Acceptance of These Terms
These Data Licensing and Transfer Terms (the “Terms”) are a binding agreement between Start.io Inc. and/or the applicable entity within the Start.io Group (“Start.io,” “we,” “us” or “our”) and the person or legal entity accepting these Terms (“Customer,” “you” or “your”). If you accept these Terms on behalf of an entity, you represent that you are authorized to bind that entity.
By clicking “I Agree,” checking an acceptance box, accessing, receiving, licensing, transferring, or otherwise using any Licensed Data (as defined below), you acknowledge that you have read and agree to these Terms. If you do not agree, do not access, receive, transfer, or use Licensed Data.
These Terms apply in addition to any written order, insertion order, data license, data transfer agreement, data processing agreement, commercial agreement, platform terms, or other agreement between you and Start.io that expressly applies to the relevant data or services (each, an “Order” and collectively, the “Commercial Agreement”). These Terms are intended to govern the licensing, transfer, receipt, access, disclosure, and use of data made available by or on behalf of Start.io, and do not replace a separately executed data processing agreement, data license agreement, or applicable transfer mechanism.
1. Definitions
1.1. “Licensed Data” means any data, information, identifiers, records, attributes, segments, insights, signals, events, statistics, outputs, or other data-related materials that Start.io or any member of the Start.io Group makes available, licenses, sells, transfers, discloses, provides access to, receives for onward transfer, or otherwise supplies to Customer, directly or indirectly, in any form or through any channel, including personal data, pseudonymous data, device or advertising identifiers, location-related data, application or usage data, audience data, derived data, and aggregated or modeled data, in each case to the extent included in the applicable Order or Commercial Agreement.
1.2. “Applicable Data Protection Laws” means privacy, data protection, consumer protection, electronic communications, data brokerage, and targeted-advertising laws and regulations applicable to a Party’s activities under these Terms, including, where applicable, the GDPR, UK GDPR, ePrivacy laws, and applicable U.S. state privacy laws.
1.3. “Data Subject” means an identified or identifiable natural person to whom personal data relates.
1.4. “Start.io Privacy Policy” means the Start.io privacy policy applicable to the relevant data and activity, including the policy available at https://www.start.io/policy/privacy-policy-site/, as updated from time to time.
1.5. “Start.io Network” means Start.io’s data and advertising ecosystem, including relevant data sources, publishers, advertisers, business partners, and data partners.
2. Scope and Relationship to Other Agreements
2.1. These Terms apply whenever Customer accesses, receives, purchases, licenses, obtains, transfers, exports, discloses, activates, combines, analyzes, or otherwise uses or processes Licensed Data made available by or on behalf of Start.io, whether directly or through a platform, marketplace, API, file transfer, data clean room, real-time bidding integration, or other arrangement.
2.2. The Licensed Data may be made available in connection with advertising inventory operated by Start.io or on inventory operated by third parties. The specific data, identifiers, permitted activation channels, territories, campaign purposes, pricing, and delivery method may be described in an Order or platform configuration.
2.3. These Terms govern Customer’s use of Licensed Data. A separate data processing agreement, data license agreement, or data transfer agreement governs to the extent it expressly applies to the relevant data or processing. In the event of a conflict: (a) a signed data processing/data license agreement controls with respect to its express data protection, processing, and transfer provisions; (b) an Order controls with respect to the commercial terms expressly addressed in it; and (c) these Terms control with respect to permitted use of Licensed Data, unless the applicable signed agreement expressly states otherwise.
2.4. Nothing in these Terms expands the data, rights, or purposes that Start.io has agreed to make available under an applicable Commercial Agreement.
3. Limited License
3.1. Subject to Customer’s compliance with these Terms and payment of applicable fees, Start.io grants Customer a limited, revocable, non-exclusive, non-transferable, non-sublicensable license during the applicable term to access, receive, transfer (where expressly authorized), and use the Licensed Data solely for the purpose of targeted advertising or marketing, if the Licensed Data is processed or used in identifiable form, or for any legal purpose, if the Licensed Data is processed or used in a non-identifiable form (i.e.: in aggregated or anonymized form).
3.2. Without derogating from the above, Customer may use, disclose, or transfer Licensed Data only to the extent expressly permitted by these Terms and the applicable Order or Commercial Agreement. Any onward transfer must comply with the recipient, purpose, territory, security, and other limitations stated in the applicable agreement and applicable law.
3.3. No ownership of Licensed Data is transferred to Customer. As between the Parties, Start.io or its licensors retain all right, title, and interest in the Licensed Data, subject to any rights of End Users and applicable law.
