Privacy Policy

Last updated: 29 July 2026

1. General Provisions

This Privacy Policy explains how SWANSTAR ENTERPRISES LIMITED collects, uses, stores, discloses and otherwise processes personal data in connection with https://swansta.com, https://starwn.com and the related Platform functionality.

SWANSTAR ENTERPRISES LIMITED, company number 16864192, with its registered office at International House, 50 Essex Street, London, England, WC2R 3JF, is the data controller for personal data processed in connection with Account administration, Platform operation, Project Requests, Orders, payments, support, security, fraud prevention, compliance and business administration.

This Privacy Policy applies to Website visitors, registered Users, Customers, Business Representatives, applicants and Independent Service Performers. Capitalised terms not defined in this Privacy Policy have the meanings given in the Terms & Conditions.

The Company operates the Platform but does not itself perform the Marketing Services displayed on the Websites. Marketing Services are independently offered and performed by Independent Service Performers. Personal data and project materials may be shared with the relevant Service Performer where reasonably necessary to assess a Project Request, communicate with the Customer or perform an Order.

Independent Service Performers generally act as independent data controllers in relation to personal data they independently process to assess, accept and perform Marketing Services. A Service Performer will act as a processor on behalf of the Company only where this is expressly established by a written agreement and the Service Performer processes personal data solely under the Company's documented instructions.

We process personal data in accordance with applicable data protection law, including the UK General Data Protection Regulation, the Data Protection Act 2018 and applicable amendments introduced by the Data (Use and Access) Act 2025. The EU General Data Protection Regulation may also apply in certain circumstances.

Where consent is required for a particular processing activity, including optional cookies, it will be requested separately. Using the Platform does not constitute consent where applicable law requires a specific affirmative choice.

2. Information We Collect

We collect personal data directly from Users, automatically through the Platform and, where permitted by law, from third parties involved in payments, verification, security, technical support or the administration of Orders.

When you create or use an Account, we may collect your full name, email address, telephone number, country or region, preferred language, Account credentials, communication preferences and other information associated with your Account.

Where you use the Platform on behalf of a business, organisation or other legal entity, we may also collect the organisation's name, your job title or role, business contact details, billing or registered address information, information about your authority to act for the organisation and any communications or documents reasonably required to confirm that authority.

When you submit a Project Request, place an Order or communicate about Marketing Services, we may process project descriptions, briefs, instructions, preferences, specifications, intended audiences, project objectives, Order references, agreed scope, Deliverables, delivery terms, revision requests, approvals, communications with Service Performers, complaints, dispute records and other project-related information.

Project and User Materials may include briefs, instructions, text, documents, images, visual references, logos, brand materials, presentations, website or campaign content, content plans, editorial materials and video files used solely as Reference Materials. Uploaded materials are not public and may be accessed only by the Company, the relevant Independent Service Performer and authorised service providers where reasonably necessary for project assessment, Order performance, Platform operation, support, security, compliance or dispute resolution.

Where an individual applies or operates as an Independent Service Performer, we may collect identity and contact details, country of residence, professional profile, areas of expertise, portfolio and supporting materials, Service Listings, project and performance records, tax and reporting information, payout details and verification or compliance results. Where cryptoasset payouts are supported, payout information may include the relevant wallet address, network and transaction reference.

Payments are processed through third-party payment service providers. The Company does not intend to collect or store complete payment card numbers, card security codes or equivalent sensitive authentication data. We may receive limited transaction information, including the payer's name, billing address, transaction identifier, Order reference, payment amount and currency, payment status, payment method type, authentication or fraud-screening results, refund or chargeback status and limited card information such as the card brand and last digits where provided by the payment provider.

We may process information contained in support requests, emails, Platform messages, complaints, cancellation or refund requests, payment disputes, fraud reports, security reports, feedback and other correspondence with the Company or Independent Service Performers. Relevant communications may be retained as part of the Account, Order, complaint, payment or compliance record.

When you access or use the Platform, we may automatically collect technical and usage information, including your IP address, browser type and version, device type and identifiers, operating system, language and regional settings, approximate location derived from technical information, referring and exit pages, pages viewed, features used, dates and times of access, session and authentication information, cookie identifiers, diagnostic data, performance information and security or fraud-prevention signals. This information is used to operate and secure the Platform, diagnose technical problems, detect misuse, understand how the Platform is used and improve its functionality.

We may receive relevant personal data from payment and payout providers, financial institutions, identity or security providers, Independent Service Performers, Business Representatives, publicly available sources and competent authorities where necessary for payments, verification, fraud prevention, compliance, complaints or legal proceedings.

