Referral Programme Terms

These Referral Programme Terms (“Terms”) govern participation in the Starlight Referral Programme (the “Programme”) offered by Star21 Limited (“Starlight”, “we”, “us”, or “our”). By applying to the Programme, accessing referral tools, or submitting referrals, you agree to comply with these Terms in addition to the platform Terms of Service .

Please read these Terms carefully. You must accept them before submitting an application at /referral-program/apply .

1. Definitions

In these Terms, “Referrer” means an approved Programme participant, “Referral” means the introduction of a new organisation to Starlight, and “Referred Organisation” is the organisation that enrols with Starlight as a result of the referral. References to “Dashboard” or “Referral Tools” mean the features made available to approved Referrers inside the Starlight platform, including tracked links and invite workflows. “Qualified Referral” means a referral that meets all eligibility and verification requirements as determined by Starlight in its sole discretion.

2. Eligibility

  • You must hold an active Starlight user account in good standing and be at least 18 years old.
  • Programme participation is by application and subject to Starlight’s sole and absolute approval. Approval may be withheld, delayed, or withdrawn at any time without notice or reason.
  • We reserve the right to request additional information to verify your identity, business activities, professional credentials, or compliance with these Terms at any time. Failure to provide requested information within 14 days may result in suspension or termination.
  • Employees, contractors, or immediate family members of Star21 Limited staff are ineligible to participate unless expressly authorised in writing.
  • You must not be subject to any sanctions, restrictions, or legal prohibitions that would prevent you from participating in commercial promotional activities.

3. Application & Approval

  • Applications must provide accurate, complete, and truthful information about your intended referral activity, professional background, and business relationships.
  • Submitting an application does not create any contractual relationship or entitlement. You may not promote yourself as a Starlight Referrer, use our brand, or share referral links until your application has been expressly approved in writing.
  • If your application is rejected, you may reapply after addressing the feedback provided, subject to any restrictions we may impose. We reserve the right to reject reapplications without providing reasons.
  • Providing false, misleading, or incomplete information in your application may result in permanent disqualification from the Programme.

4. Referral Tools & Conduct

  • Approved Referrers receive a unique referral link tied to their user UUID. You must not share, transfer, sell, or permit others to use your referral link. Any unauthorised use may result in forfeiture of all commissions.
  • Email invitations sent through the Programme must use only the provided tooling and comply with the rate limits and safeguards built into the system. Automated, scripted, bulk messaging outside approved workflows, or attempts to circumvent rate limits are strictly prohibited.
  • You must comply with all applicable marketing, privacy, anti-spam, data protection, and consumer protection laws in every jurisdiction where you promote Starlight, including but not limited to the UK GDPR, PECR, and the Consumer Protection from Unfair Trading Regulations.
  • Referrals must be made in good faith to genuinely interested prospects. Self-referrals, referring organisations you control or have a financial interest in, incentivising fraudulent sign-ups, misrepresenting Starlight’s services, or making unauthorised promises on our behalf will lead to immediate removal from the Programme and forfeiture of all commissions.
  • You must not engage in any activity that could damage Starlight’s reputation, including making disparaging comments about competitors, engaging in spam, or using unethical marketing practices.

5. Tracking & Attribution

  • Attribution relies on unique referral URLs, first-party cookies, invite tokens, and internal tracking mechanisms with a 30-day attribution window from the date of initial click or invite acceptance.
  • A referral is attributed when the Referred Organisation enrolls within the attribution window and we can verify the connection to your satisfaction using our tracking systems. Attribution decisions are made by Starlight in its sole discretion.
  • If tracking is impeded (for example, by privacy settings, use of different devices, VPNs, cookie blockers, or browser configurations), we will make reasonable efforts to validate the referral manually, but attribution cannot be guaranteed and is entirely at our discretion.
  • In cases of disputed attribution, including where multiple Referrers claim credit for the same organisation, Starlight’s determination shall be final and binding.
  • Technical issues, system errors, or tracking failures do not create any obligation to attribute referrals or pay commissions. You acknowledge that tracking is provided on a best-efforts basis.

