This privacy policy applies when you use our services. As a user of our service, you have the right to make choices about the data we collect and how it is managed, stored and distributed. Privacy will be managed in line with the EULA signed by the user before commencing service.

Startingpoint is an online platform to showcase the talents, skills and experience of users, connecting them with employers and industry professionals. We believe that transparency about the data we collect about you, why it is collected, how it is used, and with whom it will be shared, is central to this mission.

Our registered users share evidence of their personal talents, aspirations and career choices. Other users may share professional identities, engage with other users, exchange knowledge and professional insights, learn and develop skills, and find business and career opportunities.

This Privacy Policy applies to all countries within United Kingdom, the European Union (EU), European Economic Area (EEA) and Switzerland. Users in California will be subject to additional disclosures required by Californian Law and can be viewed here.

This Privacy Policy applies to mystartingpoint.co.uk and all associated mystartingpoint domains, the Startingpoint app, offsite services including advertising, and all Startingpoint related sites and communications.

Personal user profiles can not be viewed by other personal users. Limited information submitted by personal users can be viewed by professional users. Information submitted by professional users can be viewed by personal users This exchange of information is moderated by the allocated school mentor for users under 16.

My SP Ltd (No: 13387508) will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services.

As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy and other documents referenced in this Privacy Policy, as well as updates.

Startingpoint can modify this Privacy Policy as appropriate and without consultation. Any changes will be notified to users through our services or communications before they become effective. If you object to any changes, you are welcome to manage your privacy options, or close your account.

Continued use of our services after we publish or share notice about changes to the Privacy Policy, or after the date the change takes effect, will serve as the users acknowledgement that they have read, understood and are satisfied with changes to the policy. Users are welcome to close their account at any point.

Data is submitted by the user, or by a mentor on behalf of the user. Mentors are elected by the school or service agreeing to the terms and conditions of using Startingpoint. Mentors will create the initial profiles, or will contribute to the onboarding process. Data used to populate user profiles will be submitted by the individual user and moderated by the elected mentor within each service. Users are not required to upload data, but this will limit user experience and engagement with the service.  

Upon creating an account, you or your mentor (in the case of schools) will need to provide name, surname, date of birth, location, school attended, role within the school. Business users will need to provide name of business, business identity (logo etc), business address, contact name, contact details. This will include payment details where a subscription to Startingpoint is required.

Users have the choice about what information they upload. The purpose of Startingpoint is to evidence skills, talents and experience (including education, employment and work experience) to prospective employers or education providers. This can be done through uploading media such as video clips, photographs, documents or other appropriate media to optimise user experience. The information uploaded to a users profile will be the choice and responsibility of the user (or their mentor).

Users will have the option to delete media uploaded to their profile.

Users (or mentors) will be responsible for ensuring any third parties that may feature in uploaded media do so with consent.

User may choose to upload to the app directly from their mobile device. This will require the user to authorise Startingpoint access to their camera and gallery. A notification will appear on the users device specifically requesting permission for access.

We collect data about you when you provide, post or upload to our services. This may include when you complete a form, a survey, an interaction with an employer or education provider.

Typical examples of additional data we may collect include:

• Data related to advertising. This may include analytics or the behaviours of users responding to advertising. This anonymised data will be used to evaluate and better inform marketing strategies.
• Voluntary personal data such as gender, ethnicity, demographic data. This data will be anonymized and used to identify and evaluate trends to further improve the service.
• Startingpoint is a dynamic evolving service. We may introduce features or additional services that require the collection of data. These material changes will be shares with users before they are implemented.

To further enhance the user experience, we use Cookies and similar technologies (pixels / ad tags etc) to recognize you and your devices across our services. Further information about the use of cookies can be found in our cookies policy. You can choose to opt out from our use of data from cookies and similar technologies that track your online behaviours through your account settings. This technology may be used for advertising. Opting out will not reduce the number of adverts you see, but may simply show a more random unrelated selection to your interests.

When you visit or leave our Services (including some plugins and our cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to and the time of your visit. We also get information about your network and device (e.g., IP address, proxy server, operating system, web browser and add-ons, device identifier and features, cookie IDs and/or ISP, or your mobile carrier). If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location

We gather data about you when you send or receive messages when engaging with another user or mentor, or to Startingpoint in the event of service support. Messages are recorded to protect the user, and ensure content is not being shared that violates the EULA or Startingpoints community guidelines.

How we use your data will depend on which services you use, how you access those services and the choices you make in settings. We use your data to provide an optimised service and constantly develop the service to enhance user experience.  We use your data to authorize access to our service and honour the choices you make in settings.

As a careers app, Startingpoint allows personal users to connect with professional users (employers / education providers etc) to get information about employment opportunities / work experience or education placements / courses. Startingpoint allows these professional users to connect and communicate with personal users who may demonstrate a desirable talent / skill or experience to offer them employment or education opportunities. Personal users can not communicate with other personal users, or see the profiles of other personal users. For users under 18 years old, a mentor allocated by the users school will monitor communication between personal users and professional users. We use this data to monitor channels of communication and the appropriateness of communication to safeguard our users.

