Privacy Policy

Protecting your privacy is very important to StarClub, Ltd. (StarClub). We designed this Privacy Policy to make clear how you can use StarClub, and how StarClub can collect, use and share your personal information. Please read this policy carefully in order to understand what we do with your information. StarClub collects both personally identifiable information and non-personally identifiable information. "Personally identifiable information" means any information that can be used to personally identify you. This includes all information you voluntarily provide, and includes use of the information we collect. When we use the term "non-personally identifiable information" we are referring to information that StarClub may collect from you that is not collected in conjunction with your name. Non- personally identifiable information includes any information that has been aggregated or made anonymous. When we refer simply to "information" we are referring to how StarClub collects, uses, or shares both personally identifiable, and non-personally identifiable information. An "affiliated party" refers to a vendor or service provider that has a commercial relationship with StarClub. An "unaffiliated party" refers to a vendor or service provider that does not have a commercial relationship with StarClub. This Privacy Policy is incorporated into and is subject to the StarClub End User License Agreement. By using or accessing StarClub, you expressly consent to the informational handling practices, including the collection, transfer, manipulation, storage, disclosure, and other uses, as described in this notice.

The Information StarClub Collects

User Provided Information: When you sign up for StarClub, we will collect various information, including your name, email address and all other profile information that you volunteer to provide. You will also be asked to provide information for your profile record, to be made public, including a unique user name, picture and location, along with information on your background and interests that you choose to make public. Voluntarily Shared Information: Our Services are primarily designed to help you connect with entertainers, communicate and share information. Most of the information you provide us is information you have chosen to make public. This includes not only the messages and blogs that you post, the video chats you enter and all the metadata provided with these communications, such as the time posted, but also the lists you create, the channels you subscribe to, the chat rooms you join, and the contests and competitions you participate in, and many other bits of information that result from your use of StarClub. Our default rule is to consider the information you provide for these purposes, and any content you upload to the system, as public for as long as you do not delete it. When you share information or content like photos, videos, and links via the Services, you should think carefully about what you are making public. You acknowledge that the channels you participate in are controlled by the entertainers you choose to subscribe to, and not controlled by StarClub. There is no guarantee that you will be selected by an entertainer for a chat with the entertainer, or that you will not be terminated from the entertainer's channel. You are responsible for the content that you share and you understand that the entertainer is the channel operator and decides who participates and what content is presented on their channel. The entertainer may decide to terminate your participation based on the content that you share or how you participate on the channel. You also understand that record of your participation in, and possible termination from, a channel is public information. Automatically Collected Information: When you sign up for StarClub or access the StarClub platform, we may automatically record certain information from your system by using different types of tracking technology. This "automatically collected" information may include Internet Protocol address ("IP Address"), a unique device or user ID, version of software installed, system type, the dates, times and details of your transactions, and information from your account that you make publicly available. There are other data objects on our webpages that allow us to monitor your use of the website, i.e., web beacons. Web beacons are small snippets of code that are contained on websites or in emails. Web beacons allow publishers to do such things as monitor how content is being downloaded or viewed, and to create auditing and reporting of certain types of advertising. Log Files: When you visit our website, we may track information about your visit and store that information in web server logs, which are records of the activities on our sites. Our servers automatically capture and save the information electronically. Information from these server logs may include: Your unique Internet protocol address The name of your unique Internet service provider The city, state, and country from which you access our website The kind of browser or computer you use The number of links you click within the site The date and time of your visit The web page from which you arrived to our site The pages you viewed on the site Certain searches/queries that you conducted via our website(s) The information we collect in web server logs helps us administer the site, analyze its usage, protect the website and its content from inappropriate use, and improve the user's experience. Cookies Information: When you access StarClub, we may send one or more cookies – small text files that contain a string of alphanumeric characters – to your computer. StarClub may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the StarClub Platform. Persistent cookies can be removed. Please review your web browser's "Help" file to learn the proper way to modify your cookie settings. You should understand that some features of StarClub, and many other sites, may not function properly if you don't accept cookies. Ads and Links: StarClub may keep track of how you interact with links across our Services, including our email notifications, third-party services, and client applications, by redirecting clicks or through other means. We do this to help improve our Services, to provide more relevant advertising, and to be able to share aggregate click statistics such as how many times a particular link was clicked on. Purchase Transactions: If you make a purchase on StarClub, you will provide us with information and your payment source, and you confirm that you are permitted to use that payment source. You also authorize us to collect and store it, along with other related transaction information. StarClub and its service partners manage your financial information in compliance with the Payment Card Industry Data Security Standard (PCI DSS). WE MAKE NO WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, WITH RESPECT TO ANY PRODUCTS OR SERVICES SOLD BY STARCLUB AFFILIATED PARTIES OR UNAFFILIATED PARTIES.

