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Startale App Privacy Policy

Last revised on 2025/12/03

This is the Privacy Policy of Startale Labs (BVI) Ltd (herein referred to as the “Company”, “we”, “us” or “our” in this Privacy Policy), which operates the website. This Privacy Policy applies to all Personal Data (as defined below) that we hold about you as well as any Personal Data you may provide to us. The purpose of this Privacy Policy is to inform you as to how we manage, collect, use, disclose and otherwise process Personal Data. In the British Virgin Islands, such activities are subject to the Data Protection Act, 2021 (“DPA”) which came into force in the British Virgin Islands on July 9, 2021. The DPA is relevant because Startale Labs (BVI) Ltd is a BVI business company. We conduct our business in compliance with the DPA and have implemented various measures to ensure that any Personal Data we collect, use, disclose or otherwise process remains safe and secure.

By interacting with us (which includes but is not limited to, use of the website, entering into transactions with us, providing us with your Personal Data, submitting information to us, signing up for any newsletters, or using any services or products offered by us), you shall be deemed to agree and consent to all terms and conditions in this Privacy Policy. If you have any questions regarding this Privacy Policy, please contact our Data Protection Officer (“DPO”) at the contact details provided in Section 13 below.

If you do not accept and agree to any of the provisions in this Privacy Policy, you should refrain from interacting with us, providing us with your Personal Data, submitting information to us, signing up for any newsletters, or using any services or products offered by us.

Please ensure that you provide a copy of this Privacy Policy (as may be amended from time to time) to any third parties whose Personal Data you provide to us.

Data subjects have a right to be informed how their Personal Data is processed and this Privacy Policy fulfils our obligation under the DPA in this respect.

1. Definitions

“data subject” means a natural person, whether living or deceased.

“Personal Data” refers to any information that relates directly or indirectly to a data subject, who is identified or identifiable from that information, or from that and other information in the possession of, or likely to come into the possession of, a data user, including any sensitive personal data and expression of opinion about the data subject.

“sensitive personal data” includes any personal data about a data subject’s physical or mental health; sexual orientation; political opinions; religious beliefs or other beliefs of a similar nature; criminal convictions, the commission or alleged commission, of any offence; or any other personal data that may be prescribed as “sensitive personal data” pursuant to the DPA from time to time.

2. Collection of Personal Data

  1. When you interact with us or use any service or product we provide, the Personal Data and other information we may collect includes the following:
    • your personal information, including but not limited to your name, email address, mobile number and address;
    • information to process your enquiry, such as your company name, company background, company description and company website;
    • publicly available blockchain data and any other publicly accessible sources;
    • your public wallet address and blockchain identifiers of the tokens used to interact with us or our services or products; and
    • information about your interaction with us, use of our websites and services or products, including cookies, IP addresses, browser type, your mobile operating system, statistics on page views and traffic to our website and other diagnostic data.
  2. Generally, we collect your Personal Data and other information in the following ways:
    • when you submit forms relating to any of our products or services;
    • when you register for or use any of our services or products on websites owned or operated by us;
    • when you use or purchase our products or services or enter into transactions with us;
    • when you request that we contact you;
    • when you request to be included in an email or other mailing list;
    • when you browse our website. Please see the Cookie Policy in Section 8 for more information; and
    • when you submit your Personal Data to us for any other reason.
  3. Where we process sensitive personal data, we will only do so where permitted by the DPA (e.g., explicit consent or where necessary for legal claims, legal obligations or to protect vital interests).

You can always refuse to provide your Personal Data. However, this may prevent us from interacting with you, such as providing you with our products and services.

