- PRIVACY POLICY -

1. General information

The protection of your personal data is important to ZONTAP LLC, so we pay particular attention to protecting the privacy of Visitors who access www.startsera.com, as well as those whose personal data has been provided to us by a third party or to which we have had access from another source, in accordance with Regulation (EU) 2016/679 adopted by the European Parliament and the Council of the European Union on 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.

In this regard, please read carefully the terms of the following Privacy Policy on the protection and processing of personal data to understand how your information will be treated.

This Policy is an information notice and explains ZONTAP's LLC online practices, relating to the application of the provisions of the GDPR, and your rights regarding how your information is used through the www.Startsera.com website.

The processing of personal data by Startsera will always be carried out in accordance with the provisions of the GDPR, as well as with the personal data protection regulations specific to each country in which ZONTAP LLC operates.

With this Personal Data Protection Policy, Startsera wishes to inform Visitors about the nature of the personal data it collects, uses, and processes, as well as the purposes of the processing. In addition, visitors to the site are informed through this Policy also of the rights to which they are entitled.

We note that, as far as Startsera is concerned, this Policy is valid and applies both in respect of the Website and in respect of social media pages associated with our brand and name, including but not limited to Instagram, Facebook, Pinterest and Youtube.

As a result of visiting our Website, obtaining products, or interacting with Startsera through any means or medium of communication, such as email, telephone, or social media, each data subject acknowledges that they agree to this Privacy Policy. If you do not agree and do not wish to accept the information, situations, and/or conditions described in the Policy, please leave the Site and do not access the products provided.

2. Definitions

In this Privacy Policy, unless otherwise expressly stated, the following terms shall have the following meanings:

Consent

is any freely given, specific, informed, and unambiguous indication of the data subject's wishes, by which the data subject signifies his or her agreement, in a statement or unequivocal action, to the processing of personal data relating to him or her.

Personal data

means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

Controller

means the natural or legal person, public authority, agency, or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

Data subject

means any identified or identifiable natural person whose data are processed by ZONTAP LLC as controller, such as subscribers, potential customers, or visitors of the website www.startsera.com.

Privacy Policy / Policy

is the information notice containing the provisions described in this document and is supplemented by the Terms and Conditions of the Site and the Cookie Policy and may also be identified as the Data Protection Policy.

Cookies Policy

is the provision of information about the cookie files that our Site collects and the purposes for which they are used and supplements this Policy and the Site Terms and Conditions.

Processing

means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automatic means, such as collection, recording, organizing, structuring, storing, adapting or altering, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

STARTSERA / we / us / ours

is the trade name of ZONTAP LLC or associated or collaborating companies identifying the economic agent - Romanian legal entities, incorporated and operating in accordance with the laws of Romania, supplying products found on the Website and owning the Website www.startsera.com.

GDPR / GDPR

means Regulation (EU) 2016/679 adopted by the European Parliament and the Council of the European Union on 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC, also referred to as the General Data Protection Regulation.

Our website/ The Website

means the website www.Startsera.com, any section and subsection thereof, and associated Startsera social media profiles/pages, including but not limited to Instagram, Facebook, Youtube, Pinterest.

Terms and conditions

are the provisions of information regarding the use of our website, the relationship with ZONTAP LLC, the collaboration, and agreements that are concluded between you and Startsera as a result of accessing the website and obtaining the products provided, as well as the conditions that apply to the legal relationships that arise between the parties, including through subsequent agreements.

Visitor

means any person who visits, views, or accesses the website www.startsera.com.

3. Personal data controller

The personal data controller is ZONTAP LLC, a Romanian legal entity, with a registered office in Brasov, 50th Tomis St. office no1, Brasov county, registered at the Trade Register under no J8/1977/2020, with ID 43122087, e-mail: contact@startsera.com.

The notion of Startsera is the trade name of ZONTAP LLC, a Romanian legal entity.

ZONTAP LLC may also include other associated or collaborating legal entities which identify the economic agent.

As a personal data controller, Startsera is responsible for the processing of personal data belonging to you that it collects directly or from other sources. Please note that in order to ensure the protection and secure processing of your data, Startsera has made every effort to implement reasonable and appropriate technical and organizational measures.

4. Data Protection Officer (DPO)

Startsera has no legal obligation to appoint a personal data protection officer. Consequently, any request in relation to your personal data should be addressed to the contact details mentioned above.

