Privacy Policy
Last Updated: July 16, 2026
This Privacy Policy explains how GatherStar MarTech Limited (“GatherStar,” “we,” “us,” or “our”) collects, holds, processes, uses, discloses, transfers, retains, and protects personal data when you visit https://gatherstar.io/ or use products, platforms, documentation, and services that link to this Policy (collectively, the “Services”).
GatherStar MarTech Limited is the data user or controller responsible for personal data it controls in connection with the Services. We are committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and other applicable data-protection laws.
Corporate Transition and Data Responsibility
GatherStar MarTech Limited became the operator of the GatherStar brand and the associated product and research-and-development functions in July 2026. Before that transition, all prior business operations, partner contracts, and financial matters of Senior Technology Limited had been settled and concluded by April 2026.
Only the GatherStar brand and specified product and research-and-development assets were transferred in July 2026. GatherStar MarTech Limited and Senior Technology Limited are independent entities with no current corporate, ownership, management, contractual, or financial affiliation. GatherStar MarTech Limited did not acquire or assume Senior Technology Limited’s legacy business, contracts, accounts, receivables, payables, debts, liabilities, obligations, or financial matters.
This Policy applies to personal data collected or controlled by GatherStar MarTech Limited in connection with its Services. It does not make GatherStar MarTech Limited responsible for Senior Technology Limited’s historical data practices or legacy records. No legacy customer, partner, contract, financial, or personal-data database of Senior Technology Limited was transferred to GatherStar MarTech Limited as part of the limited brand and product/R&D transfer, except to the extent any specific transfer was separately authorized, lawfully notified, and required to operate the transferred product or comply with law.
1. Scope
This Policy applies to visitors, advertisers, publishers, business partners, platform users, and people who communicate with us. It does not apply to third-party websites, services, or platforms that have their own privacy policies.
2. Personal Data We Collect
Depending on how you interact with the Services, we may collect:
- Identity and contact data: name, business email, telephone number, job title, company, country, and account identifiers.
- Account and verification data: login credentials, authentication records, role and permission information, and information needed for identity, business, fraud, sanctions, or compliance checks.
- Commercial and payment data: contracts, campaign or inventory information, invoices, transaction records, payment status, tax information, and limited billing details. Payment providers may collect payment-card or bank information directly under their own policies.
- Advertising and platform data: campaign settings, creatives, publisher properties, ad requests, bid information, impressions, clicks, conversions, device or advertising identifiers, approximate location derived from IP address, and fraud or quality signals.
- Communications: messages, support requests, feedback, event registrations, and records of our correspondence.
- Device and usage data: IP address, browser type, device type, operating system, language, referring page, pages viewed, timestamps, diagnostic data, and security logs.
- Cookies and similar technologies: identifiers and preferences collected through cookies, pixels, tags, local storage, and similar tools.
- Data from third parties: information from customers, partners, service providers, public sources, fraud-prevention providers, and advertising ecosystem participants where permitted by law.
Where information is required for an account, contract, payment, security check, or legal obligation, failure to provide it may prevent us from providing the relevant Service. Other information is voluntary.
3. How We Use Personal Data
We use personal data, as permitted by applicable law, to:
- provide, operate, authenticate, maintain, and support the Services;
- create and administer accounts and business relationships;
- process advertising transactions, reporting, billing, payments, reconciliation, and support;
- measure performance, prevent invalid traffic and fraud, protect users, and secure the Services;
- respond to inquiries and communicate service, policy, security, and administrative information;
- analyze and improve functionality, reliability, usability, and product development;
- send marketing communications where permitted and subject to required consent and opt-out rights;
- enforce agreements, resolve disputes, and protect our rights and the rights of others; and
- comply with legal, regulatory, tax, accounting, sanctions, audit, and law-enforcement obligations.
Where applicable law requires a legal basis, we rely on performance of a contract, compliance with legal obligations, consent, and our or a third party’s legitimate interests, provided those interests are not overridden by your rights.
