This document is meant to explain the types of cookies and other tracking technologies that Starks Associates (“Starks”) may place on your device,whether you are visiting our web properties, or the storefront of a merchant who uses our platform to power their site.
What are cookies?
A cookie is a small piece of information that is downloaded to your computer or device when you visit certain websites. At Starks, we use different types of cookies on the website, including strictly necessary, performance, advertising, and social media or content cookies. Cookies enhance your browsing experience by allowing the website to remember your actions and preferences (such as login and region selection). This means you don’t have to re-enter this information every time you return to the site or navigate from one page to another. Cookies also help us gather on how people use the website, for instance whether it’s their first time visiting or if they are a frequent visitor. To learn more about how we use the data collected through these technologies, please refer to our Privacy Policy.
What cookies do we use and why?
At Starks, we use cookies for different purposes. Some cookies are necessary to enable you to browse our website, use its features, and access secure areas. These cookies are essential for the website to function properly . For example, we use user-input cookies for the duration of a session to keep track of a user’s input when filling in required information such as contact us forms on our website.
We also use functional cookies to remember choices you’ve made or information you’ve provided, such as your username, language, or the region you are in. This allows us to tailor your website experience specifically to your preferences. For example, authentication cookies are functional cookies that allow users to authenticate themselves on subsequent visits or to gain access to authorised content across pages. The functional cookies we use include:
User-centric security cookies to detect authentication abuses for a limited persistent duration, like repeated failed login attempts. These cookies are specifically designed to increase the security of the service.
Multimedia content player session cookies (flash cookies) are used for the duration of a session to store technical data needed to play back video or audio content (such as image quality, network link speed, and buffering parameters).
Load balancing session cookies are used for the duration of the session to identify the same server in the pool, allowing the load balancer to redirect user requests appropriately.
User interface customization persistent cookies are used to store a user’s preference regarding a service across web pages.
Starks is dedicated to user experience and we use many tools to help us improve our website and our commerce platform. To achieve this , we use reporting and analytics cookies to collect information about how you use our website or our merchants’ storefronts, and how often. These cookies only gather information for statistical purposes and use pseudonymous cookie identifiers that do not directly identify you. The performance cookies we use include:
First party analytics cookies - We use these cookies to estimate the number of unique visitors, to improve our websites and our merchants’ websites, and to detect the most searched-for words in search engines that lead to a webpage. These cookies are not used to target you with online marketing. Instead, we use them to learn how our websites and our merchants’ websites are performing, so we make relevant improvements to enhance your browsing experience.
Third party analytics cookies - We also use Google Analytics and other third-party analytics providers listed below to help measure how users interact with our website content. These cookies “remember” what our users have done on previous pages and how they’ve interacted with the website. For more information on Google Analytics, please visit Google’s information page. To opt out of Google Analytics, please follow the instructions below .
Advertising cookies are used on our website to tailor marketing to your interests and provide you with a more personalised service in the future. These cookies remember that you visited our website, and we may share this information with third-parties, such as advertisers. Although these cookies can track your device’s visits to our website and other sites, they typically cannot personally identify you. Without these cookies, the advertisements you see may be less relevant and interesting to you. Read more about how companies use cookies to conduct targeted or retargeted advertising here. We do not set advertising cookies through our merchants’ storefronts ourselves, although merchants may choose to do so independently.
Finally, Social and Content cookies are placed by many social media plugins (such as the Facebook ’like’ button), and other tools meant to provide or improve the content on a website, (for example services that allow the playing of video files, or that create comments sections). We integrate these modules into our platform to improve the browsing and interaction experience on our websites. Please note that some of these third-party services place cookies that are also used for things like behavioural advertising, analytics, and/or market research.
How long will cookies remain on my computer or mobile device?
The length of time that a cookie remains on your computer or mobile device depends on whether it is a ‘persistent’ or ‘session’ cookie. Session cookies last until you stop browsing, and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device. Please refer to the section below on how to control cookies for more information on removing them before they expire.
How to control cookies?
You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu. For more information on how to modify your browser settings or how to block, manage or filter cookies can be found in your browser’s help file or through sites such as: www.allaboutcookies.org
Contact Us
All access requests, questions, comments, complaints and other requests regarding the cookies policy should be sent to support@starksassociate.com
We may request additional details from you regarding your complaints and keep records of your requests and resolution.
Last updated: 25th August , 2023
The following Privacy Policy applies to our data collection and use practices relating to your use of Starks Associates financial services, our website and our other products and services (collectively, “Starks Services”). As a Starks client, service user or visitor, you agree to this Privacy Policy and any further modifications made to this Privacy Policy. The terms “Starks”, “we”, “our”, or “us” refer to Starks Associates Limited or the Starks entity responsible for the collection and use of personal data under this Privacy Policy. It may vary depending on your country.
Starks may enter into written product or service agreements with business customers that contain specific provisions related to the confidentiality, security or other handling of information. if any provisions of a written product or service agreement differ from or conflict with the provisions outlined in this Privacy Policy, the terms of the written agreement will apply. Otherwise, the terms of this Policy apply.
The Privacy Policy applies solely to information collected by this website and its related services, and will notify you of the following:
“Personal Data” means any information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g., device information, IP address).
“Services” means the products and services that Starks indicates are covered by this Policy, which may include Starks-provided devices and applications. Our “Business Services” are Services provided by Starks to entities (“Business Users”) who directly and indirectly provide us with “End Customer” Personal Data in connection with those Business Users’ own business and activities. Our “End User Services” are those Services which Starks directs to individuals (rather than entities) so that those individuals do business directly with Starks. “Sites” means Starkassociates.com and the other websites that Starks indicates are covered by this Policy. Collectively, we refer to Sites, Business Services and End User Services as “Services”.
Depending on the activity, Starks acts as a “data controller” or “data processor” and for more information about this and on the Starks entity that is responsible under this Policy, see our terms and conditions.
