Legal

Privacy Policy

Last updated: 16 October 2026

Starluenc respects your privacy and aims to handle personal information transparently and responsibly.

This Privacy Policy explains what personal data Starluenc collects, why we collect it, how we use it, how long we keep it, who we may share it with, and what rights you have.

01Who we are

For the purposes of applicable data protection law, the data controller is:

Sandis Milts, operating Starluenc

Latvia

Email: privacy@starluenc.com

Starluenc is currently operating prior to formal company registration. Once the business entity is registered, this Privacy Policy will be updated with the relevant legal entity details.

02Who this Privacy Policy applies to

This Privacy Policy applies to people who interact with Starluenc, including:

  • creators who submit a Creator Application
  • brands or businesses that submit a Brand Enquiry
  • people who communicate with Starluenc by email or other channels
  • people involved in potential or active partnerships and opportunities
  • visitors to the Starluenc website

03Personal data we collect

Creator information

When you submit a Creator Application, we may collect information such as:

  • your name
  • creator or public name
  • email address
  • country
  • creator category or niche
  • social media platforms and profile links
  • approximate audience size
  • audience location, interests and age range
  • partnership interests
  • brands you would like to work with
  • brands or industries you prefer to avoid
  • your goals
  • project or business ideas
  • information you voluntarily provide about what you create or want to build

Creator Applications are currently open only to people aged 18 or over.

Brand and business information

When you submit a Brand Enquiry, we may collect:

  • your name
  • work email
  • company or brand name
  • role
  • website
  • country or region
  • information about the brand or business
  • campaign or partnership objectives
  • target audience
  • collaboration interests
  • budget or timing information
  • information about products, campaigns, events or ideas
  • other information you choose to provide

Partnership and opportunity information

If we explore or manage a potential partnership, we may also record:

  • creator and brand match information
  • opportunity concepts
  • communication history
  • proposed deliverables
  • compensation or success-fee terms
  • approvals
  • partnership status
  • campaign results
  • payment or invoicing information where relevant

Communications

If you contact Starluenc directly, we may process information contained in emails, messages, meeting notes or other communications.

Public professional information

Where appropriate, Starluenc may review publicly available professional or creator information, such as public social media profiles, websites, business pages or publicly available brand information, when researching possible opportunities or partnerships.

We aim to use only information relevant to evaluating a potential professional or commercial fit.

04Why we use your personal data

We may use personal data to:

  • review Creator Applications and Brand Enquiries
  • understand creators, audiences and business objectives
  • evaluate potential partnership fit
  • research relevant brands, creators or opportunities
  • develop collaboration ideas
  • contact you about relevant opportunities
  • communicate about potential or active partnerships
  • prepare proposals, agreements or campaign plans
  • administer partnerships and payments
  • maintain internal business records
  • respond to enquiries
  • improve Starluenc’s services and processes
  • comply with legal, tax, accounting or regulatory obligations

06How creator and brand matching works

Starluenc may assess information such as:

  • creator interests and ambitions
  • audience characteristics
  • creator niche
  • brand objectives
  • campaign fit
  • collaboration potential
  • timing and commercial relevance

The current Starluenc process is human-led.

Starluenc does not currently use solely automated decision-making that produces legal or similarly significant effects for creators or brands.

Automated tools may be used in the future to assist with organization, research or recommendations, but material partnership decisions will remain subject to human review unless this Policy is updated to explain otherwise.

07Who we share personal data with

We do not sell personal data.

Personal data may be shared only where reasonably necessary with:

  • technology and service providers used to operate Starluenc
  • professional advisers such as accountants or legal advisers
  • creators, brands or business partners where information needs to be shared to explore or manage a potential partnership
  • authorities or regulators where required by law

Where we introduce a creator and brand, we aim to share only the information reasonably necessary for the relevant opportunity.

08Technology providers

Starluenc currently uses third-party technology providers including:

Google Workspace

Starluenc uses Google Workspace for tools including Google Forms, Google Sheets and Google Drive.