3. Use of Personal Data

  1. We process Personal Data only where: (a) you have given express consent; or (b) processing is necessary for performance of a contract with you or to take steps at your request; (c) compliance with a legal obligation; (d) protection of vital interests; (e) administration of justice; or (f) exercise of functions conferred by law.
  2. Your Personal Data is used only for the specific purpose(s) for which it was collected. Generally, we collect, use and disclose your Personal Data and other information you provided to us, for the following purposes:
    • providing you with the products or services that were requested;
    • evaluating your application or suitability for the products or services that were requested;
    • to ensure proper administration of our business which includes keeping proper records, responding to inquiries or requests, resolving complaints and managing our business relationships and opportunities;
    • providing user support;
    • improving the products or services available and the website, including analysing and tracking data to determine the effectiveness of our content and to understand the activity of users;
    • providing ongoing information about products and services of the Company which may be of interest to you;
    • protecting and enforcing our contractual and legal rights and obligations;
    • investigating, addressing or defending against fraud, abuse or suspicious activity linked to or associated with you;
    • communicating changes to our policies and terms and conditions;
    • to establish, exercise or defend legal claims in suspected or actual legal proceedings in any jurisdiction;
    • facilitating transactions relating to the transfer or potential transfer of our business, rights, assets, duties or liabilities (which may include any merger, acquisition or asset sale); and
    • compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by the relevant authorities.

You may unsubscribe from receiving marketing materials at any time by clicking on the “unsubscribe” link in the email you receive or updating your preferences to indicate through which modes of communication and what kind of marketing communications you wish to receive.

For us to provide information about products and services which may be of interest to you, we may analyse and rely on your overall interaction with us (such as, but not limited to, your newsletter clicks / opening results, your web surfing activities, the newsletter types you are subscribed to and your interactions with us).

4. Disclosure of Personal Data

  1. Your Personal Data is kept private and confidential. We do not sell your Personal Data to third parties. We will not disclose Personal Data for any purpose other than the purpose disclosed at the time of collection or a purpose directly related to it, and only to the classes of recipients identified herein or notified to you, unless otherwise permitted by the DPA. Subject to applicable laws, your Personal Data may be disclosed for the above stated purposes to the following classes of recipients:
    • related corporations, parent company, subsidiaries and affiliates of the Company;
    • anyone who we collaborate or partner with to provide the services or products that you have requested, such as sponsors and organisers of hackathons, incubators and/or accelerator programs that are organised, managed and/or offered by us;
    • third party service providers who provide services to us, such as market research and/or technology service providers;
    • our professional advisors, such as lawyers and auditors;
    • anyone to whom we transfer or may transfer our business, rights, assets, duties or liabilities, such as prospective or actual buyers or sellers in the event of a merger, acquisition or other reorganisation or sale or disposition of all or any portion of our business and/or assets;
    • courts, relevant government regulators or law enforcement agencies to comply with laws, rules or regulations imposed on us;
    • banks, credit card companies and their respective service providers; and
    • any other party to whom you authorise us to disclose your Personal Data.
  2. Notwithstanding the above, we may disclose Personal Data without consent where permitted by the DPA, including where necessary for the prevention or detection of crime, required or authorised by law or court order, reasonably believed to be in our legal rights, or justified as being in the public interest as determined under the DPA.

5. Transfer of Personal Data outside the British Virgin Islands

We may transfer Personal Data outside the British Virgin Islands where there are adequate data protection safeguards or where you have given your consent. Adequate safeguards may include legally enforceable contractual obligations requiring a comparable standard of protection.

6. Retention of Personal Data

The Company will store your Personal Data in accordance with applicable laws and only for as long as needed to carry out the purposes described in this Privacy Policy and will take all reasonable steps to destroy or permanently delete it when no longer required for those purposes or for legal or business needs.

7. Protection of Personal Data

We apply security measures such as encryption technology and firewalls in order to prevent the unauthorised use, alteration, loss, hacking and disclosure of our customers' Personal Data. However, neither the computer security system nor the Internet is entirely secure. As a result, we do not assume responsibility for the information you submit to or receive from us or for any unauthorised access or use of that information, and we cannot and do not guarantee the security of any information transmitted by you to us or vice versa. You agree not to hold us responsible for any loss or damage incurred as a result of any unauthorised access, modification, interception, destruction or use of the information you submit to or receive from us through the Internet. In the event of a data breach, we will notify you as soon as practicable as required by law.

