Privacy Policy

Last updated: 28 October 2026

1. Who we are

www.starladigital.com (the “Website”) is operated by Dolphin Haley LTD, trading as Starla (“Starla”, “we”, “us” or “our”), a company registered in England and Wales under company number 08396885, with its registered office at Boundary House, Cricketfield Road, Uxbridge, Middlesex, UB8 1QG, United Kingdom. Starla is a brand owned and operated by Dolphin Haley LTD.

We are the controller of the personal data described in this policy. If you have any questions about it, email us at freshthinking@voxlydigital.com.

2. What this policy covers

This policy explains what personal data we may collect when you visit and browse the Website, why we use it and what rights you have. It does not cover the Starla product itself, including any data you connect to Starla (for example, a read-only Stripe connection for a churn audit), which is covered by its own privacy terms provided when you sign up.

You do not need to create an account or give us any personal details to read the Website. We use Google Analytics to understand how the Website is used, as described in section 4. We do not use advertising tracking.

3. Data collected when you visit the Website

When your browser requests a page, our hosting and security provider, Cloudflare, receives technical information that every website receives. This can include:

• your IP address;
• your browser type and version, operating system and device type;
• the page you asked for, the page that referred you, and the date and time of the request;
• a rough location derived from your IP address (for example, country).

This information is used to deliver the Website to you, keep it secure (for example, to block malicious traffic and denial-of-service attacks) and fix technical problems. We do not use it to identify you, build a profile of you or market to you.

4. Third-party content on the Website

Some content on the Website is loaded from other companies. When it is, your browser connects directly to that company, which receives your IP address and browser information:

• Google Fonts supplies the typefaces used on every page.
• Google Analytics measures visits on every page. It collects pages viewed, how you arrived, approximate location (derived from your IP address, which Google Analytics does not store), device and browser type, and a random cookie ID. We use this only in aggregate, to see which pages are useful and improve the Website. Analytics data is kept for no longer than 14 months. Google’s advertising features are switched off, and you can opt out with one click on our Cookie Policy page. We rely on our legitimate interest in understanding how the Website is used, as UK law allows for statistics cookies when you are told clearly and can object simply and free of charge.

Google handles this information under its own privacy policy, available at policies.google.com/privacy. Our Cookie Policy explains what is stored on your device.

The Website also links to our LinkedIn page. LinkedIn only receives information about you if you click the link and visit its site.

5. Information you choose to send us

If you email us, fill in a form on the Website (such as the free churn audit form) or sign up for news from us, we will receive the details you give us, together with the page you sent it from and the date and time. Form submissions are logged in a Google spreadsheet and emailed to our team. This is usually your name, work email address, company and message. We use it to reply to you, send you what you asked for, and, only if you opted in, send you news and marketing about Starla. You can unsubscribe from marketing at any time using the link in our emails or by contacting us.

6. Our legal reasons for using your data

Under UK data protection law we rely on:

• legitimate interests to run the Website, keep it secure, measure how it is used, and reply to enquiries you send us;
• consent for marketing emails you have opted in to, which you can withdraw at any time;
• legal obligation where we need to keep or share information to comply with the law.

7. Who we share data with

We do not sell your personal data. We share it only with:

• service providers acting on our instructions: Cloudflare, which hosts and secures the Website, and Google, which provides our email and the spreadsheet where form submissions are logged (Google Workspace) and our website analytics (Google Analytics);
• the third-party services described in section 4, when a page you visit loads their content;
• other companies in the Dolphin Haley LTD group, including Voxly Digital, which helps build and run Starla, where needed to respond to your enquiry;
• professional advisers, regulators, law enforcement or courts, where the law requires it or to protect our rights.

8. International transfers

Some of our providers, including Cloudflare and Google, may process data outside the UK, including in the United States. Where they do, the transfer is protected by safeguards recognised under UK law, such as the UK Extension to the EU–US Data Privacy Framework or standard contractual clauses with the UK Addendum.

9. How long we keep data

Technical and security logs are kept by our providers for a short period, in line with their own retention schedules, and then deleted. Emails and form submissions are kept only for as long as we need them to deal with your enquiry and any follow-up, and are then deleted. If you opted in to marketing, we keep your contact details until you unsubscribe.

10. Your rights

You have the right to ask us for a copy of your personal data, and to ask us to correct, delete or restrict it, to object to how we use it, or to move it to another organisation. Where we rely on your consent, you can withdraw it at any time.

To use any of these rights, email freshthinking@voxlydigital.com. We will reply within one month.

If you are unhappy with how we have handled your data, you can complain to the Information Commissioner’s Office at ico.org.uk or on 0303 123 1113. We would appreciate the chance to put things right first, so please contact us before you do.

11. Security

We use appropriate technical and organisational measures to protect personal data, including encrypted (HTTPS) connections to the Website. No method of sending data over the internet is completely secure, so we cannot guarantee the security of information you send to us.

12. Children

The Website is intended for businesses and is not aimed at children. We do not knowingly collect personal data from anyone under 16.

13. Changes to this policy

We may update this policy from time to time. The date at the top of the page shows when it was last changed.

14. Contact us

For any question about this policy or your personal data, email freshthinking@voxlydigital.com or write to Dolphin Haley LTD, Boundary House, Cricketfield Road, Uxbridge, Middlesex, UB8 1QG, United Kingdom.