3.4. Unless expressly authorized in a signed writing by Start.io, Customer shall not create or maintain a separate data product, data marketplace, identity graph, consumer profile database, or other commercial product from Licensed Data, or use Licensed Data to build, train, validate, or enrich a general-purpose data asset.
4. Customer Obligations and Permitted Use
Customer shall:
4.1. use Licensed Data only for the purposes, channels, territories, and campaign types authorized under these Terms and the applicable Order;
4.2. comply with all Applicable Data Protection Laws, advertising laws, platform rules, industry standards, and applicable self-regulatory requirements;
4.3. ensure that its use of Licensed Data is supported by an appropriate lawful basis and any consent, notice, permission, opt-out handling, or other authorization required by applicable law;
4.4. provide End Users with all notices and choices required for Customer’s own processing and advertising activities, and honor applicable opt-outs, objections, consent withdrawals, deletion requests, and other privacy rights;
4.5. maintain appropriate technical and organizational safeguards to prevent unauthorized access, use, disclosure, loss, or alteration of Licensed Data;
4.6. limit access to Licensed Data to personnel and service providers who need access for the permitted purpose and are bound by appropriate confidentiality and data protection obligations; and
4.7. promptly notify Start.io if Customer becomes aware of a material misuse of Licensed Data, a security incident involving Licensed Data, or a legal or regulatory inquiry that materially concerns Customer’s use of Licensed Data, to the extent legally permitted.
5. Prohibited Uses
Customer shall not, and shall not permit any third party to:
5.1. use Licensed Data for any unlawful, discriminatory, deceptive, abusive, or otherwise prohibited purpose;
5.2. use Licensed Data to make decisions about an individual’s eligibility for employment, credit, insurance, housing, healthcare, education, or other similarly significant opportunities, or for any purpose that produces legal or similarly significant effects on an individual;
5.3. attempt to identify, re-identify, locate, or contact an individual from Licensed Data, or link Licensed Data to a directly identified person, except to the extent expressly authorized in writing by Start.io and permitted by applicable law;
5.4. use Licensed Data to infer, target, or create segments based on sensitive or special-category personal data, or to target children, where prohibited by law or not expressly authorized by Start.io in writing;
5.5. reverse engineer, decompile, disassemble, or attempt to derive the underlying data sources, methodology, models, or proprietary systems used to create Licensed Data, except to the extent such restriction is prohibited by applicable law;
5.6. sell, rent, sublicense, publish, disclose, distribute, or otherwise make Licensed Data available to any third party, except to authorized service providers acting solely on Customer’s behalf for the permitted purpose and subject to written obligations at least as protective as these Terms;
5.7. combine Licensed Data with other data to create or enrich a persistent individual-level profile, identity graph, or database for purposes unrelated to the permitted advertising purpose;
5.8. use Licensed Data to train or improve an artificial intelligence or machine-learning model, or to create a competing data or data product, unless expressly authorized in writing by Start.io;
5.9. circumvent technical controls, consent signals, suppression lists, opt-out mechanisms, or other restrictions applied to Licensed Data; or
5.10. retain or use Licensed Data after the relevant license expires or is terminated, except to the limited extent retention is required by law and the retained data is not used for any other purpose.
6. Privacy, Transparency, and Data Subject Rights
6.1. Start.io describes its collection, use, and sharing of personal data in the Start.io Privacy Policy applicable to the relevant data and activity. Licensed Data may originate from mobile applications, advertising interactions, real-time bidding, publishers, platforms, commercial partners, and other sources, as described in the applicable disclosures and agreements.
6.2. Customer shall independently assess and document the lawful basis, notices, consents, permissions, and other requirements applicable to Customer’s receipt, transfer, disclosure, and use of Licensed Data. Customer shall not assume that Start.io’s privacy disclosures, consent records, or other legal basis automatically satisfy Customer’s own obligations for a particular use, recipient, channel, territory, or purpose.
6.3. Customer shall maintain a process to receive and promptly action applicable privacy requests and signals, including opt-outs, objections, consent withdrawals, and deletion requests. Where Start.io provides a suppression list, opt-out signal, consent signal, or other instruction applicable to Licensed Data, Customer shall implement it without undue delay and in accordance with applicable technical specifications.
6.4. Customer shall cooperate reasonably with Start.io in responding to End User requests, regulatory inquiries, and compliance assessments relating to Customer’s use of Licensed Data. The Parties shall separately agree on any technical or operational process needed to transmit rights requests or consent/opt-out signals.