If you have any queries, questions, comments, or complaints about this Policy or the use of personal data we process, or if you wish to exercise any of your rights, you can always send us your request to contact@startsera.com.

5. What personal data do we process about you?

Depending on the products and functionality you wish to access or purchase, we may need to collect, use, store, and/or transfer certain personal data.

Your personal data that will be processed is as follows:

● identification data, such as first and last name, user name, date of birth, gender, country, etc;

● contact data, such as home address, billing address, e-mail address, and telephone number;

● financial and transactional data, such as payment or card or bank account information, bank card details, information about products purchased, and details of payments to and from the data subject;

● technical data, such as IP (internet protocol) address, login details, browser type and version, location and time zone settings, browser plug-ins and their versions, operating system, operating platform, and other technologies on the devices you use to access this Site and your user account;

● profile data, such as username, password, orders placed, the path taken on products purchased, and answers provided to various questions or surveys;

● statistical and marketing data, such as information on the use of the Site and the products provided, preferences for receiving marketing materials, and preferred means of communication;

● aggregate data, such as the collection, use, and sharing of certain statistical or demographic data.

Aggregate data may be derived from personal data but is not considered "personal data" within the meaning of the law, as this information does not directly or indirectly reveal your identity. In the exceptional situation where aggregate data is combined or linked with personal data in such a way that it is directly or indirectly identifiable, the resulting combined data will be treated by Startsera as personal data, which will be used in the manner described in this Policy.

If you do not wish to provide us with information regarding your personal data, please note that you may not be able to access certain functionalities, purchase the products provided, subscribe, create and/or access your user account, enter into any necessary contracts or collaborations at a later date, or respond to your requests.

Startsera may hold the personal data of subjects both as a result of direct interaction and by obtaining them indirectly or through technology.

For example, Startsera will receive personal data about you in the following situations:

● placing an order;

● creating a user account;

● newsletter subscription;

● sending an email or private message within social networks;

● posting a comment on social platforms, tagging us in posts, or sharing our content.

6. Data processing principles

Startsera is committed to complying with the GDPR's personal data protection principles to ensure that all data is:

● processed fairly, lawfully, and transparently;

● collected for specified, explicit and legitimate purposes;

● adequate, relevant, and limited in relation to the purposes for which it is processed;

● accurate and up-to-date;

● kept in a form that does not enable identification of data subjects for longer than is necessary for the purposes of the processing;

● processed in accordance with the rights of the data subject, in a way that ensures adequate security of the processing so that the data are whole, confidential, and available.

7. Legal basis and purposes of the processing of personal data

● In accordance with Art. 6 section (1) letter b) of the GDPR, personal data may be processed for the purpose of concluding or performing the contract. In order to be able to offer you our products or to conclude possible further cooperation contracts, we need to process personal data belonging to you, such as your name, surname, e-mail address, home or residence address, personal numerical code, series and the number of your identity card or ID card.

● In accordance with Art. 6 section (1) letter. c) of the GDPR, personal data may be processed for the purpose of fulfilling legal obligations, including tax obligations. In order to fulfill certain obligations imposed by tax authorities in connection with invoicing, reimbursement of certain amounts, payment of marketing affiliate fees, or reporting of certain information to the authorities, Startsera may request and process a range of personal data, such as name, surname, home or residence address, personal number code, series, and ID card number.

● In accordance with Article 6 section. (1) letter. a) of the GDPR, personal data may be processed if the data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes.

Startsera only relies on consent for direct marketing purposes, in which case consent is expressly requested. As such, in certain cases, personal data will be used for the purposes of a) potential transmission of newsletters or other marketing, information, or commercial messages; b) possible participation in various contests or promotions.

● In accordance with Art. 6 section (1) letter f) of the GDPR, personal data may be processed for the purposes of legitimate interests pursued by the controller or by a third party for the performance of the business purpose. Such a situation will also take into account the consideration of your interest and that your fundamental rights and freedoms are not affected. The legitimate interest may be to ensure that Startsera ensures the correct functionality of the Site and that the experience of visitors to the Site is constantly improved.

Processing the form to purchase a product on the product presentation page and processing the form to access free digital material

Startsera will use the information you provide in the appropriate section for placing an order to purchase a product or in the appropriate section for obtaining free digital material on the site solely for the purpose of processing your request.

By providing any personal data through the www. Startsera.com website, you understand and agree that your data will be processed in accordance with the provisions of this Startsera Data Protection Policy.

