Website Privacy Policy

1. Scope

This Privacy Policy applies to information collected by Starly LA, together with its affiliates and related companies operating under the Starly name, including without limitation each Starly market office and Starly’s parent, holding, and operating entities (collectively, “Starly,” “we,” “us,” or “our”), through starly.com and its subdomains (collectively, the “Site”). It does not apply to information collected offline, through separately executed representation, agency, or vendor agreements, or through any third-party website or platform, including any platform operated by our affiliate Bantyr, Inc., which maintains its own privacy policy.

2. Information We Collect

2.1 Information You Provide Directly.

We collect information you voluntarily submit through the Site, such as when you complete a contact, booking-inquiry, or talent-submission form, subscribe to communications, or otherwise correspond with us. This information may include your name, email address, telephone number, company or organization, the nature of your inquiry, and any other information you choose to include in your message.

2.2 Information Collected Automatically.

When you visit the Site, we and our service providers automatically collect certain technical and usage information through cookies, pixels, log files, and similar technologies, including your IP address, browser and device type, operating system, referring and exit pages, pages viewed, dates and times of access, and general geographic location inferred from your IP address. This information is used in the aggregate to operate, secure, and improve the Site and is not, on its own, intended to identify you personally.

2.3 Information from Third Parties.

We may supplement the information described above with information from publicly available sources, analytics providers, or business contacts, where permitted by applicable law.

3. How We Use Information

We use the information described above for the following purposes:

• to respond to inquiries submitted through the Site and to communicate with prospective and existing business contacts;
• to operate, maintain, secure, and improve the functionality and performance of the Site;
• to understand how visitors use the Site through aggregated analytics;
• to detect, investigate, and prevent fraudulent, unauthorized, or illegal activity; and
• to comply with applicable legal obligations and to establish, exercise, or defend legal claims.

We do not use information collected through the Site to make any automated decision that produces a legal or similarly significant effect concerning any individual.

4. Cookies and Similar Technologies

The Site uses cookies and similar tracking technologies to enable core site functionality and to collect the usage information described in Section 2.2. Most browsers allow you to control cookies through their settings, including by blocking or deleting cookies; however, disabling cookies may affect the functionality of the Site. The Site may incorporate third-party analytics tools, which operate pursuant to their own privacy policies and use cookies or similar technologies subject to those providers’ own terms.

5. How We Disclose Information

We do not sell personal information collected through the Site in the conventional sense of an exchange for monetary consideration, and we do not otherwise disclose personal information except as described below:

• Service Providers. We may share information with third-party vendors who perform services on our behalf, such as website hosting, email delivery, and analytics, under confidentiality and data-protection obligations consistent with this Privacy Policy.
• Affiliated Entities. We may share information among Starly’s affiliated agency offices for the purpose of processing inquiries related to talent representation and booking.
• Legal and Safety. We may disclose information where required by law, subpoena, or other legal process, or where we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Starly, our talent, our users, or the public.
• Business Transfers. We may disclose or transfer information in connection with a merger, acquisition, financing, reorganization, or sale of all or a portion of our assets, subject to customary confidentiality protections.

6. Your Privacy Rights

6.1 California Residents.

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), affords you certain rights with respect to personal information we collect about you, including the right to know the categories and specific pieces of personal information we have collected, the right to request deletion of personal information, the right to correct inaccurate personal information, and the right to non-discrimination for exercising these rights. Starly does not sell or share personal information, as those terms are defined under the CCPA. To the extent Starly collects any sensitive personal information, as defined under the CCPA, through the Site, such information is used and disclosed solely for the limited purposes permitted under the CCPA without a right to limit — for example, to provide the specific service you requested, to protect against fraud or security incidents, or to comply with legal obligations — and Starly does not use or disclose sensitive personal information for the purpose of inferring characteristics about you. You may exercise your rights under the CCPA by contacting us as described in Section 9 below. We will verify your request using the information associated with your prior communications with us before responding.

6.2 Other Jurisdictions.

Depending on your jurisdiction of residence, you may have additional rights with respect to your personal information, including rights of access, correction, deletion, restriction, or objection. Where such rights apply, you may exercise them by contacting us as described in Section 9, and we will respond in accordance with applicable law.

7. Data Retention and Security

We retain information collected through the Site for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, to comply with our legal obligations, and to resolve disputes, after which it is deleted or de-identified. We implement administrative, technical, and physical safeguards designed to protect information from unauthorized access, use, alteration, or disclosure; however, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Children’s Privacy

The Site is not directed to, and is not intended for use by, individuals under the age of eighteen (18). We do not knowingly collect personal information from individuals under eighteen (18) through the Site. If we become aware that we have inadvertently collected such information, we will take reasonable steps to delete it.

9. Contact Us

Questions, comments, or requests regarding this Privacy Policy, or requests to exercise any privacy rights described herein, may be directed to Starly at info@starlyinc.com.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site and update the Effective Date above. Material changes will be indicated by a prominent notice on the Site prior to the change taking effect. Your continued use of the Site following any such update constitutes your acceptance of the revised Privacy Policy.