The Platform is not intended for the routine collection of special category personal data, criminal offence data, complete payment card details, passwords or authentication codes. Users must not upload such information unless it is lawful, strictly necessary and expressly requested through an appropriate secure process.

If you provide personal data about another person, you must have lawful authority to do so, provide any privacy information required by law and limit the disclosure to information reasonably necessary for the relevant Project Request or Order.

3. How and Why We Use Personal Data

We process personal data only where we have a valid lawful basis and where the processing is necessary and proportionate to the relevant purpose.

We process Account, contact and verification information to register and administer Accounts, authenticate access, verify contact details and business authority, maintain security and provide Platform functionality. This processing is generally necessary to take steps at the User's request, perform our contractual obligations or pursue our legitimate interests in operating and protecting the Platform.

We process Project Requests, User Materials, Order information and communications to assess projects, involve the relevant Independent Service Performer, facilitate communication, administer Orders, deliver files, manage revisions and provide support. This processing is generally necessary for pre-contractual steps, performance of the Platform Services and facilitation of the Marketing Services contract between the Customer and the relevant Service Performer.

We process limited payment, refund, chargeback and payout information to confirm transactions, reconcile payments, administer refunds and Service Performer remuneration, prevent fraud and maintain accounting and transaction records. This processing may be based on contractual necessity, legal obligations and our legitimate interests in protecting the Platform and its participants.

We process technical, device, security and usage information to operate and secure the Websites, prevent Account misuse and unauthorised activity, diagnose technical issues, analyse Platform performance and improve functionality. This processing is generally based on our legitimate interests, subject to the rights and freedoms of affected individuals.

We process personal data where necessary to comply with accounting, tax, sanctions, digital-platform reporting, data protection, consumer protection, regulatory and other legal obligations, respond to competent authorities and establish, exercise or defend legal claims.

Where consent is required, including for optional cookies or similar technologies, we rely on consent. Consent may be withdrawn at any time without affecting processing carried out before withdrawal.

Where special category personal data is processed, we will identify both an applicable lawful basis and an additional condition required by law.

4. Data Security

We apply technical and organisational measures appropriate to the nature of the personal data, the purposes of processing and the risks associated with unauthorised access, disclosure, loss, alteration or misuse.

Access to personal data is limited to persons who reasonably require it for Platform operation, project administration, payments, support, security, compliance or another authorised purpose. Employees, contractors, Independent Service Performers and service providers with access to personal data are subject to appropriate confidentiality, security and data protection obligations.

Independent Service Performers must protect personal data and User Materials received through the Platform and use them only for legitimate project-related purposes or other purposes permitted by law.

No electronic transmission or storage system can be guaranteed to be completely secure. Users are responsible for protecting their Account credentials, using secure devices and promptly reporting suspected unauthorised access or other security incidents.

Suspected Account compromise or a personal data security concern should be reported to the support address associated with the relevant Website.

5. Cookies and Similar Technologies

The Websites may use cookies and similar technologies to provide essential functionality, maintain sessions, authenticate Users, remember preferences, protect Accounts, prevent fraud and understand Platform performance.

Strictly necessary technologies may operate without optional consent where they are required to provide requested functionality, maintain security or record cookie preferences.

Optional functionality, analytics or similar technologies will be used only where consent has been obtained or another applicable legal exception permits their use. Where required, Users may accept, reject or manage optional technologies through the cookie preference tool available on the relevant Website.

Users may also manage cookies through their browser or device settings. Blocking strictly necessary cookies may affect Account access, payment functionality, security or other essential Platform features.

Session cookies generally expire when the browser is closed. Persistent cookies remain for a defined period or until deleted. Cookies are retained only for as long as reasonably necessary for their purpose.

Current information about the cookies, providers, purposes and retention periods used on each Website may be provided through the applicable cookie preference tool or a separate Cookie Notice.

6. Sharing, Legal Disclosures and International Transfers

We do not sell personal data or disclose it to third parties for their own unrelated advertising or marketing purposes.

We may share personal data with service providers supporting hosting, storage, communications, payments, payouts, identity verification, fraud prevention, analytics, security, customer support, accounting, legal advice and other Platform functions. Such access is limited to what is reasonably necessary for the relevant service and is subject to appropriate contractual, professional or legal obligations.

Relevant personal data and project materials may be shared with the Independent Service Performer assessing or performing a Project Request or Order. Only information reasonably necessary for the relevant project should be disclosed.

Where a User acts for a business or organisation, relevant Account, Order and communication information may be made available to other authorised representatives of that organisation where necessary to administer the relationship or verify authority.

We may disclose personal data to payment providers, payout providers, financial institutions and card issuers for transaction processing, authentication, refunds, chargebacks, reconciliation, fraud prevention, sanctions screening and legal compliance.