Startsera undertakes not to process the personal data provided for any purpose other than that for which it was submitted unless it is reasonably necessary to use it for another purpose compatible with that of the original processing or unless you have given your express consent to use it for another purpose.

Processing for billing purposes

Startsera will use the information you provide in the order placement section to purchase and pay for the desired product or by sending you a subsequent message or e-mail communicating the details of the paying company, the personal data provided will be used solely for the purpose of processing your request and sending you the invoice for the purchased product.

Payment processor

Startsera uses external payment processing providers to make payments on our website. In connection with the processing of payments in this context, we do not process or retain any personal data or information such as the credit/debit card details with which the payment is made. This information will be provided directly by you to the payment processor and the use of this data is governed by the data protection policies of the providers.

Processing for registration as a User

In order to access digital products, the User must create an account. In this case, Startsera will use the information you provide in the appropriate account creation and login section, such as contact details and identification data, in order to register you as a User and subsequently allow you to access your account.

As a User, you have the possibility to request the deletion of your account and personal data processed by sending a request to this effect to Startsera through the agreed and presented means of communication.

Processing for Newsletter sending

If you have given your consent to subscribe to the Startsera newsletter, we specify that your personal data will be collected, processed, and used for the purpose of sending you various information in our area of activity, information on possible campaigns, and/or marketing messages.

Please note that Startsera reserves the right to select the subscribers to whom it will send newsletters, as well as the right to remove from the database any member who has previously given their consent. The exercise of these rights may be carried out without any further commitment on the part of Startsera and without any prior notification to this effect.

Processing in order to respond to requests

In the event that you contact us by sending a request, notification, question, or message of any kind, Startsera will collect and process the personal data you have communicated and may request additional personal data in order to respond to your request and to resolve any situation or problem you have raised.

By contacting Startsera by any of the means made available, through mediated or unmediated communications, including through the use of social platforms, you understand and agree that your personal data will be processed in accordance with the provisions of this Privacy Policy.

Processing legal claims settlement purpose

Startsera may collect, process and transmit information about your personal data to regulatory authorities, law enforcement agencies, or other entities in the following situations:

● in response to a legal request, where it can be believed in good faith that the law requires it;

● when it can be reasonably believed in good faith that it is necessary to detect, prevent and respond to fraud, unauthorized or improper use of any of our material, possible violations of our terms and conditions or policies, or other harmful or illegal activity in order to protect us (including our rights, property or materials), you and/or others, including in connection with investigations or inquiries by regulatory authorities.

Personal data information that we receive from or about you may be accessed, processed, and stored for a longer period of time if it is the subject of a legal request or legal obligation, a governmental or other investigation into possible violations of our terms and conditions or policies, or in other cases to prevent possible harm.

8. Disclosure of personal data to third parties

Personal data processed through the Startsera Website may only be disclosed and/or transferred to third parties where you have given your express consent to do so unless there is a legal/contractual obligation for Zontap LLC to do so.

By way of example, Startsera may provide personal data to various bodies of the judicial system, such as public prosecutors' offices, police, courts, or other authorized state bodies, on the basis of and within the limits of legal provisions and following an express request.

Please note that in order to process your requests submitted in the section for placing an order and purchasing a product or in the section for accessing free materials on the Site, we may be obliged to disclose your personal data to partners with whom Startsera collaborates and/or other third-party service providers of Startsera under certain circumstances.

By way of example, Startsera may pass on personal data collected to various partners, such as IT (cloud, hosting) or telecommunications service providers, advertising agencies, accounting and human resources services, integrated solution providers, or legal service providers.

However, Startsera has taken appropriate technical and organizational measures to ensure the security of the data transfer as well as the GDPR-compliant processing of your data by the aforementioned entities.

Startsera ensures, within reasonable limits, that personal data collected will not be transmitted outside the European Economic Area. However, in the event that there will be a transfer of data to third EEA states, Startsera will ensure that the transfers are legitimate and will be based on the data subject's express consent or other accepted lawful basis.

Information controlled by Startsera may be transferred, transmitted, stored, and processed in the EEA or in countries other than the country in which you reside for the purposes described in this Policy. In such cases, we note that we use standard contractual clauses approved by the European Commission and rely on country-specific adequacy decisions issued by the European Commission, as appropriate, with respect to transfers of data from the EEA to the United States and other countries.

