Privacy Policy

STARCLEAN CONNECT PRIVACY POLICY Effective Date: August 26, 2026 Last Updated: August 26, 2026 StarClean Connect Services LLC (“StarClean Connect,” “StarClean,” “we,” “us,” or “our”) respects the privacy of Businesses, Cleaning Professionals, authorized representatives, website visitors, and other individuals who interact with StarClean Connect. This Privacy Policy explains how StarClean may collect, use, disclose, retain, protect, and otherwise process personal information through the StarClean Connect website, application, marketplace, and related services (collectively, the “Platform”). This Privacy Policy should be read together with the StarClean Connect Terms of Service and, where applicable, the Business Agreement, Cleaning Professional Agreement, and other Platform policies. By using the Platform, you acknowledge the practices described in this Privacy Policy. Where applicable law requires consent for particular processing, StarClean will obtain that consent separately where required. 1. WHO OPERATES STARCLEAN CONNECT StarClean Connect is owned and operated by: StarClean Connect Services LLC StarClean operates a technology marketplace designed to connect Businesses seeking commercial cleaning services with independent Cleaning Professionals seeking commercial cleaning opportunities. Unless StarClean expressly agrees otherwise in writing, StarClean does not itself perform the underlying commercial cleaning services posted through the Platform. 2. SCOPE OF THIS PRIVACY POLICY This Privacy Policy applies to personal information processed through or in connection with: • StarClean accounts; • the StarClean website and applications; • Business registration and verification; • Cleaning Professional registration and verification; • background-screening administration; • Job creation and management; • Job acceptance; • recurring Jobs; • Job communications; • facility access information; • Job documentation; • completion photographs; • payment and payout administration; • ratings and reviews; • cancellations; • disputes; • refund determinations; • property-damage claims; • customer support; • account enforcement; • safety and fraud investigations; • administrative intervention; • privacy requests; and • other StarClean Platform functionality. This Privacy Policy does not independently govern the privacy practices of third-party services operating under their own privacy policies, except to the extent applicable law makes StarClean responsible for particular processing. 3. INFORMATION WE COLLECT The information StarClean collects depends on: • whether you are a Business, Cleaning Professional, authorized representative, or other user; • which Platform features you use; • information you provide; • verification requirements; • payment or payout requirements; • Platform functionality; • security requirements; and • applicable law. StarClean does not necessarily collect every category described in this Privacy Policy from every user. 4. ACCOUNT AND PROFILE INFORMATION StarClean may collect information used to establish, maintain, secure, and administer accounts. Depending on account type, this may include: • full name; • email address; • telephone number; • date of birth where applicable; • street address where applicable; • city; • state; • ZIP code; • service area; • work radius; • account type; • profile information; • profile photograph where applicable; • account status; • verification status; • ratings; • completed-Job information; and • other information reasonably necessary to administer the account. Information requirements differ between Business accounts and Cleaning Professional accounts. 5. BUSINESS INFORMATION For Business accounts, StarClean may collect: • Business or organization name; • contact person's name; • email address; • telephone number; • industry; • Business or facility address; • authorized representative information; • account-user information; • Business verification information; • verification status and related administrative information; • payment status information; • Job history; and • other information reasonably necessary to establish or administer a legitimate Business account. StarClean may request additional information when reasonably necessary to verify Business identity, authority, eligibility, security, or facility relationships. StarClean does not currently require Business users to provide Social Security numbers or dates of birth merely to establish an ordinary Business account. 6. CLEANING PROFESSIONAL INFORMATION For Cleaning Professional accounts, StarClean may collect: • first and last name; • email address; • telephone number; • date of birth; • street address; • city; • state; • ZIP code; • service area; • work radius; • service types; • profile photograph; • profile biography; • verification status; • background-screening status; • screening-provider information; • screening case or reference identifiers; • Job activity; • ratings and reviews; • completed-Job counts; • cancellation history; • account warnings; • payout-status information; • dispute information; and • other information reasonably necessary to administer Cleaning Professional participation. Date of birth may be retained by StarClean as part of the Cleaning Professional profile and eligibility records. Cleaning Professionals must be at least 18 years old. 7. IDENTITY VERIFICATION AND BACKGROUND SCREENING StarClean may require Cleaning Professionals or other users to complete identity verification, background screening, or other eligibility checks. These processes may be conducted by third-party providers approved by StarClean. Depending on the provider and applicable requirements, the provider may request sensitive information including: • legal name; • date of birth; • government identification; • Social Security number; • address history; or • other information necessary to perform the applicable verification or screening. StarClean seeks, where reasonably practicable, to have highly sensitive screening or identity information submitted directly to the applicable provider rather than unnecessarily collected or stored by StarClean. StarClean