Privacy Policy

Startklar. Complete business websites at a fixed price.

1. Data Controller

Zone 2 Technologies Ltd, a Bulgarian limited liability company, registered in the Bulgarian Commercial Register under UIC 206921440 and VAT number BG206921440, with seat and management address at Bulgaria, Sofia 1000, Izgrev region, Iztok district, 6 Dr. Lyuben Rusev Str., fl. 5, ap. 81 (“Zone 2 Technologies”, “We”, “Us”, or “Our”).

Through the website startklar.site, Zone 2 Technologies offers a productized website service under the Startklar brand: complete business websites at a fixed price, built within one week of the kickoff interview and delivered on a preview link.

Zone 2 Technologies is a Data Controller within the meaning of Article 4(7) of the GDPR and, as such, is responsible for processing Your data in a fair, transparent, and secure manner, as required by the Regulation and national legislation.

This Privacy Policy relates to the activities of Zone 2 Technologies (“the Controller”) in connection with the management of the website startklar.site and the provision of services through it. To fulfill legal requirements, this Privacy Policy provides You with information about Your rights, the types of personal data collected, the basis for their processing, how they are stored and used, and when they are disclosed to third parties.

In accordance with the Controller’s obligations under Regulation 2016/679 of the European Parliament and of the Council (“General Data Protection Regulation” or “GDPR”), the Controller guarantees that the processing of Your personal data will always comply with the Regulation and applicable Bulgarian data protection legislation.

Contact Information:

Zone 2 Technologies Ltd
Email: hello@startklar.site
Website: startklar.site

2. Personal Data We Collect

As the Controller of the website startklar.site (“the Website”), Zone 2 Technologies determines the purposes, collects, and processes personal data of website users necessary for their identification, contact, and service delivery.

According to Article 4 of EU Regulation 2016/679, “personal data” means any information relating to an identified natural person or to a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

The Website has no user accounts, sets no cookies, and runs no analytics and no tracking. Personal data reaches Us only in the following ways:

Contact Data (when You send Us an inquiry through the contact form on the Website or by email):

• Name
• Email address
• The content of Your message

Inquiries submitted through the contact form are delivered to Us by email and are not stored in a database on the Website. You receive a confirmation email for Your inquiry.

Bot Protection Data:

• To verify that a contact form submission comes from a person and not an automated bot, Vercel BotID runs an invisible check in the browser and processes technical signals such as IP address and browser characteristics (Section 8). BotID shows no puzzle and, according to Vercel, does not store user behavior or personally identifiable information

Booking and Project Data (when You book Our service):

• Business name, address, and, where applicable, VAT number
• The information You share in the questionnaire and the kickoff interview about Your business, customers, and goals
• Materials You provide for Your website, which may include names and photos of You or Your team
• Scheduling data for the intro call and the kickoff interview

Billing Data:

• Invoicing and payment records We are legally required to keep. Where a third-party payment provider is used, Your card details are handled directly by that provider and never reach Our servers

Technical Data:

• To deliver the Website and keep it secure, Our hosting provider processes technical data in server logs, such as IP address, browser type, requested pages, and the date and time of access

3. Personal Data We Do NOT Collect

Zone 2 Technologies does not collect or process personal data that:

• Reveals racial or ethnic origin
• Reveals political opinions, religious or philosophical beliefs, or trade union membership
• Consists of genetic or biometric data
• Concerns health or medical conditions
• Concerns sex life or sexual orientation

IMPORTANT: if such information is shared by users of the Website, it will not be subject to processing.

