Privacy Policy

Starks Technology Services, LLC· Dallas, Texas

1. Introduction

Starks Technology Services, LLC (“STS,” “Starks Technology Services,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the information entrusted to us.

This Privacy Policy explains how we collect, use, disclose, store, and protect information when you visit our website, submit information through online forms, request an assessment or consultation, communicate with us, subscribe to communications, or engage with our services.

By using our website or voluntarily providing information to us, you acknowledge the practices described in this Privacy Policy.

This Privacy Policy applies primarily to information collected through our website and related business communications. Information processed by STS on behalf of customers as part of professional services may also be governed by a Statement of Work, Master Terms and Conditions of Sale, Data Processing Agreement, Business Associate Agreement, or other contractual agreement.

2. Information We May Collect

The information we collect depends on how you interact with STS.

Information You Provide Directly

We may collect information that you voluntarily provide, including:

• Name
• Company or organization name
• Job title
• Email address
• Telephone number
• Mailing or business address
• Information submitted through contact forms
• Consultation or appointment requests
• Assessment responses
• Information about your organization's technology environment
• Cybersecurity or compliance concerns
• Business needs and service interests
• Communications with STS
• Information submitted when requesting proposals, quotations, or services
• Information provided during a customer engagement
• Other information you choose to provide

Please avoid submitting sensitive information through general website contact forms unless specifically requested by STS through an appropriate secure method.

Information Collected Automatically

When you access our website, certain information may be collected automatically through cookies, analytics technologies, server logs, and similar technologies.

This information may include:

• Internet Protocol (IP) address
• Browser type
• Device type
• Operating system
• Approximate geographic location
• Referring website or source
• Pages viewed
• Links clicked
• Date and time of visits
• Time spent on pages
• Website navigation patterns
• General website interaction information

We may use this information to understand website usage, improve website performance, enhance security, troubleshoot technical issues, and improve our marketing and services.

3. How We Use Information

STS may use information collected through our website and business interactions to:

• Respond to inquiries
• Provide requested information
• Schedule consultations or assessments
• Evaluate potential customer needs
• Prepare proposals and Statements of Work
• Provide professional services
• Manage customer relationships
• Provide customer support
• Communicate regarding projects or services
• Send administrative or transactional communications
• Send marketing communications where permitted
• Improve our website
• Analyze website traffic and usage
• Improve our products and services
• Develop new services and capabilities
• Maintain website and information security
• Detect and prevent fraud, abuse, unauthorized access, or malicious activity
• Protect STS, our customers, and our systems
• Maintain business and operational records
• Fulfill contractual obligations
• Comply with applicable legal and regulatory requirements
• Establish, exercise, or defend legal claims

We may also use information for other purposes disclosed at the time the information is collected or with your consent.

4. Customer Data

Customers retain ownership rights in their data, records, files, databases, software, intellectual property, confidential information, and business information.

When STS receives customer information in connection with professional services, STS may access, process, store, transmit, analyze, and use that information as reasonably necessary to perform the services described in the applicable agreement or Statement of Work.

Customers are responsible for ensuring they possess the appropriate rights, permissions, and authorizations to provide information to STS.

The specific handling of customer data may be further governed by contractual agreements between STS and the customer.

5. Cybersecurity and Sensitive Information

Because STS provides cybersecurity, compliance, artificial intelligence, technology, and related professional services, customers may provide STS with technical or operational information that is not normally collected through a standard business website.

Depending on the engagement, such information may include:

• Network information
• System configurations
• Security documentation
• Vulnerability information
• Cybersecurity policies
• Compliance documentation
• Infrastructure information
• Software and hardware information
• Cloud environment information
• Security assessment results
• Business processes
• Internal documentation

Information of this nature should be provided only through methods authorized by STS for the applicable engagement.

STS uses commercially reasonable safeguards appropriate to the nature of the information and services involved.

6. Artificial Intelligence Technologies

STS may use artificial intelligence and automation technologies in connection with certain internal business processes or professional services.

