Star Promotion Global Privacy Notice

This Global Privacy Notice ("Global Notice") describes how Star Promotion Agency and its group of affiliated companies and subsidiaries ("Star Promotion," "our," "us," or "we") collect, use, and disclose personal information about natural persons ("consumer," "you," or "your"), including the categories of personal information we collect, our purpose for using this information, whether such information will be sold or shared, the length of time we intend to retain this information, the privacy rights available to you for your personal information, and how to exercise those rights.

This Global Notice applies to personal information collected by us and through our group of affiliate companies and subsidiaries, marketing services, data processors, service providers, and on or through our business systems, career center, contests & sweepstakes, electronic communications (including emails, live chat, telephone and video calls, and text messages), events, podcasts, shopping carts, social media, webinars, websites and other offerings (each a "service," together, the "services").

1. What is Personal Information

When we use the term "personal information" (and its equivalent term "personal data" as defined by applicable data protection laws), we mean any information relating to an identified or identifiable natural person, and information linked or linkable to an identified or identifiable natural person. "Natural person" means a living human being.

Personal information does not include data that is publicly available or has been "aggregated" or "de-identified" (and its equivalent term "anonymized" as defined by applicable data protection laws). Aggregated and de-identified data is non-personal information. This means we have removed any personally identifiable information (including names, email addresses, postal addresses, and telephone numbers), and the remaining data cannot be reasonably used to identify you or link you to the information in question.

2. Collection and Use of Information

We collect personal information that is relevant, adequate, and necessary to accomplish the purpose for which it is collected, and we minimize the amount of personal information we collect by using privacy-enabling technologies (including key coding, pseudonymous, de-identified, anonymous, and aggregated anonymous data management practices) when it would be reasonable to do so.

Legal Bases for Processing

We use the following legal bases when we collect and use personal information:

• With Your Consent to collect and use your personal information for one or more purposes.
• In Performance of a Contract between you and Star Promotion, or for the implementation of pre-contractual measures taken at your request.
• To Comply with Legal Obligations, including: (i) to comply with applicable laws, rules, and regulations; (ii) to respond to and comply with court orders, subpoenas, and warrants, and criminal, civil, or regulatory investigations; (iii) to cooperate with government bodies and law enforcement requests; and (iv) to enforce our legal interests, such as by supporting the exercise, preparation, or defense of any legal claims.
• To Protect the Vital interests of an Individual, including where there are reasonable grounds to believe that our failure to act (by not disclosing certain personal information) could result in risk of death or serious bodily harm to you or others.
• In Pursuit of Legitimate Interests, including to conduct business activities related to the products and services that we provide to you and others, and to operate our business.

Categories of Persons

We collect personal information about the following categories of natural persons:

• Clients, Customers, and Users of our celebrity marketing services
• Children, Parents and Legal Guardians (where we provide a service with parental consent)
• Content Contributors and Writers (to our website and other publications)
• Consultants, Contractors, and Interns
• Data Recipients (for individuals receiving personal information from us)
• Artists, Talents, and Performers (celebrities and musicians using our services)
• Distributors, Resellers, and Partners (for individuals using our services)
• Employees, Former Employees, and Covered Family Members
• Job Applicants
• Service Providers, Suppliers, and Third-Party Partners (for individuals supporting our services)
• Speakers and Brand Ambassadors (at our events and webinars)
• Visitors (to our events and workplaces)
• Web Visitors (to our websites and other online services)

Sources of Information

We collect personal information from the following categories of sources:

• Information we collect directly from you depending on which services you request from us, how you engage with our services, and what specific personal information we need from you to provide these services.
• Information your organization provides to us that is necessary for you to use our services under a contractual agreement we have with your organization.
• Information we collect automatically depending on which services you request from us, how you engage with our services, and how you configured your device, browser, and email client.
• Information we receive from other parties including our advertising, measurement and analytics, and social media partners, data brokers, financial institutions, government and regulatory bodies, payment processors, public records, and service providers.