4. Purpose of Data Processing

Zone 2 Technologies collects and uses Your personal data for the following activities and purposes:

• To receive and respond to Your inquiries, send You a confirmation email, and hold the free intro call
• To protect the contact form from spam and automated abuse
• To provide the service You have booked: evaluating the questionnaire, preparing the design proposals, holding the kickoff interview, building and handing over Your website, applying the revision round, and taking the website live after Your go-ahead
• To provide monthly services You have booked, such as hosting, content, reporting, and advertising management
• To issue invoices and meet accounting and tax obligations
• For communication purposes, including scheduling and project updates
• To identify parties to contracts and maintain records
• To comply with legal requirements, settle potential disputes, and protect against fraud
• To ensure the security of the Website and Our infrastructure

Your personal data may also be processed if a government authority requests Zone 2 Technologies’ cooperation in connection with official procedures, including pre-trial, judicial, and administrative proceedings related to claims, fraud, etc. In such cases, Zone 2 Technologies discloses only the amount of data requested by the authorities, not exceeding the scope of the specific request.

5. Retention Period

Personal data is retained for as long as necessary to:

• Maintain Our correspondence and the records of Your booking and project
• Fulfill Our contractual obligations
• Comply with legal requirements, including statutory retention periods for accounting and tax records
• Resolve disputes

You may request deletion of Your personal data at any time by contacting Us at hello@startklar.site. We will process deletion requests in accordance with applicable law, subject to any legal obligations requiring Us to retain certain data.

6. Legal Basis for Processing

We collect Your data on the following legal bases:

• Contract performance (Article 6(1)(b) GDPR): processing necessary to provide the service You have requested, including steps taken at Your request before entering into a contract
• Legal obligation (Article 6(1)(c) GDPR): where processing is required to comply with applicable laws, such as accounting and tax legislation
• Legitimate interests (Article 6(1)(f) GDPR): for the security and delivery of the Website (server logs), the protection of the contact form from automated abuse (bot protection), fraud prevention, and the establishment or defense of legal claims, where such interests are not overridden by Your rights
• Consent (Article 6(1)(a) GDPR): where You have given explicit consent for specific processing activities

7. Technical Security

The Controller has implemented all technical and organizational measures necessary for the processing and protection of personal data in accordance with EU Regulation 2016/679 and applicable Bulgarian legislation.

The measures taken correspond to the specific risks associated with the processing and storage of personal data. Organizational and technical measures are in place to protect Your data from loss, alteration, theft, or unauthorized access by third parties.

These measures include:

• Encryption of data in transit
• Access controls and authentication
• Secure hosting infrastructure
• Data minimization: the Website collects no data it does not need

However, no internet transmission is completely secure, and We cannot guarantee absolute security of data transmitted to Us online.

8. Third Parties Receiving Your Data

In certain cases, the Controller may disclose personal data to partners or subcontractors who work with the Controller by providing services related to its activities. These include:

Hosting:

• Vercel hosts the Website and processes the technical data described in Section 2 as part of delivering it. For more information, see https://vercel.com/legal/privacy-policy

Bot Protection:

• Vercel also provides the BotID check on Our contact form, which verifies that submissions come from real people, not automated bots. BotID runs invisibly in the browser and may process IP address, browser characteristics, and interaction signals to assess whether a visitor is human; according to Vercel, it does not store user behavior or personally identifiable information. This is a security measure necessary to protect the Service from abuse. For more information, see https://vercel.com/legal/privacy-policy

Email Delivery:

• Postmark delivers the emails triggered by the contact form: Your inquiry to Us and the confirmation email to You. Your name, email address, and message are shared with this provider for email delivery purposes. For more information, see https://postmarkapp.com/privacy-policy
• Direct email correspondence is processed by the email service provider that operates Our mailboxes, as part of normal email delivery

Payment Processing:

• Where a payment link is offered at booking, the payment is processed by the payment provider named there. Card details are handled directly by that provider and never reach Our servers

Accounting:

• Billing data may be shared with Our accountants and with tax authorities where legally required

The Controller will share personal data with third parties only after explicitly ensuring the technical and legal mechanisms under which the processing of shared personal data will be carried out in accordance with the requirements of Regulation 679/2016 and Bulgarian legislation. We do not sell personal data.

