PRIVACY POLICY

This Privacy Policy explains how StarBoard Solution North America (“we”, “our”, “the Company”) processes personal data when users access and use this software and its related services (“Software”). We are committed to protecting personal data and handling it in full compliance.

1. Data Controller

2. What Data We Collect and How We Use It

2.1 Personal Data

We only collect personal data that is necessary to provide and improve the Software and services. Examples may include:

• Account information such as username or preferences
• Device identifiers such as IP address
• Support-related information when you contact us

We **do not** collect sensitive personal information such as full names, ID cards, phone numbers, bank details, or biometric data through the Software.

2.2 Processing Purposes and Legal Bases

We process personal data for:

Purpose	Examples	Legal Basis
Provide and operate the Software	Create and maintain accounts, enable functions	Legitimate interests
Improve services and user experience	Usage analysis, feature optimization	Legitimate interests
Troubleshooting and security	Error logs, fraud prevention	Legitimate interests
Support and communication	User-initiated inquiries	Legitimate interests

Where we rely on **consent** (e.g., optional features or analytics), users can withdraw consent at any time without affecting service availability.

3. Data We Do Not Intentionally Collect

We do not intentionally collect personal data belonging to minors without guardians’ consent.

4. Non-Personal Data

We may collect statistical or aggregated information that cannot directly identify individuals, such as:

• Device type, language, OS version
• CPU, memory and storage usage
• General location and time zone
• Software usage duration and interactions

This data helps us maintain performance, improve features, and develop new products. When such data becomes linked to personal data, we will treat it as personal data.

5. Cookies and Similar Technologies

Our Software and online services may use cookies, pixel tags, or similar technologies to analyze usage and improve performance. Users can manage cookie preferences through their browser or system settings.

6. Cloud Storage

Some features allow users to store files through regional servers. Files are encrypted during transmission. We do not access or use stored files.

7. Data Disclosure

We **do not sell** personal data.

We may share personal data only when necessary:

1. With user consent
2. Service providers and authorized partners who assist us in operating the Software
3. Affiliated companies under strict confidentiality obligations
4. Legal requirements such as court orders or regulatory requests
5. Business transfers (e.g., merger or acquisition) with continued privacy protection

8. Security Measures

We use technical and organizational measures to protect personal data, including:

• Encryption of stored and transmitted data
• Restricted access to internal systems
• Physical security at data hosting facilities

9. Data Retention

Personal data is retained only as long as needed to fulfill the purposes described in this policy. When no longer required, data will be securely deleted or anonymized unless a longer retention period is required by law.

10. User Rights

• Right to access their personal data
• Right to correct inaccurate or incomplete data
• Right to delete data (“right to be forgotten”)
• Right to restrict processing
• Right to object to processing based on legitimate interests
• Right to data portability
• Right to withdraw consent at any time
• Right to lodge a complaint with a data protection authority

To exercise any rights, please contact us at: **admin@starboard-solution.com**

We will respond within **one month**.

11. Children’s Privacy

If we become aware that we have collected data from a child without proper consent, we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Users will be informed of significant changes through the Software or our website.