1. Introduction

This privacy policy (“Policy“) explains the data protection practices of Chicory Media, LLC when using the website Starcasm.net (“Starcasm” or “Website“), including the mobile-optimized version of Starcasm.

For information about the publisher and blogger network advertising services of SK Media Group, LLC, please read the SHE Media Ad Services Privacy Policy. This Privacy Policy is incorporated into and subject to the Services’ Terms of Use. If you do not agree to the Terms of Use and this Privacy Policy, you must discontinue using the Services and all components and features therein. By using the Services, you acknowledge you have read and understand this Privacy Policy.

2. The Information We Collect

Device information and identifiers such as IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers

Internet network and device activity data such as information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services, the web sites you visit after this web site; if you share our content to social media platforms; and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information. See “Cookies and Other Tracking Technologies” below for more information about how we collect and use this information.

Geolocation information such as city, state and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and precise geolocation information from GPS-based functionality on your mobile devices, with your permission in accordance with your mobile device settings

3. How We Use the Information We Collect

Depending on the Services you use and how you use them, we, or our service providers, may use your information to:

Personalize your experience to Provide the Services, for example to:

Customize the advertising on the Services based on your activities and interests

Create and update inferences about you and audience segments that can be used for targeted advertising and marketing on the Website

Create profiles about you, including adding and combining information we obtain from third parties, which may be used for analytics, marketing, and advertising

Conduct cross-device tracking by using information such as IP addresses and unique mobile device identifiers to identify the same unique users across multiple browsers or devices (such as smartphones or tablets, in order to save your preferences across devices and analyze usage of the Website.

Use inferences about your preferences and interests for any and all of the above purposes

Improve the Website and develop new services, for example to:

Customize content that our third-party partners deliver on Starcasm (e.g., personalized third-party advertising)

We may combine the information we collect about you and conduct cross-device tracking for the marketing and advertising purposes above.

Bug detection and error reporting, including to understand and resolve technical issues, Website crashes and other issues being reported

Audit consumer interactions on the Website including to measure the placement, frequency, efficacy and compliance of advertising and ad impressions

Security, Fraud, and Legal Compliance, including by detecting, protecting against, and prosecuting security incidents, fraud, and illegal activity for example to:

Monitor, enforce, and improve the security of our Website

Comply with any applicable procedures, laws, and regulations, subpoenas, governmental requests or legal process, or in connection with a legal investigation, if in our good faith opinion such is required or permitted by law;

Establish, exercise, or defend our legal rights (e.g., to enforce compliance with our Terms of Use, Privacy Policies, or other contracts or legal rights)

Protect or defend our Website, users, or others

Aggregate and/or De-Identified Information. We may aggregate or anonymized information and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use this Aggregate/De-Identified Information for any purpose permitted under the law, including without limitation for research and marketing purposes, and disclose such information to third parties, including advertisers, promotional partners, and sponsors in our sole discretion.

4. How We Share the Information Collected

Third-Party Online Advertisers, Ad Networks and Advertising Partners. As discussed in the “Online Analytics and Advertising” Section below, Starcasm may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Website, as well as on other websites you visit and other applications you use, and these technologies will collect certain information from your use of Starcasm to assist in delivering such ads and marketing messages and enhancing our information. These third parties include advertising networks, data exchanges, ad servers, certain analytics providers and others.

Third Parties for Legal Purposes. By using Starcasm, you acknowledge and agree that we may access, retain, and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of PMC, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

5. Legal Grounds for Using (Processing) Your Information

If you are a visitor from the European Economic Area, our legal basis for collecting and using the information described above will depend on the information concerned and the context in which we collect it. We collect information from you:

• Where we need it to perform our contract with you (i.e. our Terms of Service),

• Where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights) (such as personalizing our services and marketing for example), or

• If we otherwise have your consent.

If you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact us by sending an email to starcasmtips(at)yahoo.com.

6. Online Analytics and Advertising

Delivery of Advertising and Other Content. Starcasm uses third party advertising companies and marketing services to serve ads and other content when you visit the Website, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, your searches, demographic data, user-generated content, and other information collected from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests. Third parties, whose products or services are accessible or advertised via the Services, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. We also allow other third parties (e.g., ad networks and ad servers such as Google and others) to serve tailored ads to you on Starcasm, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access Starcasm.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on the device you use to access Starcasm by such non-affiliated third parties.

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative Opt Out Page, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs.

To learn more about how to manage your preferences regarding our cookie-based advertising, please see the “Cookie Management” section in our Cookie Notice below.

