Starling Brands, Inc.

Privacy Policy


This Privacy Policy is effective as of July 6, 2018.


We at Starling Brands, Inc. (“Starling,” “We,” “Us,” or “Our”) have created this privacy policy (the “Privacy Policy”) to describe what information we collect and explain how we collect, use, share and protect your personal information.  This Privacy Policy is incorporated into and part of the Terms of Use, that govern your access to and use of the website (“Website) and related mobile application (“App”).  The Website, App and any other sites or services directly owned and controlled by Starling Brands, Inc. are collectively referred to as Our “Services”.


You are encouraged to read this entire privacy policy. By using our Services, you are agreeing to and accepting the terms of this Privacy Policy and the accompanying Terms of Use.  If these are not acceptable to you, then you should not use our Services or submit any personal information or other content to us. Our Services may also contain links to third party websites and our Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with.  This Privacy Policy applies only to information collected through our Services and does not address offline or personal communications.  Anyone may request more information regarding our data use policies, by contacting us at, or by the manner set forth herein.


Our Services are for Adults 21 years and older, and patients with medical recommendations 18 and older.  If you are a minor under the age of 18, please do not use our Services.  Our Services, Including the Website and App are not directed to children 17 and under.


The Services are targeted towards adults, 21 and older.  We adhere to the Children’s Online Privacy Protection Act (COPPA and Cal-OPPA) and will not knowingly collect personal information from any child under the age of 18, and delete any information in our database we know originates from a child under the age of 18.


If you have reason to believe any user or Registered User is under 18 please contact us immediately at  If you are under 18, you, your parent, or your legal guardian may request that we deactivate and delete any and all of your personal information in our database by contacting us at



Table of Contents






In the course of operating the Services, we will collect and/or receive the following types of “Information.”   You authorize us to collect and/or receive such information.


  1. Personal Information. For you to access certain services that we offer through the Site, we may require you to provide us with information that can identify you as an individual (“Personal Information”). We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us via our Services or email.  When you sign up to become a user of our Services, you will be required to provide us with personal information about yourself which may include your name, username, password, e-mail address, physical address, and phone number.  We only collect Personal Information you provide us voluntarily when you use our Services.

  3. Geolocational Information. Certain features and functionalities of the App are based on your location. In order to provide these features and functionalities while you are using your mobile device, we may, with your consent, automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers (collectively, “Geolocational Information”). Collection of such Geolocational Information occurs only when the App is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.

  5. Third-party Log In. If you sign in through a Third Party Log-In (such as Google, Facebook, or any other company not controlled by Starling Brands, Inc.) you are authorizing us to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed that such Third Party would provide to us through their respective terms, conditions and policies for their Application Programming Interface (“API”). Such information may include, without limitation, your first and last name, username, profile picture, headline, unique identifier and access token, and e-mail address.

  7. Third-Party Analytics. We and the third-party technology providers, ad exchanges, ad networks, advertisers, agencies, ad exchanges, and ad servers with which we work use third-party analytics services (e.g., Google Analytics) to evaluate your use of the Services, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Services and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt out from certain data collection, please visit be advised that if you opt out of any such service, you may not be able to use the full functionality of our Services.

  9. Other Information. In addition to the Personal Information, Payment Information, and Geolocational Information, we may automatically collect or receive additional information regarding you and your use of the Services; your interactions with us and our advertising; and information regarding your computer and mobile devices used to access the Services (collectively, the “Other Information”).  We may use this for general marketing purposes and to help enhance customer experience for our Services.  Such Other Information may include:


  1. From You. Additional information about yourself that you voluntarily provide to us, such as your gender and your product and service preferences.

  3. From Your Activity. We may collect or receive information regarding:

    IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device;
    Domain servers,
    Type of computer or device used to access the Services
    browser type and language;
    referring and exit pages and URLs;
    date and time; and
    details regarding your activity while using the Services, such as search queries and other performance and usage data


  5. About Your Mobile Device. We may collect or receive information regarding:

type of mobile device;
advertising Identifier (“IDFA” or “AdID”);
operating system and version (e.g., iOS, Android or Windows);
carrier; and
network type (WiFi, 3G, 4G, LTE, etc.).





