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Privacy Policy

This privacy policy ("Privacy Policy") explains how your personal information is collected, used, and disclosed by Individual Entrepreneur (FOP) Feliks Chesnokov, registered in Ukraine ("Starlie," "we," "us," or "our"). This Privacy Policy applies to users of the Starlie mobile application on mobile phones or tablets, and to any and all data or information related to or derived from your personal interaction with us. The mobile application is referred to as the "Products" in this document.

For this Privacy Policy, the following definitions apply:

  • "Personal Information" means information that allows someone to identify or contact you, including, for example, your name and email address.
  • "Anonymous Information" means data that is not associated with or linked to your Personal Information. Anonymous Information does not, by itself, permit the identification of individual persons.

Capitalized terms used in this Privacy Policy but not defined here have the meanings given to them in the Starlie Terms of Use (the "Terms of Use").

Use of Our Services

By registering with us or using our Products, you acknowledge that you have read and understand this Privacy Policy. We process personal information for the purposes described in this Privacy Policy and only as permitted by applicable law.

Data Controller

The controller responsible for your personal information is Individual Entrepreneur (FOP) Feliks Chesnokov, located at Topol 1, 11.37, Dnipro, 49000, Ukraine. You can contact us about this Privacy Policy or about your personal information by email at support.starlie@gmail.com.

Parent or Guardian as the Person Responsible for the Child's Data

The Products are designed for use by a parent or legal guardian to track and support the care of their child. When you provide information about your child, you do so as a parent or guardian who controls and is responsible for that information.

By providing a child's information, you confirm that you are the parent or legal guardian of that child, or that you have the consent of a parent or legal guardian of that child, and that you have the authority to provide that information and to give, manage, and withdraw the consents described in this Privacy Policy on the child's behalf.

We rely on you, the parent or guardian, to decide what information about your child you share with us and to keep that information accurate. You can review, change, or delete the child's information at any time through the Products or by contacting us at support.starlie@gmail.com.

Legal Bases for Processing

We only process your and your child's personal information where we have a lawful basis to do so. Under the EU General Data Protection Regulation (GDPR), Article 6, the bases we rely on are:

  • Performance of a contract (Art. 6(1)(b)): to create and manage your Account, to provide the Products and their core tracking features, to process your purchases, and to provide customer support.
  • Consent (Art. 6(1)(a)): to process delicate (health-adjacent) information about your child as described below, to process photos and attachments you choose to add, to use the Starlie AI assistant features that process such information, and to send you promotional messages. You can withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
  • Legitimate interests (Art. 6(1)(f)): to secure your Account and our Products, to prevent fraud and abuse, to understand and improve how the Products are used, and to create and use Anonymous Information. Where we rely on legitimate interests, we balance them against your rights and interests.
  • Compliance with a legal obligation (Art. 6(1)(c)): to meet our legal, tax, and regulatory obligations, and to respond to lawful requests from authorities.

For users in Ukraine, we process personal data on one of the grounds set out in Article 11 of the Law of Ukraine "On Personal Data Protection" (No. 2297-VI), which provides an equivalent set of grounds, including the data subject's consent, the performance of a contract to which the data subject is a party, and the legitimate interests of the controller.

Explicit Consent for Delicate (Health-Adjacent) Child Data

Some of the information you may record about your child is delicate in nature, including information about sleep, feeding (including allergens introduced and any reactions), diapers and bathroom habits, growth measurements, and any photos or attachments. Such information may reveal information relating to health and is treated as a special category of data under GDPR Article 9 and as "delicate data" under Article 7 of the Law of Ukraine No. 2297-VI.

We process this delicate information only on the basis of your explicit consent (GDPR Art. 9(2)(a) and the equivalent provisions of applicable law). You give this explicit consent when you accept this Privacy Policy and create an Account, and each time you choose to enter such information into the Products. You may withdraw your consent at any time by deleting the relevant information, by deleting your Account in the app, or by contacting us at support.starlie@gmail.com; withdrawal does not affect the lawfulness of processing before withdrawal. If you withdraw your consent, we will stop processing the corresponding delicate information, and the features that depend on it may be unavailable.

AI Features and Our AI Provider (Anthropic)

The Starlie AI assistant and the personalized "tip of the day" feature are powered by large language models provided by Anthropic, PBC, a U.S. company ("Anthropic"), acting as our data processor (sub-processor).

When you use these AI features, we transmit the following categories of information to Anthropic's API for processing on our behalf: your child's first name, age, and gender; aggregated tracking data for approximately the preceding 7–14 days (sleep, feeding, pumping, diapers, walks, growth measurements, and solids/allergen journal entries, including recorded reactions); the text of your diary entries for approximately the preceding 3 days; and the messages you send to the AI assistant. We do not transmit your photos or attachments to Anthropic.

