Last Updated: April 29, 2026
STARTUP SMART, LLC ("we," "us," or "STARTUP SMART") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect personal information when you use our platform at strtpsmart.com (the "Platform"), communicate with us, or engage with our services.
This Policy applies to all users of the Platform, including companies seeking fractional Operators ("Clients") and fractional Operators applying to or working through our network ("Operators"). As used in this Policy and throughout STARTUP SMART's platform and business operations, "Operator" and "SMART Network Operator" refer to independent contractors; these terms are used interchangeably with "Consultant" in legal and industry contexts. By using the Platform, you agree to the practices described in this Policy. If you do not agree, please do not use the Platform.
This Privacy Policy is incorporated by reference into our Terms of Service. Please read both documents together to understand your full rights and obligations when using the Platform.
STARTUP SMART, LLC is an Indiana limited liability company headquartered in Elkhart, Indiana. We operate a curated fractional Operator network and managed consulting services platform that connects companies in transition with vetted Operators. For purposes of applicable data protection law, STARTUP SMART, LLC is the data controller responsible for your personal information collected through the Platform.
This Policy applies to personal information collected through the Platform, through email and other communications with STARTUP SMART, and in connection with our matching and engagement services. It does not apply to third-party websites, tools, or platforms that may be linked from or used in connection with the Platform, each of which has its own privacy practices.
The Platform is intended for use by individuals 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided personal information through the Platform, please contact us at info@strtpsmart.com and we will promptly delete it.
The information we collect varies based on your relationship with us. We collect different categories of information from Clients and Operators, as well as information collected automatically from all Platform visitors.
4a. From Clients: Name, email address, job title, and company name; company address and contact information; project requirements, scope descriptions, and engagement details; payment information (processed securely through our payment processors — we do not store full card numbers or bank account details on our own systems); communications with STARTUP SMART via email, forms, or the Platform; feedback on Operator performance during and after engagements; and signed agreements and engagement documents, including Master Client Agreements, Appendices, and any related contracts uploaded to or generated through the Platform.
4b. From Operators: Name, email address, phone number, and location; professional profile information including work history, skills, areas of expertise, and availability; hourly rate or fee preferences; LinkedIn profile data if you connect your account or provide it during onboarding; references and professional recommendations; communications with STARTUP SMART and, during engagements, with clients; payment information for remittance purposes (e.g., ACH details or mailing address for checks); insurance documentation where required for specific engagement types; and referral activity and bonus payment records in connection with STARTUP SMART's Operator referral incentive programs.
4c. Automatically Collected: IP address and general location derived from it; browser type, device type, and operating system; pages visited, time spent on pages, and referring URLs; and session and usage data through cookies and similar tracking technologies. This information is used to maintain the security and operation of the Platform, analyze usage patterns, and improve user experience. It does not on its own identify you personally.
4d. From Third Parties: We may receive information about you from LinkedIn and other professional networks if you choose to connect or share your profile, and payment processors in connection with billing and payment activities. We use this information to supplement what you provide directly and to facilitate matching and engagement services.
Please note: STARTUP SMART's primary communication and collaboration infrastructure uses Google Workspace (Gmail, Google Drive, Google Meet, Google Chat, and Google Calendar). Communications and files shared through these tools are subject to Google's own privacy practices in addition to ours.
4e. Background Screening Data: STARTUP SMART offers two distinct background screening tracks for Operators. These tracks are separate and independent of each other.
STARTUP SMART Verified Certification Program. For Operators who elect to participate in STARTUP SMART's Verified certification program, we may collect and process background screening information through a consumer reporting agency ("CRA") designated or approved by STARTUP SMART. Participation is entirely voluntary and does not affect an Operator's eligibility for engagements or standing in the network. The cost of background screening is the sole responsibility of the Operator; STARTUP SMART does not cover, advance, or reimburse any screening fees.
Background screening conducted under this program may include criminal history records, employment verification, and such other categories of information as are described in the CRA's disclosure provided to the Operator at the time of screening. By initiating a screening under this program, the Operator provides written consent to the CRA's collection and processing of that information and to the disclosure of results to STARTUP SMART for network certification purposes.
We comply with the Fair Credit Reporting Act (FCRA) and applicable state law in connection with all background screening activities conducted under this program, including providing required disclosures, obtaining written authorization, and following adverse action procedures where applicable. A determination not to award Verified status based on screening results does not constitute termination of an Operator's Agreement or removal from the network.
Background screening results are used solely to determine Verified status eligibility and are not shared with third parties except as necessary to conduct the screening or as required by law. Verified status reflects completion of screening at a specific point in time and does not constitute a continuing representation about an Operator's background, character, or suitability. STARTUP SMART reserves the right to require periodic re-screening as a condition of maintaining Verified status. Screening results are deleted in accordance with applicable law, and in no event retained longer than necessary for certification purposes.
