Privacy Policy

1. Who operates this site

This website (“Starshell”, “we”, “us”, “our”) is an independent information and comparison resource for online casino offers. It is operated by [COMPANY_NAME], a company registered in [JURISDICTION] at [ADDRESS]. Starshell is the data controller for the limited personal data described in this policy.

Starshell is not a gambling operator. We do not run games, hold player funds, accept wagers or issue bonuses. We publish information about offers run by third-party operators and, where you choose to follow a link, we may direct you to them. Their handling of your data is governed by their own privacy policies, not this one.

2. Scope of this policy

This policy explains what personal data we collect when you visit starshell.ink (“the Site”), why we collect it, the legal bases we rely on, who we share it with, and the rights you have. It covers the Site only. It does not cover the operators we link to, nor any third-party site you reach by clicking an offer.

Starshell is a purely static, front-end website. There is no user account system, no login, and no server-side database of visitors. The categories of data below are the complete set we handle.

3. What data we collect

a. Analytics and technical data

If analytics is enabled, we (and our analytics provider, [ANALYTICS_PROVIDER]) collect aggregated, mostly non-identifying information about how the Site is used: pages viewed, approximate region derived from your IP address, referring page, device type, browser and operating system, and interaction events such as which offer cards or filters were used. Where our analytics configuration processes your IP address or sets a persistent identifier, that data can be personal data under the GDPR and is treated as such.

b. Cookies and similar technologies

We use a small number of cookies and equivalent browser storage. These are described in section 5, together with the identifiers attached to affiliate clicks.

c. Reviews you submit — stored on your own device

When you write a rating or review for an offer, that content is saved only in your own browser, using your browser’s local storage (under a key of the form reviews:{offer}). It is not sent to Starshell, not stored on any server, and not visible to other visitors. It stays on the device and browser you used, and you can remove it at any time by clearing your browser’s site data. Because we never receive this content, we cannot retrieve, moderate or delete it on your behalf.

d. Data we do not collect

We do not ask for or knowingly collect your name, email address, postal address, phone number, payment details or any special category data through the Site. If you email us directly, we receive whatever you choose to put in that message (see section 12).

4. Why we process it (legal bases)

Under the UK GDPR and the EU GDPR we rely on the following legal bases:

• Consent (Art. 6(1)(a)) — for analytics cookies, affiliate-tracking identifiers and any non-essential storage. Where consent is required, we ask for it through our cookie banner before setting these, and you may withdraw it at any time.
• Legitimate interests (Art. 6(1)(f)) — for strictly necessary technical operation of the Site, protecting it from abuse, and understanding aggregate usage where local law permits this without consent. We balance these interests against your rights and only rely on them where they do not override you.
• Compliance with a legal obligation(Art. 6(1)(c)) — where we must retain or disclose data to meet a legal or regulatory requirement.

Reviews you write are saved locally by your browser at your own initiative and are never transmitted to us, so no processing by Starshell — and therefore no legal basis on our part — arises for that content.

5. Cookies, tracking & affiliate clicks

A cookie is a small file stored by your browser. We use, or may use, the following categories:

• Strictly necessary — remember your cookie choices and keep the Site working. These do not require consent and cannot be switched off through the banner.
• Analytics — set by [ANALYTICS_PROVIDER] to measure aggregate traffic and usage, as described in section 3(a). Set only with your consent where required.
• Affiliate / referral tracking — see below.

Affiliate clicks and partner identifiers

Starshell earns commission when a visitor follows an offer link and signs up or deposits with an operator. To make that attribution work, a link you click may carry a partner or affiliate identifier (for example a campaign tag, click ID or tracking parameter) in its URL, and the operator or an affiliate network may set its own cookie on the destination site to record that you arrived from Starshell. These identifiers tell the operator which affiliate referred the visit; they are not used by us to build a profile of you by name.

Once you leave the Site by following an offer link, you are on the operator’s or network’s property and their privacy policy and cookie practices apply. We have no control over, and take no responsibility for, the data they collect after the click.

You can control cookies through your browser settings and, where offered, through our cookie banner. Blocking analytics or affiliate cookies does not stop you reading the Site or following an offer; it may mean a referral is not attributed to us.

6. Third-party services

We rely on a small number of third parties to run the Site. Each acts either as our processor or as an independent controller for the data it receives:

• Hosting / content delivery — [HOSTING_PROVIDER], which serves the static Site and may log request metadata such as IP addresses for security and delivery.
• Analytics — [ANALYTICS_PROVIDER], as described above.
• Affiliate networks and operators — [AFFILIATE_NETWORKS], which receive the referral identifier when you click an offer and process your data under their own policies.

We do not sell your personal data. We share it only as described here or where required by law.

7. How long we keep data

• Analytics data — retained by our analytics provider for no longer than [ANALYTICS_RETENTION], then aggregated or deleted.
• Cookies — kept for the lifetime stated in each cookie, up to a maximum of [COOKIE_MAX_LIFETIME], or until you clear them.
• Reviews stored on your device — kept by your browser until you clear its storage. We hold no copy and set no retention period, because we never receive them.
• Emails you send us — kept for as long as needed to handle your request and to meet any legal obligation, then deleted.

8. Your rights under the GDPR

If you are in the UK, EEA or a jurisdiction with comparable law, you have the right to:

• Access — obtain confirmation of, and a copy of, the personal data we hold about you.
• Rectification — have inaccurate or incomplete data corrected.
• Erasure — ask us to delete your data (“the right to be forgotten”) where no overriding basis to keep it applies.
• Restriction — ask us to limit how we use your data while a query is resolved.
• Objection — object to processing based on our legitimate interests, including any profiling.
• Portability — receive the data you provided in a structured, commonly used, machine-readable format, and have it transmitted to another controller where technically feasible.
• Withdraw consent — at any time, without affecting processing carried out before you withdrew it.

To exercise any of these, contact us using the details in section 12. You also have the right to lodge a complaint with your local supervisory authority (for example, [SUPERVISORY_AUTHORITY]).

Note that reviews you saved through the Site live only in your browser; you exercise control over them directly by editing or clearing your browser’s storage for this Site — we cannot do it for you because we never hold that data.

9. International data transfers

Our hosting, analytics and affiliate partners may process data in countries outside your own, including outside the UK and EEA. Where data is transferred to such a country, we rely on an appropriate safeguard recognised under the GDPR — for example an adequacy decision, or the UK International Data Transfer Agreement / EU Standard Contractual Clauses with [TRANSFER_SAFEGUARD]. You can request more detail using the contact below.

10. Minors — 18+ only

The Site concerns gambling-related offers and is strictly for adults. It is intended only for persons who are at least 18 years old (or the legal gambling age in their jurisdiction, which may be higher). We do not knowingly collect data from anyone under that age or direct any content at them. If you believe a minor has provided us with data, contact us and we will delete it.

11. Changes to this policy

We may update this policy to reflect changes in our practices, our partners or the law. When we do, we revise the “Last updated” date at the top. Material changes will be signalled more prominently on the Site. Your continued use after an update means you have read the current version.

12. How to contact us

For any privacy question or to exercise a right, contact us at [CONTACT_EMAIL], or by post to [COMPANY_NAME], [ADDRESS]. Where we have appointed one, our data protection contact is [DPO_CONTACT].