This privacy policy describes the types of information that StarX Network, Inc. (“StarX,” “we” or “us”) collect from you, about you, or that you provide when you visit our website () (the “Site”) or download, register with, access or use the StarX mobile application (the “App”).
Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.
We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (“EEA”), we are subject to the EU General Data Protection Regulation (“EU GDPR”), which applies across the entire European Union. When we offer goods and services to individuals in the United Kingdom, we are subject to the United Kingdom General Data Protection Regulation (“UK GDPR”) (together, the “GDPR”). We are responsible as a “controller” of that personal information for the purposes of the GDPR.
1. Personal Information We Collect About You. We collect and use the following “personal information” that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
Identifiers: name, email address, user name, country of residence, gender, device identifier
Payment information: credit card information, debit card information
Account Information: account log-in information (email and password)
Commercial Information: records of products or services purchased, purchasing histories or tendencies, event attendance
Technical Information: information regarding your interaction with the Site and the App; your browsing and search history; your IP address; your device identifier; your device’s operating system, name and model; and your time zone
Geographic Information: the geographic location of the device you used to access the App. We do not collect precise geolocation data.
Inferences: favorite sports, teams, and players
2. How Your Personal Information is Collected. We collect personal information from the following categories of sources:
• You directly
• Third parties with your consent
• Internet service providers
• Data analytics providers
• Operating systems and platforms
When you register for a StarX account in the App using your Apple ID or Google login details:
Apple: You give Apple permission to share your personal information with us. This includes your first and last name, and your email address. You can choose to hide your email and Apple will create a random email address so that your personal email will not be shared with us. This email address will be linked to your StarX profile.
Google: You give Google permission to share the personal information that you have made public in your Google profile with us. This includes your first and last name, your email address and whether your email address has been validated, a link to your Google profile, and if you have one, your profile picture. This email address will be linked to your StarX profile.
3. How and Why We Use Your Personal Information. We can only use your personal information if we have a proper reason for doing so, for example:
To comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information that is not outweighed by your own rights and interests.
The table below explains what we use (i.e., process) your personal information for and our reasons for doing so:
4. EEA/UK Data Subjects: Promotional Communications. If you’ve chosen to receive promotional communications from us, we may use your personal information to send you updates (by email or push notification) about the App, the Site, and other products and services that we think you may be interested in. In certain cases, we may not need your consent to send you promotional communications as we have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). You have the right to opt out of receiving promotional communications at any time by:
• Contacting us at privacy@starx.com
• Using the “unsubscribe” link in emails or “STOP” number in texts or
• Updating your marketing preferences in the App
• Turning off push notifications via your device settings
We may ask you to confirm or update your marketing preferences if you instruct us to contact you about the App, the Site, our partners, or other products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
5. Who We Share Your Personal Information With. We share personal information with:
• Our affiliates
• Service providers we use to help us operate the App and the Site, such as payment service providers
• Other third parties that help us conduct our business, such as marketing agencies or website hostsLeagues, teams, and athletes about whom you express interest on the App or the Site
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
If part of our business is acquired by a third party, or if there is another change to our corporate structure, including in connection with any restructuring, reorganization, or other sale or transfer of some or all of our assets, including, but not limited to, as part of a bankruptcy, liquidation, or similar proceeding in which personal information held by us about you is among the assets transferred, we may include personal information as part of that transaction, which may include some or all categories of your personal information. In addition, we may share some or all of your personal information if we apply for loans or other forms of financing, open bank or investment accounts or raise funds through an investment process. In connection with these transactions, we may disclose some or all of your personal information to prospective buyers, investors, partners, lenders, investment advisers, banks, and each of their advisers, as the case may be, as they conduct due diligence.
6. Data Retention. We retain your personal information for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish and support legal claims and defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
7. EEA/UK Data Subjects: Your Rights Under the GDPR. Subject to certain limitations, you have rights under data protection laws in relation to your Personal Data. These include:
•
Right to Be Informed – The right to know or be notified about the collection and use of your personal information.
•
Right to Access –
The right to be provided with a copy of your personal information.
•
Right to Rectification – The right to require us to correct any mistakes in your personal information.