This privacy policy will provide information on the following:
We provide User Services where we do not act as a service provider to Businesses but instead provide the Services directly to you (“an individual”) for your personal use.
Personal data that we collect about End Users
How we use and share personal data of End Users
See our Cookie Policy. We do not share End User Personal Data with third parties for their marketing or advertising unless you give us or the third-party permission to do so. We do not sell the data of End Users.
Personal data that we collect about Business Users
Starks offers Business Services to our Business Users. When we are acting as a Business User’s financial service provider, we will process Personal Data in accordance with the terms of our agreement with the Business User and the Business User’s lawful instructions. Business Users are responsible for making sure that their End Customer’s legal and privacy rights are respected, including ensuring appropriate disclosures about data collection and use that occurs in connection with their services.
Personal data that we collect about Business Users
How we use and share personal data of Business Users
We generally use and share Personal Data of End Customers with Business Users to provide Business Services as described below, as well as for Starks’ Own purposes to secure, improve and provide our Business Services, as described below.
Personal data that we collect about Visitors
Visitors refer to individuals who visit Starks sites but are not Individual or business users. When you visit our Site, we generally receive your Personal Data either by you providing it to us directly,or through our use of cookies and similar technologies.
How we use and share visitor personal data
In addition to the ways we collect, use and share Personal Data that are described above, we also process your Personal Data as follows.
Personal Data Collection
Online Activity. Depending on the Service you use and the Business Users’ implementation of our Business Services, we will collect information about:
Communication and Engagement Information. We will collect any information you choose to provide to us, such as , through support tickets, emails or social media. When you respond to Starks emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Starks, as well as other information you may provide during the call. Additionally, we will also collect your engagement data, including your registration for, attendance of, or viewing of Starks events and any other interaction with Starks personnel.
Forums and Discussion Groups. If our Sites allow you to post content, we collect Personal Data that you provide in connection with the post.
Personal Data Usage.
In addition to the ways described above in which we use Personal Data, we use Personal Data in the following ways:
Personal Data Sharing.
In addition to the ways described above, we share Personal Data in the following ways:
Compliance and Harm Prevention. We share Personal Data as we believe necessary to:
(i) comply with applicable law,
(ii) comply with rules imposed by payment methods in connection with their use (e.g. network rules for Visa);
(iii) tenforce our contractual rights;
(iv) secure or protect the Services, rights, privacy, safety and property of Starks, you or others, including against other malicious or fraudulent activity and security incidents; and
(v) respond to valid legal process requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your Personal Data. For more information see here.
a. Contractual and Pre-Contractual Business Relationships. We process Personal Data to enter into business relationships with prospective Business Users and End Users and to perform the respective contractual obligations that we have with these Users. Activities include:
b. Legal Compliance. We process Personal Data to verify the identity of our Users as part of our legal compliance obligations, which may include fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity. These obligations may include , "Anti-Money Laundering ("AML") and Know-Your-Customer ("KYC")" obligations, as well as financial reporting obligations. For example, we may be required to record and verify a User’s identity for the purpose of compliance with legislation intended to prevent money laundering and financial crimes. These obligations are imposed on us by law, industry standards, and by our financial partners, and may require us to report our compliance to third parties, and to submit to third party verification audits.
c. Legitimate Business Interests. Where allowed under applicable law, we rely on our legitimate business interests to process Personal Data about you. The following list sets out the business purposes for which we have a legitimate interest in processing your data:
d. Consent. We may rely on consent to collect and process Personal Data as it relates to how we communicate with you and for the provision of our Services. When we process data based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn.
You may have choices regarding our collection, use and disclosure of your Personal Data:
a. Opting out of receiving electronic communications from us
If you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails or by following the instructions provided here. We will make every effort to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, our Business Users may still send you messages and direct us to send you messages on their behalf.
b. Your data protection rights
Depending on your location, and subject to applicable law, you may have the following rights described here with regard to the Personal Data we control about you:
c. Process for exercising your data protection rights
To exercise your data protection rights please also see the Starks Privacy Center or contact us as described below.
We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of your Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data covered by this Policy against unauthorized access, destruction, loss, alteration or misuse. Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties. However , no data transmission or storage system can be guaranteed to be 100% secure.
To help us protect personal data, we encourage you to use a strong password and never share your password with anyone or reuse the same password with other sites or accounts. If you suspect that your interaction with us is no longer secure (for example . you feel that the security of your account has been compromised), please contact us immediately.
We retain your Personal Data as long as we are providing the Services to you or our Business Users (as applicable) or for a period during which we reasonably anticipate providing the Services. Even after we stop providing Services directly to you or a Business User with whom you are transacting , and even if you close your Starks account or complete a transaction with a Business User, we retain your Personal Data in order to comply with our legal and regulatory obligations. We may also retain it to monitor, detect, and prevent fraud. Additionally,we keep Personal Data to fulfil our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used. In cases where we keep Personal Data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
We are a global business. Personal Data may be stored and processed in any country where we conduct business, where our service providers operate or where you use an international payment method or financial partner service. We may transfer your Personal Data to countries other than yours , including to the Federal Republic of Nigeria. These countries may have data protection rules that are different from your country. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfer. In certain situations, we may be required to disclose Personal Data in response to lawful requests from Officials (such as law enforcement or security authorities).
We may change this Policy from time to time to reflect new services, changes in our privacy practices or relevant laws. The “Last updated” legend at the top of this Policy indicates when it was last revised. Any changes will be effective when we post the revised Policy on the Services.
We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our website and, if you are an End User or Business User, by contacting you through your Starks Dashboard, email address and/or the physical address listed in your Starks account.
If applicable law requires us to provide notice in a specified manner prior to making any changes to this Policy applicable to you, we will provide such required notice.
