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Privacy Policy

1. Introduction

This Privacy Policy explains how Starlet Entertainment Limited (hereinafter “Starlet”) processes personal data collected through our website [starlet-group.com]. We are committed to protecting your privacy and handling personal data in a transparent and lawful manner, as Data Controller in terms of the General Data Protection Regulation - Regulation (EU) 2016/679 (hereinafter the “GDPR”) and applicable Maltese data protection laws.

This Privacy Policy applies equally whether you are accessing the website via a computer, a mobile phone, or any other device.

Within this Policy when referring to Personal Data, one refers to any information that can directly or indirectly identify a natural person. Whilst the Processing of Personal Data means any operation or set of operations performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

In the context of this Policy, Data Subject means anyone who can be identified, directly or indirectly by Personal Data (“you”); Data Controller means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data; and Data Processor refers to a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of a Data Controller.

2. The identity and the contact details of the Data Controller

The Data Controller is Starlet Entertainment Limited (C 105787).

The Data Controller may be contacted at:

3. The contact details of the Data Protection Officer

If you have questions about Starlet’s data protection framework or wish to receive further information on how your Personal Data is processed, please reach out to our Data Protection Officer at dataprotection@starlet-group.com.

4. What Personal Data We Collect

Limited technical information may be automatically processed by servers to ensure the operation, stability, and security of the website. This may include:

  • • IP address (temporarily logged by hosting provider)
  • • Browser type and version
  • • Operating system
  • • Date and time of connection

This data is processed only for technical and cybersecurity purposes and is not used for identification or marketing.

5. Legal Basis for Processing

The processing of the technical data listed above is based on:

• Article 6(1)(f) GDPR — Legitimate Interest
(Website operation, security and network integrity)

We do not process personal data for marketing, profiling, or automated decision-making purposes.

6. Use of Cookies

Our website uses only essential/technical cookies required for functionality and security. These cookies cannot be disabled and do not require consent under GDPR and ePrivacy rules.

We do not use analytics, tracking, or advertising cookies.

7. Transfer of Personal Data

Personal data will not be shared with third parties, except:

  • • Where required by law or regulatory authorities
  • • With our trusted IT or hosting service providers under appropriate data protection agreements

8. Data Retention

Technical logs, if generated, are stored only for as long as necessary for:

  • • Security monitoring
  • • Functioning of the website
  • • Compliance with applicable laws

Logs are deleted within [insert period: 30–90 days] unless required for regulatory or security reasons.

9. Transfer of Personal Data to third-countries

Your data may be stored or processed within the European Union. We do not transfer data outside the EU/EEA unless appropriate safeguards (e.g., SCCs) are in place.

10. Your Rights as a Data Subject

You have the following rights with respect to the processing of your Personal Data:

  • (i) Right of access – you have the right to access the Personal Data that Starlet holds about you;
  • (ii) Right of rectification – you have the right to request the correction of any inaccurate or incomplete data that Starlet holds about you;
  • (iii) Right to erasure – you may request for the data held about you to be erased from Starlet’s records. This will be acceded to in certain circumstances in accordance with the GDPR;
  • (iv) Right to restriction of Processing – you have the right to request the restriction of Processing of your Personal Data. This will be acceded to in certain circumstances in accordance with the GDPR;
  • (v) Right to data portability – you have the right request that the Personal Data Starlet holds about you be transferred to another entity;
  • (vi) Right to object – in certain circumstances you have the right to object to particular processing activities; and
  • (vii) Right to withdraw consent – where Processing of your Personal Data is based on consent, you have the right to withdraw your consent at any time. Such a withdrawal will not affect the lawfulness of any Processing carried out prior to such withdrawal, and neither will it affect any Processing of your Personal Data carried out on any other lawful basis for Processing in terms of the GDPR.

In addition to the above, you also have the right to lodge a complaint with a supervisory authority. The competent supervisory authority is:

Office of the Information and Data Protection Commissioner,

Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, Malta

+356 2328 7100

idpc.info@idpc.org.mt

11. The existence of automated decision-making

By processing your data, an automated decision may be made in specific cases, as outlined in Article 22

12. Changes

If this Privacy Policy is updated, we will replace the current version on this page with the revised version. Each version will include a modification date for reference. It is the visitor’s responsibility to review all versions regularly to stay informed of any changes or updates.