Privacy Policy

Status: Pending counsel review. The version below is a working draft and not yet effective.

Effective date: [Pending counsel review]

Last updated: [Pending counsel review]

This Privacy Policy describes how Starward Capital (“we,” “us,” or “Starward Capital”) collects, uses, discloses, and otherwise processes personal information in connection with the website located at starwardcapital.com (the “Site”). This Policy applies to personal information collected through the Site, through communications with us via email or other channels in response to inquiries initiated by you, and in connection with any related online services we provide that link to or reference this Policy.

This Policy does not apply to personal information processed in connection with offerings of any securities or investment products, which are governed by separate offering documents and disclosures provided directly to relevant parties.

1. About Starward Capital

Starward Capital is a private investment firm. The Site is operated by Starward Capital and is intended to provide general information about the firm. The Site is not intended as an offering of securities, investment advice, or solicitation of investment in any jurisdiction.

If you have questions regarding this Policy or our information practices, you may contact us at the address provided in Section 12.

2. Information We Collect

We collect limited personal information through the Site. The categories of personal information we may collect are described below.

2.1 Information You Provide Directly

If you contact us through the Site (including by email to addresses published on the Site), we receive the information you choose to provide. This typically includes your name, your email address, the contents of your message, and any other information you choose to include in your communication with us. We do not require you to create an account or provide personal information to view content on the Site.

2.2 Information Collected Automatically

When you visit the Site, certain information is collected automatically by our hosting and content delivery providers. This information may include your Internet Protocol (IP) address, browser type and version, operating system, the pages you access on the Site, the date and time of your visit, the referring page (if any), and approximate geographic location derived from your IP address.

We use Cloudflare Web Analytics, a privacy-respecting analytics service that does not use cookies and does not track individual users across visits. Aggregated analytics data is used to understand how the Site is used and to improve the Site’s performance and content.

2.3 Cookies and Similar Technologies

The Site uses a minimal set of technical cookies necessary for the operation of the Site, including cookies set by Cloudflare for security and performance purposes. The Site does not use cookies for advertising, behavioral tracking, or analytics that identify individual users.

You may configure your browser to refuse cookies or to notify you when cookies are sent. If you disable cookies, certain features of the Site may not function correctly.

2.4 Information from Third Parties

We do not purchase personal information from third parties for use in connection with the Site. If you contact us in response to an introduction made by a mutual contact or in connection with an existing relationship between Starward Capital and a third party, we may receive limited information about you from that party in connection with the introduction or relationship.

3. How We Use Personal Information

We use personal information for the following purposes:

To respond to inquiries. If you contact us, we use the information you provide to respond to your inquiry, communicate with you, and provide information you have requested.
To operate and improve the Site. We use automatically collected information to operate, maintain, secure, and improve the Site.
To detect and prevent fraud, abuse, and security incidents. We use technical information to identify potential security threats and to protect the Site and our systems against unauthorized access, abuse, and other harmful activity.
To comply with legal obligations. We process personal information as necessary to comply with applicable law, regulatory requirements, and legal process.
To establish, exercise, or defend legal claims. We may process personal information as necessary to protect our legal rights or to address legal disputes.

We do not use personal information collected through the Site for marketing of investment products, solicitation of investment, or targeted advertising.

4. Legal Bases for Processing (For Individuals in the European Economic Area and the United Kingdom)

If you are located in the European Economic Area or the United Kingdom, our processing of your personal information is based on the following legal bases under the General Data Protection Regulation (GDPR) and the UK GDPR:

Legitimate interests. We process personal information based on our legitimate interests in operating the Site, responding to inquiries, securing our systems, and protecting our legal rights. Our legitimate interests are balanced against the rights and interests of data subjects.
Compliance with legal obligations. We process personal information as necessary to comply with our legal obligations under applicable law.
Consent. Where required by applicable law, we process personal information based on your consent. You may withdraw consent at any time by contacting us; withdrawal does not affect the lawfulness of processing before withdrawal.
Contractual necessity. Where personal information is processed in connection with a contractual relationship, we rely on contractual necessity as the legal basis.

