Privacy Policy

Effective date: 7 May 2026 Last updated: 7 May 2026

This Privacy Policy explains how GHLstarboys LLC ("GHLstarboys","we","us", or "our") collects, uses, shares, and protects personal information when you visit ghlstarboys.com (the "Site"), book a call with us, hire our services, or otherwise interact with us.

We have written this policy to comply with the Uii General Data Protection Regulation (UIF GDPR) and the UIF Data Protection Act 2018, and the California Consumer PrivacyAct of 2018, as amended by the California Privacy Rights Act (together, the "CCPA"). If you reside outside these jurisdictions, this policy still describes how we handle your information, but specific statutory rights may not apply to you.

Plain English summary

If you'd rather not read the full policy, here's the short version:

We collect your name, email, phone, company details, and information about how you use our website when you contact us, book a call, become a client, or browse the Site.
We use that information to deliver our services, communicate with you, run our business, market to you (where permitted), and meet our legal obligations.
We use cookies and tracking pixels (including Facebook Pixel and Google Tag Manager) for analytics and advertising. You can refuse non-essential cookies through our cookie banner or your browser settings.
We share information with vendors who help us run our business, with advertising and analytics partners, and where required by law. We do not sell personal information for money, but our use of advertising cookies counts as "sharing" under California law.
You have rights over your information, including the right to access, correct, delete, port, restrict, object, or opt out of certain uses. We explain how to exercise those rights below.
To contact us about privacy, email [email protected] with the subject line "Privacy Request".

1- Who we are

The data controller responsible for your personal information is:

GHLstarboys LLC 312 SW Greenwich Dr, Lees Summit, MO 64082, United States Email: [email protected]Phone: +1 (305) 570-4723

GHLstarboys LLC operates as a project of Rozi Academy and provides marketing automation fulfillment, virtual assistant placement, GoHighLevel implementation, media buying, and related agency services.

2- Information we collect

2.1 Information you provide to us directly

When you contact us, book a call, sign up for our services, become a client, apply to our affiliate program, or communicate with us, you may provide:

Identity information: first name, last name, business name, job title.
Contact information: email address, phone number, postal address, country, time zone.
Account information: username, password (hashed), profile preferences, communication preferences.
Commercial information: services purchased, hours used, payment records, billing details (we do not store full card numbers; payment processors handle these).
Communications: emails, SMS messages, chat transcripts, call recordings (where lawful and disclosed), support tickets, social media messages.
Marketing information: responses to surveys, feedback, testimonials you submit, content you provide for case studies.
Affiliate information: payout details, tax forms (W-9, W-8BEN where applicable), referral activity.

2.2 Information we collect automatically

When you visit the Site, we and our service providers may collect:

Device and browser information: IP address, device type, operating system, browser type and version,1anguage settings, screen resolution.
Usage information: pages viewed,1inks clicked, time spent on pages, referring and exit pages, search terms entering the Site, scroll behavior, form interactions.
Approximate location: city or region inferred from your IP address (we do not collect precise GPS-level location).
Cookies and similar technologies: see Section 4 below.

2.3 Information we collect from third parties

We may receive information about you from:

Advertising and analytics platforms (Meta, Google, LinkedIn) regarding ad performance and attribution.
Service providers that help us verify, enrich, or correct contact data.
Publlc sources such as company websites, LinkedIn, and business directories where we conduct outreach.
Referral partners and affiliates who introduce you to us.

2.4 Sensitive personal Information

We do not intentionally collect sensitive personal information as defined under CCPA Section 1798.140(ae), including government identifiers, account credentials in combination with access codes, precise geolocation, racial or ethnic origin, religious beliefs, union membership, genetic or biometric data, health information, or sex life information. If you provide such information voluntarily (for example in a free-text message), we will treat it with appropriate care and delete it where possible.

3- How we use your information and the legal basis for doing so

The table below sets out the purposes for which we process personal information and the legal basis under UK GDPR Article 6 on which we rely.

Purpose

Categories of data

Legal basis (UK GDPR)

Providing our services to clients

Identity, contact, account, commercial, communications

Performance of a contract (Art. 6(1) (b))

Responding to enquiries and support requests

Identity, contact, communications

Performance of a contract or pre contractual steps (Art. 6(1)(b)) legitimate interests (Art. 6(1)(f))

Sending service-related emails and notifications

Identity, contact, account

Performance of a contract (Art. 6(1) (b))

Marketing communications to existing clients about similar services

Identity, contact, marketing

Legitimate interests (Art. 6(1)(f)); soft opt-in under PECR Reg. 22

Marketing communications to prospects

Identity, contact, marketing

Consent (Art. 6(1)(a))

Analytics and improving the Site

Device, usage, cookies

Consent for non-essential analytics

(Art. 6(1)(a)); legitimate interests for

essential analytics

Online advertising and retargeting

Device, usage, cookies, identifiers

Consent (Art. 6(1)(a))

Operating our affiliate program

Identity, contact, payout, tax

Performance of a contract (Art. 6(1) (b)); legal obligation (Art. 6(1)(c))

Fraud prevention and security

Device, usage, account

Legitimate interests (Art. 6(1)(f))

Complying with legal, tax, accounting, and regulatory obligations

All categories as required

Legal obligation (Art. 6(1)(c))

Defending or pursuing legal

claims

All categories as required

Legitimate interests (Art. 6(1)(f)); legal obligation (Art. 6(1)(c))

Business transfers (sale, merger, restructure)

All categories as required

Legitimate interests (Art. 6(1)(f))

Where we rely on legitimate interests, we have carried out a balancing test to confirm that our interests are not overridden by your rights. You can request a summary of any balancing test by contacting us.