9. Data Processing Principles

The Controller guarantees that the personal data it processes are:

a) Processed lawfully, fairly, and in a transparent manner in relation to You (“lawfulness, fairness, and transparency”);

b) Collected for specified, explicit, and legitimate purposes and not further processed in a manner incompatible with those purposes (“purpose limitation”);

c) Adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed (“data minimization”);

d) Accurate and, where necessary, kept up to date; all reasonable steps are taken to ensure that inaccurate personal data are erased or rectified without delay (“accuracy”);

e) Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (“storage limitation”);

f) Processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures (“integrity and confidentiality”).

10. Your Data Protection Rights

Under the GDPR, You have the following rights:

Right of Access

Upon Your request, You have the right to access the personal data stored about You. You also have the right to request a copy of the personal data being processed.

Right to Rectification

You have the right to request correction of incorrect, inaccurate, or incomplete personal data. Depending on the purposes of processing, You may have the right to supplement incomplete personal data, including by providing an additional statement.

Right to Erasure (“Right to Be Forgotten”)

You have the right to request the deletion of personal data when they are no longer necessary or if their processing is unlawful. Please note that Article 17 of the GDPR defines the cases in which We are obliged to delete Your data. Please also note that We may be required to retain Your data even if You have requested their deletion (for example, to comply with a legal obligation under EU or Bulgarian law).

Right to Restriction of Processing

Under certain circumstances, You have the right to request restriction of the processing of Your personal data. For example, You may exercise this right when We no longer need Your personal data for processing purposes, but We must keep them in Our systems for use in situations such as exercising rights or defending claims.

Right to Data Portability

Under certain circumstances, You have the right to receive the personal data You have provided to Us in a structured, commonly used, and machine-readable format (i.e., in digital form), and You may have the right to request the transfer of such data to another person without hindrance from Us, if such transfer is technically feasible.

Right to Object

Under certain circumstances, You have the right to object to the processing of Your personal data, and We may be required to stop processing them in the future. You may exercise this right, for example, if We use Your email address for direct marketing purposes. In this case, after Your objection, We will no longer be able to send You marketing materials.

Right to Withdraw Consent

When the processing of Your personal data is based on Your consent, You may withdraw Your consent at any time without giving Us a reason. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

How to Exercise Your Rights

To exercise Your rights, You may contact Us with a written request at hello@startklar.site. We will respond to Your questions and requests without undue delay and within 1 month at the latest. You may be asked to provide information to verify Your identity in order to exercise Your rights.

11. Complaint to Supervisory Authority

If for any reason You are not satisfied with the way We process Your personal data, please first inform Us so that We can understand the cause of the problem and try to resolve it. We will carefully review Your request and answer all Your questions.

If You believe You have not received adequate assistance from Zone 2 Technologies or that Your right has been violated, You have the right to lodge a complaint with a supervisory authority. This authority in the Republic of Bulgaria is:

Commission for Personal Data Protection:
Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
Phone: 02/915 35 18
Email: kzld@cpdp.bg
Website: www.cpdp.bg

12. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including:

• United States (where some of Our service providers are located)
• Other countries where Our infrastructure providers maintain servers

When We transfer Your data outside the EEA, We ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses approved by the European Commission
• Transfers to countries with an adequacy decision
• Other legally recognized transfer mechanisms

13. Cookies and Tracking Technologies

The Website sets no cookies and uses no tracking technologies. There is no analytics tool, no advertising pixel, and no consent banner, because there is nothing to consent to. The spam protection on the contact form (Vercel BotID, Section 8) also runs without cookies.

If this ever changes, this Policy will be updated first, and any consent required by law will be obtained before such technologies are used.

14. Policy Updates

To keep this Privacy Policy up to date, it may be changed in whole or in part at any time without special notice. Please check this Policy periodically for updates. The date of the last update will be indicated below.

This Privacy Policy was adopted on July 18, 2026.

Last Updated: July 18, 2026.