Privacy Policy

1. The Data Controller

The entity responsible for processing your personal data is Marsix Technologies (“Starlork”), registered in Kumasi, Ashanti Region, Ghana. If you have questions regarding data privacy or wish to exercise your rights under Act 843, contact our Data Protection Officer at privacy@starlork.com.

2. Information We Collect

We practice strict data minimization and only collect information necessary for network routing, captive portal authorization, digital lifestyle fulfillment, regulatory KYC compliance, and account services:

• Hardware & Network Telemetry: When connecting to our Wi-Fi access points, our network gateways automatically detect your device’s physical Media Access Control (MAC) address, assigned local IP address, connection handshake timestamps, signal strength (RSSI), and cumulative data consumption (MB/GB).
• Account & Contact Profile: When you register an account or sign in via Google OAuth, we collect your verified name, email address, and phone/WhatsApp number for account authentication, SMS/email receipt delivery, and voucher recovery.
• Transaction & Billing Telemetry: When you purchase a Wi-Fi pass or Lifestyle Hub service, we receive confirmation records from our licensed payment processors (Paystack). This includes transaction reference IDs, the amount paid (GHS), payment timestamp, and payment channel. Starlork never collects, processes, or stores your Mobile Money PIN, bank account credentials, or card CVV numbers.
• Lifestyle, Utility & KYC Fulfillment Data:
  • Telecom & Utility Identifiers: Recipient phone numbers, ECG prepaid/postpaid meter numbers, GWCL water account numbers, and DStv/GOtv/StarTimes smartcard/IUC numbers required to validate and credit your utility account.
  • MTN AFA Registration KYC Data: Full Name, MTN Phone Number, Date of Birth, Location/Town, Occupation, and Ghana Card Number (GHA-XXXXXXXXX-X) strictly required by MTN community bundle onboarding rules.
  • Campus Print & Academic Studio Files: Uploaded PDFs, assignment prompts, course codes, lecturer/student cover-page metadata, and hostel delivery details submitted for printing or Claude AI formatting.
• Credit, Borrow Scoring & Self-Serve Ad Assets: Account tenure and purchase history for algorithmic Borrow Now eligibility, plus uploaded creative banners and contact links for self-serve ad campaigns.

3. How We Use Your Information

We process your personal information strictly for legitimate commercial, fulfillment, and technical purposes:

• Network & Digital Service Fulfillment: Authenticating your device on our gateways and transmitting your order parameters to the relevant fulfillment partner to complete your purchase.
• Campus Print & AI Compilation: Processing your academic prompts or uploaded files to generate formatted A4 PDFs and dispatching SMS/email status updates when your prints are ready at Evandy Main Hostel, 4th Floor, Room B123 or out for delivery.
• Voucher Recovery & AI Concierge Support: Enabling instant lookup of voucher PINs, utility tokens, gift card codes, and print queue status via our Voucher Recovery Portal and the Starlork AI Support Concierge.
• Security, AML/KYC & Fraud Prevention: Preventing unauthorized access, duplicate webhook replay, payment fraud, and complying with Bank of Ghana and Data Protection Commission standards.

4. Zero Third-Party Data Selling Pledge

5. Web Traffic Confidentiality & No DPI

We do NOT perform Deep Packet Inspection (DPI) on your encrypted web communications, nor do we log or monitor the contents of the websites you browse over encrypted HTTPS/TLS channels.

6. Third-Party Service Providers & Sub-Processors

To fulfill your orders reliably, we share only the minimum required transaction parameters with the following regulated infrastructure and fulfillment partners:

• Supabase Inc.: Encrypted cloud database infrastructure, Row-Level Security (RLS), and secure file storage for print jobs.
• Paystack Payments Limited: Bank of Ghana-licensed, PCI-DSS Level 1 compliant Mobile Money and card payment processing.
• Financial Technologies Ltd (Marsix): Regulated Ghanaian payment and utility switch used to validate meter/smartcard numbers and fulfill airtime, data bundles, ECG, GWCL, DStv, GOtv, and StarTimes payments.
• Inc.: Global digital goods API partner used to issue international gift cards, gaming vouchers, and cross-border top-ups.
• AFA Registration (afaregistration.com): Specialized fulfillment partner for wholesale MTN AFA community registration.
• Anthropic PBC (Claude API): AI language processor used exclusively when you invoke Tier 2/Tier 3 Academic Studio document polishing/generation or interact with the floating AI Support Concierge.
• Arkesel SMS & Resend: Transactional SMS and email gateways used to deliver utility tokens, gift card PINs, and print pickup alerts.

7. Your Rights Under Ghana Data Protection Act, 2012 (Act 843)

Under Act 843, you possess the right to request access to your personal data, rectify inaccurate profile details, object to non-essential processing, and request erasure of your account (subject to mandatory financial and statutory retention requirements). To exercise these rights, email privacy@starlork.com. We respond to all verified requests within twenty-one (21) business days.

8. Data Retention & Statutory 6-Year Record Keeping

• Financial, Utility & KYC Transaction Records (6-Year Statutory Retention): In compliance with the Payment Systems and Services Act, 2019 (Act 987) and Ghanaian financial/anti-money-laundering regulations, transaction ledgers, utility payment logs, and AFA KYC records are securely retained for a minimum statutory period of six (6) years from the date of the transaction.
• Campus Print Documents: Uploaded and AI-compiled academic PDFs are retained solely to complete physical printing and allow student re-downloads from the dashboard, and may be purged upon student request after job completion.
• Temporary Network Handshake Logs: Router connection and DHCP leasing telemetry are automatically rotated and purged after 90 days.

9. Contacting the Data Protection Officer