Categories of Personal Information

We collect and use the following categories of personal information. Not all categories or examples listed are collected for all persons:

Category of Personal Information	Examples	Sold or Shared to Third Party
Account Information	Name, contact preferences, customer number, email address, mobile SMS address, postal address, telephone number, user id and password	Yes
Biometric Data	Physiological, behavioral, and biological characteristics that contains identifying information	No
Protected Classifications	Age, citizenship, disability, gender identity, gender expression, medical conditions, military or veteran status, national origin, race, religion, and sexual orientation	No
Child Data	Name, birth date - where we provide a service with parental consent	No
Commercial Information	Records of property ownership, buying preferences, products and services purchased, purchasing histories, testimonials, and wish lists	Yes
Contact Information	Name, contact preferences, email address, mobile SMS address, postal address, and telephone number - for non-account holders	Yes
Credentials	Authentication keys and tokens, user id and password, password hints and challenge questions - for internal business users	No
Demographics Data	Age, birth date, ethnicity, gender, household income, marital status, number of children, occupation, preferred language, race or ethnicity	No
Device Data	Device id, device type, screen resolution, usage data, and MAC address - for devices used with our services	Yes
Electronic Communications	Calendaring, emails, live chats, telephone and video calls, and text messaging that we may process when communicating with you	No
Financial Information	Payment card information and wire transfer information - depending on which method of payment you have selected for your purchases	No
Fraud & Investigations Data	Fraudulent claims, police reports, and stolen credentials obtained from other parties - for fraud, theft, and security events	No
Geocoding Data	Data to convert your postal address into latitude, longitude, and map coordinates to provide you directions or locate services	No
Non-Precision Geolocation Data	Latitude, longitude, and map coordinates at a country, regional or city-level based on your Internet Protocol (IP) address or postal code	Yes
Government Identifiers	Social security, driver's license, identification card, and passport numbers - used only for employment purposes	No
Identifiers	Name, alias, electronic signature, email address, Government Identifiers, Internet Protocol (IP) address, mobile SMS address, Online Identifiers, postal address, and telephone number	Yes
Inferences & Profiling Data	Inferences drawn from or created based on personal information and automated processing to help determine preferences and interests	Yes
Internet Activities	Browser history, clickstream data, interactions with our advertisements and services, Internet Protocol (IP) addresses, pages visited, search history, and server logs	Yes
Online Identifiers	Advertiser ids, analytic ids, cookie ids, pixel tags, tracking scripts, and Internet Protocol (IP) addresses	Yes
Employment Information	Employee number, beneficiary information, certifications & licenses, compensation data, performance reviews, resume, training records - used only for employment purposes	No
Sensitive Personal Information	Biometric Data, Protected Classifications, Child Data, Credentials, Government Identifiers, passwords, and payment card number	No
Sensory Information	Audio, visual, thermal or similar sensory information (such as photographs, video and voicemail recordings)	No
User Feedback	Surveys, commenting to our social media posts and pages, service ratings and reviews	Yes
Social Media Content	Posts, engagement metrics, follower counts, and interactions on social platforms for our celebrity marketing services	Yes

Purpose for Processing

Our purpose for collecting and using personal information includes:

• To administer benefits to our employees, former employees, and covered family members
• To communicate with you about our services and updates
• To comply with laws, rules, and regulations and enforce our legal interests
• To create and maintain your account and manage our relationship with you
• To develop, sell and deliver celebrity social media marketing services and content
• To effectively use advertising campaigns and strategies
• To fulfill our contractual obligations
• To improve offerings and customers' experiences
• To manage and support our business operations and legitimate interests
• To personalize content and offers for our celebrity marketing services
• To prevent, detect, protect against, respond to and recover from fraud, theft, and security events
• To process and fulfill orders and transactions
• To provide customer service and support
• To develop and enhance social media strategies for our celebrity clients
• To analyze social media metrics and performance for marketing campaigns
• To verify your age and identity

3. Information about Children

Our online services are not directed to persons under eighteen (18) years of age, and any person using our online services represents that they are at least eighteen (18) years of age before doing so.

We do not use our online services to knowingly collect personal information from children, which we consider to be persons under thirteen (13) years of age, or the equivalent age as otherwise specified by applicable law. If we learn that a child has provided their personal information on or through our online services without appropriate parent or legal guardian consent, we will promptly delete this information.

Parental Consent Procedures

Where a parent or legal guardian would like their child to participate in our services to the extent permitted by applicable law, the following procedures apply:

• Collection, Processing, and Retention: We will provide notice to the parent or legal guardian and obtain their written authorization for the service and verifiable parental consent before collecting and processing personal information about their child.
• Disclosure: We will provide a separate notice to the parent or legal guardian and obtain their written authorization before disclosing personal information about their child to our service providers and third parties.
• Sale: Under no circumstances do we knowingly sell personal information about children.

4. Sharing and Disclosure of Information

We engage different natural and legal persons to operate our business, manage and support our services, and perform other activities described in this Global Notice.

