Privacy Policy

1. Introduction
This Privacy Policy explains how Stark Partners (“Stark Partners”, “we”, “us”, “our”) collects, uses and protects information in connection with our website and our remote advisory and agency services related to cross‑border solutions and OTC trading.
We operate fully remotely and provide consulting and introduction services; we do not directly execute OTC trades, hold client funds, or process cross‑border payments ourselves.
By using our website or communicating with us, you acknowledge that you have read and understood this Privacy Policy.
2. Our Role and Target Clients
Our services are intended for corporate and professional clients (such as companies, funds, family offices and other institutional or high‑net‑worth structures).
We act as advisors and agents, introducing clients to third‑party regulated institutions (banks, brokers, OTC desks, custodians and other providers) and assisting with structuring and coordination.
We do not target retail consumers and do not provide services directly to private individuals in a consumer capacity.
3. Data Controller and Jurisdiction
We operate remotely and may interact with clients and partners globally, while remaining subject to applicable data protection rules and, where relevant, foreign data protection laws.
4. What Information We Collect
4.1 Business Contact Information
We primarily collect business‑related information concerning representatives of corporate and professional clients, such as:
  • Name and business role (e.g. director, partner, authorized representative).
  • Business email address and business phone number.
  • Company name, legal form, jurisdiction of incorporation and sector.
  • Preferred communication channels (e.g. Telegram or other messengers used in a professional context).
4.2 Project and Engagement Information
To provide our advisory and agency services, we may also collect:
  • High‑level information about planned structures and transactions (e.g. approximate transaction sizes or ranges, preferred jurisdictions, types of assets and counterparties).
  • Information needed to suggest suitable third‑party institutions (e.g. basic risk profile, geographic constraints, regulatory requirements, corporate documentation status).
  • Records of our communications, including emails, messages and call notes, for coordination and record‑keeping.
4.3 Technical and Usage Data
When you visit our website, we may automatically collect:
  • IP address, browser type and version, device information, operating system, language settings and time zone.
  • Information about how you use our website (pages visited, time spent, referral sources) via cookies or similar technologies.
5. What We Do Not Collect
We do not intentionally collect or store:
  • Full sets of personal documents of private individuals, such as copies of passports, identity cards, or proof of address, on our own systems.
  • Detailed KYC/AML files of natural persons; any such processes are performed directly by regulated third‑party institutions under their own policies.
  • Sensitive categories of personal data (such as health data, religious beliefs, political opinions), unless strictly required by law and handled directly by regulated providers, not by us.
If you inadvertently send us sensitive personal documents, we will either securely delete them or, where appropriate, immediately forward them to the relevant regulated institution strictly for onboarding purposes, and avoid retaining copies longer than necessary.
6. How We Use the Information
We use business contact and project information exclusively for professional purposes, including to:
  • Provide remote advisory and agency services regarding cross‑border structures and access to OTC market infrastructure.
  • Assess your corporate profile and requirements in order to recommend and introduce you to suitable regulated third‑party providers.
  • Coordinate communication and onboarding between you and such providers, where you ask us to assist.
  • Manage our contractual relationship, including referral or success‑based fee arrangements with you or with third‑party institutions.
  • Comply with legal and regulatory obligations applicable to us as a consulting and agency business, including basic compliance checks and record‑keeping.
  • Improve and secure our website, internal workflows and client experience (e.g. via analytics, security logs).
  • Send service‑related updates or, where permitted, professional marketing communications about our advisory services, with the option to opt‑out at any time.
We do not carry out proprietary trading, custody, payment processing, or direct execution of cross‑border transfers; these activities are performed solely by third‑party regulated entities with whom you enter into direct relationships.
7. Legal Bases for Processing
Depending on the context and applicable law, our processing may be based on:
  • Performance of a contract or pre‑contractual steps, when you engage us for advisory or agency services.
  • Our legitimate interests, such as operating and developing our remote consulting business, maintaining professional relationships, ensuring security and preventing abuse.
  • Compliance with legal obligations, such as record‑keeping, responding to lawful requests, and basic compliance checks.
  • Your consent, where required by law (for example, for certain types of marketing communications or cookies).
8. Sharing and Disclosure
We may share limited information with third parties in the following situations:
