Last updated: January 23, 2026

This Privacy Policy ("Policy" or “Privacy Policy”) describes how Starti, Inc., (“Company,” “we,” “us,” or “our”), collects, uses, discloses, and protects information from those who visit our websites and their sub-domains. We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. If we make material changes, we will provide notice through the Services or by other appropriate means. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page. This Policy applies to our websites, sub-domains, subsidiaries and affiliated websites alongside our application (collectively, our “Services”), and it governs any and all data collection and usage by us. Please read carefully and fully this Privacy Policy before using or continuing to use our Services and, if necessary, make appropriate choices in accordance with the guidelines in this Privacy Policy. If you do not provide certain personal data to us, we may not be able to provide the Services to you, or the use of the Services may be restricted, or the Services may not function to achieve the results we intend to provide.

You may choose whether to disclose personal information to us. However, certain personal information may be required in order to create an account or access specific features of the Services, and if such information is not provided, we may be unable to register you as a user or provide all or part of the Services. We collect information in the following categories:

When you create an account, communicate with us, or use the Services, we may collect:

• Your contact information, such as name, email address, and other information you choose to provide when communicating with us;
• Account credentials and authentication information;
• Communications and inquiries you submit to us;
• Financial account information such as billing and/or credit card information etc.

When you access our websites, application or platform, we may collect certain information for the purpose of improving our products and services, troubleshooting bugs, providing the services, tracking usage and improving the overall performance of the services, including:

• IP address, device type, browser type, operating system;
• Profile information, technical session information;
• Log files, access times, referring URLs;
• Usage data related to interactions with our Services.

We may use cookies, pixels, and similar tracking technologies to:

• Operate and secure our Services;
• Analyze usage and performance;
• Remember preferences and settings.

As you use our website, your browser communicates with service providers and other entities supporting our operations to coordinate and record the interactivity and fill your requests for services and information. The information from cookies and related technology is stored in web server logs and in web cookies kept on your computers, which are then transmitted back to our website by your computers.

Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Services, because the Services may not function properly. As we adopt additional technologies, we may also gather additional information through other methods. For more information, see https://www.allaboutcookies.org/.

When you use the Services, we may collect general location information (such as general location inferred from an IP address).

We may also collect information about you from other parties, such as when you are referred to us by another user. We may also receive information about you from third party social platforms, such as Google, when you interact with our social media profiles.

We may also collect information when you connect to your account using an account maintained by a third party, such as a social media account ("Third-Party Account"). The Services may collect information about you from your Third-Party Accounts in accordance with your permissions. When you connect to us through a Third-Party Account like Google, we receive information from that third party identifying your account. We collect and store this information and use it to help you connect to the Services. Connecting your account to a Third-Party Account is completely optional, and you will have the opportunity to grant permission when you attempt to connect. You can revoke permission by logging into the Third-Party Account and disconnecting us from there, and through the native applications on your smartphone. We may retain the information we collected previously from you.

We use information collected for the following purposes:

• To provide, operate, and maintain the Services;
• To analyze and report on service performance, effectiveness, and related analytics;
• To communicate with customers regarding accounts, support, and service-related matters;
• To process transactions and manage billing;
• To monitor, secure, and improve the functionality and performance of the Services;
• To detect and prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks;
• To aggregate and de-identify information. We may disclose to our customers and other third parties aggregated or de-identified information about users for marketing, advertising, research, or other purposes;
• To comply with applicable legal obligations and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other parties, including to enforce our Terms of Service and any other agreements;
• To support the development of new features, services, or offerings, and to otherwise use information in a manner consistent with this Privacy Policy and applicable law.

We may disclose information in the following circumstances:

We may disclose information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with us. Our affiliates may use the information we disclose in a manner consistent with this Policy.

We may disclose your information to employees, consultants, and other vendors acting on our behalf and subject to contractual confidentiality and data protection obligations, such as those who provide data storage, payment, technology support and services, customer service, cloud hosting, analytics, fraud prevention, legal services, and marketing services.

We may disclose certain information to our customers where relevant to the Services we provide to those customers, including information related to usage, performance, or analytical insights generated through the Services.

We may disclose information if required to do so by law or in response to valid legal process, governmental requests, or to protect the rights, safety, and security of the Company, our customers, or others.

In connection with a merger, acquisition, financing, or sale of assets, information may be transferred as part of such transaction, subject to appropriate confidentiality protections.

In the course of providing and operating the Services, we may process, store, and use information in accordance with this Privacy Policy. Such processing may include activities such as collecting, organizing, storing, analyzing, and otherwise handling information as reasonably necessary to provide, maintain, secure, and improve the Services, and to comply with applicable legal obligations. Such processing may be carried out using automated or system-assisted tools and technologies that support the operation and improvement of the Services, in accordance with this Privacy Policy.

We retain information for as long as reasonably necessary to:

• Provide the Services;
• Comply with legal, accounting, or reporting obligations;
• Resolve disputes and enforce our agreements.

Retention periods vary depending on the nature of the data and the purpose for which it is processed.

We retain deidentified or aggregated data, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as commercially necessary.

The security of your personal information is important to us. We implement reasonable administrative, technical, and organizational measures designed to protect information against unauthorized access, disclosure, alteration, or destruction. However, no security system is impenetrable, and we cannot guarantee absolute security.

Our Services are not directed to individuals under the age of 18, and we do not knowingly collect personal information from children.

This section applies to California residents and supplements the information contained in this Privacy Policy.

Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), California residents may have the following rights with respect to their personal information, subject to certain exceptions:

• Right to Know / Access: The right to request information about the categories and specific pieces of personal information we have collected about you, the sources of such information, the purposes for which we use it, and the categories of third parties with whom we share it.
• Right to Delete: The right to request that we delete personal information we have collected from you, subject to applicable legal exceptions.
• Right to Correct: The right to request correction of inaccurate personal information.
• Right to Opt Out of Sale or Sharing: The right to opt out of the sale or sharing of personal information, as those terms are defined under the CCPA.

We do not sell personal information in exchange for monetary consideration.

Sensitive Personal Information: To the extent we collect sensitive personal information (such as account credentials or billing information), we use such information only for purposes permitted by the CCPA and do not use it to infer characteristics about you.

You may exercise your CCPA rights by contacting us using the contact information provided below. We may require you to verify your identity before processing your request.

You may also designate an authorized agent to submit requests on your behalf, in accordance with applicable law.

We will respond to verifiable consumer requests within the timeframes required by the CCPA and will not discriminate against you for exercising your rights.

Depending on your jurisdiction of residence, you may have certain rights regarding your personal information under applicable data protection or privacy laws. Such rights may include the right to access, correct, or delete personal information, or to object to or restrict certain processing activities, subject to applicable limitations and exceptions.

We will respond to such requests in accordance with applicable law.

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice through the Services or by other appropriate means. The “Last updated” date at the top of this page indicates when this Privacy Policy was last revised.

This Privacy Policy does not create any contractual rights or obligations beyond those required by applicable law.

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Starti, Inc.

Starti Limited Unit 225-22, 2/F Mega Cube 8 Wang Kwong Rd Kln Bay Hong Kong

Email: contact@starti.tv