may receive and retain information including: • verification status; • screening status; • screening-provider name; • invitation or initiation date; • result-received date; • case or reference identifier; • eligibility information; and • limited administrative notes reasonably necessary to administer screening. StarClean personnel should not place Social Security numbers, full government-identification numbers, complete criminal-history reports, or other unnecessary sensitive screening information into general administrative notes. StarClean may maintain legacy identity-document records if previously collected and legitimately retained, but such documents are not intended to be routinely collected during current Cleaning Professional onboarding unless the Platform's verification process is changed. Any legally required background-screening disclosures, notices, authorizations, or rights may be provided separately from this Privacy Policy. Businesses are not entitled merely by using StarClean to receive a Cleaning Professional's Social Security number, government identification, complete background report, bank information, or other unrelated sensitive information. 8. PAYMENT AND PAYOUT INFORMATION StarClean uses third-party payment providers, including Stripe, to facilitate Business payments and Cleaning Professional payouts. Payment providers may collect: • payment-card information; • card expiration information; • security codes; • bank-account information; • routing information; • billing information; • tax information; • identity information; • transaction information; and • other information necessary to provide payment or payout services. Full card numbers, CVV/security codes, full bank-account credentials, and similar raw payment credentials are intended to be collected and maintained by the applicable payment provider rather than stored in StarClean's ordinary Platform database. StarClean may receive and retain transaction information including: • Stripe customer identifiers; • Stripe account identifiers; • payment-intent identifiers; • checkout-session identifiers; • charge identifiers; • transfer identifiers; • payment status; • authorization status; • payment errors; • refund information; • payout status; • chargeback or payment-dispute information; • transaction amounts; • Platform Fees; • Cleaning Professional payout amounts; and • other information reasonably necessary to administer transactions. Third-party payment providers process information according to their applicable terms, privacy policies, and legal obligations. 9. JOB AND FACILITY INFORMATION Businesses may provide information concerning commercial cleaning Jobs. This may include: • facility name; • facility address; • approximate square footage; • whether the cleaning concerns the entire facility or selected areas; • room or area types; • room or area quantities; • facility type; • building type; • cleaning level; • requested tasks; • facility conditions; • scheduled date and time; • estimated duration; • recurring schedule information; • special instructions; • access requirements; • safety information; • facility restrictions; and • other information reasonably necessary to understand, price, administer, and perform the requested services. Businesses should avoid including unnecessary personal, confidential, regulated, or sensitive information in Job descriptions or instructions. 10. ADDRESS-DERIVED LOCATION INFORMATION StarClean may convert addresses provided by Businesses or Cleaning Professionals into geographic coordinates, including latitude and longitude. These coordinates may be used for: • Job-location functionality; • service-area functionality; • work-radius calculations; • marketplace matching; • market administration; • distance-related functionality; and • other legitimate Platform operations. At launch, StarClean does not intend to continuously track users through precise device GPS merely because they maintain an account. Address-derived geographic coordinates are different from continuously collected device GPS information. If StarClean later introduces functionality requiring precise device location, StarClean should provide appropriate disclosure and request applicable device permission before collecting that information where required. 11. FACILITY ACCESS INFORMATION Businesses may provide information necessary for Cleaning Professionals to lawfully access facilities. This may include: • entry instructions; • parking instructions; • alarm or security information; • restricted-area instructions; • key or lockbox information; • door or access codes; • facility contact methods; • cleaning-supply instructions; and • other access information. Some facility-access information may be considered operationally sensitive. StarClean may restrict sensitive access information so that it becomes available only to an assigned Cleaning Professional after Job acceptance. Business owners and authorized StarClean administrators may also have access where reasonably necessary. Cleaning Professionals may use facility credentials only as reasonably necessary to perform the Accepted Job and may not improperly copy, disclose, retain, or reuse them. StarClean intends to limit unnecessary post-Job accessibility of sensitive facility credentials as its technical controls permit. Until automated post-Job restriction or deletion controls are implemented, certain historical access records may remain stored with the Job. Users must not use retained access information for any unauthorized purpose. StarClean should periodically review whether sensitive access information remains reasonably necessary and should delete, mask, restrict, or otherwise protect it when continued accessibility is no longer appropriate, subject to legitimate security, dispute, fraud-prevention, or legal requirements. 