Privacy Policy

Last updated: May 10, 2026

This Privacy Policy explains how Strong Pay Services Inc. ("Star Sixty Nine", "we", "us", or "our"), incorporated in Ontario, Canada, collects, uses, discloses, and protects personal information in connection with the Star Sixty Nine platform at starsixtynine.xyz ("Services").

We comply with Canada's PIPEDA, the Australian Privacy Act 1988 and Australian Privacy Principles, the UK GDPR and Data Protection Act 2018, and applicable US state privacy laws including the CCPA.

Star Sixty Nine is an AI-powered outbound calling platform that enables businesses ("Customers") to contact leads and prospects using AI voice agents. Our registered office is in Ontario, Canada.

Privacy enquiries: privacy@starsixtynine.xyz

2.1 Information You Provide

• Account information: name, business name, email address, phone number, billing address
• Payment information: processed securely via Stripe; we do not store card details
• Business configuration: call scripts, qualification criteria, agent settings, and lead data you upload
• Communications: messages you send via email or support channels

2.2 Information About Your Leads

When you use our platform to make outbound calls, you provide us with information about the individuals you intend to contact ("Leads"), which may include name, phone number, email address, lead source, and any additional fields you import.

You represent and warrant that every Lead has previously expressed interest in or enquired about your products or services, and that you have a lawful basis to contact them. Our platform is not intended for cold calling.

2.3 Call Data

• Call recordings and transcripts (processed via ElevenLabs)
• Call metadata: duration, outcome, timestamps
• AI-generated qualification scores, summaries, and labels

2.4 Usage Data

Log data, IP addresses, browser type, device identifiers, feature usage, and error logs.

2.5 Cookies

We use cookies for authentication, session management, and analytics. You may control cookies through your browser settings, though disabling them may affect platform functionality.

• Provide, operate, and improve the Services
• Process payments and manage your subscription
• Facilitate outbound AI calls on your behalf
• Generate call transcripts, recordings, and qualification data
• Send transactional communications (account notices, call results, hot lead alerts)
• Comply with legal obligations
• Detect and prevent fraud, abuse, and security incidents

We do not sell your personal information or your Leads' personal information to third parties.

• Contract performance: processing necessary to provide the Services you have subscribed to
• Legitimate interests: operating and improving our platform, preventing fraud, ensuring security
• Legal obligation: complying with applicable laws and regulations
• Consent: where required by law

5.1 Service Providers

We share information with trusted third-party providers who assist us in operating the platform:

• ElevenLabs - AI voice and call infrastructure
• Twilio - telephony and call routing
• Stripe - payment processing
• Supabase - data storage and authentication
• Vercel - hosting and infrastructure
• Resend - transactional email

All providers are bound by confidentiality obligations and may only process information to provide services to us.

5.2 CRM Integrations

If you connect a CRM (e.g. HubSpot, Salesforce), call results may be written back to your CRM at your direction.

5.3 Legal Requirements

We may disclose information if required by law, court order, or government authority, or to protect the rights, property, or safety of Strong Pay Services Inc., our Customers, or the public.

5.4 Business Transfers

In the event of a merger, acquisition, or asset sale, personal information may be transferred as part of that transaction. We will notify affected users as required by law.

Our infrastructure is hosted in the United States and other jurisdictions. By using our Services, you acknowledge that your information may be transferred to and processed in countries outside your country of residence. Where required, we ensure appropriate safeguards are in place through contractual protections with our service providers.

We retain personal information for as long as necessary to provide the Services and comply with our legal obligations. Upon account termination, we will delete or anonymise your data within a reasonable period, except where retention is required by law.

We implement commercially reasonable technical and organisational measures to protect personal information, including encryption in transit and at rest, access controls, and regular security reviews. No method of internet transmission is completely secure and we cannot guarantee absolute security.

Depending on your jurisdiction, you may have the right to access, correct, delete, or port your personal information, and to withdraw consent or object to processing.

• United States (CCPA): right to know, delete, and opt out of sale (we do not sell personal information)
• Canada (PIPEDA): access, correction, and complaints to the Office of the Privacy Commissioner
• UK (UK GDPR): access, correction, deletion, objection, restriction, and complaints to the ICO
• Australia (Privacy Act 1988): access, correction, and complaints to the OAIC

To exercise any of these rights, contact: privacy@starsixtynine.xyz

Our Services are not directed at individuals under 18. We do not knowingly collect personal information from children. Contact us immediately if you believe we have done so.

We may update this Policy from time to time. We will notify you of material changes by email or by posting a notice on the platform. Continued use of the Services after changes are posted constitutes acceptance of the updated Policy.

Strong Pay Services Inc. (operating as Star Sixty Nine)
Ontario, Canada
Email: privacy@starsixtynine.xyz