The Ways StarClub Uses Personal Information

Quality Control and Routine Maintenance: StarClub uses the information that you provide or that we collect to operate, maintain, enhance, and provide all of the features and services. We may share your information with our affiliated parties, to ensure that you have a safe, high- quality experience when using StarClub. We rely on some of our affiliated parties for support of the products and services we offer. Our affiliated parties are all required to preserve the confidentiality of any personal information they may access. Participation on a Channel: When you use the StarClub service, including when you participate in a channel or enter a transaction, we may use the information that we have collected. Knowing this information allows us to verify your identity, communicate with you and enforce our agreements with you, as well as to ensure compliance with U.S. state and federal laws and our own policies. We will not disclose any personally identifiable information or information about your usage of StarClub to affiliated parties or unaffiliated parties, except as necessary to service the account, to enforce the terms of use, to meet our obligations to content and technology providers, as required by law, or as otherwise indicated in this Policy. We may share certain non-personally identifiable information about you to affiliated parties or unaffiliated parties. We do this for purposes such as analyzing how the StarClub service is used, diagnosing service or technical problems, maintaining security, and personalizing content. Administrative Contact: We will use your email address, without further consent, for administrative communications. If you wish to change you communication settings, you may do so in your account settings. We will not sell, rent, lease or otherwise disclose your email address or other personal information or customer data to others, and we will not make your personal information available to any unaffiliated parties, except our approved agents and contractors, or as otherwise described in this Privacy Policy. Marketing: We may use your contact information to send you information about our Services or to market sponsored events, products or services that we believe may be of interest to you. If you do not wish to receive such offers, you may access your account settings and make a selection to opt out. Your transaction history and address may be used to generate general statistics about purchasing behavior of a population that you are a part of. This information is aggregated and generated into non-personally identifiable information. We may use or distribute this aggregated data without your consent. This data is made anonymous and cannot be reversed engineered to derive your individual personal data. We also prohibit users of that data from attempting to reverse engineer the data. Our Site contains links to other websites whose information practices may be different from ours. Visitors and Members should consult the other sites' privacy notices, as those sites are not covered by our Privacy Policy. Cross-Posting Between StarClub and Another Service: If you connect your StarClub account to your account on another service in order to cross-post between StarClub and that service, the other service may send us your registration or profile information on that service and other information that you authorize, such as your contact or friends lists. This information enables cross-posting, and helps us improve the Services. Legal Compliance: We may also disclose information where we are required to do so by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose information in response to a law enforcement agency's or other public agency's request or if we feel that such disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our websites, protect the security or integrity of our websites, or enable us to take precautions against liability.

How Your Personal Information is Protected

Data Security: We maintain your personal data in a secure server environment. We have implemented certain appropriate security measures to help protect your personal information from accidental loss and from unauthorized access, use, or disclosure. For example, some of our websites are protected with Secure Sockets Layer (SSL) technology. Also, we store the information about you in a data center with restricted access and appropriate monitoring, and we use a variety of technical security measures to secure your data. In addition, we use intrusion detection and virus protection software. However, please note that we cannot guarantee that unauthorized persons will always be unable to defeat our security measures. Also, please note that we may store and process your personal information in systems located outside of your home country. However, regardless of where storage and processing may occur, we take appropriate steps to ensure that your information is protected, consistent with the principles set forth under this Policy.

Children's Privacy

StarClub requires that individuals be at least 18 years old before they can create an account. In some jurisdictions, the age limit may be higher. Providing false information to create an account is a violation of the End User License Agreement. This includes accounts registered on behalf of under 18 year old children by older parties such as legal guardians. We do not knowingly collect or maintain personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take the appropriate steps to delete such information and terminate the child's account. If you become aware that your underage child has created an account or provided us with personal information without your consent, please email us atprivacy@starclubnetworks.com. If you would like to report an account registered for an underage child to us, please emailprivacy@starclubnetworks.com. We will take the appropriate steps to delete the account of any child under the age of 13 that is reported to us.

EU Safe Harbor Framework

StarClub complies with the U.S.-E.U Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.

International Visitors

We strive to create a global community with consistent standards for everyone, but we also strive to respect local laws. The following provisions apply to users outside the United States:

You consent to having your personal data transferred to and processed in the United States. Your Choices, Opt-In and Opt-Out Provisions If you do not want to receive e-mail or other mail from us, please adjust your Communication Preferences in your profile settings. The Help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on's settings or visiting the Web site of its manufacturer. Because cookies allow you to take advantage of many features of our website, we recommend that you leave them turned on. You can always choose not to provide some voluntarily provided information, even though it might be needed to subscribe to StarClub, to participate on channels, or to take advantage of any contests and rewards programs we may provide. You can always amend your account and the information you voluntarily provide. To do so, you can adjust your account settings. You can opt-out of disclosures to affiliated parties and unaffiliated parties by terminating your account. You may request that your data be removed and that your account be terminated by sending an email with your account information to termination@starclubnetworks.com. If you delete your StarClub account, it will typically take about 90 days. Some information may remain in backup copies and logs for up to 180 days. If you wish to suspend your account, you may do so here suspend@starclubnetworks.com. When you suspend your account, we will retain your information, however it will not be visible to other users. We will alert you by e-mail if we would like to use your information for a new purpose, other than those listed in this policy. The e-mail will provide you with an opportunity to opt-in to the new uses of your information.

Consent In the Event of Merger or Sale of StarClub

In the event that StarClub is acquired by or merged with a third-party entity, you hereby consent to transfer or assign the information that we have collected from users as part of that merger, acquisition, sale or other change of control, to the extent permitted by applicable law.

Changes and Updates to this Privacy Policy

If our information practices change in a significant way, we will post the policy changes here. Changes to the Privacy Policy will become effective when they are posted on this page. This Privacy Policy was last updated on July 20, 2012. We will email you in the event that changes have been made to the privacy policy.

StarClub Contact Information

We have an internal privacy policy ombudsman, who can be contacted with any complaints or comments atcomplaints@starclubnetworks.com. Our ombudsman periodically checks that our project complies with our Privacy Policy.