Privacy Policy for startsmartly.co

Effective Date: September 30, 2025
Contact: contact@startsmartly.co

This Privacy Policy explains how startsmartly.co (“the Platform”, “we”, “our”, “us”) collects, uses, and protects your personal data in compliance with the General Data Protection Regulation (GDPR), the Payment Services Directive 2 (PSD2), and Strong Customer Authentication (SCA) requirements.

By accessing or using the Platform, you agree to this Privacy Policy.

1. Information We Collect

We collect and process the following categories of personal data:

• Account Information: Name, email address, password, and profile details.
• Transaction Data: Payment details, purchase history, payout information (processed securely by third-party payment providers).
• Verification Data (SCA/PSD2): Identity confirmation, authentication tokens, device/browser identifiers required for secure transactions.
• Content & Communications: Listings, reviews, and messages shared on the Platform.
• Technical Data: IP address, cookies, device identifiers, browser type, and usage analytics.

2. How We Use Your Information

We use your personal data to:

• Provide and operate the Platform.
• Process payments and seller payouts in compliance with PSD2 and SCA.
• Authenticate transactions securely (e.g., 2-factor authentication, biometrics).
• Communicate updates, support, and promotional offers (with consent).
• Ensure fraud prevention, legal compliance, and platform security.

3. GDPR Compliance

Under GDPR, we process personal data based on the following lawful bases:

• Contractual necessity: To provide products, process transactions, and fulfill agreements.
• Consent: For marketing communications, optional features, or non-essential cookies.
• Legal obligation: To comply with tax, financial, and regulatory requirements.
• Legitimate interests: To secure the Platform, prevent fraud, and improve services.

GDPR Rights

If you are in the EU/EEA or UK, you have the right to:

• Access, correct, or delete your personal data.
• Restrict or object to processing.
• Request portability of your data.
• Withdraw consent at any time.
• File a complaint with your local supervisory authority.

4. PSD2 & Strong Customer Authentication (SCA)

We comply with PSD2 requirements for secure payment services:

• Authentication: All electronic payments may require two or more independent authentication factors:
  1. Something you know (e.g., password or PIN)
  2. Something you have (e.g., phone or card)
  3. Something you are (e.g., fingerprint, facial recognition)
• Exemptions: Low-value or recurring transactions may be exempt, but security checks are applied where risk is detected.
• Payment Data: Sensitive payment data is never stored on our servers and is handled by PCI-DSS compliant payment providers.

5. Data Sharing

We only share your personal data with:

• Payment processors and banks (to securely process transactions).
• Service providers (hosting, analytics, technical support).
• Legal authorities (where required by law).

We do not sell or rent your personal data.

6. Data Security & Retention

• We use encryption, secure servers, and industry-standard safeguards to protect your information.
• Payment-related data is protected with SCA measures and processed exclusively by compliant providers.
• Personal data is retained only as long as necessary for service delivery, legal compliance, and dispute resolution.

7. International Transfers

Where data is transferred outside the EU/EEA/UK, we ensure appropriate safeguards such as Standard Contractual Clauses (SCCs) are in place.

8. Cookies & Tracking

We use cookies and similar technologies to:

• Authenticate logins and secure transactions.
• Remember preferences.
• Improve analytics and performance.

You may disable cookies via your browser, but this may impact functionality.

9. Updates

We may revise this Privacy Policy to reflect changes in law, technology, or our practices. Updates will be posted with a new Effective Date. Continued use of the Platform constitutes acceptance of the revised Policy.

10. Contact

For questions or to exercise your rights, contact us at:
📧 contact@startsmartly.co