Client-Initiated Background Verification. Certain clients may independently require background verification of an Operator as a condition of commencing or continuing a specific engagement. This process is conducted solely by the client or a consumer reporting agency engaged by the client. STARTUP SMART is not the consumer reporting agency for client-initiated verification processes and does not receive, retain, or act on the results of such screening. The client bears sole responsibility for compliance with the FCRA and all applicable state law in connection with any client-initiated screening process. Where a client requires independent verification, that requirement will be communicated to the Operator in writing before the engagement begins, as described in the applicable Engagement Appendix. Operators may decline to proceed with any engagement for which they are unwilling to undergo client-required verification; such declination does not affect the Operator's standing under their Operator Agreement or eligibility for other engagements.
4f. SMART Audit™ Assessment Submissions: When you submit a SMART Audit™ assessment form through the Platform or by email, we may collect: business information provided in the assessment form (which may include financial data, organizational details, strategic plans, or transaction information); your name, email address, job title, and company name; and any supporting materials you include. This information may be sensitive and is treated as Confidential Information.
We use SMART Audit™ submission data solely to: (a) generate and deliver your report using AI-assisted technology; (b) follow up about STARTUP SMART's services where you have expressed interest; and (c) improve our assessment processes in anonymized, non-identifying form. We do not sell SMART Audit™ submission data or use it for unrelated marketing without consent. SMART Audit™ assessment submissions are processed by AI technology providers who are contractually prohibited from using your submitted information to train AI models. SMART Audit™ submissions are retained for two (2) years following the date of submission and then deleted or anonymized. You may request earlier deletion by contacting info@strtpsmart.com, subject to applicable retention obligations.
We use the information we collect to: match Clients with Operators; communicate about your account and engagements; process payments and manage billing; improve the Platform and matching process; send service and administrative communications; send marketing communications (with opt-out available); comply with legal obligations; prevent fraud and ensure Platform security; manage Operator vetting and network quality; administer Operator referral incentive programs; in connection with business transfers; and to identify Clients as customers for marketing purposes (as set out in applicable Master Client Agreements). We do not sell your personal information to third parties. We do not use your personal information for purposes that are incompatible with those described in this Policy without first obtaining your consent.
We use essential cookies (required for Platform functionality, including keeping you logged in and maintaining session security), analytics cookies (to understand how visitors interact with the Platform and improve performance and user experience), and preference cookies (to remember your settings and preferences across sessions). You can control or disable cookies through your browser settings. Please note that disabling certain cookies may affect Platform functionality, including your ability to remain logged in. We do not currently use advertising or behavioral tracking cookies. If this changes, we will update this Policy and provide notice as described in Section 15.
Some browsers include a "Do Not Track" (DNT) feature that signals to websites that you do not want your online activity tracked. The Platform does not currently alter its behavior in response to DNT signals, as there is no industry-standard interpretation of how to respond to them. We have disclosed our tracking practices in Section 6 above so you can make informed choices about your use of the Platform.
We share personal information only as described below and never sell it to third parties.
Between Clients and Operators: Relevant profile and project information is shared between Clients and Operators to facilitate introductions and engagements. Operator profiles are shared with Clients only after a matching fee has been paid and the Client proceeds to view the profile. Client project requirements and company information are shared with matched Operators in connection with the engagement. Both parties are bound by confidentiality obligations under their respective agreements with STARTUP SMART.
Service Providers: We work with third-party vendors who help us operate the Platform, including payment processors, email and communication tools, cloud hosting providers, and analytics services. These vendors are contractually required to protect your information and may only use it to provide services to us.
STARTUP SMART uses two payment processors depending on the transaction type: Stripe, Inc. processes matching fees collected on the Platform at the time a Client reveals an Operator profile through the SMART Match™ platform. Stripe is PCI DSS Level 1 certified. Melio Payments processes recurring retainer invoices billed to Clients and all payments made to Operators. ACH and check payments to Operators flow through Melio. Where Melio uses Plaid to facilitate bank account linking, financial institution data is also subject to Plaid's Privacy Policy. For both processors, STARTUP SMART does not store full card numbers or bank account details on its own systems.
Artificial Intelligence Technology Providers: STARTUP SMART uses AI technology providers to power the SMART Match™ Operator-client matching system and the SMART Audit™ report generation service. These providers process personal data on STARTUP SMART's behalf and solely to provide these features. AI technology providers are contractually prohibited from using your personal data or submitted information to train AI models. AI processing does not make final engagement decisions; all final matching and engagement decisions remain with STARTUP SMART and the relevant parties.
Google Workspace: STARTUP SMART uses Google Workspace for email, file storage, and collaboration. Information shared through these tools is processed by Google in accordance with Google's Privacy Policy and data processing terms.