1. Cookies And Tracking Technology. Cookies are small files your computer or device can use to recognize a repeat visitor to our Services. We use both session cookies, which expire once you close your session and persistent cookies, which stay on your computer or mobile device until deleted.  We may also use other other technologies to help us collect data and enhance your experience such as single pixel gifs known as web beacons. We may use cookies or other technology for various purposes, including to:


  • personalize your experience;
  • analyze visitor and user interaction with the Website and App;
  • measure and optimize advertising and promotional effectiveness.


If you do not want us to deploy cookies in the App, you can opt out by setting your mobile device to reject cookies. You can still use the App if you choose to disable cookies, although your ability to use some of the features may be affected.




You authorize us to use the Personal Information, Payment Information, Geolocational Information, and the Other Information (collectively, the “Information”):

To provide, enhance and improve our Services;
To administer our promotional programs;
To solicit your feedback, respond to your requests,
To respond to your inquiries and requests;
To inform you about our products and services;
To inform you about changes to our Services
To identify you when you sign in to your account;
To respond to your requests and inquiries;
To send you Notices (for example, in the form of e-mails, mailings, text or SMS, etc.) regarding products or services you are receiving, and/or changes to our Services.
To send you information you may find useful or that you have requested from us;
To analyze the use of the Site and the Service and the people visiting to improve our content and Site and the Service;
For system administration, Service development, and making business decisions;
To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our policies, or as otherwise required by law;
For billing and collection purposes;
For any other purposes disclosed at the time the information is collected or to which you consent; and as otherwise specifically described in this Privacy Policy.



  1. Third-Party.  In order to provide our services and administer our promotional programs we may share the Information with third-parties.  We may disclose your personal information to our suppliers, service providers and other third parties engaged to assist in the provision of information, products and services to you, to provide services to the Company.  This may also include promotional and marketing partners, including, without limitation, businesses participating in our various programs.

  3. Affiliated Businesses. We may also engage third-party companies and individuals to perform functions on our behalf as set out in this Privacy Policy.  Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law;

  5. Aggregate Data.  In an ongoing effort to better understand our users, and our Services, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve such products and Services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the App and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.

  7. Internally.  We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

  9. Merger or Acquisition.  As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

  11. Disclosure.  Under certain circumstances, to the extent permitted by law, Information may be subject to disclosure:
  1. when required by law, court order, subpoena, warrant or other government or law enforcement authority or regulatory agency; or

  3. whenever we believe that disclosing such Information is reasonably necessary to protect the rights, property, or safety of us or others, including you.




We take the security of your Information seriously. We use reasonable safeguards – including administrative, physical and technical security and safeguarding measures – appropriate to the sensitivity of the personal information in the Company’s possession or under Our control to help protect the information from unauthorized access, collection, use, disclosure, deletion or similar risks. Nevertheless, security risks cannot be eliminated and we cannot guarantee the security of your personal information or that your personal information will not be accessed, used, disclosed or deleted in ways not otherwise described in this Privacy Policy.


We maintain written policies and procedure for the security, integrity and protection of Information We Collect from You and have put in place physical, technical, and organizational measures and processes to safeguard the Information We Collect from You, and to prevent unauthorized disclosure or loss.  When accessing the Services, We utilize Secure Socket Layer (SSL) technology which protects information using both server authentication and data encryption to help ensure data is safe and secure in transit. We also have implemented an advanced security method based on dynamic data and encoded session identifications and host the Services on servers located in a secure data center environment using a firewall and other advanced technology to prevent interference or access from outside intruders.


No security is guaranteed to be 100% secure, and there is always some risk assumed by sharing Information.  Although We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information through the Services or by e-mail will not be intercepted while being transmitted over the Internet.