If you have any questions or complaints about this Policy, please contact us at support@starksassociate.com
Please read carefully the provisions of these Terms of Use (the “Agreement” or “Terms of Use”). It is a legal agreement between you and Starks Associate, Ltd. (“Starks Associate”, “we”, or “us”) regarding the use of our online and/or mobile services, website, and software provided by us (collectively known as the “Starks Associate Service”). By accessing or using the Starks Associate Service, you agree that you have read, understood, and agree to be bound by these Terms of Use, whether or not you are a registered user of the Starks Associate Service.
We reserve the right to amend this Agreement at any time by notifying you as provided in this Agreement, provided that no notice shall be required or given for non-substantive changes to the Agreement. If we substantively amend This Agreement, we will give you at least seven (7) days’ notice before the changes take effect, during which period of time you may reject the changes by terminating your account. Your continued use of the Starks Associate Service after any such change takes effect constitutes your acceptance of the new Terms of Use. If you do not agree to any of these terms or any future Terms of Use, your only remedy shall be to not use or access (or continue to access) the Starks Associate Service. This Agreement applies to all visitors, users, and others who access the Starks Associate Service (“Users”).
USE OF OUR SERVICE
ELIGIBILITY
You may use the Starks Associate Service only if you can form a binding contract with Starks Associate, and only in compliance with this Agreement and all applicable local, state, national, and international laws, rules and regulations. If you are under 18 of age, your parent or guardian must enter into this Agreement on your behalf, and will be responsible for your use of and access to the Starks Associate Service. Any use or access to the Starks Associate Service by anyone under 13 is prohibited and in violation of this Agreement. If you are under 13, please do not attempt to register for the Starks Associate Service or send any information about yourself to us, including your name, address, telephone number, or email address. If we learn that we have collected personal information from anyone under age 13 without verification of parental consent, we will delete that information as quickly as possible. Starks Associate reserves all rights not expressly granted under this Agreement. Any attempt by you to transfer any of the rights, duties or obligations hereunder, except as expressly provided for in this Agreement, is void.
STARKS ASSOCIATE ACCOUNT
You must create an account in order to gain access to the services and functionality that we may establish and maintain from time to time and at our sole discretion. You may not use another User’s account without permission. You are solely responsible for the activity that occurs on your account, and you must keep your account password secure. You must notify Starks Associate immediately of any breach of security or unauthorised use of your account. Starks Associate will not be liable for any losses caused by any unauthorised use of your account.
The Starks Associate Service is available through the Google Sign-In service, which requires an active Google account. By accessing the Starks Associates Service through Google Sign-In you represent and warrant that you have read and agreed to be bound by all applicable Google policies and will act in accordance with those policies, in addition to your obligations under this Agreement. If you access the Starks Associate Service through Google Sign in, Starks Associate may require that your Starks Associate user ID be the same as your username for Google.
If you sign into Starks Associate through Google Sign in, you will provide your Google account credentials to Starks Associate, and you are consenting to have the information in that account transmitted into your Starks Associate account, and you agree that you shall only use Google accounts owned by you, and not by any other person or entity. By providing Starks Associate your email address, you consent to us using that email address to send you Starks Associate Service-related notices, including any notices required by law, in lieu of communication by snail mail. We may also use your email address to send you other messages, such as changes to features of the Starks Associate Service and special offers. If you do not want to receive such email messages, you may opt out by sending us a request at [email protected]. Opting out may prevent you from receiving email messages regarding updates, improvements, or offers. Please note that if you do not want to receive legal notices from us, including without limitation a notice that this Agreement has changed, those legal notices will still govern your use of the Starks Associate Service. We will post legal notices to the Starks Associate Service, and you are responsible for reviewing such legal notices for changes. Please see our Privacy Policy for more details.
SERVICE RULES
You agree not to engage in any of the following prohibited activities in connection with the Starks Associate Service:
You may not access or use the Starks Associate Service if you work with or for a competitor, except with Starks Associate’s prior written consent.
In addition, you may not use or access the Starks Associate Service for purposes of monitoring the performance or functionality for a competitor or for any third party, or for any other benchmarking or competitive purposes and you may not share any benchmarking data regarding the Starks Associate Service usage with any third party without Starks Associate’s prior written consent. We may, without prior notice, change the Starks Associate Service, stop providing the Starks Associate Service or features of the Starks Associate Service (to you or generally), or create usage limits for the Starks Associate Service. You agree that Starks Associate has no responsibility or liability for the deletion or failure to store any documents, data or other content maintained or uploaded by you to the Starks Associate Service. We may permanently or temporarily terminate or suspend your access to the Starks Associate Service without notice or liability to Starks Associate, for any reason or for no reason, including if in our sole determination you violate any provision of this Agreement. Upon termination of this Agreement or your access to the Starks Associate Service for any reason or no reason, you will continue to be bound by the terms of this Agreement which, by their nature, should survive termination, including without limitation ownership provisions, warranty disclaimers, indemnity, and limitations of liability.
USER CONTENT
You are solely responsible for all data (“User Content”) that you upload, post, publish or display (hereinafter, “upload”) or email or otherwise use via the Service. You agree not to upload User Content that:
For the purposes of this Agreement, “Intellectual Property Rights” means all patent rights, copyright rights, mask work rights, moral rights, rights of publicity, trademark, trade dress and service mark rights, goodwill, trade secret rights and other intellectual property rights as may now exist or hereafter come into existence, and all applications therefore and registrations, renewals and extensions thereof, under the laws of any state, country, territory or other jurisdiction.
In connection with your User Content, you affirm, represent and warrant that your User Content and Starks Associate’s use thereof as contemplated by this Agreement and the Starks Associate Service will not violate any law or infringe any rights of any third party, including but not limited to any Intellectual Property Rights and privacy rights.