Where we engage a data processor, we will ensure that the processor provides sufficient guarantees of technical and organisational measures and takes reasonable steps to ensure compliance. We also take measures to ensure the secure transfer of Personal Data.

8. Cookies

We use “cookies” to enhance user experience. “Cookies” are files that a website or its service provider transfers to your mobile device or computer’s hard drive which enable the website’s or service provider’s systems to recognise your device or browser and capture and remember certain information. We use cookies to track information such as the number of page views, the number of users, frequency of use, duration of use and common entry and exit points into the website.

If you do not agree to our use of cookies, you may disable cookies by configuring your browser or device settings. However, this may restrict your use of certain parts of the website.

9. Third-party Sites

You may find links on the website which direct you to sites and services of a third party that may require you to share your Personal Data. You acknowledge that we do not control how these third-party sites collect, use and share your Personal Data and you further acknowledge that these third-party sites fall outside the scope of this Privacy Policy and are governed by their own respective privacy policies. We are not responsible for the activity or content of any third-party site. You are advised to read the privacy policies of the respective third-party sites you visit.

10. Access and Correction Rights

You may request access to your Personal Data. Within 30 days of receiving your written request, we will inform you whether access will be given to all or part of the data and, if so, provide a description of the data, purposes of processing, recipients or classes of recipients, and any available source information. We may charge a reasonable fee for access but not for corrections. We may extend the 30-day period by up to a further 30 days where necessary (e.g., operational impact or required consultations) and will notify you of the extension and your right to complain to the BVI Information Commissioner. Access may be refused in the circumstances permitted by the DPA (including where it would breach confidentiality, affect the rights of others, or falls within an exemption). Where requested by a person with a sensory disability, access will be provided in an alternative format where reasonable.

If you believe your Personal Data is inaccurate, incomplete, misleading or not up-to-date, you may request rectification in writing specifying the data concerned, the reasons, and the requested amendment. We will make corrections where satisfied, and where we refuse, we will notify you with reasons and inform you of your right to complain to the BVI Information Commissioner.

11. Withdrawing Consent

Where processing is based on your consent, you may withdraw consent at any time; withdrawal does not affect the lawfulness of processing before withdrawal. Withdrawal may affect our ability to interact with you or provide services or products. You may at any time require us, by written notice, to stop processing your Personal Data for direct marketing and we will comply within three days and confirm in writing.

We may ask you to provide proof of identity before we can respond to your request. In some situations, we may reject your request for access or correction where permitted under the law (for example, if an access request is frivolous or vexatious). If your request has been rejected by the Company, we will notify you of this as soon as practicable.

12. Changes to our Privacy Policy

We reserve the right to make changes and updates to this Privacy Policy without giving you prior notice. You are responsible for keeping track of the changes made to the Privacy Policy. Your continued use of the website shall constitute your agreement to be bound by any such changes to this Privacy Policy. If we make any changes, the updated Privacy Policy will be posted on the website with a revised effective date.

13. Data Protection Officer - Contact Information

If you have any questions relating to your Personal Data or our Privacy Policy, please contact our DPO at [email protected]indicating:

  1. your full name and contact information;
  2. a brief description of your query; and
  3. the nature of your query in the subject header (for example, Correction of Personal Data Request, or Personal Data Access Request).

14. Complaints and Civil Remedies

You may contact our DPO with any inquiries or complaints regarding your Personal Data and this Privacy Policy and if you consider that your Personal Data has not been handled in accordance with the DPA, you may also lodge a complaint with the BVI Information Commissioner. You may also institute civil proceedings in the court if you suffer damage or distress due to our contravention of the DPA.