with the Company, and to help us provide you with more relevant messages, including marketing communications. These cookies collect information about how Visitors use our Web sites and Services, including which pages visitors go to most often and if they receive error messages from certain pages.

Startle may use its own technology or third parties to track and analyse usage and volume statistical information from Visitors and Customers, to provide enhanced interactions and more relevant communications, and to track the performance of the Company's advertisements.

Startle and it's third-party partners may also utilise local storage for these purposes. Local storage is different from browser cookies because of the amount of, type of, and how Data is stored.

Note that opting out of functionality cookies may impact the functionality you receive when using Startle’s Web sites and Services.

To learn more about how to control cookies using your browser settings click here.

Targeting or Advertising cookies

Startle sometimes uses cookies delivered by third parties to show you ads for Startle products and services that we think may interest you on any devices you may use and to track the performance of Company advertisements. For example, in these cases, cookies remember information such as which browsers have visited the Company’s Web sites. The information provided to third parties does not include personal information, but this information may be re-associated with personal information after the Company receives it. If Startle is using one of its own cookie-related products on our own Web site, then a cookie related to ads may appear on our Web site under the Startle or one of our affiliated company's name.

Startle also contracts with third-party advertising networks that collect IP addresses and other information from Web beacons (see below) on the Company’s Web sites and Services, from emails, and on third-party Web sites. Ad networks follow your online activities over time and across different sites or other online services by collecting Web Site Navigational Information through automated means, including through the use of cookies. These technologies may recognise you across the different devices you use, such as a desktop or laptop computer, smartphone or tablet. Third parties use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other Web sites or mobile applications on any of your devices. This process also helps us manage and track the effectiveness of our marketing efforts.

To learn more about these and other advertising networks and your ability to opt out of collection by certain third party, please visit the opt-out pages of the Network Advertising Initiative, here.

Web Beacons

Startle uses Web beacons alone or in conjunction with cookies to compile information about Customers and Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognise certain types of information on your computer, such as cookies, when you viewed a particular Web site or Service tied to the Web beacon, and a description of a Web site or Service tied to the Web beacon. For example, Startle may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. Startle uses Web beacons to operate and improve the Company’s Web sites, Services and email communications.

Log Files, IP Addresses, URLs and Other Data

As is true of most Web sites, we gather certain information automatically to analyse trends in the aggregate and administer our Web sites and Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use the Company’s Web sites and Services, we usually automatically receive the URL of the Web site from which you came and the Web site to which you go when you leave our Web site. This information is used to analyse overall trends, to help us improve our Web sites and Services, to track and aggregate non-personal information, and to provide the Web sites and Services. For example, Startle uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites. Startle also collects IP addresses from Customers when they log into the Services as part of the Company’s security features.

Social Media Features, Single Sign-on and Bots

The Company’s Web sites may use social media features, such as the Facebook “like” button (“Social Media Features”). These features may collect your IP address and which page you are visiting on the Company’s Web site, and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on the Company’s Web site to a profile page of yours that is provided by a third party social media network in order to share with others within your network. Social Media Features are either hosted by a third party or hosted directly on the Company’s Web site. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.

You may also be given the option to connect Startle’s Bot Applications to your Facebook page(s) or engage with Startle through third party’s Facebook page(s). Our Bot Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. The permissions asked are the following:

  • Basic information - By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
  • Access Page CTA (Call To Action) - Provides the access to manage call to actions on User-managed Pages.
  • Manage Pages - Enables the application to retrieve access_tokens for Pages and Applications that the User administrates.
  • Mobile Messaging on behalf of Page - Send and receive mobile messages on behalf of a Facebook Page.
  • Page Messaging - Send and receive messages through a Facebook Page.
  • Publish as Page - Enables the ability to post, comment and like as any of the Pages managed by the User.
  • Read page mailbox - Enables the ability to read messages sent to Pages managed by the User in order for the Bot to function.
  • Show List of Managed Pages - Provides the access to show the list of the Pages that the User manages.

For convenience, Startle also allows you to log in to some of our Web sites and Services using sign-in services such as Facebook Connect and Google. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our login forms.

