1. Policy Introduction and Scope

This Privacy Policy (“Policy”) describes how Starti, Inc. ("We", "Starti", “Platform”) collects, uses, processes, and shares personal information related to our advertising services. This Policy applies to all services operated by Starti, including the AI Dash advertising campaign management platform and AI Studio AI creative generation platform (hosted at ad.starti.ai and relevant subdomains). It covers client business contact information and U.S. end-consumer data we process as a Service Provider on behalf of Clients across both products.

2. Categories of Personal Information We Collect

In the preceding 12 months, we may collect the following categories of personal information:

• (a) Identifiers: names, email addresses, IP addresses, device IDs;
• (b) Commercial Information: purchase records, payment information;
• (c) Electronic Network Activity Information: browsing history, ad interactions;
• (d) Geolocation Data: approximate geolocation;
• (e) Inference Data: interests and preferences derived from AI model analysis for audience segmentation; and
• (f) User-Provided Content: any text, images, or other materials voluntarily uploaded by Clients to the AI Studio platform, which may contain personal information if so provided.

3. AI Usage Transparency Disclosure

We deploy Artificial Intelligence and machine learning tools on both AI Dash and AI Studio:

• AI Dash: AI for ad performance prediction, smart bidding and audience segmentation;
• AI Studio: Generative AI for advertising creative generation, editing and optimization.

All profiling activities are necessary to improve Clients’ ROAS and core platform functionality. All Client Data Assets sourced from either platform used for general AI model training are de-identified and aggregated, with no linkage to identifiable consumers or individual Client accounts.

4. “Sale” and “Sharing” of Data (CCPA/CPRA Requirements)

4.1 Starti does not “Sell” identifiable individual consumer personal information for monetary compensation in the traditional sense.

4.2 “Sharing” (for Cross-Context Behavioral Advertising): Under the CPRA definition, “Sharing” includes the disclosure of personal information for the purpose of cross-context behavioral advertising. We share end-user data (such as device IDs, ad interaction data) with SSPs, DSPs, and Ad Exchanges to serve targeted advertisements across different websites and applications.

4.3 Right to Opt-Out Mechanism: California residents may opt out of the above cross-context data sharing by submitting an opt-out request via email to contact@starti.ai.

5. California Consumer Rights (CCPA/CPRA)

• Right to Know: The right to request disclosure of the categories and specific pieces of personal information we have collected, used, and disclosed in the preceding 12 months.
• Right to Delete: The right to request that we delete personal information we hold about you (subject to statutory exceptions).
• Right to Correct: The right to request that we correct inaccurate personal information we hold about you.
• Right to Opt-Out of “Sale/Sharing”: The right to direct us not to “Sell” or “Share” your personal information (refer to Section 4.3).
• Right to Limit Use of Sensitive Personal Information: The right to request that we limit the use and disclosure of your sensitive personal information to only those purposes permitted by the CPRA.
• Right to Non-Discrimination: The right not to be discriminated against for exercising your privacy rights.
• How to Submit a Request: You may submit all verifiable consumer requests, including opt-out requests for cross-context data sharing, by sending an email to contact@starti.ai. We will respond to a verifiable consumer request within the statutory time limit.

6. Data Security and Retention

We maintain reasonable administrative, technical and physical safeguards to protect personal information against unauthorized access, loss or misuse. Personal data is retained only to fulfill the original collection purpose, satisfy legal, tax and reporting obligations. Upon Client service termination, we securely delete or return all identifiable Client Data Assets within ninety (90) days. Only fully de-identified Aggregated Data may be retained to maintain and improve Starti’s shared AI models for AI Dash and AI Studio.

7. Children’s Privacy

Our AI Dash and AI Studio platforms are not intended for users under the age of 16. We do not knowingly collect personal information from children under 16. If we learn that we have inadvertently collected personal information from a child under 16, we will promptly delete it.

8. Contact Us

If you have questions, comments about this Policy, or wish to exercise your privacy rights, please contact our Privacy Officer:

Email: contact@starti.ai