Starks Associate takes no responsibility and assumes no liability for any User Content that you or any other User or third-party posts or sends over the Starks Associate Service. You acknowledge and agree that Starks Associate may preserve your User Content and may also disclose content if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to:
You understand that the technical processing and transmission of the Starks Associate Service, including your content, may involve –
(a) transmissions over various networks; and
(b) changes to conform and adapt to technical requirements of connecting networks or devices
By uploading any User Content, you hereby grant and will grant Starks Associate and its affiliated companies a non-exclusive, worldwide, royalty free, fully paid up, transferable, sublicensable, perpetual, irrevocable licence to copy, display, upload, perform, distribute, store, modify and otherwise use your User Content in connection with the operation of the Starks Associate Service, in any form, medium or technology now known or later developed.
THE DATA PROTECTION ACT 2018
We comply with the provisions of the Data Protection within the jurisdictions where Starks Associates operates. We have expressly stated some of these jurisdictions. In the UK, we comply with the Data Protection Act 2018 (“DPA”) applicable to controllers within the ambit of Section 6 of the DPA. The Data Protection Act 2018 is the UK’s implementation of the General Data Protection Regulation (“GDPR”). If you have an intellectual property rights-related complaint about material posted on the Starks Associates Service, you may contact our Designated Agent at the following UK address:
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
THE DATA PROTECTION LAWS IN CANADA
We comply with the provisions of Personal Information Protection and Electronic Documents Act 2000 ('PIPEDA'); Personal Information Protection Act, SBC 2003 c 63 ('BC PIPA'); Personal Information Protection Act, SA 2003 c P-6.5 ('AB PIPA'); and the Act respecting the Protection of Personal Information in the Private Sector, CQLR c P-39.1 ('Quebec Private Sector Act'), If you have an intellectual property rights-related complaint about material posted on the Starks Associates Service, you may contact our Designated Agent.
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
THE KENYA DATA PROTECTION ACT 2019
We comply with the provisions of the Kenya Data Protection Act 2019 applicable to Data controllers and Processors particularly with respect to the provisions of Part IV – 48 – 50. If you have an intellectual property rights-related complaint about material posted on the Starks Associates Service, you may contact our Designated Agent.
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
THE UGANDA DATA PROTECTION AND PRIVACY ACT, 2019 AND THE DATA PROTECTION AND PRIVACY REGULATIONS 2021
We comply with the provisions of the Uganda Data Protection and Privacy Act 2019 applicable to Data controllers and Processors. If you have an intellectual property rights-related complaint about material posted on the Starks Associates Service, you may contact our Designated Agent.
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
THE GHANA DATA PROTECTION ACT (Act 843), 2012
We comply with the provisions of the Ghanaian Data Protection and Privacy Act 2012 applicable to Data controllers and Processors. If you have an intellectual property rights-related complaint about material posted on the Starks Associates Service, you may contact our Designated Agent.
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
THE SOUTH AFRICAN PROTECTION OF PERSONAL INFORMATION ACT (POPIA), 2021
We comply with the provisions of the South African Protection of Personal Information Act (“POPIA”) applicable to Data controllers and Processors. If you have an intellectual property rights-related complaint about material posted on the Starks Associates Service, you may contact our Designated Agent.
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
NIGERIA DATA PROTECTION REGULATION 2019
We comply with the provisions of the Nigeria Data Protection Regulation 2019 (“NDPR”) applicable to Internet service providers (particularly sections 16 – 31of the NDPR). If you have an intellectual property rights-related complaint about material posted on the Starks Associate Service, you may contact our Designated Agent at the following address:
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
Any notice alleging that materials hosted by or distributed through the Starks Associate Service infringe intellectual property rights must include the following information:
Repeat Infringers.
Starks Associate will promptly terminate without notice the accounts of users that are determined by Starks Associate to be “Repeat Infringers.” A Repeat Infringer is a user who has been notified of infringing activity or has had User Content removed from the Starks Associate Service at least twice.
CONFIDENTIALITY
Any materials or data that you provide to Starks Associate for the purpose of providing the Starks Associate Service will be your “Confidential Information,” except to the extent such documents –
Starks Associate will not disclose your Confidential Information to any third party without your prior consent, ,except for providing such Confidential Information to our directors, officers, employees, agents, consultants, contractors, representatives or affiliated entities (collectively, “Associated Persons”) who need to have access to such Confidential Information in connection with the Permitted Purpose.
Starks Associate will use reasonable care to protect the confidentiality of your Confidential Information. In the event that Starks Associate is required by law to make any disclosure of any of your Confidential Information, whether by subpoena, judicial or administrative order or otherwise, Starks Associate will make commercially reasonable efforts to give you notice of such requirement (to the extent legally permissible) and will permit you to intervene in any relevant proceedings to protect your interests in your Confidential Information
FEES
To use the Starks Associate Service, you may be required to make one or more payments and provide us with information regarding your credit card. You represent and warrant to Starks Associate that such information is true and that you are authorised to use the payment instrument.
You will promptly update your account information with any changes (for example, a change in your billing address or credit card expiration date) that may occur. You agree to pay Starks Associate the amount that is specified by the Starks Associate Service in accordance with the terms therein and this Agreement.
Starks Associate reserves the right to change our prices. If we change our prices, we will provide notice of the change on the Starks Associate web site or in email to you, at our option. Your continued use of the Starks Associate Service after the price change becomes effective constitutes your agreement to pay the changed amount. If Starks Associate agrees, in its sole discretion, to invoice you for your receipt of the Starks Associate Service (rather than requiring you to pay all fees by credit card), you must nevertheless provide Starks Associate with your credit card information (as reasonably requested by Starks Associate) and promptly update such information with any changes that may occur.
If you fail to pay any invoices within 30 days of the date of the invoice, Starks Associate will notify you by email of the overdue charge and, if the invoice remains unpaid, Starks Associate will charge your credit card the full amount owing under the invoice on the 31st day following the date of the invoice.
You hereby authorise us to charge any such overdue amounts to your credit card on file and acknowledge that Starks Associate may suspend its provision to you of the Starks Associate Service if any amounts remain unpaid.