Our services allow you to stay informed about opportunities, employment market data, education provision and changes to the service. We use the data we have about you within your profile to personalize the service to suggest or recommend employers, employment opportunities, job sectors and education providers that may be of interest to the user. We may also use this data to alert your profile to a professional user who may want to offer a personal user an employment or education opportunity. We may also use this data to inform personalized advertising from 3^rd parties.

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your Startingpoint account, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use our Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

We use targeted advertising to engage our users both on and off our services directly or through external advertising. This may include sponsored content that will appear in the same format as none sponsored content. We do this using:

• Data from advertising technologies on and off our Services, pixels, ad tags, cookies, and device identifiers;
• Member-provided information
• Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.),
• Information from advertising partners, vendors and publishers.
• Targeted marketing from employers and education providers based on the interests, skills and talents uploaded to users personal profiles.

Users can personalize their preferences in their settings. This will not remove advertising but simply opt you out from personalized marketing. You will still receive ads.

We use data to conduct research to identify trends, provide a more enhanced personalized experience to the user, grow the service and ensure the service remains innovative.

Our aim is to support the connections between users and employers and / or education providers. We will use data to identify local employment and education trends and opportunities. We will use data to ensure users are kept up to date with the most current offers from employers and education providers. We will use personal data to research social and economic trends, such as job availability compared with local skills market, to inform various industries in different geographical locations.

We will offer anonymised aggregated data to employers and / or education providers to support their development. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

We use your data to produce and share insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or create demographic workforce insights.

We will use data gathered from surveys, polls and feedback. These will be presented to users through the app, email or other appropriate communication. Users are not obliged to take part.

We use your data (such as messages / profile details) to offer support in the event that you contact us with any queries / concerns about the app, or for technical support.

The safety and security of our users is paramount. We will use your data to investigate or prevent violations of our user agreement, in the event of suspected fraud, or any other instance where it is deemed necessary to protect our users. Any legal requests should be emailed to legal@mystartingpoint.co.uk.

Users with personal profiles (School users / individual accounts) can not view the profiles of others, or communicate directly with users with the same accounts. School users and individual users can communicate with and view the profile of professional users. Communication between school users and professional users can only be done with authorisation from the schools allocated mentor.

School users profiles are visible to their allocated school mentor. Mentors also have the ability to edit the profiles of school users.

We collate and evaluate user data to identify trends in (including, but not limited to;) employment patterns, labour markets, employment and education opportunities geographically. We may share aggregated data with third parties. We will not share personal data, or data that can identify a user as an individual with any third party. The exception to this will be sharing any data requested by law for legal requirements / investigations. Data can be requested by contacting legal@mystartingpoint.co.uk.

We will share personal data of personal users with professional users within Startingpoint. This will be limited to data relevant to employment or education. We will not share any data with any user that can be used to leave a personal user vulnerable to any type of discrimination, direct or otherwise.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Startingpoint, our Members, personnel or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

Startingpoint will share your data as a result of any merger, takeover or sale of the company (as a whole or in part), or in preparation for any of these. Any change in privacy as a result of any of the aforementioned will be notified to the user with options to change settings or consent to continued use of data.

Users rights are protected under the General Data Protection Regulations (GDPR), California Consumer Privacy Act (2018)(CCPA) and other local laws. It is the responsibility of Startingpoint to ensure compliance with these regulations to ensure you know why we gather your data, how we use it and what your rights are.

We will retain your data for as long as your account remains open. You have the option to suspend your account if you choose to take a break from using the service, with all data remaining present when you decide to resume use of the service again. You have the option to close your account. We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse (e.g., if we have restricted your account for breach of our Professional Community Policies), enforce our User Agreement, or fulfil your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Users who delete their account are always welcome to return, but data from old accounts can not be transferred to new accounts. You can request to see the data we hold about you by submitting a data access request to data@mystartingpoint.co.uk. We will endeavour to respond to your request in a timely manner. Data will be shared only with the person making the request after a process of due diligence to validate the identity of the person making the request against the data being requested. Data will be presented back in a format deemed appropriate by the service.

Of the data we hold about you, there is either the option within the app, or via a data access request, you can ask us to;

• Request a copy of specific data we hold about you, taking it with you as a downloadable form.
• Delete all or part of the data we hold
• Edit the data
• Ask us to change, edit or repair data we hold about you
• Ask us to limit or restrict the access of others to data about you
• Request us to remove data in which you have been named or displayed by another user
• Ask us to investigate data where you believe another user is acting fraudulently in your name, using your details for a fake account for example, or displaying plagiarised work.
• Ask us to investigate any content posted by a user that could be harmful to the user posting the content, the user highlighting the concern, or any other user.
• Share data where you believe that Startingpoint as a service has not honoured its own privacy policy.
• Discuss any concerns around privacy issues

Startingpoint reserve the right to close or suspend your account in the event that a user has violated the user agreement, with all personal data being retained in the event of an investigation.

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.