Privacy Policy

In our Privacy Policy, we provide you with an overview of how we process your personal data when you use our services or visit our websites, in accordance with our information requirements and in accordance with the General Data Protection Regulation. The Privacy Policy applies regardless of whether you are a registered user, using our app (“Starpics”) or are visiting our websites.

1. Data Controller & Data Protection Officer

The data controller responsible for the processing of your personal data when using our services is: 6, Teheran-ro 79-gil, Gangnam-gu, Seoul, Republic of Korea CEO: MinChang, Jung Data protection officer:

2. What is personal data?

"Personal data" is: "... any information relating to an identified or identifiable natural person (hereinafter the "data subject"); a natural person is considered as being identifiable, directly or indirectly, in particular by means of an identifier such as a name, an identification number, location data, an online identifier or one or more special characteristics expressing the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person."

3. The purposes for which we process your personal data

We collect and process your personal data for the purpose of providing you with our services and their advanced features, continuously improving and developing them, ensuring their technical functionality and ensuring the security of our services.

4. What personal information we collect from you and how we use it

4.1 Data you submit to us

  (a) When you register as a user
    You are a “stargrapher” if you want to share your content with us within the community. or if you also want to offer it for licensing. To set up a stargrapher account, we need:
Your email address
Your username chosen by you or generated automatically by us (@username), which also corresponds to your user ID and which will be linked to your email address
A password to protect your user account
If you register with us via a social network like Facebook, Inc. or Google, Inc., we do not collect your data directly from you, but from a third party – namely the respective social network.

We use this data:

To create your user account as a stargrapher also determine your identity, because we need to know who the licensor is in case of a license sale.
To contact you in case of required releases.
To contact you in the event of alleged copyright infringement and to clarify any other issues with your content.
To inform you about any license sale (e.g. via e-mail).
To pay your license share to you.
If necessary, to ask you if you would like to carry out service orders for us.
According to your account settings, you can receive notifications via the app (push notifications) and/or via email, e.g. community updates, promotions, mentions, etc. If you do not want to receive such notifications, you can unsubscribe from them at any time in the settings of the app or via the unsubscribe link in the email.
To send our newsletter or community updates, if you have given your consent (see below).
Storage time: In principle, we only store this data until the deletion of your user account. If you have sold a license to your content, your data will also be archived for the duration of the statutory retention periods (tax-related, e.g. 10 years).

(b) When you provide additional, voluntary information in your profile
If you have a Account, you can voluntarily provide additional profile information in your profile to make it more meaningful.
For example, you can:
Change the username.
Specify a name for your profile.
Upload a picture of you as profile picture.
Provide further information about you in your profile.
We use this data to make it visible in your profile to other users.

(c) When you upload content
When you have registered as a stargrapher, you can upload content to Starpics via our website or app.
When you would like to upload content to Starpics via the app, you must first give Starpics access to your media library (i.e. Camera Roll or Photo Albums) on your mobile device. With this permission, we will display the folders and photos available in your media library from which you can select photos and upload them to your profile. In addition, the "Suggestions" tab within the upload process will show you the photos that you have either already liked in your media library (“Favorites”) or edited in other photo related apps (e.g. VSCO, Snapseed, Lightroom, Instagram, Flickr, etc.) and that also have a minimum size of 4 million pixels.
With this function we want to make it possible for you to quickly find and upload suitable photos for the Starpics from the abundance of content in your media library. This pre-selection takes place automatically and exclusively on your mobile device. Beyond the purpose of a preselection of your photos, we do not process or store your photos or any other data that may be contained in your photos or media library before you select a photo and start to upload it. You can revoke your consent to access your media library at any time in the privacy settings of your mobile device. Without this consent you cannot upload pictures to the app, but you can still use other functions of the app (e.g. discover pictures of selected photographers, read articles in the Starpics magazine).
When you upload content, we also process the information contained in the metadata of such content (so- called exif data), such as the date, time and location of the shot, camera type, shutter speed, etc., as well as any additional information you provide about the content (e.g. tags, captions). We only collect and process information about the location of the photograph or recording if this information is already included in the metadata, if this information is derived from the content (e.g. for sights, landmarks) or if you add the location yourself when uploading.
We use this data to provide our services, in particular to optimize the quality and sales opportunities of your content.

(d) When you contact our support team
When you contact our support team, we will save your email address and any other information that you provide in the context of your request.
The data will be stored and used exclusively for the processing of your respective request and any subsequent correspondence.

(e) When you contact us for business purposes
When you send us inquiries via our contact form or via email, we will save:
Your email address
All other information provided by you voluntarily.
We use this data to answer your inquiries and to contact you regarding possible cooperations or information of events.

