Privacy Policy for A2P Compliance

Effective Date: 11/1/24

Starpower Network LLC (referred to as “we,” “us,” or “our”) is committed to protecting the privacy of individuals who communicate with us via our application-to-person (A2P) messaging services. This Privacy Policy outlines our practices for collecting, using, maintaining, and disclosing information obtained through our A2P messaging services in compliance with applicable privacy and data protection regulations.

### 1. Information We Collect

We may collect personal information when you interact with us through our A2P messaging services. The types of information we collect include:

- Contact Information: such as phone numbers, names, and email addresses, necessary to send you relevant messages.

- Message Data: including the content, date, and time of messages sent to or received from you.

- Device Information: information about the device you use to receive our A2P messages, including device type, operating system, and mobile carrier information.

- Usage Data: information related to your interaction with our messaging services, such as engagement rates and opt-in/opt-out preferences.

### 2. How We Use Your Information

We may use the information we collect through our A2P messaging services to:

- Provide and deliver our messaging services;

- Personalize and improve communications with you;

- Respond to your inquiries and provide customer support;

- Send promotional messages, updates, or other information relevant to our services, subject to your consent and opt-in preferences;

- Comply with legal obligations and enforce our terms and conditions.

### 3. Legal Basis for Processing

We process your personal information for A2P messaging on the following legal bases:

- Consent: We rely on your consent for processing certain data, particularly for sending marketing messages.

- Legitimate Interests: Processing is necessary for the purpose of our legitimate interests in delivering and improving our messaging services, provided that such interests are not overridden by your rights and interests.

### 4. How We Share Your Information

We may share your information with:

- Service Providers: We work with trusted third-party service providers to help deliver our messaging services, and these providers are obligated to maintain the confidentiality and security of your data.

- Legal Requirements: We may disclose your information to comply with applicable laws, regulations, legal processes, or enforceable governmental requests.

- Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred to the acquiring entity.

### 5. Data Security

We implement appropriate technical and organizational measures to protect the security, confidentiality, and integrity of your personal information. However, please note that no electronic transmission or storage system can be guaranteed to be 100% secure.

### 6. Data Retention

We retain your personal information only as long as necessary to fulfill the purposes outlined in this policy or as required by applicable laws and regulations.

### 7. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

- Access: Request access to the information we hold about you.

- Correction: Request corrections to your personal data.

- Deletion: Request the deletion of your personal information under certain circumstances.

- Opt-Out: You may opt out of receiving A2P messages by following the instructions provided in the message or contacting us directly.

### 8. Children’s Privacy

Our services are not intended for use by individuals under the age of 13, and we do not knowingly collect or solicit personal information from children.

### 9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will post the updated policy on our website and encourage you to review it periodically.

### 10. Contact Us

If you have any questions or concerns about this Privacy Policy or our A2P messaging practices, please contact us:

Starpower Network LLC

Email: sales@starpower.network

Phone: 808-515-2444

Address: 8 The Green Street 4000 Dover DE 19901

By using our A2P messaging services, you acknowledge and agree to the terms of this Privacy Policy.