  • Third‑party regulated institutions (banks, payment institutions, OTC desks, brokers, exchanges, custodians, corporate service providers) to whom you request or permit us to introduce you, to facilitate initial contact and pre‑assessment.
  • Service providers that support our remote operations, such as secure email and messaging platforms, IT hosting and infrastructure, website analytics, and basic compliance tools.
  • Professional advisers (lawyers, tax advisors, consultants) involved in specific projects at your request or where necessary to provide you with a coherent solution.
  • Authorities and regulators, where we are legally required to disclose certain information or to protect our rights, property or the rights of others.
  • Other parties, where you explicitly instruct us to share information or give your clear consent.
We do not sell business contact information or any personal data to third parties.
All detailed KYC/AML and transaction‑level data is collected and held by the third‑party regulated entities you work with, under their own legal and privacy frameworks.
9. International Transfers
As a remote advisory and agency firm working with cross‑border solutions, we may transfer business contact and project‑related information to jurisdictions outside Indonesia and your country of residence, for example when introducing you to foreign institutions.
Where required by applicable law, we will take reasonable steps to ensure that appropriate safeguards are in place before such transfers, such as contractual protections consistent with data protection standards.
10. Data Retention
We keep information only for as long as reasonably necessary to:
  • Provide our remote consulting and agency services and manage the business relationship.
  • Fulfil legal, regulatory and contractual obligations, including basic record‑keeping for a period typically required by law (for instance, 5–10 years after the end of a mandate, where such obligations exist).
  • Protect our legitimate interests, including accounting, dispute resolution and audit purposes.
Once information is no longer required, we will securely delete or anonymize it.
11. Security
We implement appropriate technical and organizational measures aimed at protecting information against unauthorized access, loss, misuse or alteration.
These measures may include restricted access on a need‑to‑know basis, secure communication channels, password and device protection, and regular review of access rights.
While we strive to protect your information, no system or transmission method can be guaranteed to be completely secure.
12. Your Rights
Depending on where you are located and which laws apply, you may have certain rights regarding information that relates to you personally, including:
  • Right to request confirmation whether we hold information relating to you and to obtain a copy of such information.
  • Right to request correction of inaccurate or incomplete information that identifies you in a professional context.
  • Right, in some cases, to request deletion or restriction of processing, subject to our legal and contractual obligations.
  • Right to object to certain types of processing, such as direct marketing.
  • Right to withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing.
13. Cookies and Website Analytics
Our website may use cookies and similar technologies for:
  • Ensuring functionality, security and performance of the site.
  • Remembering certain preferences (such as language).
  • Analyzing aggregated traffic and usage data to improve our remote services and online presence.
Where required by law, we will obtain your consent before using non‑essential cookies, and you can adjust your browser or device settings to manage or block cookies at any time.
14. Third‑Party Websites
Our website may contain links to or references to third‑party websites, platforms and services, including those of regulated financial institutions and service providers.
We are not responsible for the privacy practices or content of such third parties. You should review their privacy policies before providing any personal or business information to them.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in laws, our remote business model, or our data practices.
The updated version will be published on our website with a revised “Last updated” date, and where required we may inform you of significant changes through appropriate channels.
16. Disclaimer and Limitation of Liability
Stark Partners is NOT a regulated financial institution, broker, bank,
payment provider, or custodian. We do not hold licenses under MiFID,
SEC, FCA or similar regulations. We provide consulting services only.

We make no warranties regarding third-party institutions we introduce.
Any transactions are at your sole risk. Our liability is limited to
the fees you paid us, and excludes consequential damages.

17. Data Breach Notification
In case of a data breach affecting your information, we will notify
you and relevant authorities as required by law within 72 hours.

18. Governing Law and Disputes
This Privacy Policy is governed by Indonesian law. Disputes shall be
resolved through arbitration in [Singapore/Jakarta] under [SIAC/BANI] rules.

19. Blockchain and Public Data
Cryptocurrency transactions are recorded on public blockchains. We cannot
control or delete on-chain data. Wallet addresses and transaction hashes
may be publicly visible forever.
20. Contact
If you have any questions or concerns about this Privacy Policy or how we handle information, please contact us at:
Email: info@starkpartners.pro
Website: https://starkpartners.pro
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