Legal Requirements: We may disclose your personal information if required by law, court order, or governmental authority, or if we believe disclosure is necessary to protect the rights, property, or safety of STARTUP SMART, our users, or the public. Where legally permitted, we will notify affected users before making such disclosures.
Business Transfers: If STARTUP SMART is acquired, merges with another company, or transfers its assets, your personal information may be part of the transferred assets. We will provide notice of any such transfer and any material changes to privacy practices that result from it.
We may send you marketing communications such as the SMART Brief newsletter, platform updates, and service announcements if you have opted in to receive them or if we have a legitimate interest in contacting you as an existing user. You may opt out of marketing communications at any time by following the unsubscribe instructions in any marketing email, or by contacting us at info@strtpsmart.com. All commercial email communications comply with the CAN-SPAM Act (15 U.S.C. § 7701) and include a clear opt-out mechanism. Opting out of marketing communications will not affect transactional or service-related communications related to your account or active engagements.
We retain your personal information for as long as your account is active or as needed to provide services. When your account is closed or an engagement concludes, we retain information for the following purposes and periods:
You may request deletion of your personal information at any time by contacting info@strtpsmart.com. We will process deletion requests promptly, subject to the retention obligations described above. Some information may be retained in anonymized or aggregated form after deletion, where it can no longer be associated with you personally.
We implement industry-standard technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include access controls, encrypted transmission (HTTPS), and restricted access to personal data on a need-to-know basis.
No method of internet transmission or electronic storage is completely secure. While we take reasonable precautions to protect your information, we cannot guarantee absolute security. You are also responsible for maintaining the confidentiality of your account credentials. Personal data processed by AI technology providers on STARTUP SMART's behalf is subject to contractual data protection requirements, including a prohibition on the use of your data to train AI models.
In the event of a data breach that compromises personal information, STARTUP SMART will comply with Indiana's data breach notification law (IC 24-4.9) and any other applicable notification requirements. We will notify affected individuals and, where required, applicable regulatory authorities, in a timely manner consistent with our legal obligations.
Depending on your location, you may have the following rights with respect to your personal information. To exercise any of these rights, contact us at info@strtpsmart.com. We will respond to verifiable requests within the timeframes required by applicable law.
All Users: You may request access to, correction of, or deletion of your personal information, subject to the retention obligations described in Section 10. You may opt out of marketing communications at any time as described in Section 9.
California Residents (CCPA/CPRA): You have the right to know what personal information we collect, its sources, and how we use it; to request deletion; to request correction; to opt out of sale or sharing (we do not sell personal information or share it for cross-context behavioral advertising); and the right to non-discrimination for exercising your CCPA rights. You may designate an authorized agent to submit requests on your behalf, subject to identity verification requirements. To submit a CCPA request, contact info@strtpsmart.com.
EU and UK Residents (GDPR/UK GDPR): You have the right of access, rectification, erasure, restriction of processing, data portability, objection to processing, withdrawal of consent, and the right to lodge a complaint with your local data protection authority. STARTUP SMART is based in the United States; if you are in the EU or UK, your personal data may be transferred to and processed in the United States. We take steps to ensure appropriate safeguards are in place for such transfers consistent with applicable law.
Automated Decision-Making (GDPR Article 22): Where STARTUP SMART uses automated processing, including AI-assisted matching, to make decisions that significantly affect you, you have the right to obtain information about the logic involved, the significance of such processing, and its envisaged consequences. You may request human review of any automated decision that significantly affects your participation in the STARTUP SMART network. To exercise this right, contact info@strtpsmart.com.
The Platform may contain links to third-party websites, tools, or services. STARTUP SMART is not responsible for the privacy practices of any third-party site or service, and this Policy does not apply to them. We encourage you to review the privacy policies of any third-party sites you visit. The presence of a link does not constitute an endorsement by STARTUP SMART.
The Platform is intended for use by adults 18 years of age or older and is not directed to children under 18. We do not knowingly collect personal information from anyone under 18. If we become aware that we have inadvertently collected information from a minor, we will delete it promptly. If you have reason to believe a minor has provided personal information through the Platform, please contact us at info@strtpsmart.com.
We may update this Privacy Policy from time to time to reflect changes in our practices, the Platform, or applicable law. When we make changes, we will update the "Last Updated" date at the top of this page. For material changes, we will provide notice via email to registered users or by prominent posting on the Platform prior to the change taking effect. Your continued use of the Platform following notice of any changes constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically. If you disagree with any changes, you should discontinue use of the Platform and contact us to request deletion of your information.
If you have questions, concerns, or requests regarding this Privacy Policy or how STARTUP SMART handles your personal information, please contact us:
STARTUP SMART, LLC | Elkhart, Indiana | info@strtpsmart.com
We will respond to all privacy-related inquiries within thirty (30) days of receipt. For CCPA-related requests, we will respond within the timeframes required by applicable California law.
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