This processing is based on your explicit consent (GDPR Art. 6(1)(a) and Art. 9(2)(a), the equivalent provisions of the UK GDPR, and the Law of Ukraine No. 2297-VI), which you give when you accept this Privacy Policy and create an Account. You may withdraw this consent at any time by contacting us at support.starlie@gmail.com or by deleting your Account; if you withdraw consent, the AI features will no longer be available to you.

Anthropic processes this information under its commercial API terms, under which Anthropic may use the data solely to provide the API services to us and does not use data submitted through its commercial API to train its models. Anthropic may process the data on servers located in the United States. For transfers from the EU/EEA and the UK, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses (with the UK Addendum, as applicable) and/or Anthropic's participation in applicable data-transfer frameworks. For transfers governed by Ukrainian law, we rely on your unambiguous consent and the mechanisms permitted under Article 29 of Law No. 2297-VI.

Product Analytics (PostHog)

To understand how the Products are used and to improve them, we use the analytics service PostHog, provided by PostHog, Inc. ("PostHog"), acting as our data processor under a data-processing agreement. We use PostHog's EU Cloud, and the analytics data is hosted in the European Union (Frankfurt, Germany).

The information processed for analytics is limited to: usage events (for example, which screens you view, which buttons you tap, and which features you use, such as adding a tracking entry or opening an article); technical information about your device (device model, operating system and version, app version, screen size, language, and your IP address, which is used to derive an approximate, city-level location); and an internal numeric account identifier that allows us to count unique users and understand usage across sessions.

We do not send to PostHog: your name or email address; your child's name, birthdate, or the content of any tracking records; the content of your diary entries; the content of your messages to the AI assistant; or your photos and attachments. Analytics events describe actions (for example, "a sleep entry was created"), never the recorded content, and no special categories of data are processed for analytics.

We process this information on the basis of our legitimate interests (GDPR Art. 6(1)(f)) in understanding and improving how the Products are used, and, for users in Ukraine, on the equivalent grounds under the Law of Ukraine No. 2297-VI. PostHog may process this information only to provide the analytics service to us and may not use it for its own purposes.

International Transfers of Personal Information

Your personal information may be transferred to, stored in, or processed in Ukraine and in other countries where we or our service providers operate. The hosting and processing locations are: Amazon Web Services — EU (Stockholm, Sweden) for storage of your Account data, tracking data, diary entries, and photos; the European Union (Frankfurt, Germany), where our analytics provider (PostHog, Inc.) hosts the usage analytics data described in the section "Product Analytics (PostHog)"; and the United States, where our AI provider (Anthropic, PBC) processes the data described in the section "AI Features and Our AI Provider (Anthropic)". These countries may have privacy laws that differ from those in your jurisdiction.

To provide the Products, we use third-party processors that may process personal information in their own countries or in other countries. These processors include our hosting and infrastructure provider(s), the provider of the AI features used in the Starlie AI assistant (Anthropic, PBC), and our product-analytics provider (PostHog, Inc., with data hosted in the European Union). Each processor is permitted to process the information only to provide services to us and in accordance with our instructions. The identity providers used for social login (Google, Apple, and Facebook) are independent controllers of the information they process during sign-in, under their own privacy policies.

When we transfer personal information internationally, we rely on one or more of the following mechanisms, as applicable:

  • a finding that the destination country provides an adequate level of protection (for transfers within the EU/EEA, or to a country recognized as providing adequate protection);
  • where required for transfers from the EU/EEA to a country without an adequacy decision, an appropriate safeguard, such as the European Commission's Standard Contractual Clauses; and
  • for transfers governed by the Law of Ukraine No. 2297-VI, the protection mechanisms permitted under Article 29 of that Law, which include transfers to states ensuring an adequate level of protection (the EU/EEA member states are treated as ensuring such protection) and transfers based on the unambiguous consent of the data subject.

We take steps designed to ensure that your information is handled in accordance with this Privacy Policy and with applicable legal requirements, including implementing appropriate safeguards where required.

Information That We Collect About You or Your Child

As we are an application and service that helps improve the wellness of young children (including, but not limited to, behavior, feeding, bathroom, activities, temperament, personality, and the length and quality of their sleep), we must collect some information about them. We will also collect some information about you, the child's parent or guardian, since you will be the user of the Products.