We share or disclose personal information with the following categories of data recipients:

• Within our Corporate Group of affiliate companies and subsidiaries to provide our celebrity marketing services and support our business operations
• With our Contractors and Service Providers who perform services on our behalf including cloud service providers, social media analytics tools, marketing platforms, payment processing services, and website hosting
• With our Third-Party Providers who provide cross-context behavioral advertising services for our celebrity marketing campaigns
• Corporate Transactions: We may share or disclose personal information in connection with any sale of company assets, merger, acquisition, or corporate reorganization
• Legal, Regulatory, and Law Enforcement Bodies: We may disclose information as required to comply with applicable laws, court orders, subpoenas, and regulatory investigations

5. Retention of Information

We store your personal information for as long as is necessary to provide our services to you, to operate our business, and for as long as required to comply with applicable laws, rules, and regulations.

We minimize the amount of personal information we retain by using privacy-enabling technologies when it would be reasonable to do so.

Typical retention periods include:

• For customers: We typically retain your personal information for up to six (6) years after your contractual relationship with us ends or your last account transaction occurred
• For employees: We typically retain your personal information for up to six (6) years after your employment relationship with us ends
• For unsuccessful applicants: We typically retain your personal information for up to four (4) years after we have communicated our hiring decision to you

6. Protection of Information

We take commercially reasonable, adequate and appropriate administrative, technical, and physical security measures that are designed to protect the confidentiality, integrity, and availability of our services, and safeguard your personal information from accidental or unlawful destruction, loss, or alteration, and from unauthorized access, use, or disclosure.

Our security measures include:

• Information security policies and security incident response plans
• Encrypting data in-transit and data at-rest
• Restricting access to personal information to authorized persons
• Employee security training
• Maintaining full and incremental backups to our services

7. Manage your Account Information, Orders, and Settings

You can manage various aspects of your account through our online portal:

• Account Information: Update your name, business name, mailing address, email address, and account password
• Subscription Services: Add, modify, pause or cancel your subscription services
• Orders & Tracking: View order history, track orders, and re-order
• Payment Methods: Add, modify or remove your payment information
• Addresses: Add, modify or remove your addresses
• Favorites: Add, modify or remove your favorites

For assistance managing your account, contact our customer service at (213) 555-7890.

8. Manage your Contact Preferences & Marketing Communications

Sometimes we have service announcements and promotional offers about our celebrity marketing services that may interest you. When we send these communications to you, we do so with your consent and through our business relationship with you. You can choose what types of communications we send to you, how you want these delivered, and opt-out (or unsubscribe) at any time.

If you require help managing your contact preferences, contact our customer service at (213) 555-7890.

9. Opt-out from Automated Decision-Making Technology

"Automated decision-making technology" means any system, software, or process (including one derived from artificial intelligence, data analytics, machine learning, and statistical modeling) that uses your personal information to make or execute legal or similarly significant decisions about you without human intervention.

We may use automated decision-making technology to personalize our celebrity marketing offerings and customers' experiences. Where we use automated decision-making technology, you can opt-out by submitting a request as described in the Privacy Rights section.

10. Opt-out from Cookies & Interest-based Advertising

Our online services use cookies, pixel tags, tracking scripts, and similar technologies to authenticate users, enable secure online purchasing, deliver our celebrity marketing services, and personalize content and offers. Our Cookie Notice provides instructions on how to opt-out from or remove our cookies from your device or browser.

You may also opt-out from interest-based ads through the following industry tools:

• Digital Advertising Alliance:
  • WebChoices to opt-out using your browser
  • YourAdChoices to opt-out using your email address or telephone number
• Network Advertising Initiative:
  • NAI Consumer opt-out

11. Opt-out from Direct Mail and Email Communications

If you receive an unsolicited message from us or want to opt-out from receiving certain promotional or marketing communications about our celebrity marketing services, you can take the following steps. We will honor your request within ten (10) business days.

• For direct mail: Opt-out by contacting our customer service at (213) 555-7890
• For email messages: Opt-out by clicking on the "Unsubscribe" link in the email message we sent or by contacting our customer service

12. Opt-out from Text Messaging Communications

For text messaging services, you can opt-out by replying STOP, END, CANCEL, UNSUBSCRIBE or QUIT to any text message you receive from Star Promotion Agency. You may receive one final text message confirming your request. For help, reply HELP to any text message or contact us at (213) 555-7890.

13. Opt-out from the Sale or Sharing of Information

Star Promotion Agency does not sell your personal information in the conventional sense, for money. However, we use cross-context behavior advertising services to deliver interest-based ads about our celebrity marketing services, which may be considered a "sale" or "sharing" of personal information. The Privacy Rights section provides instruction on how to opt-out from this sale or sharing of your personal information.