6. Commission & Payment

  • The default referral commission is a one-time payment of £250 (inclusive of any taxes you are obliged to remit) per Qualified Referral that completes full enrolment as determined by Starlight.
  • Commission amounts are indicative and may be adjusted by Starlight at any time. We reserve the right to set different commission amounts for different Referrers, organisations, or promotional periods without notice.
  • Only one commission is payable per Referred Organisation. Duplicate referrals, re-referrals, enrolments of existing customers, organisations that have previously trialled Starlight, or organisations already in discussions with Starlight do not qualify for commission.
  • Commission becomes potentially payable only when: (a) the Referred Organisation has fully enrolled and paid all required fees; (b) any applicable cooling-off, trial, or probationary period has passed; (c) the account remains active and in good standing for at least 60 days; (d) no refunds, chargebacks, or disputes have been raised; and (e) we have verified the referral as Qualified in our sole discretion.
  • Starlight reserves the right to withhold, delay, reduce, or refuse commission payments at our sole discretion, including but not limited to cases where we suspect fraud, policy violations, payment disputes, quality concerns, or any conduct that may harm Starlight’s interests.
  • Payments are processed manually and at Starlight’s convenience. While we aim to issue payouts within 90 days of verification, no guaranteed timeline exists. Payments are subject to receipt of any required invoices, tax documentation, identity verification, bank details, and completion of our compliance checks.
  • We may aggregate multiple commissions and issue payments on a quarterly basis if individual amounts fall below £100.
  • All payment methods and currencies are at Starlight’s discretion. We reserve the right to deduct processing fees, transfer costs, or currency conversion charges from commission payments.
  • Commissions are earned by individuals, not transferable, and cannot be assigned, sold, or passed to third parties. In the event of your death or incapacity, unpaid commissions may be forfeited unless we agree otherwise in writing.

7. Commission Forfeiture & Clawback

  • Starlight reserves the right to withhold or reclaim any commission if: (a) the Referred Organisation cancels, requests a refund, or ceases using Starlight within 90 days of enrolment; (b) we determine the referral was not made in good faith; (c) you breach any provision of these Terms; (d) the Referred Organisation's account is terminated for policy violations; or (e) we identify any fraudulent, misleading, or unethical conduct in connection with the referral.
  • If we have already paid a commission that subsequently becomes subject to forfeiture or clawback, you agree to repay the full amount to Starlight within 30 days of our written request. We may offset such amounts against future commission payments or pursue recovery through legal means.
  • Chargebacks, payment failures, or fraud associated with a Referred Organisation will result in immediate forfeiture of related commissions and may lead to Programme termination.

8. Taxes & Reporting

You are solely responsible for determining and satisfying any tax obligations arising from referral commissions, including income tax, VAT, national insurance, or any other applicable taxes in your jurisdiction. Starlight may request invoices, VAT registration details, tax forms (such as W-9, W-8BEN), or other documentation before releasing payment and may withhold payments until such documentation is provided. We may report payments to HMRC or other relevant tax authorities as required by law. You indemnify Starlight against any tax liabilities, penalties, or interest arising from your participation in the Programme.

9. Data Protection & Confidentiality

  • You must protect any non-public information you access through the Programme, including dashboard data, performance metrics, commission information, referral invite details, and any communications with Starlight personnel. This information is confidential and proprietary.
  • Personal data obtained through the Programme may only be used for the legitimate purposes of managing the referral relationship with Starlight and must be handled in strict compliance with the UK GDPR, Data Protection Act 2018, PECR, and all other applicable data protection laws.
  • You must obtain valid consent before sending marketing communications and maintain evidence of such consent. You must honour all opt-out requests promptly and maintain your own suppression lists.
  • You must promptly notify Starlight of any suspected unauthorised access, data breach, or misuse of Programme data. Failure to do so may result in liability for resulting damages.
  • Upon termination, you must immediately cease processing any personal data obtained through the Programme and securely delete or return such data as directed by Starlight.