Depending on the service or interaction, information may be processed using AI-enabled technologies for purposes such as:

• Research and analysis
• Workflow automation
• Data organization
• Content generation
• Technical analysis
• Customer support
• Cybersecurity analysis
• Business process automation
• Reporting
• Service delivery

Where appropriate, STS seeks to use such technologies in a manner consistent with contractual obligations, confidentiality requirements, security considerations, and applicable law.

Customers should not submit highly sensitive, regulated, classified, export-controlled, or confidential information to an AI-enabled feature unless its use has been specifically authorized for that purpose.

AI-related processing performed as part of a customer engagement may be governed by additional contractual terms.

7. Cookies and Similar Technologies

Our website may use cookies, pixels, analytics technologies, and similar tools to operate the website and understand how visitors interact with it.

These technologies may be used to:

• Maintain website functionality
• Remember certain preferences
• Analyze website traffic
• Understand visitor behavior
• Measure marketing effectiveness
• Improve website performance
• Detect suspicious or malicious activity
• Support advertising or remarketing activities where applicable

You may be able to control cookies through your browser settings or through a cookie-management tool made available on our website.

Disabling certain cookies may affect website functionality.

8. Analytics

STS may use third-party analytics services to understand website traffic and visitor interactions.

These providers may collect information such as device information, IP address, browser information, referring pages, pages visited, and interaction data.

Analytics information helps us evaluate website performance, understand how visitors find and use our website, and improve our services and marketing.

9. Contact Forms and CRM Systems

Information submitted through STS website forms may be transmitted to and stored within customer relationship management (“CRM”), marketing automation, scheduling, email, communications, or other business systems used by STS.

These systems help us:

• Respond to inquiries
• Track prospective customer relationships
• Schedule appointments
• Maintain communication records
• Follow up on service requests
• Send requested information
• Manage customer relationships
• Automate appropriate business communications

Information may therefore be processed by service providers that operate these systems on behalf of STS.

10. Email Communications

If you provide your email address, STS may use it to respond to inquiries, provide requested information, communicate regarding services, send transactional messages, or provide relevant business and marketing communications where permitted by law.

Marketing emails sent by STS will generally provide a method for unsubscribing from future marketing communications.

Unsubscribing from marketing communications does not prevent STS from sending necessary transactional, contractual, security, administrative, or service-related communications.

11. SMS and Text Messaging

If you voluntarily provide your mobile telephone number and consent to receive text messages, STS may send SMS or other text communications related to inquiries, appointments, services, requested information, or other communications for which you have provided consent.

Message frequency may vary.

Message and data rates may apply depending on your mobile carrier and service plan.

You may opt out of non-essential text communications by replying STOP to a message. You may reply HELP for assistance where supported.

Consent to receive marketing text messages is not a condition of purchasing STS products or services.

Mobile information will not be sold or shared with third parties for their own marketing or promotional purposes. SMS consent and opt-in information will not be shared with third parties or affiliates for their marketing purposes.

Information may be shared with telecommunications providers, messaging platforms, and service providers solely as necessary to deliver and support authorized communications.

12. How We Share Information

STS does not sell personal information in the ordinary course of its business.

We may disclose information to third parties when reasonably necessary for legitimate business purposes, including:

• Website hosting providers
• Cloud service providers
• CRM providers
• Email providers
• Telecommunications and messaging providers
• Scheduling platforms
• Analytics providers
• Cybersecurity providers
• IT service providers
• Payment processors
• Professional advisors
• Contractors and subcontractors assisting with service delivery
• Other technology providers supporting STS operations

These organizations may process information on our behalf as necessary to provide their services.

We may also disclose information when reasonably necessary to:

• Comply with applicable law
• Respond to a subpoena, court order, or lawful governmental request
• Protect STS's legal rights
• Protect the security of our systems
• Investigate suspected fraud or malicious activity
• Protect customers or other individuals
• Enforce contractual agreements
• Establish, exercise, or defend legal claims

We may also transfer information in connection with a merger, acquisition, financing, restructuring, sale of assets, or similar business transaction, subject to applicable legal requirements.

13. Third-Party Services

Our website and services may interact with or contain links to third-party websites, applications, cloud services, social networks, scheduling tools, payment systems, or other platforms.

STS does not control the privacy practices of independent third parties.

When you interact directly with a third-party service, its privacy policy and terms may govern the collection and use of your information.