You may be required to pay all subsequent fees by credit card if you fail to pay an invoice within 35 days of the invoice date. Starks Associate will only remove a credit card on file at your request if your account balance is N0 and there are no Starks Associate Services pending for you.
LIABILITY FOR INVALIDATED PAYMENTS AND OTHER LIABILITIES
You are liable for all claims, expenses, fines and liability we may incur arising out of:
END USER LICENCE GRANT
STARKS ASSOCIATE SERVICE
Subject to the terms and conditions of this Agreement, you are hereby granted a nonexclusive, limited, non-transferable, freely revocable licence to use the Starks Associate Service for your personal, non-commercial use, as permitted by the features of the Starks Associate Service. Starks Associate reserves all rights not expressly granted herein in the Starks Associate Service and the Starks Associate Content (as defined below). Starks Associate may terminate this licence at any time for any reason or no reason.
MOBILE APPLICATION
We may make available Application to access the Starks Associate Service via a mobile device (“Mobile Application”). To use the Mobile Application, you must have a mobile device that is compatible with the Mobile Starks Associate Service. Starks Associate does not warrant that the Mobile Application will be compatible with your mobile device. Starks Associate hereby grants you a nonexclusive, non-transferable, revocable licence to use a compiled code copy of the Mobile Application for one Starks Associate account on one mobile device owned or leased solely by you, for your personal, non-commercial use. You shall not:
MOBILE APPLICATION FROM APPLE APP STORE
This paragraph is intended to apply to you if you have downloaded the Mobile Application from the Apple App Store. Starks Associate and you acknowledge that this Agreement is concluded between Starks Associate and you only, and not with Apple Inc. (“Apple”), and as between Starks Associate and Apple, Starks Associate, not Apple, is solely responsible for the Application and Starks Associate Services and the content thereof. You acknowledge that Apple, Ltd. has no obligation whatsoever to furnish any maintenance and support services with respect to the Mobile Application. You acknowledge that you have reviewed the App Store Terms and Conditions (located online at http://www.apple.com/legal/itunes/us/terms.html#APPS).
You represent and warrant that i. You are not located in a country that is subject to a Nigerian Government embargo, or that has been designated by the NIGERIAN Government as a “terrorist supporting” country; and ii. You are not listed on the Nigerian Government “watch list” of prohibited or restricted parties. This Agreement incorporates by reference the Licensed Application End User License Agreement (the “LAEULA”) published by Apple, Ltd. (located online at http://www.apple.com/legal/itunes/appstore/dev/stdeula/). For purposes of this Agreement, the “Mobile Application” is considered the “Licensed Application” as defined in the LAEULA and “Starks Associate” is considered the “Application Provider” as defined in the LAEULA. If any terms of this Agreement conflict with the terms of the LAEULA, the terms of this Agreement shall control.
MOBILE APPLICATION FROM THE GOOGLE ANDROID MARKET
This paragraph is intended to apply to you if you have downloaded the Mobile Application on a device powered by the Android operating system. Starks Associate and you, the end‐user of the Mobile Application and Starks Associate Services, acknowledge that the Agreement is entered into by and between Starks Associate and you. Starks Associate is solely responsible for the Application and Starks Associate Services. Should you have downloaded the Application from the Google Android Market located online at https://play.google.com/store.
You acknowledge that you have reviewed the Android Market Terms of Service (located online at https://play.google.com/about/play-terms.html) and the Android Market Business and Program Policies (located online athttp://play.google.com/about/play-terms.html). You represent and warrant that
STARKS ASSOCIATE PROPRIETARY RIGHTS
Except for your User Content, the Starks Associate Service and all materials therein or transferred thereby, including, without limitation, Application, images, text, graphics, illustrations, logos, patents, trademarks, service marks, copyrights, photographs, audio, videos, music, and User Content (the “Starks Associate Content”), and all Intellectual Property Rights related thereto, are the exclusive property of Starks Associate and its licensors. Except as explicitly provided herein, nothing in this Agreement shall be deemed to create a licence in or under any such Intellectual Property Rights, and you agree not to sell, licence, rent, modify, distribute, copy, reproduce, transmit, publicly display, publicly perform, publish, adapt, edit or create derivative works from any materials or content accessible on the Starks Associate Service. Use of the Starks Associate Content or materials on the Starks Associate Service for any purpose not expressly permitted by this Agreement is strictly prohibited.
PREMIUM SERVICES
From time to time, Starks Associate may provide additional features and/or Starks Associate Services that require payment (“Premium Starks Associate Services”). Starks Associate may also offer from time to time in its sole discretion, certain Premium Starks Associate Services for free, whether for a trial period or otherwise. Unless expressly stated otherwise, references in this Agreement to the Starks Associate Service include the Premium Starks Associate Services.
PRIVACY
For information about how Starks’ Associate protects your privacy, please read the Starks Associate Privacy Policy. This policy explains how Starks’ Associate treats your personal information, and protects your privacy, when you use the Starks Associate Service.
DELIVERY TERMS OF SERVICE
Starks Associate will undertake service delivery to complete transactions in the shortest amount of time possible. Where time commitments are explicitly agreed on, the time indicated is confined to business days only in the Pacific Standard Time zone. For example, 24- hour transaction delivery equates to 1 business day, 48-hour delivery equates to 2 business days and so forth. Our standard hours of service are 8am to 6pm Monday-Friday, Pacific Standard time. Additional support hours and after-hour service is available by inquiry.
INTELLECTUAL PROPERTY
All the content, trademarks, data, information or information contained in any materials or documents (“Documentation”) or used in relation to the Starks Associate Services, including but not limited to any and all copyrighted works, software, databases, text, graphics, icons, designs, hyperlinks, domain names, information and agreements (“Content”), are the property of or licensed to Starks Associate and as such are protected from copyright infringement. The Content may not be reproduced, distributed or copied by any means, whether electronically or not, without Starks Associate’s prior written permission.