Information About You That We Collect From You

  • When you register for one of our Products, we ask you for and collect your name, email address, and password for your Account.
  • Information that we may ask for about your child, used strictly and confidentially to provide the activity-tracking and childcare services, includes:
    • Your child's name.
    • Your child's age and birthdate.
    • Your child's gender.
    • The time zone where your child resides.
    • Your child's daily activities, including but not limited to:
      • Your child's sleep patterns and how he or she falls asleep or wakes up.
      • How your child is cared for during the day.
      • Scheduling information, such as when your child eats meals, activities, when the child gets ready for bed, and when the child is first put down to sleep.
      • Your child's feeding (including breast, bottle, pumping, and solids/first foods, including allergens introduced and any reactions), diapers, growth measurements, walks, and other activities.
      • Temperament.
      • Bathroom habits.
      • Other child development and behavioral improvement markers and behaviors.
    • Information that you voluntarily provide to us about your child, including diary entries (such as thoughts, notes, achievements, and mood) and any photos or attachments you choose to add.
  • Any and all information about your child will only be used in the context of providing services through the Products and will be held in the strictest confidence.
  • If you choose to register for or sign in to one of our Products using Google, Apple, or Facebook (social login), we receive from that provider your name and email address. We use this information solely to create and identify your Account and to sign you in. We do not receive your password for the third-party service, and we receive only the information that you authorize the provider to share during the sign-in process. Your use of social login is also governed by that provider's own privacy policy; the provider acts as an independent controller of the information it processes during sign-in.
  • Specific Products may ask you for and collect additional information, such as your date of birth (to assist with customer service).
  • If you choose to add information to your user profile, we will collect that information, including any profile photo you choose to upload.
  • When you pay for one of our Products, your payment is processed by the applicable app store (such as the Apple App Store). We do not collect or store your complete credit card or other payment method information.

Information About You That Is Created When You Use Our Products

  • When you use our Products, we record certain information automatically, for example your Internet protocol ("IP") address, device type, operating system, screen size and resolution, the time and date at which you access our Products, and an estimate of your geographic location.
  • When you use our Products, we record actions you have taken in our Products, for example what buttons you click, events that occur, and your usage, progress, and performance data.

How We Get and Store Information About You

  • Our Products may use device identifiers and similar standard technologies to enable our Products to work, to keep you logged in, and to personalize your experience. We use one third-party product-analytics provider, PostHog, acting as our data processor as described in the section "Product Analytics (PostHog)". We do not use attribution or advertising SDKs, we do not use third-party advertising networks, and we do not permit any third party to collect personal information through the Products for its own purposes.
  • Our Products on mobile phones and tablets store information about you on your mobile phone or tablet.
  • Our Products store information about you on computer servers and databases managed by us and hosted by third party companies.

How We Use Information About You

  • We use your Personal Information to provide our service to you, to personalize your experience with our Products, to improve our Products, and to secure your Account.
  • We may use your Personal Information to send you transactional messages and push notifications (such as a password reset, growth-spurt predictions, reminders, or notices of material changes to our Terms of Use or this Privacy Policy) and, where permitted, promotional messages (such as a special offer).
  • We may create Anonymous Information from your Personal Information, for example by making a copy of the data collected by or created in our Products that is not linked to your Personal Information. We may use aggregated or fully anonymised information — information that can no longer be linked to you or your child by us or by anyone else — for statistics, research, and product improvement. We apply recognised anonymisation techniques before any such use.
  • We may use Anonymous Information to conduct scientific studies, and we may publish the results, for example at scientific conferences or in research journals. We do not use Personal Information in such work, nor do we disclose Personal Information in the conduct of such work.
  • The Products do not make any decision producing legal effects or similarly significantly affecting you or your child based solely on automated processing. AI-generated content is informational only and always subject to your own judgment.

How We Disclose Information About You

Except as otherwise stated in this Privacy Policy, we do not trade, rent, or share your Personal Information with third parties, unless you ask or authorize us to do so.

Situations Where We Disclose Personal Information About You With Specific Protections For You To Ensure Our Products Work And You Can Use Them Properly

We may provide your Personal Information to third party service providers who work on behalf of or with us to provide functionality to our Products, such as hosting, AI processing, and complementary childcare services. These service providers are obligated to use your Personal Information only to provide services to us and not to disclose your Personal Information (except pursuant to a legal requirement such as a subpoena or warrant).

Sharing Within Your Family Group

If you join or create a family group in the Products, the members of that family group can view and edit the child profiles and tracking data shared with the group. You should only invite people you trust to your family group. If a member leaves the family group or is removed from it, that member loses access to the group's data; however, entries that the member added while part of the group may remain in the group.

