Privacy Policy

1. Controller

StarApps BV, Dok-Noord 4D 101, 9000 Gent, Belgium, company number 0758.840.403, is the controller for personal data processed about Track.app account holders. Contact us at administration@starapps.com. Where you upload data about third parties into your workspace, you act as controller and we act as processor on your instructions.

2. Data we process

• Account data: name, email address, authentication identifiers, workspace role.
• Workspace content you submit: entities, holdings, valuations, transactions, liabilities, contacts, documents and forwarded or uploaded emails and attachments.
• Usage data: page views, sign-in events, device and browser information, IP address and technical logs.
• Support correspondence you send us.

3. Purposes and legal bases

• Providing the Service and your workspace — performance of a contract (Art. 6(1)(b) GDPR).
• Security, abuse prevention, service improvement and aggregated statistics — legitimate interests (Art. 6(1)(f)).
• Invoicing, accounting and legal retention — legal obligation (Art. 6(1)(c)).
• Optional communications where required — consent (Art. 6(1)(a)).

4. Automated processing and AI

Content you email or upload may be analysed by AI models to extract suggested records (for example investments, valuations or KPIs). These suggestions are always presented for your review and approval; no legally or financially binding decision is taken automatically without human review.

5. Recipients and processors

We share data only with service providers acting on our behalf under data processing agreements: cloud hosting and database providers, email delivery and inbound email processing, AI model providers, mapping and address verification services, and company data providers. We do not sell personal data.

6. International transfers

Some providers may process data outside the European Economic Area. Where that happens, transfers are covered by an adequacy decision or the European Commission’s Standard Contractual Clauses with appropriate supplementary measures.

7. Retention

Workspace content is retained while your account is active and deleted within 30 days of workspace deletion, except where longer retention is required by law (for example invoicing records, kept for seven years). Technical logs are kept for a limited period for security purposes.

8. Security

We apply technical and organisational measures appropriate to the risk, including encryption in transit, access controls with per-workspace isolation and role-based permissions, and audit logging of changes. No system can be guaranteed fully secure.

9. Your rights

You have the right to access, rectification, erasure, restriction, data portability, and objection to processing based on legitimate interests, and the right to withdraw consent at any time. Write to administration@starapps.com and we will respond within one month. You may also lodge a complaint with the Belgian Data Protection Authority (Gegevensbeschermingsautoriteit), Drukpersstraat 35, 1000 Brussels.

10. Cookies

We use strictly necessary cookies and local storage to keep you signed in and to remember display preferences. We do not use advertising or third-party tracking cookies.

11. Changes

We may update this policy. Material changes will be communicated by email or in the app before they take effect.