To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the opt out choices above, you will still see advertising when you use Starcasm, but it will not be tailored to you based on your online behavior over time.

Do Not Track. Starcasm does not act on “do not track” requests from your browser because, this way, we are able to personalize your experiences on the Website.

7. Your Rights & Your Choices

Privacy Information for California Residents. If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). We describe the categories of personal information we collect, the sources and uses of such information and the entities to which we share such information in our California Privacy Notice.

A. California Data Access & Deletion Rights

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.

• Provide access to and/or a copy of certain personal information we hold about you.

• Delete certain personal information we have about you.

• Provide you with information about the financial incentives that we offer to you, if any.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide Starcasm to you.

Verification: We will take reasonable steps to verify your identity before responding to a request, which may include, depending on your request and relationship with you verifying your name, email address, address, and/or having you respond to an email from us.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

B. Notice of Right to Opt Out of Sale of Personal Information

California residents may opt out of the “sale” of their personal information. Under the CCPA, sale is also broadly defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on Starcasm or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you advertising relevant to you.

Starcasm may provide the following categories of personal information to third parties for this purpose:

• For online targeted advertising purposes: demographic and statistical information, device information and identifiers, connection and usage data, geolocation, and social media information.

If you would like to opt out of Starcasm’s use of your information for such purposes that are considered a “sale” under California law, you may do so by emailing starcasm(at)yahoo.com. In your request, please specify that you want a “PMC California Opt Out.” Please allow at least 30 days for a response.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your access, deletion or sale opt out rights.

C. California “Shine the Light” Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. If you are a California resident and would like a copy of this notice, please email a written request to starcasmtips(at)yahoo.com. In your request, please specify that you want a “Chicory Media California Privacy Rights Notice.” Please allow at least 30 days for a response.

D. International Users

Some international users of our Services have certain legal rights to access certain information we hold about them and to request its deletion. For example, your local laws may permit you to request that we:

• Provide access to and/or a copy of certain information we have about you;

• Prevent the processing of your information for direct-marketing purposes;

• Update information which is out of date or incorrect;

• Delete certain information which we have about you;

• Restrict the way that we process and disclose certain of your information;

• Transfer your information to a third party provider of services; and

• Revoke your consent for the processing of your information.

We will consider all requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

8. Retention of Your Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

9. Cookies and Other Tracking Technologies

We use and allow certain other companies to use certain tracking technologies, including cookies, web beacons, and other similar technologies (collectively, “Cookies”) on Starcasm. To see an explanation what these technologies are and why we use them, as well as your rights to control our use of them please see the “Cookie Notice” section below. We endeavor to adhere to the Digital Advertising Alliance’s (DAA) self-regulatory principles governing interest-based advertising.

10. Links to Third Party Sites

When you are on the Website, you may be directed to other websites that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. If you access a third-party website from Starcasm, you do so at your own risk, and you understand that this Privacy Policy does not apply to your use of such websites.

11. Security

We implement appropriate administrative, technical and security safeguards to help prevent unauthorized access, use, or disclosure of the information we collect. However, no systems can be completely secure. Therefore, while Chicory Media uses reasonable efforts to protect your information, Chicory Media cannot guarantee its absolute security, and your use of the Website indicates your agreement to assume this risk.

12. Special Note For Parents

Starcasm is for a general audience and are not designed or intended for use by children, especially those under age thirteen (13) or sixteen (16) in the EU.

13. Transfer Information to the United States

Starcasm is operated in the United States of America (USA) and is intended for users located in the USA. If you are located outside of the USA, please note that the information you provide to us will be transferred to and processed in the USA, where laws regarding processing of personal data may be less stringent than the laws in your country.

14. Changes to This Privacy Policy

We reserve the right to change this Privacy Policy at any time without prior notice. Any changes will be effective immediately upon the posting of the revised Privacy Policy.

15. Disputes; No Rights of Third Parties

If you choose to access Starcasm, any dispute over privacy is subject to our Terms of Use, including limitations on damages, resolution of disputes by binding arbitration, and application of the laws of the United States, and the State of Texas. This Privacy Policy does not create rights enforceable by third parties.

If you have any questions or concerns about any aspect of this Privacy Policy, please contact us at starcasmtips(at)yahoo.com

Last revised on September 11, 2020

Appendix A: California Privacy Notice

This Privacy Notice for California residents supplements the Chicory Media Privacy Policy.