(f) When you provide us with a model or property release
When you provide us with a model or property release for the release of photographs or recordings of you, your private rooms, your works or other property rights to which you are entitled, we will store the personal data as stated in the respective release form, namely:
Your name
Your address
Your email address
Where applicable, your date of birth (model release), and
Where applicable, the location or description of your property (property release).
Providing this information is necessary in order to prove to third parties that you agree that the content depicting you or your property can be used commercially.
We only disclose the information to our distribution partners (by sending them the entire release document) and, if necessary, to the specific licensee.

4.2 Data that we automatically collect when you visit our website(s) and use our app

(a) Log data
Log data is data that is automatically recorded when you visit our website(s) or use our app. Specifically, this is the following data:
IP address,
Type of Internet browser used,
Name of your Internet Service Provider (ISP),
Device data,
Start and end page you visited, and
Other activities within the app or on our website (so-called “events”), etc.
We use this data solely for troubleshooting and quality-assurance purposes, for statistical and analytical purposes, and for monitoring system security.

(b) Location data
When you share your location data in your device settings, we process that data to suggest locations for tagging your content and to display nearby recorded content in our discover feed.

(c) Cookies and similar technologies
For our service to work properly, we sometimes store small files – called cookies – on your device. This is common on most major websites.

(i) What are cookies?
A cookie is a small text file that leaves a web portal on your device (computer, tablet or smartphone) when you visit it. This allows the portal to “remember” certain inputs and settings (e.g., login, language, font size, and other display preferences) over a period of time, and you do not need to re-enter them each time you visit and navigate the portal.

(ii) How can you exercise control over cookies?
You can control and/or delete cookies at your convenience. You can find out how to do this in the help function of the browser you are using or, for example, here: You can delete all cookies stored on your device and set most browsers to prevent the storage of cookies, but then you may be required to make some settings manually each time you visit a page and accept the impairment of some features.

(iii) Starpics cookies
On our website we use the following cookies:

Strictly necessary cookies: These cookies are necessary for our website and services to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies store your session ID so that our servers can recognize you, but do not store any personally identifiable information. The use of necessary cookies is justified on grounds of legitimate interest in a needs-based design and statistical evaluation of our platform
With your explicit consent (in the cookies banner displayed on our website) we use the following cookies:
Performance cookies: These cookies allow us to count visits and traffic sources so we can measure, analyze and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
Targeting cookies: These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Functional cookies: These cookies enable the website to provide enhanced functionality and personalisation of our website and services, such as the language you selected. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
The cookies are not used for any purposes other than those mentioned above. After having given your consent you can opt-out of each cookie category (except strictly necessary cookies) in the “cookie settings” of your account. The cookie customization settings are provided by the service provider OneTrust.

(iv) Cookies and similar third-party technologies
In addition to our own cookies, we also use third-party cookies and similar technologies (such as counting pixels) to provide our services, including troubleshooting, quality assurance, system-security monitoring, statistics and analytics, and a user-friendly design of our offerings (e.g. location-based photo contests), to measure efficiency and for optimization of advertisements we provide with other providers. As the providers and other technologies used may change, you should periodically review our Privacy Policy for updates.

Provision of our services

- Google Analytics
On our website we use Google Analytics, a web analytics service provided by Google Inc. Google Analytics uses cookies which are text files placed on your computer to help analyze how users use our website(s). The information generated by the cookies is regularly transmitted to a Google server in the US and stored there. However, since IP anonymization is enabled on our website, Google will abbreviate the IP address of users within the EU Member States or within other parties to the Agreement on the European Economic Area prior to transmission to Google. Only in exceptional cases the full IP address will be sent to a Google server in the US and abbreviated there. Google processes this information on our behalf to analyze the use of the website by the user, to provide reports on the activities on the website and to provide other services in connection with the use of the website for Starpics. As part of the services provided by Google Analytics, the IP address transmitted by the user's browser will not be merged with other data collected by Google.

4.3 Data that we receive from third parties
When you register with us through Facebook, Inc. or Google, Inc., we will receive the authentication information required for your registration, i.e.:

Your full name
Your email address
Your user ID, and
All data that you have specified in your public profile.
We use all of this information only to the same extent as the data that you provide when registering through our app or website.

5. Whom do we share your personal data with?
We will only disclose your personal information to third parties (including processors, i.e. third parties who process data for us on our behalf) if the transfer is necessary to fulfill our contractual obligations to you, if we are otherwise legally entitled or obliged to disclose it, or if you have given us consent to do so. In order to provide our services, selected personal information may be shared with certain departments within our company. This includes employees from the accounting, legal, product management, marketing and IT departments. In certain cases, we also use external service providers who are commissioned by us to process data for us in accordance with instructions.