9. Data processing by third parties, other sites, and sponsors

The www.Startsera.com website may at some point contain links to other websites whose data processing policies may differ from those of Startsera.

Please be aware of and consult the privacy policies of other sites, and Startsera assumes no responsibility for information submitted to or collected by these third parties.

Also, in situations where you interact with Startsera via social media, please be aware that other third parties may also have access to the personal data you provide, such as Facebook or Instagram.

10. Automatic data processing. Cookies

The www.Startsera.com website uses cookie identifiers.

Matters relating to the use of Cookie identifiers are governed by the Cookie Policy, which forms an integral part of and supplements this Policy and the Site Terms and Conditions. Please read the entire Cookie Policy carefully.

As a data subject, you have the option to exercise your right to disable Cookies, as stated in the section on your rights.

11. Data storage

Startsera may retain the processed data for various periods of time necessary to fulfill the stated purposes or deemed reasonable in accordance with the purposes stated above.

Other Startsera legal obligations, lawsuits, and/or investigations may also require the retention of certain personal data you have provided to us.

In general, we retain your personal data only for as long as necessary to fulfill the purpose for which you have provided it to us, to meet your needs, to respond to your requests, or to fulfill our legal obligations.

At this time, we refer to the following criteria for determining the duration of data storage:

● If you have provided us with information in order to obtain products supplied by Startsera, by placing an order, we will collect and process personal data for the purpose of fulfilling the order, as well as fulfilling contractual and/or legal obligations. Such personal data stored in our databases will be deleted from our records within a maximum of 5 (five) years from the date of the last order, with the exception of personal data required from a financial-accounting perspective, which will be processed and stored for the period established by law.

● If you have provided us with information to create and access your User account in order to access digital products, we will collect and process personal data in order to recognize and enable access to the account. Taking into account the permanent possibility to access the account and watch the video courses, granted for an unlimited period of time, such personal data will be processed and stored in our databases until the moment you decide you no longer wishes to hold the account and send us a request to delete your personal data.

● Where you have provided us with information for the purposes of entering into any subsequent contracts or collaboration agreements, we will collect and process personal data for the purposes of concluding and performing the contract and fulfilling contractual and/or legal obligations. Such personal data will be processed and stored for the period necessary to fulfill the subject matter of the contract and any legal obligations arising from it. For example, in the case of financial accounting supporting documents, the storage period laid down by law is 10 (ten) years from the end of the financial year in which they were drawn up.

● If you have opted to subscribe to the Startsera newsletter, we will collect and process your personal data in order to send you various information in our area of activity, information on possible campaigns and/or marketing messages. Such data will be processed and stored until you decide to unsubscribe using one of the options offered for this purpose.

● If you contact us with certain questions or requests, we will collect and process your personal data for the purpose of responding to your request. Such personal data will be processed and stored for the period necessary to process the request and to resolve it, but no longer than 5 (five) years from the last correspondence sent.

● In the case of cookies used, they are stored on the computer for as long as necessary to achieve the purposes they serve (e.g. cookies for the account login session) and for a period defined in accordance with the usual regulations and guidelines.

To learn more about the use of cookies, please review the Cookie Policy on our Site.

12. Rights of data subjects

Data subjects have the following rights under the GDPR with regard to the personal data Startsera processes:

● Right of access to processed data: you have the right to access the personal data we hold. The first provision of information will be done without any charge. If you require further copies of the information already provided, we may charge a reasonable fee, taking into account the administrative costs of providing the information. Obvious unreasonable, excessive, or repeated requests may not be answered.

● Right to rectification of data: you have the right to ask for your data to be rectified if it is inaccurate or out of date and/or to have it completed if it is incomplete.

● Right to erasure of data ("right to be forgotten"): In certain circumstances, you have the right to have your data erased or destroyed. This is not an absolute right, as sometimes we may need to retain your data for legal or judicial reasons.

● Right to restrict processing: you have the right to request that we restrict the processing of your data. This means that the processing of your data is restricted so that we can keep the data but not use or process it. This right applies in specific circumstances set out in the General Data Protection Regulation, namely:

○ the accuracy of the data is contested by the data subject (you), for a period that allows the controller (Startsera) to verify its accuracy;

○ the processing is unlawful and the data subject (you) objects to the erasure of the data and requests the restriction of its use;

○ the controller (Startsera) no longer needs the data for processing, but they are requested by the data subject (you) for the establishment, exercise, or defense of legal claims;

○ the data subject (you) has raised objections to the processing on legitimate grounds on the part of the controller (Startsera), based on the verification of whether the legitimate grounds of the controller (Startsera) outweigh those of the data subject (you).

