We collect only what we need to run the Services and meet our legal duties. Your private keys and recovery phrase never leave your device, and we never see them. We do not sell your data.
1. Who we are
Starpay Digital Limited (“Starpay”, “we”) is the controller of the personal data described in this policy. Our registered office is Level 15-16, Nexxus Building, 41 Connaught Road Central, Hong Kong. You can reach our privacy team at privacy@starpay.inc. Privacy enquiries may be directed to Starpay Digital Limited at dpo@starpay.inc.
2. What we never collect
Starpay is a self-custody wallet. Your private keys and your 12-word recovery phrase are generated and stored on your device. They are never sent to us and we cannot access them.
3. What we collect
- Account details: email address, phone number and the name you give us.
- Identity verification (card users): full name, date of birth, nationality, residential address, identity document images, a selfie or liveness check, and the results of those checks. This is collected by us and our verification partner Artha FinTech Pte Ltd.
- Card data: card balance, loads, payments, declines, merchant names and the public wallet addresses you link to load the card.
- Wallet data: the public addresses and transaction history the app needs to show your balance. Public blockchain data is visible to anyone.
- Device and usage data: device model, operating system, app version, crash reports, IP address and approximate location derived from it.
- Support data: messages you send us and our replies.
Website analytics, only if you accept analytics cookies: pseudonymous identifiers, the pages you view, your browser and device type and an approximate location, processed for us by Google Analytics (Google Ireland Limited / Google LLC). Our legal basis is your consent, which you can withdraw at any time through “Cookie settings” in the website footer. Google Analytics 4 does not store IP addresses, and analytics data is kept for at most 14 months. We use no advertising trackers. See the Cookie Policy.
4. How we use it and why
- To provide the Services you ask for, such as showing balances and issuing and running your card — because it is necessary for our contract with you.
- To verify your identity and prevent fraud — because the law requires it.
- To keep the Services secure, investigate problems and improve them — because we have a legitimate interest in doing so, balanced against your rights.
- To send you service messages, such as card alerts and security notices — for our contract with you. Marketing messages are sent only with your consent, which you can withdraw at any time.
6. International transfers
Some of our providers process data outside Hong Kong. Where they do, we use legally recognised safeguards such as contractual clauses based on the Recommended Model Contractual Clauses for cross-border transfers published by Hong Kong’s Privacy Commissioner for Personal Data.
7. How long we keep it
We keep your data only as long as we need it for the purposes above, then delete or anonymise it.
8. Security
We protect personal data with encryption in transit and at rest, access controls and regular reviews. No system is perfectly secure; if a breach affects you, we will tell you and the regulator as the law requires.
9. Your rights
Depending on where you live, you may have the right to access, correct, delete, restrict or port your data, to object to certain uses and to withdraw consent. To use any of these rights, email us. We may need to keep some data where the law requires it.
You can also complain to the Office of the Privacy Commissioner for Personal Data (PCPD), Hong Kong.
10. Public blockchains
Transactions you make are recorded on public blockchains, which are permanent and visible to anyone. We cannot change or delete blockchain records.
11. Children
The Services are not for anyone under 18, and we do not knowingly collect data from children.
12. Changes and contact
We will post any changes on this page and tell you in the app if they are significant. Questions: privacy@starpay.inc.