10. Use of Starlight Brand & Intellectual Property

  • You may reference Starlight and use only approved marketing materials expressly provided by us solely to promote legitimate referral opportunities. Any other use requires prior written approval.
  • You must not modify, adapt, or create derivative works from Starlight trademarks, logos, creative assets, or copyrighted materials. You must not register or attempt to register any domain names, social media handles, or trademarks incorporating Starlight branding.
  • You must not imply any partnership, joint venture, employment, agency, endorsement, or authorised reseller relationship beyond that of an independent referral partner.
  • All intellectual property rights in the Starlight platform, brand, and materials remain the exclusive property of Star21 Limited. No licence or rights are granted except as expressly set forth herein.
  • You must immediately cease all use of Starlight branding and materials upon termination of your participation.

11. Prohibited Activities

In addition to the general conduct requirements, you must not:

  • Purchase, bid on, or otherwise use search advertising (including Google Ads, Bing Ads, or similar) that targets Starlight trademarks, brand terms, product names, or common misspellings thereof.
  • Engage in misleading, deceptive, false, or high-pressure sales tactics, or make any unauthorised claims, guarantees, or promises about Starlight’s services, pricing, or capabilities.
  • Offer unauthorised incentives, discounts, bonuses, or rewards to prospects in exchange for enrolling via your referral link without our prior written consent.
  • Distribute malware, spyware, viruses, or other harmful code; engage in hacking, phishing, or social engineering; or compromise the security or integrity of any systems in connection with referral activities.
  • Publish, share, or distribute content that violates our community standards, Acceptable Use Policy, applicable law, or infringes third-party rights.
  • Engage in cookie stuffing, forced redirects, iframing, or any other techniques designed to fraudulently trigger tracking or attribution mechanisms.
  • Misrepresent your identity, credentials, relationship with Starlight, or affiliation with any organisation.
  • Solicit referrals from prospects who are already in active discussions with Starlight, have previously used Starlight, or have been contacted by Starlight’s sales team within the past 12 months.

12. Verification & Compliance

  • Starlight reserves the right to investigate and verify any referral, application, or commission claim through any means we deem appropriate, including requesting supporting documentation, conducting interviews, or engaging third-party verification services.
  • You agree to cooperate fully with any such verification efforts and provide requested information within reasonable timeframes. Failure to cooperate may result in denial of commission and termination from the Programme.
  • We may audit your referral activities, marketing materials, and compliance with these Terms at any time. You agree to provide access to relevant records, communications, and systems upon request.
  • If we identify any violations, discrepancies, or concerns during verification, we may suspend payments pending investigation and resolution.

13. Suspension & Termination

  • Starlight may suspend or terminate your participation immediately and without prior notice if we believe, in our sole discretion, that you have breached any provision of these Terms, our platform Terms of Service, Acceptable Use Policy, or applicable law, or if we determine that continued participation may harm Starlight’s interests, reputation, or business relationships.
  • We may also terminate your participation for convenience at any time with or without cause by providing 30 days’ written notice.
  • You may end your participation by providing written notice to Starlight and immediately ceasing all use of the referral tools and Starlight branding.
  • Upon termination for any reason: (a) you must immediately stop holding yourself out as a Starlight Referrer; (b) cease all use of referral links, tools, and marketing materials; (c) remove or disable any content, links, or materials that reference your participation in the Programme; and (d) return or destroy any confidential information in your possession.
  • Termination does not automatically entitle you to payment of pending commissions. All commissions remain subject to verification, the terms of Section 6, and our discretion to withhold or forfeit payments as set forth in Section 7.
  • Sections that by their nature should survive termination (including but not limited to Sections 6, 7, 8, 9, 10, 14, 15, 16, and 17) shall remain in full force and effect.

14. Changes to the Programme

  • We reserve the right to modify, update, suspend, or discontinue the Programme or any aspect thereof, including these Terms, commission structures, eligibility criteria, tracking mechanisms, and available tools, at any time and for any reason at our sole discretion.
  • Material changes to these Terms will be communicated via email to the address associated with your account or through a dashboard notification. Non-material changes may be implemented without notice.
  • Continued participation in the Programme after changes take effect constitutes your acceptance of the updated Terms. If you do not agree to the changes, you must terminate your participation immediately.
  • Changes to commission rates or Programme terms will not apply retroactively to Qualified Referrals already verified and approved for payment, unless required by law or to prevent fraud.