Where we rely on consent, you can withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

4. Cookies and similar tracking technologies

The Site uses cookies, pixels, web beacons, and similar technologies. Specifically, we currently use:

Strictly necessary cookies: required for the Site to function (session, security, load balancing). These cannot be disabled.
Analytics cookies: Google Tag Manager (container ID GTM-5FT6NK92), HighLevel platform analytics. Used to understand how visitors use the Site.
Advertising cookies: Meta (Facebook) Pixel (IDs 3261571180772642and 1033160828637690) and any other advertising tags we may add. Used for retargeting, conversion tracking, and measuring ad performance.
Functional cookies: remember your preferences, such as language and consent choices.

4.1 Your cookie choices

For visitors from the UIF, EU, and California, the Site presents a cookie consent banner on first visit. Non-essential cookies (analytics and advertising) do not load until you accept them. You can change your choices at anytime by clicking the Cookie Preferences link in the Site footer.

You can also manage cookies through your browser settings. Information on doing so is available at:

For California residents, see Section 9 (Do Not Sell or Share My Personal Information).

5. How we share your information

We share personal information with the following categories of recipients:

Service providers and processors who act on our instructions, including:

HighLevel (CRM, marketing automation, hosting)
Stripe and other payment processors
Google Workspace and Microsoft 365 (email, productivity, storage)
Slack (internal and client communication)
Calendar and scheduling tools
Customer support tools
Cloud hosting and infrastructure providers
Advertising and analytics partners, including Meta, Google, and LinkedIn, who receive cookie and pixel data for ad measurement and retargeting.
Professional advisors: lawyers, accountants, auditors, and insurers.
Government, regulators, and law enforcement where required by law, court order, or to protect our rights, property, or safety, or that of our users or others.
Acquirers and other parties to a corporate transaction (sale, merger, financing, restructuring, bankruptcy), subject to confidentiality obligations.
Affiliates of GHLstarboys LLC, including Rozi Academy and other commonly controlled entities, where necessary to provide services or run our group operations.

We do not sell personal information for monetary consideration. Under California law, the use of advertising cookies that pass identifiers to advertising platforms can constitute "sharing" or "selling". See Section 9.

b. International data transfers

GHLstarboys LLC is based in the United States and operates with team members and service providers located in the United States, the United Kingdom, the United Arab Emirates, Pakistan, the Philippines, the European Economic Area, Canada, and other countries.

When we transfer personal data of UK residents outside the United Ifingdom to a country that has not been deemed adequate by the UK Government, we rely on appropriate safeguards under Article 46 of the UK GDPR, including:

The UK International Data Transfer Agreement (IDTA), or
The European Commission's Standard Contractual Clauses with the UIF Addendum, or
Binding corporate rules where applicable.

You can request a copy of the relevant safeguards by emailing [email protected].

7. How long we keep your information

We retain personal information only for as long as necessary for the purposes for which it was collected, including any legal, accounting, or reporting requirements.

Typical retention

Prospect enquiries that do not become clients

24 months from last contact, then deleted or anonymized

Active client account data

Duration of the engagement plus 7 years for tax and contractual records

Billing and tax records Marketing email lists Cookies and pixel data

7 years (US IRS and UK HMRC requirements)

Call recordings (where collected)

Until you unsubscribe or after 24 months of inactivity

Affiliate program data Backups

Up to 13 months (varies by cookie; see cookie banner for detail)

12 months unless retained for a specific dispute

Duration of participation plus 7 years Up to 90 days after primary deletion

When retention periods expire, we delete or anonymize the data unless we are required to keep it longer to comply with a legal obligation or to defend a legal claim.

8. Your rights

8.1 Ifyou are in the United Itingdom (UIF GDPR)

You have the following rights, subject to the conditions and limitations in the UK GDPR:

Right of access to your personal data and information about how we process it (Art. 15).
Rlght to rectification of inaccurate or incomplete data (Art. 16).
Right to erasure in certain circumstances, also called the "right to be forgotten" (Art. 17).
Right to restrict processing in certain circumstances (Art. 18).
Right to data portability for data you provided to us, where processing is based on consent or contract and is carried out by automated means (Art. 20).
Right to object to processing based on legitimate interests, including profiling, and to direct marketing at any time (Art. 21).
Rights related to automated decision-making and profiling (Art. 22). We do not currently make decisions about you that produce legal or similarly significant effects on a solely automated basis.
Right to withdraw consent where processing is based on consent.
Right to lodge a complaint with the UIF Information Commissioner's Office (ICO) at https:Pico.org.uk or by calling +44 0303123 1113. We would appreciate the chance to address your concerns first.