Any and all intellectual property rights subsisting in the Documentation, Content, Starks Associate Services and Starks Associate Software or otherwise developed by or on behalf of Starks Associate, including all patents, rights in inventions, rights in designs, trademarks, trade and business names and all associated goodwill, rights to sue for passing off or for unlawful competition, copyright, moral rights and related rights, rights in databases, topography rights, domain names, rights in information (including know how and trade secrets) and all other similar or equivalent rights subsisting now or in the future in any part of the world, in each case whether registered or unregistered and including all applications for, and renewals or extensions of, such rights for their full term (“Intellectual Property”), vests in Starks Associate, its licensors or suppliers, as the case may be, and all rights not expressly granted are reserved.
Save as expressly set out herein, the User shall not acquire any right, title, or interest in the Starks Associate Intellectual Property. This Agreement does not grant either party any rights in connection with the other party’s trademarks. The User shall not use or alter Starks Associate’s trademarks without Starks Associate’s prior written consent or do anything which would adversely affect the value of Starks Associate’s trademarks.
The User may not use the Intellectual Property in a manner which may place the Intellectual Property at risk of loss or loss of value to Starks Associate. SECURITY Starks Associate cares about the integrity and security of your personal information. However, we cannot guarantee that unauthorised third parties will never be able to defeat our security measures or use your personal information for improper purposes. You acknowledge that you provide your personal information at your own risk.
THIRD PARTY LINKS
The Starks Associate Service may contain links to third-party websites, advertisers, services, special offers, or other events or activities that are not owned or controlled by Starks Associate. Starks Associate does not endorse or assume any responsibility for any such third-party sites, information, materials, products, or services. If you access a third-party website from the Starks Associate Service, such as through Facebook Connect, you do so at your own risk, and you understand that this Agreement and Starks Associate’s Privacy Policy do not apply to your use of such sites. You expressly relieve Starks Associate from any and all liability arising from your use of any third-party website, service, or content. Additionally, your dealings with or participation in promotions of advertisers found on the Starks Associate Service, including payment and delivery of goods, and any other terms (such as warranties) are solely between you and such third parties. You agree that Starks Associate shall not be responsible for any loss or damage of any sort relating to your dealings with such third parties.
BREACH
Should either party breach any material provision of this Agreement, then the aggrieved party will be entitled, without prejudice to any other rights it might have in law:
INDEMNITY
You agree to defend, indemnify and hold harmless Starks Associate and its subsidiaries, agents, licensors, managers, and other affiliated companies, and their employees, contractors, agents, officers and directors (collectively, the “Starks Associate Parties”), from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses (including but not limited to attorney’s fees) arising from:
NO WARRANTY
ANY SERVICE YOU PURCHASE THROUGH THE STARKS ASSOCIATE WEBSITE (“PRODUCT”) ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. USE OF THE SERVICE IS AT YOUR OWN RISK. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE STARKS ASSOCIATE SERVICE AND THE PRODUCTS ARE PROVIDED WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON INFRINGEMENT. WITHOUT LIMITING THE FOREGOING, STARKS ASSOCIATE, ITS SUBSIDIARIES, AND ITS LICENSORS DO NOT WARRANT THAT THE CONTENT IS ACCURATE, RELIABLE OR CORRECT; THAT THE STARKS ASSOCIATE SERVICE OR THE PRODUCTS WILL MEET YOUR REQUIREMENTS; THAT THE SERVICE WILL BE AVAILABLE AT ANY PARTICULAR TIME OR LOCATION, UNINTERRUPTED OR SECURE; THAT ANY DEFECTS OR ERRORS WILL BE CORRECTED; OR THAT THE SERVICE IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. ANY CONTENT DOWNLOADED OR OTHERWISE OBTAINED THROUGH THE USE OF THE STARKS ASSOCIATE SERVICE IS DOWNLOADED AT YOUR OWN RISK AND YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM SUCH DOWNLOAD OR YOUR USE OF THE STARKS ASSOCIATE SERVICE. STARKS ASSOCIATE DOES NOT WARRANT, ENDORSE, GUARANTEE, OR ASSUME RESPONSIBILITY FOR ANY PRODUCT OR SERVICE ADVERTISED OR OFFERED BY A THIRD PARTY THROUGH THE STARKS ASSOCIATE SERVICE OR ANY HYPERLINKED WEBSITE OR SERVICE, AND STARKS ASSOCIATE WILL NOT BE A PARTY TO OR IN ANY WAY MONITOR ANY TRANSACTION BETWEEN YOU AND THIRD PARTY PROVIDERS OF PRODUCTS OR SERVICES.
IF YOU DOWNLOADED THE MOBILE APPLICATION FROM THE APPLE APP STORE, YOU FURTHER ACKNOWLEDGE THAT APPLE HAS NO RESPONSIBILITY FOR ADDRESSING ANY CLAIMS RELATING TO THE APPLICATION OR STARKS ASSOCIATE SERVICES OR YOUR POSSESSION AND/OR USE OF THE APPLICATION OR STARKS ASSOCIATE SERVICES, INCLUDING, BUT NOT LIMITED TO: (I) PRODUCT LIABILITY CLAIMS; (II) ANY CLAIM THAT THE APPLICATION OR STARKS ASSOCIATE SERVICES FAIL TO CONFORM TO ANY APPLICABLE LEGAL OR REGULATORY REQUIREMENT; AND (III) CLAIMS ARISING UNDER CONSUMER PROTECTION OR SIMILAR LEGISLATION.