We may also process or disclose personal data where required by law, court order or a lawful request from a competent authority, or where reasonably necessary to investigate fraud or security incidents, enforce the Terms & Conditions or Acceptable Use Policy, protect the rights and safety of Platform participants, administer a dispute or establish, exercise or defend legal claims.

Relevant records may be preserved where a complaint, chargeback, investigation, regulatory request or legal proceeding is active or reasonably anticipated. Any disclosure will be limited, where practicable, to information necessary for the relevant purpose.

Personal data may also be disclosed in connection with a merger, acquisition, financing, restructuring, sale of assets or similar corporate transaction, subject to appropriate confidentiality and data protection safeguards.

Where personal data is transferred outside the United Kingdom or, where applicable, the European Economic Area, we use a lawful transfer mechanism, which may include an applicable adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or another recognised safeguard.

Where required, additional contractual, technical or organisational measures may be applied having regard to the destination country and the risks associated with the transfer.

7. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, taking account of the nature of the information, the status of the relevant Account or Order, legal recordkeeping requirements, applicable limitation periods and the need to prevent fraud or resolve disputes.

Account and contact information is ordinarily retained while the Account remains active and afterwards where necessary to complete outstanding Orders, administer payments or payouts, respond to complaints, prevent misuse or comply with legal obligations.

Project Requests, project communications, uploaded materials and working files may ordinarily be retained for up to twelve months after completion or cancellation of the relevant project. A longer period may apply where necessary for a complaint, chargeback, fraud investigation, intellectual property claim, contractual dispute or legal proceeding.

Payment, payout, invoice, accounting, tax and digital-platform reporting records may be retained for the periods required by applicable law. Security, verification, fraud-prevention and complaint records may be retained for as long as reasonably necessary for the relevant risk, investigation or dispute.

The Platform is not a permanent file-storage or backup service. Users should download and retain Deliverables and project records they require.

When personal data is no longer required, it will be securely deleted, anonymised or otherwise disposed of. Information may remain temporarily in backups until it is overwritten or deleted through the ordinary backup cycle.

8. Your Data Protection Rights and Complaints

Subject to applicable law and relevant exemptions, you may have the right to request access to your personal data, correction of inaccurate or incomplete data, deletion, restriction of processing and data portability. You may also object to processing based on legitimate interests and withdraw consent where processing is based on consent.

You may also have rights relating to solely automated decisions that produce legal or similarly significant effects. The Company does not intend to make such decisions without the safeguards required by law.

Requests should be submitted to the support address associated with the relevant Website:

• Swansta: support@swansta.com
• Starwn: support@starwn.com

The request should identify the relevant Account or interaction and clearly describe the right or personal data concerned. We may request information reasonably necessary to verify your identity or authority to act for another person.

We will respond without undue delay and within the applicable statutory timeframe. A request may be limited or refused where an exemption applies, continued processing is legally required, disclosure would adversely affect another person's rights or the request is manifestly unfounded or excessive.

You may also submit a privacy complaint through the applicable support address. We will acknowledge, investigate and respond to the complaint in accordance with applicable data protection requirements.

If you remain dissatisfied, you may complain to the Information Commissioner's Office in the United Kingdom or another competent supervisory authority where applicable.

9. Use by Minors

The Platform is intended only for individuals who are at least eighteen years old and have reached the applicable age of majority.

We do not knowingly create Accounts for or intentionally collect personal data directly from persons under eighteen.

If we become aware that personal data has been collected from a minor without an appropriate legal basis, we may restrict the relevant Account and take reasonable steps to delete the information. Certain records may be retained where required by law or necessary to investigate fraud, resolve a payment issue or protect legal rights.

A parent, legal guardian or authorised representative who believes that a minor has provided personal data through the Platform may contact the support address associated with the relevant Website.

10. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in the Platform, our processing activities, service providers or applicable legal requirements.

The current version and its revision date will be published on both Websites.

Where a change materially affects how personal data is collected, used or disclosed, we will provide additional notice where required or appropriate through the Website, Account, email or another suitable method.

Where a new processing activity requires consent, consent will be requested separately. Continued use of the Platform will not be treated as consent where a specific affirmative choice is required.

Contact Information

The data controller responsible for the processing described in this Privacy Policy is:

SWANSTAR ENTERPRISES LIMITED Company number: 16864192 Registered office: International House, 50 Essex Street, London, England, WC2R 3JF Website: https://starwn.com Privacy and support enquiries: support@starwn.com Telephone: +447330152787

Privacy requests should ordinarily be submitted through the support address associated with the Website through which the relevant Account, Order or interaction occurred.