PRIVACY POLICY

Controller: Starfall Distribution Ltd, 128 City Road, London, United Kingdom, EC1V 2NX

Contact: support@starfall.tg

1. Overview

This Privacy Policy explains how we process personal data when you use our VPN Service, website, and apps. We aim to provide a privacy-first VPN and we do not sell your personal data.

2. What We Collect

We collect only what we need to operate the Service and comply with law.

2.1 Account and subscription data

* email (or other identifier you provide)

* subscription status, plan, renewal date

* payment reference IDs (handled primarily by payment processors)

* billing country (if required for tax)

2.2 Technical and diagnostics data (minimal)

* app version, device/OS type, language

* crash reports and error diagnostics (where enabled)

* aggregated performance metrics (e.g., server load, connection success rate)

2.3 Customer support data

* messages you send to support and related metadata (date/time, ticket ID)

2.4 What we do NOT collect (No-Logs stance)

We do not collect or store:

* browsing history, DNS queries, or the content of your traffic

* the VPN IP addresses you use over time

* connection timestamps tied to your VPN activity

* the sites or services you access while connected

Note: if you use third-party services while connected (e.g., websites), those services may collect data independently under their own policies.

3. How We Use Data

We use data to:

* provide and maintain the Service (account access, authentication, preventing fraud and abuse)

* process payments and manage subscriptions

* improve stability and performance using aggregated analytics

* provide customer support

* comply with legal obligations (e.g., tax, accounting)

4. Legal Bases (UK GDPR)

We process personal data under:

* Contract: to provide the Service you request

* Legitimate interests: preventing fraud, service security, and service improvement (balanced with your rights)

* Legal obligation: accounting, tax, lawful requests

* Consent: where required (e.g., optional analytics or marketing emails)

5. Cookies and Similar Technologies

Our website may use cookies for essential functionality and (optionally) analytics. You can control cookies through your browser and our cookie banner where applicable.

6. Sharing and Processors

We share personal data only with service providers acting as processors, such as:

* payment processors and subscription platforms

* email delivery providers

* hosting and infrastructure providers

* customer support ticketing providers

* crash reporting/analytics providers (if enabled)

We do not sell personal data. We do not share VPN traffic content.

A current list of subprocessors may be provided at: [subprocessors URL] (optional).

7. International Transfers

If personal data is transferred outside the UK, we use appropriate safeguards (e.g., UK International Data Transfer Agreement, UK Addendum to SCCs) and vendor due diligence.

8. Data Retention

We retain:

* account and subscription records while your account is active and as needed for legal/accounting requirements

* support communications as needed to resolve issues and for reasonable periods thereafter

* aggregated, non-identifying metrics may be retained longer for trend analysis

You can request deletion of your account data, subject to legal retention obligations.

9. Your Rights

Depending on your location (including UK GDPR), you may have rights to:

* access your data

* correct inaccurate data

* delete data ("right to be forgotten") where applicable

* restrict or object to certain processing

* data portability (for certain data)

* withdraw consent (where processing is based on consent)

* lodge a complaint with the UK ICO (Information Commissioner’s Office)

10. Security

We use technical and organizational measures to protect data (encryption in transit, access controls, least privilege, monitoring). No system is 100% secure, but we take security seriously.

11. Children

The Service is not intended for children under 18. We do not knowingly collect data from children.

12. Changes to this Policy

We may update this Privacy Policy. Material changes will be posted with an updated effective date and, where appropriate, notified in-app or by email.