15. Disclaimers & Limitation of Liability

  • The Programme is provided “as is” and “as available” without warranties of any kind, whether express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, non-infringement, uninterrupted operation, or accuracy of tracking.
  • Starlight does not guarantee any particular level of referrals, conversions, earnings, or commission payments. Your success in the Programme depends on numerous factors outside our control.
  • We are not responsible for: (a) technical failures, tracking errors, or system outages that affect attribution; (b) third-party actions or decisions of Referred Organisations; (c) changes in market conditions, customer behaviour, or competitive factors; or (d) your failure to comply with these Terms or applicable laws.
  • To the maximum extent permitted by law, Star21 Limited, its directors, officers, employees, agents, and affiliates shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits, revenue, data, or business opportunities arising from or related to your participation in the Programme, even if advised of the possibility of such damages.
  • Our total aggregate liability to you for all claims arising from or related to the Programme shall not exceed the total commission payments actually received by you in the 12 months immediately preceding the claim, or £100, whichever is less.

16. Indemnification

You agree to indemnify, defend, and hold harmless Star21 Limited, its subsidiaries, affiliates, officers, directors, employees, agents, licensors, and suppliers from and against any and all claims, liabilities, damages, losses, costs, expenses, or fees (including reasonable legal fees and costs) arising from or relating to: (a) your participation in the Programme; (b) your breach of these Terms or any applicable law; (c) your referral activities, marketing practices, or communications with prospects; (d) your infringement or misappropriation of any intellectual property or other rights of any third party; (e) any data protection violations or privacy breaches; (f) any misrepresentation or unauthorised claim made by you; or (g) any dispute between you and a Referred Organisation. This indemnification obligation survives termination of your participation.

17. Independent Contractor Relationship

You are an independent contractor and nothing in these Terms creates any partnership, joint venture, agency, franchise, sales representative, or employment relationship between you and Starlight. You have no authority to bind Starlight or make commitments on our behalf. You are solely responsible for your own tax obligations, business expenses, insurance, and compliance with laws applicable to your activities. You will not be entitled to any employee benefits, including but not limited to pension schemes, sick pay, holiday pay, or redundancy payments.

18. General Provisions

  • Governing Law: These Terms are governed by and construed in accordance with the laws of England and Wales, without regard to conflict of law principles. Any disputes arising from or related to these Terms or the Programme shall be subject to the exclusive jurisdiction of the courts of England and Wales.
  • Entire Agreement: These Terms, together with the Starlight Terms of Service and Privacy Policy, constitute the entire agreement between you and Starlight regarding the Programme and supersede all prior or contemporaneous communications, agreements, and understandings, whether written or oral.
  • Severability: If any provision of these Terms is held to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect, and the invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable.
  • Waiver: Our failure to enforce any right or provision of these Terms shall not constitute a waiver of such right or provision or any other right or provision. Any waiver must be in writing and signed by an authorised representative of Starlight.
  • Assignment: You may not assign, transfer, or delegate your rights or obligations under these Terms without our prior written consent. Starlight may assign or transfer these Terms or any rights hereunder without restriction.
  • No Third-Party Beneficiaries: These Terms are solely for the benefit of you and Starlight and do not create any third-party beneficiary rights.
  • Force Majeure: Starlight shall not be liable for any failure or delay in performance due to circumstances beyond our reasonable control, including but not limited to acts of God, war, terrorism, strikes, pandemics, government actions, or technical failures.
  • Notices: All notices under these Terms must be in writing and sent to the email address associated with your account (for notices to you) or to referrals@starlightmentor.com (for notices to Starlight). Notices are deemed received when sent by email.

19. Contact

Questions about the Programme or these Terms? Contact us .

Last updated: 30 October 2025