•
Right to be Forgotten –
The right to require us to delete your personal information—in certain situations including where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note that we may refuse a request for erasure, for example, where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defense of legal claims.
•
Rights to Restriction of Processing –
The right to require us to restrict processing of your personal information—in certain circumstances, for example, if you contest the accuracy of the data, where our use of the information is unlawful, but you do not want us to erase it; where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
•
Right to Data Portability –
The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations.
•
Right to Object – The right to object (i) at any time to your personal information being processed for direct marketing (including profiling); and (ii) in certain other situations to our continued processing of your personal information, for example, processing carried out for the purpose of our legitimate interests.
•
Right Not to be Subject to Automated Individual Decision-Making – The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply. For example, we may refuse to comply with a request if it is manifestly unfounded or excessive.
8. EEA/UK Data Subjects: Where Your Personal Information is Held. Information may be held at our offices, or by our third-party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).We and some of these third parties are based outside the EEA and the UK. For more information, including on how we safeguard your personal information when this occurs (see below: “Transferring Your Personal Information Out of the EEA/UK”).
9. EEA/UK Data Subjects: Transferring Your Personal Information Out of the EEA/UK. If you are based in the EEA or the UK, it is sometimes necessary for us to share your personal information outside the EEA or UK, for example:
• Between our offices, which are outside the EEA/UK;
• With our service providers located outside the EEA/UK;
• With our marketing partners outside the EEA/UK;
• With leagues, teams, and athletes located outside the EEA/UK; or
• Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under EU and UK data protection law.
10. International Transfers of Personal Information. StarX is headquartered in and has offices in the United States. Our servers are also located in the United States. This means that, if you are located outside of the United States, personal information that you transfer to us through use of the Site and App will be transferred to, stored, or processed in the United States or in other jurisdictions where our affiliates, business partners, third-party service providers, employees, agents, contractors, consultants, professional advisers, data processors, and persons employed and/or retained by each of them operate.
11. Keeping Your Personal Information Secure. While we take responsible steps endeavoring to use appropriate technical and organization measures to protect your personal information, we cannot guarantee or promise that your use of the Site, the App or the services will be completely safe. Any transmission of your data to the Site or the App is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.The safety and security of your personal information also depends on you. We encourage you to use caution when using the Internet. For example, where we have given you (or where you have chosen) a password for access to certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
12. EEA/UK Data Subjects: How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information. If you have concerns relating to your data privacy or the processing of your personal information, please bring them to our attention by contacting us (see “How to contact us” below).
The GDPR also gives you the right to lodge a complaint with a supervisory authority, in the EEA state where you work, normally live, or where any alleged infringement of data protection laws occurred. A list of EEA data protection supervisory authorities is available at
https://ec.europa.eu/justice/article-29/structure/data-protection-autho….
Information regarding the UK data protection supervisory authority is available at:
https://ico.org.uk/
13. Third Party Websites. The Site and App display advertisements and/or other content from third parties or partners that link to third-party websites that we do not own or operate. This privacy policy does not apply to the privacy practices of those third parties, which may collect information from you. We provide links to these third-party sites as a convenience to you. They are not intended as an endorsement of or referral to the linked services. The linked services are subject to their separate and independent privacy statements, notices, and terms. Read those statements, notices, and terms carefully. We are not responsible for those third parties’ privacy practices.
14. Children. The App and Site are not directed to children under the age of 13. We will not knowingly collect personal information from any child under the age of 13. Minors under the age of 13 are prohibited from registering to use the App. If a child under the age of 13 has provided us with personal information, we ask that a parent or guardian of that child contact us (see “How to contact us” below) and request that such information be deleted from our records.
15. Changes to This Privacy Notice. This privacy notice was published on April 22nd, 2024 and last updated on April 22nd, 2024. We may change this privacy notice from time to time–when we do, we will post any changes on the Site and App. If we make material changes to how we treat your personal information, we will inform you via the App and email of any such changes. You are responsible for periodically visiting the Site and App privacy policy links to check for any changes.
16. How to Contact Us. Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
Our contact details are shown below:
StarX Network, Inc.
Attn: Legal Team
StarX at Zero Bond, 0 Bond St, 4
th Floor New York NY 10012
privacy@starx.com
213-255-5617
17. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).