LIMITATION OF LIABILITY
IN NO EVENT SHALL THE STARKS ASSOCIATE PARTIES BE LIABLE, WHETHER BASED IN CONTRACT, TORT (INCLUDING NEGLIGENCE), OR ANY OTHER LEGAL THEORY, FOR ANY LOSSES, LIABILITIES, CLAIMS OR DAMAGES OF ANY KIND, WHETHER DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL OR PUNITIVE, OR FOR LOSS OF REVENUE OR PROFITS, LOSS OF BUSINESS, OR ANY OTHER DAMAGES, ARISING OUT OF OR IN CONNECTION WITH THE APPLICATION AND/OR ANY OF THE STARKS ASSOCIATE SERVICES, THESE TERMS OF USE OR THE PERFORMANCE, SUSPENSION, TERMINATION OR BREACH HEREOF, EVEN IF STARKS ASSOCIATE OR ANY OTHER STARKS ASSOCIATE PARTY HAS BEEN ADVISED OF THE POSSIBILITY THEREOF.
THE STARKS ASSOCIATE PARTIES SHALL HAVE NO LIABILITY IN CONNECTION WITH OR ARISING FROM THESE TERMS OF USE OR USE OF THE APPLICATION OR ANY OF THE STARKS ASSOCIATE SERVICES. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OF LIABILITY FOR PERSONAL INJURY, OR OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THIS LIMITATION MAY NOT APPLY TO YOU.
IN NO EVENT SHALL STARKS ASSOCIATE’S (OR APPLE’S IF YOU DOWNLOADED THE APPLICATION FROM THE APPLE APP STORE) TOTAL LIABILITY TO YOU FOR ALL DAMAGES (OTHER THAN AS MAY BE REQUIRED BY APPLICABLE LAW IN CASES INVOLVING PERSONAL INJURY) EXCEED THE AMOUNT YOU HAD PAID TO STARKS ASSOCIATE OVER THE PRECEDING THREE MONTHS PERIOD. THE FOREGOING LIMITATIONS WILL APPLY EVEN IF THE ABOVE STATED REMEDY FAILS OF ITS ESSENTIAL PURPOSE. THESE LIMITATIONS OF LIABILITY ALSO APPLY WITH RESPECT TO DAMAGES INCURRED BY YOU BY REASON OF ANY PRODUCTS OR STARKS ASSOCIATE SERVICES SOLD OR PROVIDED BY THIRD PARTIES OTHER THAN STARKS ASSOCIATE AND RECEIVED THROUGH OR ADVERTISED ON ANY OF THE STARKS ASSOCIATE SERVICES. YOU AGREE THAT IN THE EVENT YOU INCUR ANY DAMAGES, LOSSES OR INJURIES THAT ARISE OUT OF STARKS ASSOCIATE ACTS OR OMISSIONS, THE DAMAGES, IF ANY, CAUSED TO YOU ARE NOT IRREPARABLE OR SUFFICIENT TO ENTITLE YOU TO AN INJUNCTION PREVENTING ANY EXPLOITATION OF ANY WEB SITE, PROPERTY, PRODUCT, SERVICE, OR OTHER MATERIALS OWNED OR CONTROLLED BY THE STARKS ASSOCIATE PARTIES, AND YOU WILL HAVE NO RIGHTS TO ENJOIN OR RESTRAIN THE DEVELOPMENT, PRODUCTION, DISTRIBUTION, ADVERTISING, EXHIBITION OR EXPLOITATION OF ANY WEB SITE, PROPERTY, PRODUCT, SERVICE, OR OTHER MATERIALS OWNED OR CONTROLLED BY THE STARKS ASSOCIATE PARTIES.
SOME COUNTRIES DO NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY IN CONTRACTS WITH CONSUMERS AND AS A RESULT THE CONTENTS OF THIS SECTION MAY NOT APPLY TO YOU.
GENERAL
GOVERNING LAW AND JURISDICTION
Without prejudice to the provisions of the “Breach” clause, this Agreement shall be governed by the Laws of the Federal Republic of Nigeria, and in the event of any dispute, difference or claim arising out of or in connection with this Agreement, the parties shall meet in good faith, within a month of the knowledge of the dispute, for negotiation in an effort to resolve the dispute amicably.
If the dispute is not settled by Negotiation within 14 (Fourteen) days of commencement of such negotiations, or within a longer period as agreed to by the parties, the dispute, difference or claim shall be referred to The Lagos Multi-Door Courthouse (“LMDC”) for mediation which shall be conducted in accordance with the LMDC Mediation Procedure Rules or such other rules mutually agreed by the parties. If the parties fail to reach a settlement via mediation within 21 days, the matter shall be settled by reference to the High Court of Lagos State.
This Agreement shall be subject to and governed by and construed in accordance with the Laws of Lagos State of Nigeria. Where parties resort to Mediation in the resolution of disputes, each party will bear its respective legal and ancillary costs. Dispute Resolution and Arbitration Generally. In the event of any dispute, difference or claim arising out of or in connection with this Agreement, the parties shall meet in good faith, within a month of the knowledge of the dispute, for negotiation in an effort to resolve the dispute amicably.
Exceptions. Despite the provisions above, nothing in these Terms of Use will be deemed to waive, preclude, or otherwise limit the right of either party to:
Starks Associate’s address for Notice is: Starks Associate Ltd., Lekki.
The Notice must:
The parties will make good faith efforts to resolve the claim directly, but if the parties do not reach an agreement to do so within 30 days after the Notice is received, you or Starks Associate may commence an arbitration proceeding. During the arbitration, the amount of any settlement offer made by you or Starks Associate must not be disclosed to the arbitrator until after the arbitrator makes a final decision and award, if any.
If the dispute is finally resolved through arbitration in your favour, Starks Associate will pay you the highest of the following:
Modifications to this Arbitration Provision. If Starks Associate makes any future change to this arbitration provision, other than a change to Starks Associate’s address for Notice, you may reject the change by sending us written notice within 30 days of the change to Starks Associate’s address for Notice, in which case your account with Starks Associate will be immediately terminated and this arbitration provision, as in effect immediately prior to the changes you rejected will survive. Enforceability. If Section 23.f. is found to be unenforceable or if the entirety of this Section 23 is found to be unenforceable, then the entirety of this Section 23 will be null and void and, in that case, the parties agree that the exclusive jurisdiction and venue described in Section 22 will govern any action arising out of or related to these Terms of Use.