12. JOB PHOTOGRAPHS AND DOCUMENTATION Cleaning Professionals may upload photographs and other documentation concerning Job performance. These materials may be used for: • completion documentation; • task verification; • completion-percentage determinations; • dispute resolution; • refund administration; • property-damage investigations; • payment administration; • fraud prevention; • safety investigations; • customer support; • enforcement of Platform agreements; and • legal compliance. Users should avoid intentionally capturing unnecessary: • people; • children; • patient information; • medical information; • student information; • confidential documents; • computer screens; • financial information; • passwords; • facility credentials; • customer information; or • unrelated private areas. Businesses should identify areas where photography is prohibited or restricted. Job photographs may be retained after Job completion when reasonably necessary for disputes, payments, chargebacks, property-damage claims, fraud prevention, safety, account enforcement, or legal purposes. StarClean does not treat its operational ability to process Job photographs as unrestricted permission to use identifiable facility photographs for unrelated advertising or promotional purposes. 13. MESSAGES AND COMMUNICATIONS StarClean may process and retain communications sent through Platform messaging features. These may include: • Business-to-Cleaning-Professional messages; • Cleaning-Professional-to-Business messages; • attachments; • support communications; • dispute communications; • safety reports; and • account-review communications. Authorized StarClean administrators may access Platform messages where reasonably necessary for: • customer support; • Job administration; • disputes; • harassment or misconduct investigations; • safety investigations; • fraud prevention; • account enforcement; • security; or • legal compliance. StarClean does not represent that every message is routinely reviewed by a human. Messages and related attachments may remain in historical Platform records following Job completion or account deletion where legitimately retained. 14. JOB ACTIVITY AND PLATFORM RECORDS StarClean may collect or generate records concerning Platform and Job activity, including: • Job creation; • Job acceptance; • scheduled start time; • Start attempts; • actual Start timestamp; • start-window information; • completion submission; • completion timestamp; • final-photo timestamp; • calculated Job duration; • task completion; • completion percentage; • status changes; • recurring-Job information; • cancellations; • late-start events; • contractor removal or reposting; • disputes; • warnings; • administrative corrections; • payment events; and • related Platform history. Technical records associated with certain events may include: • IP address; • user-agent information; • session information; • authenticated account identifiers; • timestamps; and • other information reasonably necessary for security, auditability, or transaction administration. 15. RATINGS, REVIEWS, DISPUTES, CLAIMS, AND WARNINGS StarClean may process information concerning: • ratings; • reviews; • complaints; • cleaning-quality disputes; • partial-completion determinations; • refund requests; • property-damage allegations; • chargebacks; • safety reports; • cancellation reviews; • account warnings; • appeals; • administrative investigations; and • resolutions. This information may include: • written statements; • photographs; • attachments; • estimates; • invoices; • communications; • timestamps; • transaction records; • completion information; • task-completion information; • administrative notes; and • other relevant evidence. 16. EMAIL RECORDS StarClean may send transactional or operational emails concerning: • account verification; • Job acceptance; • Job reminders; • Job Start; • cancellations; • completion; • payments; • payouts; • disputes; • account enforcement; • privacy matters; • legal notices; and • other Platform activity. StarClean may maintain records of emails sent through the Platform, including: • recipient; • subject; • rendered message content; • delivery status; and • related transaction or Job information. These records may be available to authorized administrators for support, dispute resolution, audit, troubleshooting, and legal purposes. 17. INFORMATION COLLECTED AUTOMATICALLY Depending on the production technology and services used, StarClean or its providers may automatically process technical information including: • IP address; • device type; • operating system; • browser or application version; • authentication information; • login activity; • session information; • timestamps; • user-agent information; • security events; • diagnostic information; • performance information; and • other technical information reasonably necessary to operate, secure, troubleshoot, or improve the Platform. Certain hosting, authentication, diagnostic, or technical information may be processed by Base44 as part of operating the underlying Platform infrastructure. The exact scope of Base44's independent or platform-level processing is subject to Base44's applicable technology, terms, and privacy practices. 18. COOKIES, LOCAL STORAGE, AND SIMILAR TECHNOLOGIES StarClean and applicable service providers may use: • cookies; • authentication tokens; • session storage; • local storage; • SDK technologies; and • similar technologies for purposes including: • authentication; • account security; • navigation; • session management; • user preferences; • Platform functionality; • diagnostics; and • security. At the time of the current technical audit, StarClean had not intentionally implemented third-party advertising cookies or advertising pixels through its application code. StarClean should review the production technology stack before launch and update disclosures where necessary. 19. ANALYTICS AND DIAGNOSTICS StarClean may use internal or third-party analytics or diagnostic technologies to: • understand Platform usage; • measure performance; • diagnose errors; • investigate crashes; • improve functionality; • detect abuse; • support security; and • improve user experience. At the time of the current technical audit, no separate third-party advertising or analytics SDK was identified in StarClean's application code. Base44 or other infrastructure providers may independently process operational or diagnostic information necessary to provide their services. StarClean should review applicable provider practices before production launch. 