Privacy Policy

Last updated: 22 September 2026

This Privacy Policy explains how StArt Unlimited Ltd (“StArt”, “we”, “us” or “our”) collects, uses, stores and protects personal data when you visit StArt Unlimited, create an account, subscribe to our newsletter, contact us, purchase our products or services, participate in our educational offerings, or otherwise interact with us.

We are committed to processing personal data lawfully, fairly and transparently and in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable data protection laws.

1. Who We Are

The data controller responsible for the processing of personal data described in this Privacy Policy is:

StArt Unlimited Ltd
Registered office: 2415 Izvor, Radomir Municipality, Pernik Province, Bulgaria
Email: contact@startunlimited.net
Additional contact email: info@startunlimited.net
Phone: +359 899 277 607

For questions concerning this Privacy Policy or the processing of your personal data, you may contact us at contact@startunlimited.net.

2. Personal Data We Collect

The personal data we collect depends on how you interact with StArt.

Information You Provide Directly

We may collect information that you voluntarily provide to us, including:

first and last name;
email address;
telephone number;
billing or contact address;
account and registration information;
order and transaction information;
information provided when purchasing or accessing courses, digital products, systems, tools or programs;
information contained in messages, enquiries or other correspondence you send to us;
newsletter subscription information; and
any other information you choose to provide through our website or services.

We only request personal data that is relevant to the particular service or interaction.

Information Collected Automatically

When you use our website, certain technical information may be collected automatically, depending on your browser settings and cookie preferences.

This may include:

IP address;
browser type and version;
device type;
operating system;
time zone;
referring website or source;
pages viewed;
interactions with the website;
date and time of visits;
cookie identifiers; and
similar technical and usage information.

For more information about our use of cookies and similar technologies, please refer to our Cookie Policy and the cookie settings available on our website.

3. How We Collect Personal Data

We may collect personal data:

directly from you when you provide it to us;
when you create or use an account;
when you purchase a product or service;
when you enrol in or access an educational offering;
when you subscribe to our newsletter;
when you submit a contact form or communicate with us;
automatically when you interact with our website, subject to applicable cookie and consent requirements;
through service providers that support the operation of our website and services; or
where permitted by law, from other legitimate sources.

4. How and Why We Use Personal Data

We process personal data only where we have an appropriate legal basis for doing so.

Depending on your interaction with StArt, we may process personal data for the following purposes.

Providing Our Products and Services

We may process your personal data to:

create and administer your account;
process orders;
provide access to digital products, courses, systems, tools and programs;
manage customer relationships;
provide customer support; and
fulfil our contractual obligations to you.

The legal basis for this processing is generally Article 6(1)(b) GDPR — performance of a contract or taking steps at your request before entering into a contract.

Contact and Enquiries

When you contact us, we may process your name, contact information, message and related correspondence in order to respond to your enquiry and communicate with you.

Depending on the nature of the enquiry, the legal basis may be:

Article 6(1)(b) GDPR, where the communication concerns a contract or steps requested before entering into one; or
Article 6(1)(f) GDPR — our legitimate interests, including communicating with individuals and organisations interested in StArt and managing our business correspondence.

Newsletter and Marketing Communications

If you subscribe to the StArt newsletter or expressly request marketing communications, we may use your email address and related subscription information to send you editorial updates, new releases, educational content and other StArt communications.

Where required, this processing is based on your consent under Article 6(1)(a) GDPR.

You may unsubscribe at any time using the unsubscribe mechanism included in our communications or by contacting us.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Website Operation and Security

We may process limited technical information where necessary to:

operate and maintain the website;
maintain security;
detect technical problems;
prevent fraud, misuse or unauthorised access; and
protect our systems, users and business.

Where applicable, this processing is based on our legitimate interests under Article 6(1)(f) GDPR in operating and securing our website and services.

Analytics and Website Improvement

Subject to your cookie choices and applicable law, we may use analytics technologies to understand how visitors use our website and to improve its functionality, structure and content.

Where consent is legally required for the relevant technologies, such processing will take place only after you have provided the necessary consent.

You can manage your preferences through our cookie settings.

Legal and Regulatory Obligations

We may process and retain certain information where necessary to comply with applicable legal obligations, including accounting, taxation, consumer protection and other regulatory requirements.

The legal basis for this processing is Article 6(1)(c) GDPR — compliance with a legal obligation.

5. Legal Bases for Processing

Depending on the circumstances, StArt may process personal data on one or more of the following legal bases:

Consent — Article 6(1)(a) GDPR
Where you have freely given consent for a specific purpose, such as certain marketing communications or non-essential cookies.

Contract — Article 6(1)(b) GDPR
Where processing is necessary to provide a product or service you have requested or to take steps before entering into a contract.

Legal obligation — Article 6(1)(c) GDPR
Where we are required to process or retain information in order to comply with applicable law.

Legitimate interests — Article 6(1)(f) GDPR
Where processing is necessary for our legitimate business interests and those interests are not overridden by your fundamental rights and freedoms.

Such legitimate interests may include website and information security, responding to general enquiries, preventing fraud and misuse, maintaining business records and improving the operation of our services.

6. Accounts, Orders and Digital Products

If you create an account, purchase a product or service, or access educational or digital content through StArt, we may process information necessary to administer your account, fulfil your order, provide access to the relevant content and provide customer support.

Certain information may also need to be retained after completion of a transaction in order to comply with accounting, taxation, consumer protection or other legal requirements.

Where information is required in order to enter into or perform a contract, failure to provide the necessary information may mean that we cannot provide the relevant product or service.

7. Payments

Payments may be processed through third-party payment service providers.

Depending on the payment method you select, the payment provider may collect and process payment information directly under its own terms and privacy practices.