Google acts as a data processor for relevant Workspace customer data under its Cloud Data Processing Addendum. Starluenc has accepted the Google Workspace Cloud Data Processing Addendum and certified that EU data protection law applies. Google describes the CDPA as addressing its processor obligations under applicable data protection laws. Google Workspace Help

Lovable

The Starluenc website is built and hosted using Lovable.

Starluenc has disabled Lovable visitor analytics for the current V1 website. Lovable states that app/site usage analytics are only collected when enabled by the site owner. Lovable

Lovable may still process technical information necessary to operate, secure and deliver the website and its services.

09International data transfers

Some service providers used by Starluenc may process data outside Latvia or elsewhere outside the European Economic Area.

Where applicable, Starluenc relies on appropriate safeguards required by data protection law, including contractual safeguards and mechanisms used by its service providers.

Information about the safeguards used by Google and Lovable is available through their respective privacy and data-processing documentation. Lovable

10How long we keep personal data

Starluenc does not intend to keep personal data indefinitely.

Current internal retention guidelines are:

  • rejected or inactive creator applications: generally up to 12 months after review
  • rejected or inactive brand enquiries: generally up to 12 months after review
  • Hold / Watch profiles: reviewed within 12 months
  • accepted creators: while the relationship remains active and generally up to 24 months after the last meaningful interaction
  • accepted brands: while the relationship remains active and generally up to 24 months after the last meaningful interaction
  • closed opportunities: generally up to 12 months after closure
  • partnership, contract, accounting and payment records: retained for as long as required by applicable legal, tax or accounting obligations

At the end of the relevant retention period, information may be deleted or anonymised unless there is a valid reason to keep it longer.

11Your data protection rights

Depending on the circumstances and applicable law, you may have the right to:

  • access your personal data
  • correct inaccurate data
  • request deletion of your data
  • restrict processing
  • object to certain processing
  • receive certain data in a portable format
  • withdraw consent where processing is based on consent
  • lodge a complaint with a supervisory authority

Latvia’s Data State Inspectorate confirms these rights under Articles 15–22 GDPR and notes that organizations must generally respond to rights requests without undue delay and within one month. Datu valsts inspekcija

To exercise your rights, contact:

We may need to verify your identity before acting on a request.

12Supervisory authority

If you believe your personal data has been processed unlawfully, you have the right to lodge a complaint with the competent supervisory authority.

For Latvia, the supervisory authority is:

Datu valsts inspekcija

(Data State Inspectorate of Latvia)

Official website

Information about the Inspectorate and data-subject rights is available on its official website. Datu valsts inspekcija

13Sensitive personal data

Starluenc does not intentionally request special-category personal data such as health information, political opinions, religious beliefs, biometric data or other sensitive information unless there is a specific lawful reason to do so.

Creator categories refer to public content niches and professional interests, not personal characteristics or beliefs.

Please avoid including sensitive personal information in free-text fields unless it is genuinely necessary.

14Children

Creator Applications are currently open only to people aged 18 or over.

Starluenc does not intentionally invite minors to submit Creator Applications.

If we become aware that personal data has been submitted by a person who does not meet the applicable age requirement, we may delete or restrict that information where appropriate.

15Website analytics and cookies

Starluenc currently has Lovable visitor analytics disabled and does not currently use Google Analytics, Meta Pixel or similar advertising-tracking tools on the public Starluenc website.

The website may still use strictly necessary technical functionality required to operate, secure and deliver the site.

Lovable distinguishes between strictly necessary technologies and optional analytics or marketing technologies, and states that analytics for published apps are only collected when the owner enables them. Lovable

If Starluenc introduces non-essential analytics, advertising pixels, session recording or similar technologies in the future, this Privacy Policy and any required cookie-consent mechanism will be updated before or when those tools are introduced.

16Security

Starluenc takes reasonable organizational and technical measures intended to protect personal information against unauthorized access, loss, misuse or disclosure.

No online system can be guaranteed to be completely secure, but we aim to limit access to personal data to people and service providers who genuinely need it.

18Changes to this Privacy Policy

We may update this Privacy Policy as Starluenc develops, including when:

  • the business becomes formally registered
  • new services are introduced
  • technology providers change
  • analytics or advertising tools are added
  • legal or regulatory requirements change

The latest version will be published on the Starluenc website with an updated date.

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