20. HOW STARCLEAN USES INFORMATION StarClean may use personal information to: • create and administer accounts; • authenticate users; • verify Businesses; • verify Cleaning Professionals; • administer background screening; • maintain account security; • create and manage Jobs; • calculate and display Job pricing; • facilitate Job acceptance; • facilitate communications; • administer facility access; • administer recurring Jobs; • track Job status; • document Job Start and completion; • calculate completion information; • process payments; • facilitate payouts; • issue refunds or partial refunds; • administer cancellations; • resolve disputes; • review property-damage claims; • maintain ratings and reviews; • provide customer support; • detect and prevent fraud; • prevent Platform abuse; • enforce agreements; • investigate safety incidents; • protect users and the Platform; • comply with applicable law; • maintain appropriate records; • perform internal analytics; • diagnose technical problems; • improve Platform performance; and • develop and test Platform features. StarClean may also use information for other purposes disclosed at collection or otherwise permitted by applicable law. 21. PAYMENT, COMPLETION, AND REFUND ADMINISTRATION StarClean may process Job records, task-completion information, photographs, communications, payment information, and other relevant evidence to administer payments and refunds. If a Job is cancelled before a valid Job Start, applicable cancellation and refund rules are governed by the Terms of Service and Business Agreement. Once a Cleaning Professional validly starts a Job, the Platform Fee applicable to that Job is non-refundable except where applicable law requires otherwise or StarClean expressly determines otherwise. Where a Job is only partially completed, StarClean may use task-completion information, completion percentage, photographs, communications, Job records, and other relevant evidence to determine what portion of the cleaning-service amount corresponds to work completed and what portion, if any, should be refunded or otherwise adjusted. A dispute or refund request does not guarantee a refund. This Privacy Policy explains how information may be processed for these decisions. The substantive payment and refund rules are governed by the Terms of Service, Business Agreement, and applicable Platform policies. 22. AUTOMATED SYSTEMS AND ARTIFICIAL INTELLIGENCE StarClean may use automated systems to support legitimate Platform functions including: • pricing calculations; • marketplace administration; • fraud or risk signals; • security monitoring; • analytics; • Platform support; • feature improvement; and • future Platform functionality. StarClean does not represent that artificial intelligence independently makes every significant Platform decision. Consequential matters such as serious account enforcement, disputes, or eligibility determinations may involve authorized human administrative review where appropriate. StarClean will provide additional disclosures or rights concerning automated decision-making where required by applicable law. 23. GENERAL-PURPOSE AI TRAINING At launch, StarClean does not intend to use users': • full background-screening reports; • Social Security numbers; • government-identification information; • full payment credentials; • facility access credentials; or • private Job photographs to train general-purpose artificial-intelligence models. If StarClean materially changes these practices, StarClean should first evaluate applicable legal requirements, contractual restrictions, disclosures, safeguards, and consent requirements. 24. INFORMATION SHARED BETWEEN BUSINESSES AND CLEANING PROFESSIONALS StarClean may make information available to transaction participants when reasonably necessary to facilitate a Job. Cleaning Professionals may receive information including: • Business or facility name; • Job location; • scheduled date and time; • cleaning scope; • requested areas and tasks; • facility requirements; • relevant access instructions; and • other information reasonably necessary to perform the Job. Businesses may receive information including: • Cleaning Professional displayed name; • verification or eligibility status; • rating information; • Job status; • completion information; and • other information reasonably necessary to administer the Job. StarClean seeks to avoid unnecessary disclosure of sensitive information. Businesses should not ordinarily receive a Cleaning Professional's: • Social Security number; • full date of birth; • home address; • full background report; • government-identification information; • bank-account information; or • other sensitive information unrelated to the Job. Cleaning Professionals likewise should not receive unnecessary Business payment credentials or confidential Business records unrelated to the Job. 25. SERVICE PROVIDERS StarClean may disclose or make information available to vendors and service providers that help operate the Platform. Depending on the production systems used, providers may support: • application hosting; • authentication; • database services; • file storage; • payment processing; • payouts; • identity verification; • background screening; • email delivery; • communications; • analytics; • diagnostics; • security; • fraud prevention; • customer support; and • other Platform functionality. Providers receive information reasonably necessary to perform their applicable services. StarClean should periodically review provider access and data practices. 