StArt may receive information necessary to confirm and administer a transaction, such as payment status, transaction identifiers, customer information and related billing information.

We do not intentionally collect or store full payment-card credentials where those credentials are processed directly by an authorised payment service provider.

8. Newsletter and Marketing

Subscription to the StArt newsletter is voluntary.

When you subscribe, we may process information such as your email address, name where provided, subscription status, consent records and information necessary to administer the subscription.

You may unsubscribe at any time.

Where marketing processing is based on consent, you also have the right to withdraw that consent at any time.

We do not require you to subscribe to marketing communications in order to purchase unrelated products or use services where such subscription is not necessary.

9. Cookies and Similar Technologies

Our website may use cookies and similar technologies for purposes including:

essential website functionality;
security;
remembering preferences;
analytics; and
other functions disclosed through our cookie management system.

Cookies that are strictly necessary for the operation of the website may be used without consent where permitted by applicable law.

Where consent is required for non-essential cookies or similar technologies, they will be used in accordance with the preferences you provide through our cookie consent mechanism.

You can review or change your cookie preferences through the cookie settings available on our website.

Please refer to our Cookie Policy for additional information.

10. Service Providers and Other Recipients

We may use carefully selected third-party service providers to support the operation of StArt.

Depending on the services you use, these may include providers of:

website hosting and technical infrastructure;
payment processing;
email and newsletter delivery;
customer and account management;
educational or course-delivery technology;
analytics;
security and fraud prevention;
professional accounting, legal or technical services; and
other infrastructure necessary to provide our services.

These parties may receive or process personal data only where necessary for their respective functions and subject to applicable data protection requirements.

We may also disclose personal data where required by law, court order or a lawful request from a competent public authority, or where reasonably necessary to establish, exercise or defend legal claims.

11. International Data Transfers

Some of the service providers we use may process personal data outside Bulgaria or the European Economic Area (“EEA”).

Where personal data is transferred outside the EEA, we take steps to ensure that the transfer is made in accordance with applicable data protection law.

Depending on the destination and service provider, this may include reliance on:

an adequacy decision adopted by the European Commission;
appropriate contractual safeguards, including Standard Contractual Clauses; or
another lawful transfer mechanism available under the GDPR.

Where applicable, you may contact us for further information regarding the safeguards used for international transfers of your personal data.

12. How Long We Keep Personal Data

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected and as required by applicable law.

The appropriate retention period depends on factors including:

the nature of the personal data;
the purpose for which it was collected;
the duration of our relationship with you;
whether you maintain an account or subscription;
applicable accounting, taxation, consumer protection or other legal requirements;
the need to resolve disputes or respond to enquiries; and
the establishment, exercise or defence of legal claims.

Where consent is the basis for processing, we will cease the relevant processing when consent is validly withdrawn unless another lawful basis permits or requires continued retention of particular information.

When personal data is no longer required, we will delete, anonymise or otherwise dispose of it in accordance with applicable requirements.

13. Data Security

We use reasonable technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

These measures may include appropriate access controls, technical safeguards, secure service providers and organisational procedures.

However, no method of transmitting or storing information electronically can guarantee absolute security.

14. Your Rights Under the GDPR

Where the GDPR applies to the processing of your personal data, you may have the following rights, subject to the conditions and limitations provided by law:

Right to information — to receive clear information about how your personal data is processed.
Right of access — to request confirmation of whether we process your personal data and obtain access to it.
Right to rectification — to request correction of inaccurate or incomplete personal data.
Right to erasure — to request deletion of personal data in circumstances provided by law.
Right to restriction of processing — to request that processing be restricted in certain circumstances.
Right to data portability — to receive certain personal data in a structured, commonly used and machine-readable format and, where applicable, have it transmitted to another controller.
Right to object — to object to processing based on legitimate interests in circumstances provided by law.
Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time.
Rights concerning automated decision-making — rights relating to certain decisions based solely on automated processing, including profiling, where applicable.

These rights are not absolute and may be subject to exceptions or limitations under applicable law.

GDPR expressly provides these core data-subject rights. Eur-Lex

15. How to Exercise Your Rights

To exercise your data protection rights or ask a question about our processing of your personal data, contact:

contact@startunlimited.net

We may need to request information reasonably necessary to verify your identity before fulfilling certain requests.

We will respond to valid requests within the time limits required by applicable data protection law.

16. Right to Lodge a Complaint

If you believe that your personal data has been processed in violation of applicable data protection law, you have the right to lodge a complaint with a competent supervisory authority.

In Bulgaria, the supervisory authority is the:

Commission for Personal Data Protection (CPDP)
2 Prof. Tsvetan Lazarov Blvd.
1592 Sofia
Bulgaria

The Bulgarian CPDP confirms the right to lodge a complaint against a controller or processor for alleged infringements of GDPR or the Bulgarian Personal Data Protection Act. Комисия за защита на личните данни

You may also have the right to approach another competent supervisory authority where permitted under the GDPR.

17. Automated Decision-Making

StArt does not currently use personal data to make decisions that produce legal effects concerning you, or similarly significantly affect you, based solely on automated processing, including profiling.

If this changes, we will update this Privacy Policy and provide the information required by applicable law.

18. Third-Party Websites

Our website may contain links to websites or services operated by third parties.

StArt is not responsible for the privacy practices, content or security of third-party websites that we do not control.

We encourage you to review the privacy information provided by the relevant third party before providing personal data.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, technologies, legal obligations or data-processing practices.

When we make changes, we will update the “Last updated” date at the beginning of this Privacy Policy.

Where required by law, we will provide additional notice or request renewed consent before implementing a material change affecting processing based on consent.