This Notice applies to website visitors in California. This Notice does not apply to employees, former employees, candidates, contractors, service providers, or business contacts of Chicory Media. This supplemental privacy notice gives California residents additional information about our information collection and use practices required by the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA also provides California residents with specific privacy rights, which are outlined in our Privacy Policy here.

This notice provides information about the categories of personal information that we collect from California residents generally, the purposes for which we use the information, the sources of the information, and the categories of third parties to whom we disclose the information for business purposes. More detailed information is available in our Privacy Policy at How We Use Personal Information and How We Share Personal Information.

If you would like to opt out of Chicory Media’s use of your information for such purposes that are considered a “sale” under California law, you may do so as outlined on the following page: Do Not Sell My Personal Information. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

Categories of information collected:

Device information and identifiers

such as IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers

Internet network and device activity data

such as information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services, the web sites you visit after this web site; if you share our content to social media platforms; and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information.

(See the “Cookies and Other Tracking Technologies” section below for more information about how we collect and use this information.)

Geolocation information

such as city, state and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and precise geolocation information from GPS-based functionality on your mobile devices, with your permission in accordance with your mobile device settings

Purposes of use (see “How We Use Personal Information” in our Privacy Policy for additional information):

• Provide the Services

• Personalize Your Experience

• Improve the Services

• Our Marketing and Third-Party Marketing and Advertising Purposes

• Bug detection and error reporting

• Auditing Consumer Interactions

• Security, Fraud, and Legal Compliance

Cookies and Other Tracking Technologies

Last Updated Date: September 11, 2020.

What are Cookies? Cookies are text files that contain a certain amount of information and are downloaded to your computer or mobile device when you visit a website. They are useful because they allow websites to recognize a user’s device. They are then returned to the original website on each subsequent visit or to any other website that recognizes them. For more information on cookies, go to http://www.allaboutcookies.org. The term “Cookie” is used in this Notice in the broad sense to include all similar techniques and technology, including web beacons and log files. For more information on these additional tools, see our glossary below.

Types of Information We Collect. Cookies help us to understand Website usage and to improve the content and offerings on our Services and in other media. Examples of the types of information that we collect through Cookies include: The number of users visiting Services, the number of times a Website was viewed, the pages viewed, the clicks made on the Services and the total duration of navigation on the Services; The name of the page that referred you to the Website; Whether this is your first time visiting the Website; Your viewing preferences (e.g. layout, sizing preferences, language etc.); Your user name, your password, the type of browser used and your IP address, so that we can identify you during your next visits.

How We Use Cookies. Examples of ways that we use Cookies include:

• To control the display of ads;

• To track usage patterns on the Services;

• To deliver editorial content;

• To record requests for subscriptions;

• To implement our affiliate marketing program; and

• To personalize information.

Third party service providers on our behalf may also use cookies to collect aggregate information about Website users on an anonymous basis (“Anonymous Information”). We may share demographic and usage information with our prospective and actual business partners, advertisers and other third parties for any business purpose.

Types of Cookies We Use on Our Website. We use first party and third party Cookies for several reasons. Some Cookies are required for technical reasons in order for our Site to operate, and we refer to these as “essential” or “strictly necessary” Cookies. Other Cookies also enable us to track and target the interests of our users and to enhance the experience on our Website. Third parties also serve Cookies through our Website for advertising, analytics and other purposes. The specific types of first and third party Cookies served through our Website and the functions they perform are described in more detail below.

First-party Cookies. These cookies are created by Chicory Media. They allow you to browse our Website and use their features.

Essential Cookies. These cookies are strictly necessary to allow you to move around the Website and use their features, such as accessing your subscriptions. Without these cookies, we cannot enable appropriate content based on the type of device you are using. Therefore, these cookies cannot be disabled.

Functional Cookies. These cookies allow us to remember choices you make on our Website (such as your preferred language or the region you are in). To refuse these Cookies, please follow the instructions below under the section Cookie Management. Note that by disabling functional cookies, you may not be able to use some of our features or those features may not function properly.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Website, such as the links you click on. The code is temporarily downloaded onto your computer or other device, is active only while you are connected to the Website, and is deactivated or deleted thereafter.

Analytics Cookies. We use Cookies and other identifiers (such as web beacons) to see how you use our Website in order to enhance their performance and develop them according to the preferences of our customers and visitors. For example, cookies and web beacons may be used to track and provide trend analysis on how our users interact with our Website, track errors, and measure the effectiveness of our promotional campaigns. To refuse these Cookies, please follow the instructions below under the section Cookie Management.