26. CURRENT MATERIAL PROVIDERS Current or planned material providers may include: Base44 Used for application infrastructure, authentication, database functionality, file storage, backend functions, and related Platform services. Stripe Used for Business payment processing and Cleaning Professional payout/Connect functionality. Stripe may directly collect and maintain card, bank, identity, tax, or other information necessary to provide its services. StarClean generally retains relevant Stripe identifiers and transaction status information rather than full payment credentials. Certn Used or planned for Cleaning Professional background-screening services. Sensitive screening information may be collected and maintained directly by Certn, while StarClean may maintain screening status and limited administrative metadata. Google Google OAuth may be available as an account sign-in option. Authentication information may be processed according to the applicable authentication flow. Base44 Email Services StarClean currently uses Base44-provided email functionality for certain transactional communications. StarClean should verify the final provider list and provider-specific data flows before publication of the production Privacy Policy. 27. LEGAL, SAFETY, AND SECURITY DISCLOSURES StarClean may disclose information when reasonably necessary to: • comply with applicable law; • respond to valid legal process; • respond to court orders or subpoenas; • protect legal rights; • investigate fraud; • investigate unlawful activity; • address credible safety concerns; • protect users; • protect StarClean personnel; • protect the Platform; • investigate security incidents; • enforce applicable agreements; or • respond to emergencies where disclosure is legally appropriate. 28. BUSINESS TRANSFERS If StarClean is involved in a merger, acquisition, financing, restructuring, reorganization, bankruptcy, sale of assets, or similar corporate transaction, personal information may be disclosed or transferred as part of that transaction where permitted by law. Any successor receiving personal information remains subject to applicable legal obligations concerning that information. 29. SALE OF PERSONAL INFORMATION At launch, StarClean does not sell personal information for monetary consideration. Privacy laws may define “sale,” “sharing,” “targeted advertising,” and similar concepts differently. If applicable law treats a future StarClean practice as a sale, sharing, or regulated disclosure, StarClean will provide applicable notices and choices required by law. 30. TARGETED AND CROSS-CONTEXT BEHAVIORAL ADVERTISING At launch, StarClean does not use Business or Cleaning Professional personal information for cross-context behavioral advertising. At the time of the current technical audit, no advertising SDK, advertising pixel, retargeting system, or behavioral-advertising technology was identified in the StarClean application code. If StarClean materially changes its advertising practices, StarClean should update applicable privacy disclosures and provide legally required consent or opt-out mechanisms. 31. TRANSACTIONAL COMMUNICATIONS StarClean may send communications reasonably necessary to operate the Platform. These may include: • account-verification messages; • security alerts; • Job-acceptance confirmations; • Job reminders; • Job Start notifications; • cancellation notices; • completion notices; • dispute communications; • refund communications; • payment communications; • payout communications; • account-enforcement notices; • privacy notices; • legal notices; and • other service-related communications. Users may not be able to opt out of communications reasonably necessary to provide the Platform, administer transactions, protect account security, or satisfy legal obligations while maintaining an active account. 32. MARKETING COMMUNICATIONS Where permitted by law, StarClean may send promotional or marketing communications. Users may opt out of applicable marketing emails through the provided unsubscribe mechanism or another available method. Opting out of marketing does not prevent StarClean from sending necessary transactional, security, Job, account, payment, dispute, privacy, or legal communications. 33. TEXT MESSAGES SMS or text-message functionality is not currently implemented as part of the audited production flow. If StarClean introduces SMS functionality, telephone numbers may be processed to provide authorized Platform communications. Where applicable law requires separate consent for particular text messages, including promotional messages, StarClean should obtain that consent through an appropriate consent process. Acceptance of this Privacy Policy alone does not constitute separate marketing-text consent where separate consent is legally required. 34. PUSH NOTIFICATIONS StarClean may introduce or use device push notifications where supported. If enabled, push notifications may provide information concerning Jobs, accounts, payments, safety, messages, or other Platform activity. Users may generally manage device notification permissions through their device settings. StarClean should update applicable disclosures if its push-notification practices materially affect personal-information processing. 35. DATA MINIMIZATION StarClean seeks to collect and process information reasonably appropriate to legitimate Platform purposes. StarClean should avoid collecting sensitive information merely because it might potentially become useful. Where practical, StarClean may use specialized third-party providers to process particularly sensitive information rather than unnecessarily storing that information itself. 36. DEVICE PERMISSIONS StarClean may request device permissions only when reasonably related to an applicable Platform feature. Depending on functionality, permissions may involve: • camera; • photographs; • notifications; or • location. StarClean should not request unrelated permissions merely because a device operating system makes them available. Users may manage applicable permissions through device settings, although disabling a permission may prevent functionality that legitimately depends on it. 37. SENSITIVE FACILITIES AND REGULATED INFORMATION StarClean may facilitate commercial cleaning for facilities that handle sensitive information, including: • medical offices; • urgent-care facilities; • educational facilities; • childcare facilities; • nursing or residential-care facilities; • government facilities; • financial facilities; and • other sensitive environments. Businesses should not intentionally use StarClean as a system for transmitting: • protected medical records; • patient records; • student education records; • government secrets; • full financial records; • passwords; • authentication credentials; or • other highly regulated information unless StarClean expressly supports such processing and appropriate legal, contractual, technical, and security requirements have been satisfied. The fact that a healthcare facility uses StarClean for commercial cleaning does not by itself mean StarClean represents the Platform as a system designed for transmitting protected health information. Businesses remain responsible for determining whether their use of the Platform is appropriate for their regulatory obligations. 