ENTIRE AGREEMENT / SEVERABILITY
This Agreement, together with any amendments and any additional agreements you may enter into with Starks Associate in connection with the Starks Associate Service, shall constitute the entire agreement between you and Starks Associate concerning the Starks Associate Service. If any provision of this Agreement is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Agreement, which shall remain in full force and effect.
NO WAIVER
No waiver of any term of this Agreement shall be deemed a further or continuing waiver of such term or any other term, and Starks Associate’s failure to assert any right or provision under this Agreement shall not constitute a waiver of such right or provision.
THIRD PARTY BENEFICIARIES AND AGREEMENTS
If you downloaded the Mobile Application from the Apple App Store, you acknowledge and agree that Apple, and Apple’s subsidiaries, are third party beneficiaries of this Agreement, and that, upon your acceptance of the terms and conditions of this Agreement, Apple will have the right (and will be deemed to have accepted the right) to enforce this Agreement against you as a third-party beneficiary hereof. You agree to comply with, and your licence to use the Mobile Application and Starks Associate Service is conditioned upon your compliance with, all applicable third-party terms of agreement, as may be applicable, when using the Mobile Application and/or Starks Associate Service.
ASSIGNMENT
This Agreement, and any rights and licences granted hereunder, may not be transferred or assigned by you, but may be assigned by Starks Associate without restriction or notice.
NOTICES
We may provide notices, whether such notices are required by law or are for marketing or other business-related purposes, to you via email notice, written or hard copy notice, or through posting of such notice on our website, Apple App Store or Google Android Marketplace, as determined by us in our sole discretion. We reserve the right to determine the form and means of providing notifications to our Users, provided that you may opt out of certain means of notification as described in this Agreement.
CONTACT US
Should you wish to contact us with any questions, complaints or claims with respect to the Starks Associate Service, you should visit the Starks Associate website at wwwstarksassociates.com, by email at [email protected]
These terms of service were last amended on 25th August, 2023.
USER CONTENT
You are solely responsible for all data (“User Content”) that you upload, post, publish or display (hereinafter, “upload”) or email or otherwise use via the Service. You agree not to upload User Content that:
For the purposes of this Agreement, “Intellectual Property Rights” means all patent rights, copyright rights, mask work rights, moral rights, rights of publicity, trademark, trade dress and service mark rights, goodwill, trade secret rights and other intellectual property rights as may now exist or hereafter come into existence, and all applications therefore and registrations, renewals and extensions thereof, under the laws of any state, country, territory or other jurisdiction.
In connection with your User Content, you affirm, represent and warrant that your User Content and Starks Associate’s use thereof as contemplated by this Agreement and the Starks Associate Service will not violate any law or infringe any rights of any third party, including but not limited to any Intellectual Property Rights and privacy rights.
Starks Associate takes no responsibility and assumes no liability for any User Content that you or any other User or third-party posts or sends over the Starks Associate Service. You acknowledge and agree that Starks Associate may preserve your User Content and may also disclose content if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to:
You understand that the technical processing and transmission of the Starks Associate Service, including your content, may involve –
(a) transmissions over various networks; and
(b) changes to conform and adapt to technical requirements of connecting networks or devices
By uploading any User Content, you hereby grant and will grant Starks Associate and its affiliated companies a non-exclusive, worldwide, royalty free, fully paid up, transferable, sublicensable, perpetual, irrevocable licence to copy, display, upload, perform, distribute, store, modify and otherwise use your User Content in connection with the operation of the Starks Associate Service, in any form, medium or technology now known or later developed.
THE DATA PROTECTION ACT 2018
We comply with the provisions of the Data Protection within the jurisdictions where Starks Associates operates. We have expressly stated some of these jurisdictions. In the UK, we comply with the Data Protection Act 2018 (“DPA”) applicable to controllers within the ambit of Section 6 of the DPA. The Data Protection Act 2018 is the UK’s implementation of the General Data Protection Regulation (“GDPR”). If you have an intellectual property rights-related complaint about material posted on the Starks Associates Service, you may contact our Designated Agent at the following UK address:
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
THE DATA PROTECTION LAWS IN CANADA
We comply with the provisions of Personal Information Protection and Electronic Documents Act 2000 ('PIPEDA'); Personal Information Protection Act, SBC 2003 c 63 ('BC PIPA'); Personal Information Protection Act, SA 2003 c P-6.5 ('AB PIPA'); and the Act respecting the Protection of Personal Information in the Private Sector, CQLR c P-39.1 ('Quebec Private Sector Act'), If you have an intellectual property rights-related complaint about material posted on the Starks Associates Service, you may contact our Designated Agent.
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
THE KENYA DATA PROTECTION ACT 2019
We comply with the provisions of the Kenya Data Protection Act 2019 applicable to Data controllers and Processors particularly with respect to the provisions of Part IV – 48 – 50. If you have an intellectual property rights-related complaint about material posted on the Starks Associates Service, you may contact our Designated Agent.
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
THE UGANDA DATA PROTECTION AND PRIVACY ACT, 2019 AND THE DATA PROTECTION AND PRIVACY REGULATIONS 2021
We comply with the provisions of the Uganda Data Protection and Privacy Act 2019 applicable to Data controllers and Processors. If you have an intellectual property rights-related complaint about material posted on the Starks Associates Service, you may contact our Designated Agent.
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
THE GHANA DATA PROTECTION ACT (Act 843), 2012
We comply with the provisions of the Ghanaian Data Protection and Privacy Act 2012 applicable to Data controllers and Processors. If you have an intellectual property rights-related complaint about material posted on the Starks Associates Service, you may contact our Designated Agent.
Starks Associates, Ltd.
ATTN: Copyright Notification
E-mail: support@starksassociate.com