Specific Business Deals May Require Us to Share Your Personal Information

We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

Situations Where We Are Required To Disclose Your Personal Information

We may be required by law, or by law enforcement officers acting under the color of law, to record some or all of your communications on or through the Products. We may, and you hereby authorize us to, disclose your Personal Information (including your Account information) and your communications through the Products, if required by law or by law enforcement officers acting under the color of law, or if we believe in good faith that disclosure is necessary to: (a) comply with relevant laws or to respond to subpoenas or warrants served on us; (b) protect and defend the rights, property, or safety of us, our Affiliates, other users, or you; or (c) investigate any violation or potential violation of the law, this Privacy Policy, the Terms of Use, or any other agreements between you and Starlie.

Your Choices Regarding Your Personal Information

We offer you choices regarding the collection, use, and sharing of your Personal Information.

  • You can manage your notification preferences, indicating that you want or do not want to receive informational or promotional push notifications or messages (such as a special offer). As long as you maintain an Account with us, you will receive transactional messages (such as a password reset, or notices of material changes to our Terms of Use or this Privacy Policy).
  • You may change the information you submitted for your Account either in the Products or by contacting us at support.starlie@gmail.com. You may request deletion of your Personal Information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete Personal Information, it will be deleted from the active database. When we delete your Personal Information, we will retain data derived from your use of the Products as Anonymous Information that is no longer linked to your deleted Personal Information.

Data Retention

We retain your and your child's personal information for as long as your Account is active and for as long as needed to provide the Products and to fulfil the purposes described in this Privacy Policy. As a rule: account and child profile data are retained for the life of your Account and deleted within 30 days after Account deletion; server backups are purged on a rolling basis within 90 days; support correspondence is retained for up to 24 months.

When you delete your Account, or when we no longer need your personal information for the purposes for which it was collected, we delete it from our active databases or anonymise it so that it can no longer be linked to you or your child, except where we are required or permitted by applicable law to retain it for a longer period (for example, to comply with legal, tax, or regulatory obligations, or to establish, exercise, or defend legal claims). Where we are required to retain certain information for a defined period, we will fulfil a deletion request only after that period has ended. We may continue to use Anonymous Information after deletion, as described in this Privacy Policy.

Your Data Protection Rights

Subject to applicable law, you have the following rights in relation to your personal information, and (acting as the responsible parent or guardian) in relation to your child's personal information:

  • Access: to obtain confirmation of whether we process the information and to receive a copy of it;
  • Rectification: to have inaccurate or incomplete information corrected;
  • Erasure: to request deletion of the information in certain circumstances;
  • Portability: to receive certain information in a structured, commonly used, machine-readable format, and to have it transmitted to another controller where technically feasible;
  • Restriction: to request that we limit our processing of the information in certain circumstances;
  • Objection: to object to processing that is based on our legitimate interests, and to object to processing for direct-marketing purposes; and
  • Withdrawal of consent: to withdraw any consent you have given at any time, without affecting the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact us at support.starlie@gmail.com. We will respond within the time limits required by applicable law. We may need to verify your identity before acting on a request.

You also have the right to lodge a complaint with a supervisory authority. In Ukraine, the supervisory authority is the Ukrainian Parliament Commissioner for Human Rights (the Ombudsman). If you are in the European Union or the European Economic Area, you may lodge a complaint with the Data Protection Authority in your country of residence, place of work, or place of the alleged infringement.

Users in the United Kingdom (UK GDPR)

If you are in the United Kingdom, we process your and your child's personal information in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. You have the same rights as those described in the section "Your Data Protection Rights," which you can exercise by contacting us at support.starlie@gmail.com. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO); see ico.org.uk. For transfers of personal information out of the United Kingdom, we rely on the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the European Commission's Standard Contractual Clauses, or another lawful transfer mechanism.

California Residents (CCPA/CPRA)

This section applies to California residents and supplements the rest of this Privacy Policy. Under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), we collect the following categories of personal information: identifiers (such as your name, email address, and IP address); account details; characteristics (such as your child's age and gender, provided by you as the parent or guardian); usage data (such as actions taken in the Products); coarse geolocation derived from your IP address; photos you choose to upload; and sensitive personal information (health-adjacent information about your child, such as sleep, feeding, allergen, and growth records, and your diary entries).

We do not sell personal information and do not share personal information for cross-context behavioral advertising, and we have no actual knowledge of selling or sharing the personal information of consumers under 16 years of age. We use and disclose sensitive personal information only for the purposes permitted by the CCPA/CPRA, such as providing the Products you request, securing the Products, and preventing fraud.