38. CHILDREN StarClean is intended for users who are at least 18 years old. StarClean does not knowingly permit children under 18 to create Business or Cleaning Professional accounts. If StarClean learns that it collected personal information directly from a child in circumstances where collection was not permitted, StarClean may take reasonable steps to delete the information, subject to applicable legal retention requirements. A child or another individual appearing incidentally in the background of a facility photograph does not thereby become a StarClean user. Users should avoid unnecessarily photographing individuals, particularly children, while documenting Jobs. 39. INFORMATION SECURITY StarClean uses or seeks to use reasonable administrative, technical, and organizational safeguards designed to protect personal information. Depending on the system and information involved, safeguards may include: • authentication; • role-based authorization; • access controls; • restricted sensitive fields; • private file storage; • time-limited file access; • secure payment providers; • security monitoring; • audit logging; • fraud prevention; • administrative controls; and • other reasonable security practices. No method of electronic transmission, processing, or storage is completely secure. StarClean therefore cannot guarantee absolute security or that unauthorized access, loss, misuse, or disclosure will never occur. 40. INTERNAL AND ADMINISTRATIVE ACCESS StarClean personnel may access personal or sensitive information only where authorized and reasonably necessary for legitimate Platform responsibilities. Depending on permissions and responsibilities, authorized administrators may have access to: • Jobs; • Business profiles; • Cleaning Professional profiles; • contact information; • date of birth; • verification status; • limited background-screening metadata; • messages; • Job photographs; • dispute evidence; • payment-status information; • Stripe transaction identifiers; • cancellation records; • warnings; • administrative notes; • email records; • agreement-acceptance records; • deletion records; • safety information; and • audit records. StarClean uses role-based administrative permissions to limit administrative functionality. Certain sensitive administrative fields may be restricted to administrators. Not every administrator necessarily has identical permissions. Administrative actions may be logged where appropriate. Routine viewing of every record is not necessarily individually audit-logged. 41. SECURITY INCIDENTS If StarClean discovers or reasonably suspects unauthorized access, disclosure, loss, or misuse of information, StarClean may take reasonable steps to: • investigate; • contain the incident; • preserve relevant evidence; • mitigate harm; • remediate affected systems; • work with relevant service providers; • improve security measures; and • provide legally required notifications. Where required by applicable law, StarClean may notify affected individuals, regulators, law enforcement, or other appropriate parties. Not every attempted attack, suspicious event, or security alert constitutes a legally reportable data breach. 42. USER SECURITY RESPONSIBILITIES Users are responsible for taking reasonable measures to protect: • passwords; • authentication credentials; • devices; • account access; and • facility credentials within their control. Users should promptly notify StarClean if they reasonably believe their account has been accessed without authorization. Cleaning Professionals may not share their accounts or verification status with another person. 43. DATA RETENTION StarClean retains personal information for as long as reasonably necessary for the purposes described in this Privacy Policy or as otherwise permitted or required by applicable law. Retention considerations may include: • active account administration; • completing Jobs; • maintaining Job history; • processing transactions; • accounting; • taxes; • payouts; • refunds; • chargebacks; • disputes; • property-damage claims; • fraud prevention; • safety investigations; • account enforcement; • security; • agreement enforcement; • legal claims; • regulatory requirements; and • administrative audit requirements. Different categories of information may have different retention periods. StarClean does not represent that every category is retained for one universal period. At the time of the current technical audit, several historical record categories do not yet have automatic deletion schedules. StarClean intends to establish appropriate internal retention criteria before or as part of production compliance operations. 44. JOB PHOTOGRAPH AND EVIDENCE RETENTION Completion photographs, dispute evidence, message attachments, safety evidence, and similar documentation may be retained after Job completion. Such information may remain relevant to: • cleaning-quality disputes; • completion-percentage determinations; • refunds; • property-damage claims; • chargebacks; • payment disputes; • fraud investigations; • safety investigations; • account enforcement; and • legal claims. StarClean should not retain sensitive evidence indefinitely merely because storage is technically possible. Appropriate retention criteria should be established based on legitimate business, legal, security, and dispute needs. 