6.5. These Terms do not represent that any particular Licensed Data is anonymous, non-personal, lawfully available for every possible transfer or use, or exempt from Applicable Data Protection Laws.
7. Sharing and Service Providers
7.1. Customer may allow its advertising agency, demand-side platform, campaign manager, or other service provider to access Licensed Data only where that access is necessary to perform the permitted advertising purpose on Customer’s behalf. Customer remains responsible for its service providers’ acts and omissions relating to Licensed Data.
7.2. Before providing access to Licensed Data, Customer shall ensure that each permitted recipient is bound by written confidentiality, security, privacy, and use restrictions that are no less protective than the relevant requirements of these Terms. Customer shall ensure that recipients do not use Licensed Data for their own independent purposes.
7.3. Customer shall not onward-transfer Licensed Data to a data broker, data marketplace, or other data recipient for its own use without Start.io’s prior written consent and a documented legal basis for the transfer.
8. Security and Incident Notification
8.1. Customer shall maintain reasonable and appropriate technical and organizational measures designed to protect Licensed Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.
8.2. Customer shall notify Start.io without undue delay after becoming aware of any actual or reasonably suspected unauthorized access, disclosure, loss, or misuse of Licensed Data. The notice shall include, to the extent then known, the nature of the incident, affected data and systems, likely consequences, and steps taken or planned to contain and remediate it. Customer shall reasonably cooperate with Start.io in investigating and mitigating the incident.
8.3. Any additional security, breach-notification, audit, or assistance obligations in a signed DPA or other applicable agreement remain in effect and control to the extent applicable.
9. Retention, Deletion, and Suspension
9.1. Customer shall retain Licensed Data only for as long as reasonably necessary for the permitted purpose and any shorter period specified in the applicable Order or signed agreement.
9.2. Upon expiry or termination of the applicable license, or upon Start.io’s reasonable written request, Customer shall stop using the affected Licensed Data and delete or return it, including copies held by its service providers, unless retention is required by applicable law. Any retained copy must be access-restricted, protected, and not used for any other purpose.
9.3. Start.io may suspend or restrict access to Licensed Data immediately where Start.io reasonably believes that continued access could violate applicable law, compromise End User rights, breach these Terms or another applicable agreement, or create a material security, regulatory, or reputational risk. Where reasonably practicable and legally permitted, Start.io will notify Customer and provide an opportunity to address the issue.
9.4. Start.io may discontinue, modify, replace, or withdraw any data or data feature, subject to any contrary commitment in an applicable signed Commercial Agreement.
10. Representations and Disclaimers
10.1. Each Party represents that it has the authority to enter into these Terms.
10.2. Customer represents and warrants that it will use Licensed Data in accordance with these Terms, the applicable Commercial Agreement, and Applicable Data Protection Laws, and that it will not use Licensed Data in a manner that infringes the rights of any person.
10.3. Licensed Data is provided on an “AS IS” and “AS AVAILABLE” basis, except to the extent expressly stated otherwise in a signed Commercial Agreement. To the maximum extent permitted by law, Start.io disclaims all implied warranties, including merchantability, fitness for a particular purpose, non-infringement, accuracy, completeness, and uninterrupted availability. Start.io does not guarantee campaign performance, data size, match rates, reach, conversion, or commercial results.
10.4. Nothing in these Terms excludes or limits any warranty, liability, or obligation that cannot lawfully be excluded or limited.
11. Indemnification
To the extent permitted by applicable law and subject to any limitations in the applicable Commercial Agreement, Customer shall defend, indemnify, and hold harmless Start.io and its affiliates, and their respective directors, officers, employees, and agents, from third-party claims, losses, liabilities, penalties, and reasonable legal fees arising out of or relating to: (a) Customer’s breach of these Terms; (b) Customer’s use or onward disclosure of Licensed Data; (c) Customer’s violation of Applicable Data Protection Laws or advertising laws; or (d) acts or omissions of Customer’s agencies, contractors, or other recipients of Licensed Data. Start.io shall provide reasonably prompt notice of a claim and reasonable cooperation, at Customer’s expense. Customer may not settle a claim in a manner that admits fault by or imposes obligations on Start.io without Start.io’s prior written consent.
