GDPR Privacy Policy

Star Promotion Agency ("we", "us", "our") is committed to protecting and respecting your privacy in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. This policy explains how we collect, use, and protect your personal data when you interact with our celebrity social media marketing services.

Interpretation and Definitions

Interpretation

Words with initial capital letters have meanings defined under the following conditions. These definitions shall have the same meaning regardless of whether they appear in singular or plural form.

Definitions

For the purposes of this GDPR Privacy Policy:

• Account means a unique account created for you to access our service or parts of our service.
• Company (referred to as either "the Company", "we", "us" or "our") refers to Star Promotion Agency, 8900 Sunset Blvd, Los Angeles, CA 90069.
• Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website.
• Data Controller means the natural or legal person who determines the purposes and means of the processing of Personal Data.
• Data Processor means any natural or legal person who processes Personal Data on behalf of the Data Controller.
• Data Subject is any living individual who is the subject of Personal Data.
• Device means any device that can access the service such as a computer, cellphone or digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the website located at https://www.labowatrol.com and our celebrity social media marketing services.
• Service Provider means any natural or legal person who processes the data on behalf of the Company.
• Usage Data refers to data collected automatically when using the service.
• You refers to the individual accessing or using the service, or the company, or other legal entity on behalf of which such individual is accessing or using the service.

Data Controller Information

Star Promotion Agency acts as the Data Controller for the personal data collected through our services. Our contact details are:

Legal Bases for Processing Personal Data

Under the GDPR, we process your personal data based on the following legal bases:

• Consent: You have given clear consent for us to process your personal data for specific purposes
• Contract: Processing is necessary for the performance of a contract with you
• Legal Obligation: Processing is necessary for compliance with a legal obligation
• Vital Interests: Processing is necessary to protect someone's life
• Public Task: Processing is necessary for the performance of a task carried out in the public interest
• Legitimate Interests: Processing is necessary for our legitimate interests or those of a third party

Types of Data We Collect

Personal Data

While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. This may include:

• Name (first name and last name)
• Email address
• Phone number
• Postal address, including city, state, province, ZIP/Postal code, and country
• Company name and position
• Social media profiles and handles
• Marketing preferences and interests
• Payment information (processed securely by third-party providers)

Usage Data

Usage Data is collected automatically when using the service and may include:

• Your device's Internet Protocol address (IP address)
• Browser type and version
• Pages of our service that you visit
• Time and date of your visit
• Time spent on those pages
• Unique device identifiers
• Operating system
• Other diagnostic data

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track activity on our service and store certain information. For detailed information about our use of cookies, please refer to our Cookie Notice.

How We Use Your Personal Data

Star Promotion Agency may use personal data for the following purposes:

• To provide and maintain our service: Including monitoring usage of our service and celebrity marketing platform
• To manage your account: Managing your registration as a user of the service
• For the performance of a contract: Development, compliance and undertaking of the purchase contract for services
• To contact you: By email, telephone, SMS, or other equivalent forms of electronic communication
• To provide you with news and updates: About our services, events, and promotions unless you opt out
• To manage your requests: Attending and managing your requests to us
• For business transfers: Evaluating or conducting mergers, acquisitions, or asset sales
• For other purposes: Data analysis, identifying usage trends, and improving our services

Sharing of Your Personal Data

We may share your personal information in the following situations:

• With Service Providers: To monitor and analyze the use of our service
• For business transfers: In connection with mergers, acquisitions, or asset sales
• With affiliates: We may share your information with our affiliates
• With business partners: To offer you certain products, services, or promotions
• With other users: When you share personal information in public areas
• With your consent: For any other purpose with your consent
• Legal requirements: When required by law or to protect our rights

International Data Transfers

Your information, including personal data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal data, to the United States and process it there.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and adequate safeguards such as Standard Contractual Clauses.

Data Retention

Star Promotion Agency will retain your personal data only for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when this data is used to strengthen the security or improve the functionality of our service.

Data Security

The security of your personal data is important to us. We use commercially acceptable means to protect your personal data, including:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication measures
• Employee training on data protection
• Incident response procedures

However, remember that no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.

Your GDPR Data Protection Rights

Under the GDPR, if you are located in the European Economic Area (EEA), you have certain data protection rights:

Exercising Your Rights

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at:

• Email: [email protected]
• Online Form: Privacy Request Form
• Phone: (213) 555-7890

Right to Withdraw Consent

Where we are relying on consent to process your personal data, you have the right to withdraw that consent at any time. You can withdraw consent by contacting us using the contact details provided above.

Right to Lodge a Complaint

If you believe that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.

Children's Privacy

Our service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us.

If we become aware that we have collected personal data from anyone under the age of 16 without verification of parental consent, we take steps to remove that information from our servers.

Links to Other Websites

Our service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Data Protection Officer

We have appointed a Data Protection Officer (DPO) to oversee compliance with this privacy policy. If you have any questions about this privacy policy or our treatment of your personal data, please contact our DPO:

Changes to This Privacy Policy

We may update our privacy policy from time to time. We will notify you of any changes by posting the new privacy policy on this page and updating the "Last updated" date at the top of this privacy policy.

We will let you know via email and/or a prominent notice on our service, prior to the change becoming effective and update the "Last updated" date at the top of this privacy policy.

You are advised to review this privacy policy periodically for any changes. Changes to this privacy policy are effective when they are posted on this page.

Contact Information

If you have any questions about this GDPR Privacy Policy, you can contact us:

Effective Date: June 24, 2025
Last Review Date: June 24, 2025
Next Scheduled Review: December 2025