45. FACILITY-CREDENTIAL RETENTION Facility access credentials warrant heightened protection because unauthorized continued access could create security risks. StarClean may retain facility-access records where reasonably necessary for Job administration, disputes, security, fraud prevention, or legal purposes. StarClean intends to reduce unnecessary continued accessibility of sensitive access credentials after the applicable Job ends. Businesses should change temporary access codes where appropriate following Job completion. Cleaning Professionals are prohibited from using access credentials after authorization to access the facility has ended. 46. ACCOUNT DELETION Users may request deletion of their StarClean account through available Platform functionality or another deletion process provided by StarClean. StarClean's current account-deletion architecture may: • deactivate the user's marketplace account; • remove the user from active Platform participation; • anonymize or clear designated profile information; and • retain certain historical records where reasonably necessary or legally permitted. Certain records may remain after account deletion or anonymization, including records reasonably necessary for: • completed Jobs; • payments and payouts; • accounting; • taxes; • accepted legal agreements; • disputes; • refunds; • chargebacks; • property-damage claims; • fraud prevention; • safety; • security; • account-enforcement history; • administrative audits; • legal claims; • regulatory requirements; and • surviving contractual obligations. Historical Jobs, messages, photographs, disputes, transaction records, audit records, and agreement-acceptance records may therefore remain where legitimately retained. StarClean should not use retained information merely to continue treating a deleted user as an active marketplace participant. PRE-LAUNCH REQUIREMENT: StarClean must verify the final production deletion process, including whether the underlying Base44 authentication identity and active authentication sessions can be deleted or revoked, before describing account deletion more specifically in the final published Privacy Policy. 47. CLEANING PROFESSIONAL ACCOUNT DELETION When a Cleaning Professional account is closed or deleted, the Cleaning Professional should cease appearing as an active Cleaning Professional through ordinary marketplace functionality. StarClean may retain historical information reasonably necessary to document: • completed Jobs; • payouts; • financial and tax records; • accepted agreements; • disputes; • property-damage matters; • fraud or safety matters; • account-enforcement history; and • administrative audit records. Retention does not mean the Cleaning Professional remains eligible to accept new Jobs. 48. BUSINESS ACCOUNT DELETION When a Business account is closed or deleted, the Business should cease appearing as an active marketplace participant through ordinary Platform functionality. StarClean may retain historical records reasonably necessary to document: • Jobs; • payments; • refunds; • chargebacks; • accepted agreements; • disputes; • property-damage claims; • fraud or safety matters; • account enforcement; and • legal or accounting obligations. Cleaning Professionals should not use historical access to Business information for purposes unrelated to legitimate retained Job records. 49. ACCOUNT-DELETION METHODS StarClean should provide a readily discoverable method for eligible users to initiate account deletion through the Platform. StarClean should also maintain any external account-deletion method required by applicable app-store rules or law. The external mechanism may include a dedicated web page, request form, or other compliant method allowing a user to request deletion without reinstalling the application. PRE-LAUNCH REQUIREMENT: Confirm and test the in-app deletion pathway and any required external deletion resource before production App Store or Google Play submission. 50. PRIVACY RIGHTS Depending on where a user resides and applicable law, a user may have rights concerning personal information. These may include rights to request: • access; • confirmation of processing; • correction; • deletion; • a copy of certain information; • data portability; • information concerning certain disclosures; • opt-out from certain processing; • withdrawal of consent where applicable; or • appeal of certain privacy-request decisions where required. Not every privacy right applies to every person, company, or circumstance. StarClean will honor applicable privacy rights as required by law. 51. PRIVACY REQUESTS Privacy requests may be submitted using a method designated by StarClean. Proposed privacy contact: privacy@starcleanconnect.com PRE-LAUNCH REQUIREMENT: Confirm that this mailbox is active, secured, and monitored before publishing it as the final privacy-request address. StarClean may also provide in-app or web-based privacy-request functionality. 52. VERIFYING PRIVACY REQUESTS StarClean may take reasonable steps to verify the identity of a person submitting a privacy request before: • providing protected information; • correcting information; • deleting information; or • taking another action affecting account security or privacy. StarClean should request only information reasonably necessary for verification. For Business requests, StarClean may verify the requester's authority to act for the applicable organization. If StarClean cannot reasonably verify a request, StarClean may limit or deny it to the extent permitted by applicable law. 53. AUTHORIZED AGENTS Where applicable law permits an authorized agent to submit a privacy request, StarClean may require reasonable evidence of: • the agent's authority; • the user's identity where permitted; and • other information legally appropriate to verify the request. 54. NO UNLAWFUL DISCRIMINATION FOR PRIVACY REQUESTS StarClean will not unlawfully discriminate against a user merely because the user exercised a privacy right protected by applicable law. Exercising a privacy right does not necessarily eliminate: • valid payment obligations; • active Jobs; • unresolved disputes; • fraud investigations; • safety investigations; • legal-preservation requirements; or • other obligations applicable law permits StarClean to maintain. 