● Right to data portability: you have the right to move, copy or transfer the data concerning you from our database to another one. This only applies to data you have provided, where the processing is based on your consent or on the basis of a contract and is implemented by automated, easily accessible means.

● Right to object: you may object at any time to the processing of your data when such processing is based on legitimate interest.

● Right to withdraw consent at any time: you may withdraw your consent to the processing of your data where such processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to the withdrawal of consent.

● Right to lodge a complaint with the competent supervisory authority: you have the right to lodge a complaint with the data protection authority in your country of residence or domicile to challenge Startsera's data protection practices. In Romania, this body is represented by the National Supervisory Authority for Personal Data Processing (ANSPDCP), which is based in Bucharest, bd. G-ral. Gheorghe Magheru nr. 28-30, Sector 1, postal code 010336, and has the following contact details: telephone +40.318.059.211 or +40.318.059.212, e-mail address anspdcp@dataprotection.ro.

● The right to object to the processing of your data by us when we are acting in the public interest or in our own or a third party's legitimate interests: you may object at any time to the processing of your data when such processing is based on a legitimate interest.

● The right to object to the processing of your data for direct marketing purposes (right to unsubscribe): you have the option, permanently and in full, to unsubscribe from our newsletter or to request us to stop sending you marketing messages, either by accessing the unsubscribe link included in the emails or by sending Startsera an email requesting to be removed from the database.

● Right to disable Cookies: you have the ability, in part or in whole, to disable cookies. Internet browser settings are usually programmed by default to accept cookies, but you can easily change them by going to and changing your browser settings. For more details, visit our Cookie Policy.

You can exercise any of these rights in relation to the personal data Startsera processes by simply sending a request to Startsera at the contact details provided. In such a case, we may well require proof of your identity.

Please note that the rights listed above are not absolute. In certain situations there may be exceptions, so each request received will be examined to decide whether it is justified or not. If the request is justified, it will be dealt with as requested. If the request is unfounded, we will reject it and if necessary, we will give you the reasons for the rejection and your further rights.

Startsera will make every effort to respond to your request within a maximum of 30 (thirty) days. However, in certain situations and taking into account different circumstances, this deadline may be extended, depending on the complexity of the request, the large number of requests received, the impossibility of identifying the applicant in the optimal timeframe, or the waiting for responses from other bodies.

In the event of unsubscribing from marketing messages, please note that this unsubscription does not apply to personal data you have provided to us for another purpose, for example when you have requested a product from Startsera.

13. Processing security

Startsera has adopted technical and organizational data processing measures, updated in accordance with GDPR requirements, in order to protect your personal data against any unauthorized access, misuse or disclosure, unauthorized modification, destruction, or accidental loss. All Startsera employees and collaborators, as well as any third parties acting on behalf of and for Startsera, are obliged to respect the confidentiality of your information in accordance with the provisions of this Data Protection Policy.

In order to guarantee the protection provided with regard to the personal data we process, Startsera has implemented measures such as adopting dedicated data processing policies and protecting systems against possible unauthorized access, minimizing and limiting the data it processes, restricting access to the data processed, using technologies to ensure data security and training staff and collaborators on applicable legislation.

However, we draw attention to the fact that undesirable events may also occur, involving various security incidents or breaches. In such situations, we will follow the procedure for reporting and notifying security incidents and will take all necessary steps to mitigate the effects of the incident and restore the situation to its previous normal state.

14. Disclaimer of liability

The Startsera website may contain links to other websites and/or webpages that are not owned by Startsera. Startsera assumes no responsibility for the content of such sites and therefore shall not be liable for any content, advertising, goods, services, software, information, or other materials available on or through such sites. Startsera shall not be liable for any loss of personal data, any adverse effects on visitors' personal data, or any other moral and/or pecuniary damage caused by accessing such sites.

As such, Startsera encourages and advises you to read and be aware of the existing Privacy Policies on any site and/or application you access before proceeding to provide personal data.

15. Update of the Personal Data Protection and Processing Policy

Please note that this Policy may be subject to periodic content changes by updating the Startsera Site. You should therefore check this page for any updates.

Please do not continue to use the Startsera Site if you do not agree to such changes.

The terms of this Policy shall be construed in accordance with applicable law.