Cross-Device Cookies. Chicory Media may use cookies in combination with the information we collect — for instance, IP addresses and unique mobile device identifiers — to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of the Website. To refuse these Cookies, you may install the Google Analytics Opt-out Browser Add-on.

Third-Party Cookies. Some of our third party partners (including advertisers and marketing services companies) may set and access Cookies on your computer as well, or we may do so on their behalf. We do not have control over how these third parties use such cookies and similar technologies or the information derived therefrom, and this Privacy Policy does not cover any use of information that such third parties may have collected from you or the methods used by the third-parties to collect that information. To see a list of our third party partners, please click here. These types of cookies include:

Advertising Cookies. These Cookies, defined exclusively by third parties, collect several types of data about your browsing habits, as well as your preferences for products and services. This information allows Chicory Media to serve you relevant advertisements on our Website. To refuse these cookies, please follow the instructions below under the section Cookie Management. Some advertisements may also contain an icon that you may click on to find out more about how to manage your advertising preferences.

Third-Party Functional Cookies. These Cookies are defined by third parties who support our Website and allow you to use useful services and features. To refuse these cookies, please follow the instructions below under the section Cookie Management.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “clear GIFs” or “pixel tags”) or similar technologies may be included in our web pages. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Website, to monitor how users navigate the Website, or to count how many particular articles or links were actually viewed. A clear gif may enable us to relate your viewing or receipt of a web page or message to other information about you, including your Personally Identifiable Information. To refuse Web Beacons, please follow the instructions below under the section Cookie Management.

HTML. HTML, the language some websites are coded in, may be used to store information on your computer or device about your interaction with and use of the Website. This information may be retrieved by us to help us manage our Website, such as by giving us information about how our Website is being used by our visitors, how they can be improved, and to customize them for our users.

Types of Cookies We Serve on Third-Party Services.

Duration of Storage of Cookies on Your Device. We use both “session cookies” (which expire once you close your web browser) and “persistent cookies” (which stay on your computer until you delete them).

Cookie Management.

Analytics. To learn about Google Analytics’ currently available opt-outs for the Web, please visit https://support.google.com/analytics/answer/181881?hl=en.

Disabling Advertising Cookies. Some of the advertising service providers may be members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. If you opt-out of receiving targeted ads in this manner, you will continue to receive advertising messages after you opt-out, but they will not be customized to you based on your use of the Website and/or third party websites. If you would like more information about advertisers’ use of tracking technologies and about your option not to accept these cookies, you can go to www.networkadvertising.org. If you would like to learn more about how interest-based information is collected, whether the companies we use are part of an industry network regarding behavioral advertising and to know your choices about not having information used in this manner, you can go to www.aboutads.info. The collection of information via certain ads served to users in Canada may be managed by visiting youradchoices.ca. Please note that the-opt out is cookie-based and will only affect the specific computer and browser on which the opt-out is applied.

Using Browser Settings. You can disable and/or delete most types of cookies by using your browser settings. Please note that if you use your browser settings to block all cookies you may not be able to access parts of our or others’ Websites. The following links provide information on how to modify the cookies settings on some popular browsers:

• Apple Safari

• Google Chrome

• Microsoft Internet Explorer

• Mozilla Firefox

Do Not Track Signals. Chicory Media does not act on “do not track” requests from your browser because, this way, we are able to personalize your experiences on Starcasm. For more information, go to www.networkadvertising.org or www.aboutads.info. If you have questions about the use of Cookies on our Website, please contact us by sending an email to starcasmtips(at)yahoo.com.

List of third party partners as of April 3, 2020

To see a list of our third party partners as of the date noted above, please see below. This list may be updated from time to time.

Ad Servers:

AdButlerAtlas
Celtra
Clipcentric
DCM
Flashtalking
Google AdSense
Jet Pack
LiveIntent
Sizmek
Spotible
Teads

Tracking Vendors:

Adjuster
Adobe Audience Manager DMP
Adrizer
Apester
Blockthrough
Bluekai
Ceros
Collective UK
Conversant
Dioh
Double Verify
Flluct
Google Analytics
Ideon
Innovid
Integral Ad Science
Keywee
Lotame
Lucid
Marketing Evolution
Millward Brown Digital
Moat
Neustar
Nielsen
Optimera
Optimizely
Oracle
Permutive
Piwik
Placed
Research Now
Salesforce DMP / Krux
Samba TV
Sizmek/Peer39
Skimlinks
SpotX
Stanza
Visual IQ
White Ops