California residents have the right to know and access the personal information we collect, to delete it, to correct inaccurate information, to receive it in a portable format, to limit the use of sensitive personal information, and not to be discriminated against for exercising these rights. To exercise these rights, contact us at support.starlie@gmail.com. We will verify your request using the email address associated with your Account. You may also use an authorized agent to submit a request on your behalf; we may require proof of the agent's authority. We honor opt-out preference signals such as the Global Privacy Control (GPC) to the extent required by applicable law.

Children's Privacy

The Products are intended for use only by adults — parents and legal guardians. Children may not create Accounts or use the Products. We do not knowingly collect personal information directly from children under 13 (or a higher age where applicable law provides for one). All information about a child in the Products is provided by the child's parent or legal guardian, who consents to its processing as described in this Privacy Policy, consistent with the Children's Online Privacy Protection Act (COPPA), under which a parent may provide such information and consent on the child's behalf. Any and all information about your child will only be used in the context of providing services through the Products and will be held in the strictest confidence. If you believe a child has provided us with personal information directly, please contact us at support.starlie@gmail.com, and we will delete such information immediately.

Third Party Products, Services, Content, and Links

Please be aware that the terms of this Privacy Policy do not apply to third party products, services, or content, or to links provided for the foregoing in our Products. Third party providers of such third party products, services, or content may collect (via tracking technologies) and use information regarding your interaction with the third party product, service, or content that they deliver and with which you interact.

Security

We protect your and your child's information using administrative, technical, and physical safeguards, including encryption of personal information at rest in our databases, storage of photos in access-controlled cloud storage, and encryption in transit (TLS) between your device and our servers. Your information is stored on servers managed by us and hosted by Amazon Web Services in the European Union (Stockholm, Sweden), except for the AI processing by Anthropic described above.

We make reasonable efforts to protect your Personal Information, but no company, including Starlie, can fully eliminate security risks connected to handling information on the Internet.

YOU ACKNOWLEDGE THAT SECURITY SAFEGUARDS, BY THEIR NATURE, ARE CAPABLE OF CIRCUMVENTION AND STARLIE DOES NOT AND CANNOT GUARANTEE THAT YOUR PERSONAL INFORMATION WILL NOT BE ACCESSED BY UNAUTHORIZED PERSONS CAPABLE OF OVERCOMING SUCH SAFEGUARDS. IN PARTICULAR, OUR PRODUCTS MAY BE USED TO ACCESS AND TRANSFER INFORMATION, INCLUDING YOUR PERSONAL INFORMATION, OVER THE INTERNET. YOU ACKNOWLEDGE AND AGREE THAT STARLIE DOES NOT OPERATE OR CONTROL THE INTERNET AND THAT UNAUTHORIZED USERS (SUCH AS HACKERS) MAY USE VIRUSES, WORMS, TROJAN HORSES, AND OTHER UNDESIRABLE DATA AND SOFTWARE TO OBTAIN ACCESS TO OR DAMAGE OUR PRODUCTS, OR YOUR PERSONAL INFORMATION.

Furthermore, we cannot be responsible for any of your Personal Information that you release on your own, or that you request or authorize us to release.

Amendment

This Privacy Policy may be amended by Starlie from time to time. If we make material changes to this Privacy Policy, we will notify you by posting the revised Privacy Policy in our Products or notifying you at your primary email address (if any, as specified in your Account information). You are responsible at all times for updating your Account to provide to us your most current email address. If the last email address that you have provided to us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the email containing such notice will nonetheless constitute effective notice of the changes described in the notice. Any changes to this Privacy Policy will be effective immediately for new users of our Products. For existing users, material changes will be effective thirty (30) calendar days following our dispatch of an email notice to you or thirty (30) calendar days following our posting of a notice in our Products, whichever occurs first; non-material changes will be effective upon the earlier of five (5) calendar days following our dispatch of an email notice to you or five (5) calendar days following our posting of a notice in our Products. Your continued use of our Products after the applicable notice period will constitute your agreement to such changes. Where a change concerns processing that is based on your consent (including your child's delicate information), we will ask for your renewed consent before the change applies to you. If you object to any change, your sole recourse shall be to immediately terminate your Account and cease using the Products. Except as otherwise provided in this Section, no amendment to this Privacy Policy will be valid.

Our Contact Information

If you have any questions about this Privacy Policy, please contact us by email at support.starlie@gmail.com or by writing to us at FOP Feliks Chesnokov, Topol 1, 11.37, Dnipro, 49000, Ukraine, in each case marking the message "Attention: Privacy Policy."

Last Updated: September 7, 2026