Privacy Policy, Start Over Fresh

1. INTRODUCTION

This Privacy Policy describes how Fleck Labs LLC, an Illinois limited liability company doing business as Start Over Fresh ("Fleck Labs," "we," "us," or "our"), collects, uses, discloses and safeguards personal information in connection with the website located at startoverfresh.com and the related online dispute resolution service (collectively, the "Service"). By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is incorporated into and governed by our Terms of Service.

2. INFORMATION WE COLLECT

(a) Information you provide. When you file, respond to or participate in a matter, we collect your name, email address and the content of your submissions, including any complaint, response, rebuttal, timeline, requested remedy and supporting statements. If you upload evidence, we collect and store those files. If you elect to receive text messages, we collect your mobile telephone number and a record of your consent.

(b) Account information. If you create an account, your login credentials are managed by our hosting platform's authentication system. We do not have access to your password.

(c) Technical information. We automatically collect limited technical data, such as IP address, browser type, device information and the pages you visit, together with essential cookies and similar technologies needed to keep you signed in and to operate and secure the Service.

3. HOW WE USE INFORMATION

We use personal information to provide, operate and maintain the Service; to administer matters, including mediation suggestions and advisory decisions; to send notices about matters in which you are a party; to respond to inquiries and requests; to detect, investigate and prevent fraud, abuse and security incidents; to comply with applicable law and enforce our Terms of Service; and to improve the Service. We do not sell personal information.

4. PROCESSING BY ARTIFICIAL INTELLIGENCE PROVIDERS

To generate advocate arguments, mediation suggestions and advisory decisions, the content of your submissions and evidence is transmitted to third party artificial intelligence providers acting on our behalf: Anthropic, OpenAI, Google, xAI and Mistral AI (France). These providers process that content solely to produce outputs for the Service. You should not submit information that you do not wish to be processed in this manner. All decisions rendered through the Service are advisory and nonbinding.

5. EVIDENCE

Evidence files, including documents, images, screenshots, audio and video, are maintained in private storage and are never published. Access is limited to the parties to the matter and authorized administrators through authenticated sessions, using secure links that expire after fifteen (15) minutes.

6. PUBLICATION OF OUTCOMES

Following issuance of a decision, a limited summary of the outcome may be published to our public archive in accordance with our publication policy. Any published summary is restricted to the first names of the parties, the category of the dispute, the outcome, any monetary award and a neutral summary of the reasoning. Email addresses, telephone numbers, street addresses, account numbers and full names are removed prior to publication. Where the responding party did not participate, that party's name is never published. Evidence is never published.

7. TEXT MESSAGES

If you elect to receive text message notifications, we collect your mobile telephone number and a record of your consent, including the consent language presented to you, the date and time, the page on which consent was given, your IP address and your browser. Your number is stored in encrypted form and is used solely to send Start Over Fresh case update notifications. Consent to receive text messages is optional and is not a condition of using the Service. Message frequency varies, up to six (6) messages per case. Message and data rates may apply. You may opt out at any time by replying STOP, by using the Stop texts setting on your case or by visiting our stop texts page. Reply HELP for help. See our SMS Policy for additional terms. We do not sell, rent or share mobile telephone numbers or text messaging opt in data or consent with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt in data and consent are excluded from every category of disclosure described in this Privacy Policy and will not be shared with any third parties.

8. DISCLOSURE OF INFORMATION

Subject to Section 7, we disclose personal information only as follows: (a) to the other parties to a matter, to the extent necessary to administer that matter; (b) to service providers that host, store, process or transmit information on our behalf, including the artificial intelligence providers identified in Section 4, under obligations consistent with this Privacy Policy; (c) as required by law, subpoena or other legal process, or where we believe in good faith that disclosure is necessary to protect the rights, property or safety of Fleck Labs, our users or others; and (d) in connection with a merger, acquisition, financing or sale of all or part of our business, provided that any successor remains bound by this Privacy Policy with respect to information collected under it.

9. DATA RETENTION

We retain matter records, submissions and evidence while a matter is active and for a reasonable period after closure to permit appeals, removal requests and the resolution of disputes, and as otherwise required by law. Published summaries remain in the public archive unless removed upon request or withdrawn by us.

10. DATA SECURITY

We maintain administrative, technical and physical safeguards designed to protect personal information, including encryption of mobile telephone numbers, private storage of evidence and expiring access links. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. YOUR RIGHTS AND CHOICES

Subject to applicable law, you may request access to, correction of or deletion of your personal information, and you may request removal of a published summary. To submit a request, contact us at support@startoverfresh.com. We may need to verify your identity before acting on a request, and we will respond to verified requests within thirty (30) days.

12. ELIGIBILITY AND CHILDREN

The Service is intended solely for adults eighteen (18) years of age or older. We do not knowingly collect personal information from anyone under eighteen. If we learn that we have collected such information, we will delete it.

13. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Amendments are effective when posted, as reflected by the Effective Date above. Your continued use of the Service after an amendment is posted constitutes acceptance of the amended Privacy Policy.

14. CONTACT

Fleck Labs LLC, an Illinois limited liability company doing business as Start Over Fresh, 303 E Main St, Suite 102, Barrington, Illinois 60010. Telephone: (312) 489 8888. Email: support@startoverfresh.com.