55. PRIVACY-REQUEST RECORDS StarClean may maintain appropriate records concerning privacy requests. These may include: • request type; • account involved; • date received; • verification status; • applicable response deadline; • action taken; • completion date; • applicable denial or limitation reason; and • administrator handling the request. These records may be retained as reasonably necessary to demonstrate compliance, prevent fraud, and protect privacy. 56. UNITED STATES AND STATE PRIVACY RIGHTS StarClean is initially designed to operate in the United States. Privacy rights may vary depending on a user's state of residence and applicable law. Where an applicable U.S. state privacy law provides additional rights or disclosures, StarClean will provide those rights and disclosures as legally required. Nothing in this Privacy Policy is intended to provide fewer rights than applicable law requires. StarClean should periodically review its geographic operations, applicable thresholds, processing activities, and privacy-law obligations as the Platform expands. 57. INTERNATIONAL PROCESSING Although StarClean may primarily operate in the United States, certain service providers or technical infrastructure may process information from locations outside the user's state or country. Where applicable law imposes requirements concerning international data transfers, StarClean will take legally required measures. This provision does not represent that StarClean currently offers its marketplace in every country. 58. THIRD-PARTY LINKS AND SERVICES The Platform may contain links to or integrations with third-party websites or services. Those services may maintain their own privacy policies. StarClean is not responsible for independent privacy practices of unrelated third parties merely because the Platform provides a link or integration. Users should review applicable third-party privacy policies where appropriate. 59. CHANGES TO THIS PRIVACY POLICY StarClean may update this Privacy Policy prospectively. Updated versions will display an updated effective or revision date. For material changes, StarClean may provide notice through: • the Platform; • email; or • another reasonable electronic method. Where applicable law requires consent or another affirmative action for a material change, StarClean will seek that action as required. StarClean should review whether material privacy changes also require updates to: • Apple App Privacy disclosures; • Google Play Data Safety disclosures; • device permissions; • consent screens; • third-party contracts; or • other Platform documentation. 60. PRIVACY BY CHANGE CONTROL When StarClean introduces functionality materially affecting personal information, StarClean should evaluate privacy implications before or as part of production deployment. Examples include: • precise-location tracking; • biometric verification; • new identity-verification systems; • new background-screening systems; • SMS messaging; • marketing SMS; • behavioral advertising; • new analytics SDKs; • artificial-intelligence processing involving personal information; • new sensitive-data processing; • new facility-monitoring functionality; or • materially expanded information sharing. The review should determine whether changes are required to: • this Privacy Policy; • Platform disclosures; • consent mechanisms; • permissions; • Apple App Privacy disclosures; • Google Play Data Safety disclosures; • security controls; • retention rules; or • applicable agreements. 61. APP STORE PRIVACY DISCLOSURES Before submitting StarClean to an application marketplace, StarClean should review the actual production application and determine what information is processed by: • StarClean; • Base44; • Stripe; • Certn; • authentication providers; • email providers; • third-party SDKs; • analytics or diagnostic services; and • other production integrations. StarClean's application-store privacy disclosures should accurately reflect actual production behavior. 62. APPLE APP PRIVACY Before Apple App Store production submission, StarClean should: • maintain a publicly accessible Privacy Policy URL; • make the Privacy Policy reasonably accessible from within the application; • complete applicable App Privacy disclosures; • account for relevant third-party provider and SDK practices; • verify device permissions; • verify account-deletion functionality; • review applicable privacy-manifest or SDK requirements; and • ensure the disclosures match the production application. StarClean should update applicable Apple disclosures when its data practices materially change. 63. GOOGLE PLAY DATA SAFETY Before Google Play production submission, StarClean should: • maintain a publicly accessible Privacy Policy; • make the Privacy Policy accessible from the application where required; • complete applicable Data Safety disclosures; • review data processed through third-party libraries and providers; • accurately disclose applicable security and deletion practices; • provide required account-deletion functionality; • maintain any required external account-deletion resource; and • ensure declarations match the production application. StarClean should update Google Play disclosures when relevant data practices materially change. 64. PRODUCTION DATA INVENTORY Before launch, StarClean should maintain an internal privacy-data inventory documenting, where applicable: • data category; • source; • purpose; • applicable user role; • whether collection is required or optional; • storage location; • third-party recipient; • retention rule; • security classification; • deletion process; • applicable device permission; • applicable consent requirement; and • applicable App Store or Google Play disclosure. The inventory should account for all material production integrations that process user information. 65. CONTACT INFORMATION Questions concerning this Privacy Policy or StarClean's privacy practices may be directed to: StarClean Connect Services LLC StarClean Connect Privacy Email: privacy@starcleanconnect.com Support Email: support@starcleanconnect.com Legal Email: legal@starcleanconnect.com Business Mailing Address: 755 W. Big Beaver Road, Suite 2020, Box IO245 Troy, Michigan 48084