For employees and job applicants, Star Promotion Agency does not sell or share your personal information with third parties for cross-context behavior advertising purposes.

14. Opt-out using Universal Opt-Out Mechanisms

Where your device or browser has been properly configured to transmit your privacy choices to our online services using "universal opt-out mechanisms" (including Global Privacy Control signals) our online services will honor your request and display the confirmation message "Opt-Out Request Honored" in our cookie consent banner and cookie preferences center.

15. Privacy Rights & Your Privacy Choices

Data protection laws may provide you with certain privacy rights to personal information that we have collected about you. Which privacy rights are available to you depends upon your country of residence, and the nature, scope, context, and purpose of your request.

These rights may include:

• Right to Access your personal information and be informed about what processing, sharing, or disclosure we have done
• Right to Correct inaccuracies to your personal information
• Right to Delete your personal information from our business systems
• Right to Data Portability to your personal information in a machine-readable format
• Right to Restrict Processing to your personal information under certain conditions
• Right to designate an Authorized Agent to act on your behalf regarding your personal information
• Right to Opt-out from targeted advertising, the sale or sharing of your personal information, and automated decision-making technology
• Right to Withdraw Consent to our collection, use, and disclosure of your personal information
• Right to Appeal Decisions we have made about your personal information and privacy rights
• Right to File Complaint with your applicable data protection authority

To exercise these rights, you can:

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

16. Non-Discrimination for exercising your Privacy Rights

Star Promotion Agency will not discriminate against or retaliate against you for exercising any of the privacy rights afforded to you in this Global Notice and by applicable data protection laws. This means we will not deny you goods or services, charge different prices or rates for goods or services, or provide a different level of quality of goods or services when exercising your privacy rights.

17. Privacy & Data Protection Impact and Risk Assessments

Our business systems and processes undergo impact and risk assessments on an as needed basis taking into consideration the nature, scope, context, and purposes of our data processing activities and as defined by applicable data protection laws.

18. Breach of Personal Information

If our services experience a potential security incident involving your personal information, we will promptly investigate. If our investigation determines that your personal information was involved in a breach as defined by applicable data protection laws, we will notify you by emailing a copy of this breach notification to the email address on file for your account or as otherwise specified by applicable law.

19. International Data Transfers

Star Promotion Agency is based in the United States and does not maintain any establishment in any other country.

When you use our services, we process, access, and store your personal information on servers and equipment located in the United States, and in other countries, depending on the location of our service providers. This means your personal information will be transferred to the United States and to other countries that may not provide the same equivalent level of protection as your country of residence.

Where we transfer personal information, we rely on appropriate mechanisms for data transfers including:

• Adequacy Decisions: European Commission adequacy decisions and UK adequacy decisions
• By Contract: EU standard contractual clauses ("EU SCCs"), the UK International Data Transfer Addendum to the EU SCCs ("UK Addendum"), or equivalent model clauses
• With Your Consent: Where you have provided consent to the proposed transfer after being informed of possible risks

20. Country and Regional-specific Supplemental Privacy Notices

The following supplemental privacy notices address any additional country or regional-specific privacy terms and rights:

• California Consumer Privacy Act (CCPA) Notice
• GDPR Privacy Notice

21. Additional Terms Incorporated or Excluded by Reference

• For clients, customers, users, and web visitors, you must read this Global Notice together with our General Terms & Conditions
• This Global Notice does not apply to third-party links from our services to websites or online resources not controlled by Star Promotion Agency

22. Privacy Questions, Issues, and Complaints

We are committed to resolving your questions, issues, and complaints about this Global Notice and related privacy management practices by emailing [email protected] or calling (213) 555-7890.

If you are not satisfied with how we have resolved your complaint, you can escalate your complaint to our management team. If you are still not satisfied with our resolution, you can lodge a complaint with your applicable data protection authority.

23. Controller Contacts

The Data Controller for personal information collected under this Global Notice is:

24. Privacy & Data Protection Officer Contacts

Contact our Privacy & Data Protection Officer:

25. Changes to this Global Privacy Notice

We may modify, amend, or otherwise change this Global Notice from time to time. The "Last Updated" date shown at the top of this Global Notice indicates when these changes will go into effect.

Any material change to this Global Notice will be effective upon posting the revised Global Notice to our services at https://www.labowatrol.com/legal/global-privacy-notice.html or by emailing a copy of these changes to the email address on file for your account or by any other means consistent with applicable law. It is your responsibility to check this Global Notice for changes prior to each use of our services.

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