We encourage you to review the privacy policies of third-party services you choose to use.

14. Data Security

STS takes the security of information seriously and uses commercially reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, disclosure, alteration, misuse, or destruction.

Security measures may vary depending on the nature and sensitivity of the information being processed.

However, no website, network, cloud platform, storage system, transmission method, or security technology can guarantee absolute security.

Users should exercise appropriate caution when transmitting sensitive information electronically.

15. Data Retention

STS may retain information for as long as reasonably necessary to:

• Provide services
• Maintain customer relationships
• Fulfill contractual obligations
• Maintain business records
• Resolve disputes
• Enforce agreements
• Comply with legal or regulatory obligations
• Maintain security records
• Protect against fraud or abuse
• Establish or defend legal claims

Retention periods may vary based on the type of information, purpose for which it was collected, contractual requirements, security considerations, and applicable law.

When information is no longer reasonably required, STS may delete, anonymize, aggregate, or securely dispose of it in accordance with applicable policies and requirements.

16. Your Privacy Choices

Depending on your location and applicable law, you may have certain rights or choices regarding your personal information.

These may include the ability to request:

• Access to personal information we maintain about you
• Correction of inaccurate personal information
• Deletion of certain personal information
• Information regarding how personal information is used
• Withdrawal of certain consent
• Opt-out from certain marketing communications

These rights are not absolute and may be subject to legal, contractual, security, recordkeeping, or other exceptions.

To submit a privacy-related request, please contact STS using the contact information provided on our website.

STS may need to verify your identity before processing certain requests.

17. Texas Residents

STS is headquartered in Texas.

Where applicable, Texas residents may have rights regarding their personal data under the Texas Data Privacy and Security Act and other applicable laws.

Subject to applicable requirements and exemptions, these rights may include requesting access to, correction of, or deletion of certain personal data and obtaining information regarding certain processing activities.

STS will evaluate applicable privacy requests in accordance with the laws and regulations applicable to the particular request.

18. Children's Privacy

STS services are intended for businesses, organizations, professionals, governmental entities, and adult users.

Our website and services are not directed toward children under the age of 13, and STS does not knowingly collect personal information from children under 13 through its general website.

If we become aware that personal information from a child has been collected inappropriately, we will take reasonable steps to address the information in accordance with applicable law.

19. Do Not Submit Restricted Information Through General Forms

Unless specifically instructed by STS through an authorized process, users should not submit the following through general website forms, chat tools, email marketing forms, or other unsecured public-facing channels:

• Passwords
• Authentication credentials
• Social Security numbers
• Financial account credentials
• Payment card information
• Protected health information
• Controlled Unclassified Information
• Classified government information
• Export-controlled technical data
• Encryption keys
• Private cryptographic keys
• Highly sensitive cybersecurity credentials
• Other highly sensitive or regulated information

STS may provide separate secure methods for transmitting sensitive information when required for a professional engagement.

20. Business Transfers

If STS is involved in a merger, acquisition, reorganization, financing, sale of assets, or similar business transaction, information may be transferred as part of that transaction.

Any successor organization may assume the rights and obligations relating to information held by STS, subject to applicable law and contractual obligations.

21. Changes to This Privacy Policy

STS may update this Privacy Policy periodically to reflect changes in our services, technology, business practices, legal requirements, or privacy practices.

When material changes are made, we may update the “Last Updated” date at the top of this Privacy Policy.

We encourage visitors to periodically review this Privacy Policy.

22. Relationship to Customer Agreements

This Privacy Policy describes general STS privacy practices.

Professional engagements may be subject to additional or different requirements established through:

• Master Terms and Conditions of Sale
• Statements of Work
• Data Processing Agreements
• Business Associate Agreements
• Nondisclosure Agreements
• Government contracts
• Subcontracts
• Security requirements
• Other written agreements

Where a written agreement imposes more specific obligations concerning customer information, that agreement will govern the applicable engagement.

23. Contact Us

If you have questions regarding this Privacy Policy or would like to submit a privacy-related request, please contact:

Starks Technology Services, LLC
Dallas, Texas

Please use the contact information provided on the Starks Technology Services website for privacy-related inquiries.