5. How We Share Personal Information

We do not sell personal information. We share personal information only in limited circumstances:

With service providers. We share personal information with service providers that perform services on our behalf, including hosting providers (Vercel), content delivery and security providers (Cloudflare), email service providers, and similar providers. These service providers are bound by confidentiality obligations and are restricted from using personal information for purposes other than providing services to us.
For legal compliance and protection. We may disclose personal information when required by applicable law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to protect our rights, the safety of any person, or the integrity of the Site.
In connection with business transactions. If Starward Capital is involved in a merger, acquisition, financing, reorganization, or sale of assets, personal information may be transferred as part of that transaction, subject to appropriate confidentiality protections.
With your direction or consent. We share personal information at your direction or with your consent.

6. International Data Transfers

Starward Capital is a global firm and processes personal information in multiple jurisdictions. Personal information collected through the Site may be transferred to, stored in, or processed in jurisdictions other than your country of residence, including the United States. These jurisdictions may have data protection laws that differ from those of your country of residence.

Where personal information is transferred from the European Economic Area, the United Kingdom, or other jurisdictions with data export restrictions, we implement appropriate safeguards as required by applicable law, including the use of Standard Contractual Clauses adopted by the European Commission or equivalent transfer mechanisms.

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with applicable legal obligations, to resolve disputes, and to enforce our agreements. Specific retention periods depend on the nature of the information and the purposes of processing.

Information collected through Site analytics is retained in aggregated form and is generally not associated with individual users. Inquiry communications are retained for a period appropriate to the nature of the inquiry and any resulting relationship.

When personal information is no longer needed for the purposes described in this Policy, we securely delete or anonymize it.

8. Data Security

We implement reasonable technical and organizational measures designed to protect personal information against unauthorized access, alteration, disclosure, or destruction. These measures include access controls, encryption of data in transit (TLS), secure hosting infrastructure, and operational practices designed to limit access to personal information to those with a legitimate need.

No method of transmission over the internet or method of electronic storage is fully secure, and we cannot guarantee absolute security. You are responsible for safeguarding any credentials used to access systems controlled by us and for protecting communications you send to us.

9. Your Rights

Depending on your jurisdiction and the applicable law, you may have rights with respect to your personal information, including:

Access. The right to obtain confirmation of whether we process personal information about you and to access such information.
Correction. The right to request correction of inaccurate or incomplete personal information.
Deletion. The right to request deletion of personal information, subject to limitations under applicable law.
Restriction of processing. The right to request restriction of processing in certain circumstances.
Portability. The right to receive personal information in a structured, commonly used format and to transmit it to another data controller.
Objection. The right to object to processing based on legitimate interests or for direct marketing purposes.
Withdrawal of consent. Where processing is based on consent, the right to withdraw consent.
Complaint to a supervisory authority. The right to lodge a complaint with the data protection authority of your jurisdiction.

For individuals in California, the United States, applicable rights under the California Consumer Privacy Act and the California Privacy Rights Act include the right to know what personal information is collected, the right to delete personal information, the right to correct inaccurate personal information, the right to limit use and disclosure of sensitive personal information, the right to non-discrimination for exercising these rights, and the right to opt out of the sale or sharing of personal information. Starward Capital does not sell or share personal information for cross-context behavioral advertising.

To exercise any of these rights, please contact us at the address provided in Section 12. We will respond to verifiable requests within the timeframes required by applicable law. We may request information to verify your identity before responding to a request.

10. Children’s Privacy

The Site is not directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16. If we become aware that we have collected personal information from a child under the age of 16, we will take steps to delete that information promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or other factors. The effective date at the top of this Policy indicates when the Policy was last revised. Material changes will be communicated through reasonable means, which may include posting an updated Policy on the Site. Your continued use of the Site after the effective date of an updated Policy constitutes acceptance of the updated Policy to the extent permitted by applicable law.

12. Contact

For questions regarding this Privacy Policy, to exercise rights described in this Policy, or to communicate with us regarding personal information, please contact:

Starward Capital
Email: privacy@starwardcapital.com

For data protection matters specifically relating to individuals in the European Economic Area or the United Kingdom, you may also contact the data protection authority of your jurisdiction. A list of European Economic Area data protection authorities is maintained by the European Data Protection Board. The United Kingdom Information Commissioner’s Office serves this function in the United Kingdom.