8.2 If you are a California resident (CCPA / CPRA)

You have the following rights:

Right to know what personal information we collect, use, disclose, sell, or share, and the categories of sources, purposes, and recipients.
Right to access the specific pieces of personal information we hold about you.
Right to correct inaccurate personal information we maintain about you.
Right to delete personal information we have collected from you, subject to exceptions.
Rlght to opt out of the sale or sharing of your personal information.
Right to limit the use and disclosure of sensitive personal information for purposes other than those set out in the CCPA. We do not currently use sensitive personal information for any purpose that triggers this right.
Right to portability of your personal information.
Right to non-discrimination for exercising any of your CCPA rights. We will not deny services, charge different prices, or provide different quality of service because you exercised your rights.

8.3 Categories of personal information we have collected, disclosed, or shared in the past 12 months (CCPA disclosure)

CCPA Category

Collected

Disclosed for a Shared for cross-context

business purpose behavioral advertising

A. Identifiers (name, email, IP, account ID)

Yes

B. Customer records (CA Civ § 1798.80(e))

Yes

CCPA Category

Collected

Disclosed for a business purpose

Shared for cross-context behavioral advertising

C. Protected classifications

D. Commercial information

Yes

E. Biometric information

F. Internet or network activity

Yes

G. Geolocation (approximate only)

Yes

H. Audio, visual, or similar information (testimonials,

recordings)

Yes

I. Professional or employment

information

Yes

J. Education information

K. Inferences drawn from the above

Yes

We have not sold personal information for monetary consideration in the past 12 months.

8.4 How to exercise your rights

To exercise any of the rights described above, please contact us using one of the methods below:

Email: [email protected] with the subject line "Privacy Request"
Phone: +1 (305) 570-4723
Mail: GHLstarboys LLC, Attn: Privacy Officer, 312 SW Greenwich Dr, Lees Summit, MO 64082, United States

We will acknowledge your request within 10 business days (CCPA) or without undue delay (UIF GDPR), and respond substantively within 45 days (CCPA, extendable by 45 days where reasonably necessary) or one month (UK GDPR, extendable by two further months for complex requests).

8.5 Verification and authorized agents

To protect your information, we will need to verify your identity before responding to a rights request. We will typically ask you to confirm information we already hold about you (such as

your email address and one other data point). We will not use the information you provide for verification for any other purpose.

You may use an authorized agent to submit a request on your behalf. We will require:

A signed written permission from you authorizing the agent to act, or a valid power of attorney; and
Verification of your own identity directly with us.

9. Do Not Sell or Share My Personal Information (California residents)

We use advertising cookies and pixels (such as the Meta Pixel) that share online identifiers and browsing activity with advertising platforms for cross-context behavioral advertising. Under California law, this may be considered "sharing" or "selling" personal information.

To opt out, you can:

Click "Do Not Sell or Share My Personal Information" in the Site footer.
Reject non-essential cookies in our cookie banner.
Enable a Global Privacy Control (GPC) signal in your browser. We honor GPC as a valid opt-out.
Email [email protected] with the subject line "Do Not Sell or Share".

We do not knowingly sell or share personal information of consumers under 16 years of age.

10. Data security

We use commercially reasonable administrative, technical, and physical safeguards to protect personal information, including encryption in transit (TLS), access controls, and vendor due diligence. However, no system is perfectly secure. We cannot guarantee absolute security and you should take care when transmitting information online.

If we become aware of a personal data breach affecting your information, we will notify you and the relevant supervisory authority where required by law.

11. Children's privacy

Our Site and services are not directed to children. We do not knowingly collect personal information from individuals under 16 years of age. If you believe a child has provided us with personal information, please contact us at [email protected] and we will delete it.

For UIF residents, the age of consent for information society services under the UK GDPR is 13. We do not knowingly collect data from anyone under 13 without parental consent.

12. Third-party links and services

The Site may contain links to third-party websites and services that we do not control. This Privacy Policy does not apply to those third parties. We encourage you to review their privacy policies before providing them with personal information.

13. Changes to this policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date at the top, post the revised policy on this page, and where required, notify you by email or through a prominent notice on the Site. Your continued use of the Site after the revised policy takes effect indicates your acceptance of the changes.

14. Complaints

If you are unhappy with how we handle your personal information, please contact us first so we can try to resolve the issue. You also have the right to complain to the relevant supervisory authority:

UK Information Commissioner's Office (ICO): https:/ico.org.m‹, +44 03031231113
California Privacy Protection Agency: https:/cppa.ca.gov

15. Contact us

For any privacy-related questions, requests, or complaints:

GHLstarboys LLC Attn: Privacy Officer 312 SW Greenwich Dr, Lees Summit, MO 64082, United States Email: [email protected] (subject line:"Privacy Request") Phone: +1(305) 570-4723