If you have reason to believe that your Account has been compromised or is no longer secure, please immediately notify us at


In the event that any of Your Information under Our control is compromised as a result of a breach of security, we will investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with Applicable Laws.




The Services are targeted towards adults 21 and older, and medical patients with a doctor’s recommendation 18 and older.  If you are under 18, please do not use our Services.  Our Services, including the Website and App are not directed to children 17 and under. We adhere to the Children’s Online Privacy Protection Act (COPPA and Cal-OPPA) and will not knowingly collect personal information from any child 17 and under, and delete any information in our database we know originates from any such child.  If you are under 17, you, your parent, or your legal guardian may request that we deactivate and delete any and all of your personal information in our database and/or opt-out from receiving communications from us by contacting us at




You have the right to opt-out, or at any time to cease permitting Your Information from being collected, used or disclosed by Us to Our affiliates, assignees and third-parties.  You may cancel Your Account at any time, subject to the restrictions contained in Our Terms of Use.  At any time, at no cost to You, You may also request we cancel your account and delete all of Your Information from our servers and databases by contacting us at or by any manner set forth below.


We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in Our Services without terminating Your Account. For example, subject to the Terms of Use, You cannot opt out of receiving transactional e-mails related to the Services (such as certain account notifications and requests for support).


If You no longer wish to receive any promotional, marketing or other non-transactional communications from Us, you may opt-out by following the instructions included in each email communication, or by clicking on the “unsubscribe” link.  You may also opt-out of certain communications when adding Services, features or placing an order.  If You are a Registered User, you may also opt-out of certain communications and manage Your own profile information and preferences through Your Account page.


With your permission We may also deliver notifications, and/or use your location via Your mobile device, You can always change these and other App specific settings on Your mobile device.  Through Your browser, You can modify your preferences for using cookies.   However, if you choose to reject all cookies, you may not be able to use or access Our Services, the services or promotions offered by Our Affiliates or portions thereof.


Any Information you have provided to Starling Brands, you may access, remove, review, and/or make changes to such Information or how it has been collected, used or disclosed by contacting us at




Third parties that have links on Our Services may collect personally identifiable information about you. We are not responsible for the privacy policies or practices of such sites and the practices of these sites are not governed by this Privacy Policy. If you have questions about the privacy policies or practices of a third party site, you should contact the site administrator of the specific site.


We may from time to time partner with other companies to offer co-branded services as well as sweepstakes, contests and promotions. Any information that you provide in connection with the co-branded services or any jointly sponsored sweepstakes, contests or promotions will be retained by Starling Brands and its affiliates, assignees or partners. As always, We will maintain your information in accordance with the terms of this Privacy Policy. However, this Privacy Policy does not govern the privacy policies and practices of our business partners. If you have questions about the privacy policies or practices of our business partners, you should contact them directly.





This Privacy Policy and these Terms of Use, and any other agreements, rules and posted policies located at represent the entire agreement between You and Starling Brands with respect to Your use of the Services, govern Your use of the Services and supersede any and all prior communications and prior agreements, whether electronic, oral or written, between You and Our Company regarding the Services.  Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms of Use.


This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time and will post any changes as soon as they go into effect.  While we will make an effort to inform our visitors and Users of any changes to this Privacy Policy, the Terms of Use or any other policy, rule or regulation – such notice of a change provided via Our Services or by e-mail is done as a courtesy.  By accessing the Site or using the Services after we make any such changes to this Privacy Policy, you agree to and accept such changes. Please refer back to this Privacy Policy on a regular basis.




The Services and its servers are operated in Canada and Your data may be stored in more than one place.  If you are located outside of the United States, please be aware that your Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use Our Services, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.




If you have questions, comments, or a complaint about this Privacy Policy, you may contact us by e-mail us at with “Privacy Policy” in the subject line or mail us at the following address:


Starling Brands, Inc.,

100 King Street West, Suite 5600

Toronto, Ontario, M5X 1C9