5.1 Other users
Other users of our services, whether registered or not, or those accessing the content uploaded to Starpics through a so-called API (Application Programming Interface), may be shown any information displayed on your public Starpics profile (not your email address).

5.2 Distributors and licensees
We will pass your names and/or usernames for the purpose of naming and identifying the copyright owner, to all who acquire use licenses for your content as well as our partners who market your content abroad. At the latest at their request, they also receive model releases and property releases for the purpose of proving the consent of the persons depicted or the persons entitled to the objects depicted. You agree with this transfer of data if you send us the respective model release or property release.

5.3 Service providers
We also share your information with companies whose services we use to provide our services and manage our business affairs. In particular, the following services are provided to us by contractors we use: Payment services, hosting services, newsletter delivery, maintenance and support, web/app analysis, fraud monitoring and prevention, marketing services, CRM services, customer service management services, geodata transformation into actual locations, etc. Such service providers will be contractually obliged by us to process your data in accordance with the strict guidelines of the GDPR and may not use your data for any other purpose.

5.4 Government agencies, authorities & courts, legal representatives
Insofar as we are legally obliged to do so or this is permitted under data protection law, we transmit personal data to authorities such as the police or the public prosecutor's office. This data is disclosed on the basis of our legitimate interest in combating misuse, prosecuting criminal offences and securing, asserting and enforcing claims, provided that your rights and interests in the protection of your personal data do not predominate.

5.5 Legal successor
We may disclose and transfer data collected, processed and stored under this Privacy Policy in the course of a sale, merger or change of control. As part of a due diligence, we will only disclose and transfer anonymous data in a virtual space without any personal reference. In the event of legal succession, the acquiring company has the right to use your data in accordance with this Privacy Policy in order to fulfil its legal obligations as legal successor.

6. Your control options & rights
In addition to the ability to exercise control over your personal information and other data by changing your information and settings in your user account and, if necessary, creating links to third-party applications such as Facebook or Google, allowing or blocking cookies, or making do-not-track settings in your browser, you have the following legally protected rights. We offer you communications and measures in this respect in principle free of charge. However, in the case of manifestly unfounded or excessive requests, especially in the case of frequent repetition, we may levy a fee or refuse to act.

6.1 Information, correction, deletion and/or restriction
You have the right at any time to request information about what personal data we process about you and to demand correction, deletion and/or restriction of your personal data stored by us. For your security, we will ask you to verify your details in the event of such a request or change. Please send us a message at:

6.2 Revocation of your consent
If the data processing by us is based on your consent, you can revoke this consent at any time. To revoke your consent, please send us a message at:

6.2 Revocation of your consent
If the data processing by us is based on your consent, you can revoke this consent at any time. To revoke your consent, please send us a message at:

6.3 Right to data portability
If applicable, you have the right to demand that we provide you with your personal data in a structured, common and machine-readable format, provided that the data processing is based on your consent or a contract between us or is carried out by automated means. However, this does not apply if the processing is not necessary for the performance of a task in the public interest or in the exercise of official authority assigned to the data controller. Furthermore, you have the right to have the personal data transferred directly from one responsible person to another responsible person, as far as this is technically feasible and as long as the rights and freedoms of other persons are not affected.

6.4 Right to lodge a complaint with the regulatory authority
You also have the right to lodge a complaint about us with our regulatory authority.

7. What do we do for the security of your data?
We have made technical and organizational arrangements to secure the website, mobile applications and other systems against loss, destruction, access, modification or disclosure of your personal data. Access to your profile is only possible after entering a password. You should always treat access information confidentially and close the browser window as soon as the connection with Starpics is finished.

8. Changes & updates to our Privacy Policy
We have made technical and organizational arrangements to secure the website, mobile applications and other systems against loss, destruction, access, modification or disclosure of your personal data. Access to your profile is only possible after entering a password. You should always treat access information confidentially and close the browser window as soon as the connection with Starpics is finished.

We occasionally change and update our Privacy Policy to adapt it to changing requirements. If we make any material changes, we will notify you in advance by email or through our services so that you can review the changes before they come into force. In the event of other updates or changes, we will publish the amended Privacy Policy without a separate notice on our website. Accordingly, you should periodically visit our Privacy Policy to ensure that you know the current regulations. If you do not agree with the changes, you should not use our services and delete your account if you have one. If you use our services after the effective date of our amended or updated Privacy Policy, the processing of your personal data is automatically subject to our updated Privacy Policy.