4. Cookies, Analytics, and Advertising Technologies
We use necessary cookies for security and functionality and may use analytics and measurement technologies, including Google tag technologies, to understand visits and improve the Services. Advertising services may process identifiers and event data to deliver, measure, limit, or protect advertising. Where required, we request consent before using non-essential cookies or similar technologies.
You can control cookies through available consent tools and your browser or device settings. Blocking some technologies may affect functionality. Browser “Do Not Track” signals are not handled uniformly across the industry; we respond where required by applicable law.
5. How We Disclose Personal Data
We do not sell personal data for money. We may disclose personal data to the following classes of recipients for the purposes described above:
- hosting, cloud, security, analytics, communications, support, payment, audit, and professional service providers acting under appropriate obligations;
- advertisers, publishers, exchanges, measurement providers, fraud-prevention providers, and other advertising ecosystem participants as needed to operate requested Services;
- our personnel, contractors, professional advisers, auditors, insurers, banks, and regulators;
- law-enforcement bodies, courts, government authorities, or other parties when required by law or reasonably necessary to protect rights, safety, and security;
- a proposed or completed purchaser, investor, lender, or successor in a genuine corporate financing, reorganization, merger, or transfer of the relevant business or assets, subject to appropriate safeguards; and
- other parties at your direction or with your consent.
6. Direct Marketing
Where required by the PDPO or other applicable law, we will not use personal data for direct marketing or provide it to another person for direct marketing without the required notice and consent. You may opt out at any time by using the unsubscribe link in a message or contacting us at support@gatherstar.io. Service and security messages are not marketing messages.
7. Data Retention
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including to provide Services, maintain security and records, resolve disputes, enforce agreements, and comply with legal, tax, accounting, and regulatory requirements. Retention periods vary based on the type of data, relationship, sensitivity, risk, and applicable obligations. We delete or anonymize data when it is no longer required, unless continued retention is permitted or required by law.
8. International Transfers
Our Services and service providers may process personal data in Hong Kong and other jurisdictions. These jurisdictions may have different data-protection laws. Where required, we use contractual, organizational, or other lawful safeguards for cross-border transfers and take reasonable steps to require recipients to protect the data consistently with this Policy.
9. Security
We use reasonable technical and organizational measures designed to protect personal data against unauthorized or accidental access, processing, erasure, loss, use, alteration, or disclosure. Measures may include access controls, encryption in transit, logging, monitoring, vendor controls, and incident procedures. No system or transmission method is completely secure, so we cannot guarantee absolute security.
10. Your Rights and Choices
Subject to applicable law, you may have rights to request access to and correction of your personal data and, in some jurisdictions, deletion, restriction, portability, objection, or withdrawal of consent. Withdrawing consent does not affect processing already lawfully carried out.
To make a request, contact support@gatherstar.io. Please describe your request and relationship with GatherStar. We may verify your identity and authority before responding. Under the PDPO, a reasonable fee may be charged for a data-access request where permitted by law.
11. Children
The Services are intended for businesses and are not directed to children under 18. We do not knowingly collect personal data directly from children. If you believe a child has provided personal data to us, please contact us so we can take appropriate action.
12. Third-Party Services
The Services may contain links to or integrate with third-party services. We do not control their privacy practices. Review the applicable third-party privacy policy before providing information or using those services.
13. Changes to This Policy
We may update this Policy to reflect changes in our Services, practices, or legal obligations. We will post the updated Policy and change the “Last Updated” date. We will provide additional notice where required by law.
14. Contact Us
Questions, complaints, and requests concerning this Policy or personal data may be sent to:
Data Protection Contact
GatherStar MarTech Limited
RM 701, Unit 127, 7/F, Tower B
New Mandarin Plaza, 14 Science Museum Road
Tsim Sha Tsui, Hong Kong
Email: support@gatherstar.io
Website: https://gatherstar.io/