Do Not Track

Currently, various browsers - including Internet Explorer, Firefox, and Safari - offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Web sites’ visited by the user about the user's browser DNT preference setting. Startle does not currently commit to responding to browsers' DNT signals with respect to the Company's Web sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Startle takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

5. Sharing of information collected

Service Providers

Startle may share Data about Startle Visitors and Customers with the Company’s contracted service providers so that these service providers can provide services on our behalf. These service providers are authorised to use your personal information only as necessary to provide the requested services to us. Without limiting the foregoing, Startle may also share Data about Startle Visitors and Customers with the Company’s service providers to ensure the quality of information provided, and with third–party social networking and media Web sites, such as Facebook, for marketing and advertising on those Web sites. Unless described in this Privacy Policy, Startle does not share, sell, rent, or trade any information with third parties for their promotional purposes.

Startle Affiliates

The Company may share Data about Startle Customers with other companies in order to work with them, including affiliates of the Startle corporate group. For example, the Company may need to share Data about Startle Customers with other companies within the Startle corporate family for customer support, marketing, technical operations and account management purposes.

Third Parties

Section 4 of this Privacy Policy, Web Site Navigational Information, specifically addresses the information we or third parties collect through cookies and web beacons, and how you can control cookies through your Web browsers. We may also disclose your personal information to any third party with your prior consent.


Startle uses a third-party service provider to manage credit card, debit card and direct debit processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card, debit card and direct debit processing on the Company’s behalf.

Compelled Disclosure

Startle reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.

6. International transfer of information collected

The Company primarily stores Data about Startle Customers based in North America in the United States of America and customers based in the Rest Of The World in Europe. To facilitate Startle’s global operations, the Company may transfer and access such information from around the world, including from other countries in which the Company has operations. A list of the Company’s global offices is available here. This Privacy Policy shall apply even if Startle transfers data about Startle International customers to other countries.

7. The Service is not directed to children under the age of 13

Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance may persons under the age of 13 use this Application.

8. Correcting and updating your information

Startle may retain your information for a period of time consistent with the original purpose of collection. For instance, we may retain your information during the time in which you have an account to use our Web sites or Services and for a reasonable period of time afterward. We also may retain your information during the period of time needed for Startle to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

You may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us through the Company’s Web sites and Services. For other requests to access, correct, modify or delete Your Data, please review the “Contacting Us” section below. Requests to access, change, or delete your information will be addressed within a reasonable timeframe. If you are an employee of a Startle customer, you may also wish to contact your company’s system administrator for assistance in correcting or updating your information.

9. Customer Data

Startle’s Customers may electronically submit Data or information to the Services for hosting and processing purposes (“Customer Data”). Startle will not review, share, distribute, or reference any such Customer Data except as provided in Startle’s Terms and Conditions, or as may be required by law. In accordance with Startle’s Terms and Conditions, Startle may access Customer Data only for the purpose of providing the Services or preventing or addressing service or technical problems or as may be required by law.

Startle acknowledges that you have the right to access your personal information. If personal information pertaining to you as an individual has been submitted to us by a Startle customer and you wish to exercise any rights you may have to access, correct, amend, or delete such Data, please inquire with our customer directly. Because Startle personnel have limited ability to access Data our customers submit to our Services, if you wish to make your request directly to Startle, please provide the name of the Startle customer who submitted your Data to our Services. We will refer your request to that customer, and will support them as needed in responding to your request within a reasonable timeframe.

10. Security/Technology

Startle uses robust security measures to protect our information assets. These technologies are deployed as part of sophisticated security architecture. All Data resides in a tightly controlled, secure Data center. This means that information about the identity and preferences of individual members is strongly protected by Startle against unauthorised access. We will maintain safeguards to protect the security of these servers and your personal information. Startle may process, store and back up its information with the assistance of those providers.

11. Changes to our Privacy Policy

Startle reserves the right to change this Privacy Policy from time to time in response to changing legal, regulatory or operational requirements. We keep our privacy policy under regular review and we will place any updates on this web page. Please check this page occasionally to ensure that you’re happy with any changes. By using our Web site, you’re agreeing to be bound by this Policy.

12. Contacting us

Questions regarding this Privacy Policy or the information practices of the Company’s Web sites and Services should be directed to Startle by mailing us at: Startle International, St Johns Studios, 6-8 Church Road, Richmond, Surrey, TW9 2QA, United Kingdom.

Please note that if you contact us to assist you, for security we may need to authenticate your identity before fulfilling your request.