12. Limitation of Liability
TO THE MAXIMUM EXTENT PERMITTED BY LAW, IN NO EVENT WHATSOEVER SHALL NEITHER START.IO NOR CUSTOMER NOR THIER AFFILIATES, OR RESPECTIVE EMPLOYEES, OFFICERS, SHAREHOLDERS, AGENTS, LICENSORS OR REPRESENTATIVES, BE LIABLE FOR ANY INDIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL, PUNITIVE OR EXEMPLARY DAMAGES, OR FOR ANY LOSS OF PROFITS OR REVENUE, INCLUDING BUT NOT LIMITED TO DAMAGES FOR THE USE OR INABILITY TO USE THE SERVICES, LOSS OF SALES, DATA, INFORMATION GOODWILL, BUSINESS INTERRUPTION, OR UNAUTHORIZED ACCESS TO INFORMATION, COMPUTER DAMAGE OR SYSTEM FAILURE, SOFTWARE OR COSTS OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, ARISING OUT OF OR IN CONNECTION WITH THE AGREEMENT OR THESE GENERAL TERMS, BASED ON CONTRACT OR TORT (INCLUDING PRODUCTS LIABILITY, STRICT LIABILITY AND NEGLIGENCE), AND WHETHER OR NOT EITHER PARTY OR AN AFFILIATE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
TO THE FULLEST EXTENT POSSIBLE UNDER APPLICABLE LAW, IN NO EVENT SHALL EITHER PARTY OR ITS AFFILIATES BE LIABLE TO THE OTHER PARTY FOR AN AMOUNT EXCEEDS THE NET CONSIDERATIONS ACTUALLY PAID BY CUSTOMER TO START.IO IN CONNECTION WITH THE AGREEMENT AND/OR ANY SERVICE PROVIDED BY START.IO TO CUSTIMER DURING ONE (1) YEAR PERIOD PRIOR TO THE DATE OF THE RELEVANT CLAIM. NO ACTION, SUIT OR PROCEEDING SHALL BE BROUGHT AGAINST START.IO MORE THAN ONE (1) YEAR AFTER THE DATE OF THE APPLICABLE SERVICE.
13. Term and Termination
13.1. These Terms take effect when Customer accepts them and remain in effect while Customer accesses or uses Licensed Data, unless terminated earlier in accordance with this Section.
13.2. Customer may stop using Licensed Data at any time. Start.io may suspend or terminate Customer’s access to Licensed Data for breach of these Terms, non-payment under an applicable Order, legal or regulatory requirements, or a material risk to Start.io, End Users, or a third party.
13.3. Upon termination, Customer’s license ends immediately and Customer shall comply with the cessation and deletion obligations in Section 9. Sections that by their nature should survive termination, including Sections 3.3, 5, 6, 8, 9, 10, 11, 12, and 14, shall survive.
14. General
14.1. Changes. Start.io may update these Terms by posting a revised version at the URL where they are published. The revised Terms will state an updated effective date. Material changes will become effective after notice or a reasonable advance period, except where an earlier effective date is required by law or necessary to address a legal, security, or regulatory issue. Continued use after the effective date constitutes acceptance of the revised Terms. If Customer does not agree, Customer must stop using Licensed Data.
14.2. Electronic acceptance and records. Customer agrees that electronic acceptance and electronic records may be used to form and evidence the agreement, to the extent permitted by applicable law. Start.io or its platform provider may retain records of acceptance, including the accepting entity, user, date/time, and version of the Terms.
14.3. No third-party rights. Except for Start.io’s affiliates and the persons expressly protected under an indemnity, these Terms do not create rights in any third party.
14.4. Assignment. Customer may not assign or transfer these Terms or its rights to Licensed Data without Start.io’s prior written consent. Start.io may assign these Terms to an affiliate or in connection with a merger, reorganization, or sale of substantially all relevant assets.
14.5. Severability; waiver. If a provision is unenforceable, it will be modified to the minimum extent necessary to make it enforceable, and the remaining provisions will remain in effect. A failure to enforce a provision is not a waiver.
14.6. Governing law and venue. These Terms are governed by the laws of the State of New York, without regard to conflict-of-law principles, and the state and federal courts located in Manhattan, New York shall have exclusive jurisdiction, except where mandatory law provides otherwise.
14.7. Entire agreement. These Terms, together with the applicable Commercial Agreement and any Order, constitute the agreement regarding Customer’s use of Licensed Data, subject to the order of precedence in Section 2.3.
15. Contact
Questions or notices relating to these Terms may be sent to: privacy@start.io, with a copy to the Customer’s Start.io account contact where applicable.
Start.io Inc. | 584 Broadway, Suite 1206 | New York, NY 10012, USA
Last update: October 11, 2026