DATA POLICY

Last Updated: 01/07/2026

1. PURPOSE

This Data Policy explains how StartDotCom processes, stores, secures, transfers, retains, and deletes information across its platform, products, applications, APIs, artificial intelligence systems, integrations, and supporting infrastructure.

This document supplements the:

and forms part of the contractual framework governing the use of StartDotCom Services.

This policy has been designed to support compliance with:

  • UK GDPR
  • EU GDPR
  • UK Data Protection Act 2018
  • CCPA (where applicable)
  • International privacy obligations
  • Enterprise procurement requirements
  • ISO 27001 security principles
  • Industry-standard SaaS governance practices

2. DATA GOVERNANCE PRINCIPLES

StartDotCom is committed to the following principles:

Lawfulness

Data is processed only where lawful grounds exist.

Fairness

Processing activities are conducted fairly and transparently.

Transparency

Users are informed about how information is processed.

Purpose Limitation

Data is collected only for specified and legitimate purposes.

Data Minimisation

Only data necessary to provide Services is collected.

Accuracy

Reasonable efforts are made to maintain accurate records.

Storage Limitation

Information is retained only as long as necessary.

Integrity and Confidentiality

Appropriate technical and organisational measures are implemented to protect information.

Accountability

StartDotCom maintains governance processes designed to demonstrate compliance with applicable laws.

3. DATA CONTROLLER AND DATA PROCESSOR ROLES

Depending on the Services used, StartDotCom may act as either:

Data Controller

Where StartDotCom determines the purposes and means of processing. Examples include:

  • Account management
  • Billing
  • Security monitoring
  • Fraud prevention
  • Platform analytics
  • Product improvement

Data Processor

Where StartDotCom processes information on behalf of customers. Examples include:

  • CRM data
  • Customer contact records
  • Ecommerce customer information
  • Marketing databases
  • Uploaded business documents
  • Social media management data
  • AI-generated business assets

Customers remain responsible for ensuring that information uploaded to the Services is collected and processed lawfully.

4. CATEGORIES OF DATA PROCESSED

Information processed through StartDotCom may include:

Identity Data

  • Names
  • Usernames
  • Account details

Contact Data

  • Email addresses
  • Telephone numbers
  • Contact records

Business Data

  • Business names
  • Industries
  • Company information
  • Uploaded documents

Technical Data

  • Device identifiers
  • IP addresses
  • Browser information
  • Login history

Usage Data

  • Feature usage
  • Analytics
  • Session behaviour

Transaction Data

  • Subscription information
  • Payment records
  • Billing information

Social Media Data

  • Social account identifiers
  • Connected pages
  • Publishing metadata
  • Analytics information

Customer Data

Information uploaded and managed by users within CRM, ecommerce, support, marketing, or automation tools.

5. AI DATA PROCESSING

StartDotCom uses artificial intelligence systems to provide platform functionality.

AI systems may process:

  • User prompts
  • Business information
  • Uploaded content
  • Customer instructions
  • Generated outputs

AI processing may be used to:

  • Generate business plans
  • Generate content
  • Generate websites
  • Generate automations
  • Generate marketing campaigns
  • Generate recommendations
  • Improve workflow execution

Unless explicitly authorised by customers, StartDotCom does not use customer content to train publicly available artificial intelligence models.

Customer content remains under customer ownership.

6. DATA LOCATION AND HOSTING

StartDotCom uses reputable cloud infrastructure providers and technology vendors.

Data may be hosted, processed, replicated, backed up, or secured within:

  • United Kingdom
  • European Economic Area
  • United States
  • Other approved jurisdictions

Processing locations may vary depending on infrastructure architecture, disaster recovery requirements, service providers, or customer-selected configurations.

7. SUBPROCESSORS

StartDotCom may engage approved subprocessors to support Service delivery. Examples may include providers supporting:

  • Cloud infrastructure
  • Artificial intelligence services
  • Payment processing
  • Authentication
  • Email delivery
  • Customer support
  • Security monitoring
  • Analytics
  • Backup and recovery

All subprocessors are required to maintain appropriate security and confidentiality obligations.

StartDotCom remains responsible for managing subprocessor relationships in accordance with applicable law.

8. INTERNATIONAL DATA TRANSFERS

Where personal information is transferred internationally, StartDotCom implements appropriate safeguards, including where applicable:

  • Standard Contractual Clauses (SCCs)
  • UK International Data Transfer Addendum
  • Adequacy Decisions
  • Contractual protections
  • Technical safeguards

Transfers are conducted only where lawful mechanisms exist.

9. SECURITY GOVERNANCE

StartDotCom maintains security controls designed to protect information against unauthorised access, accidental loss, destruction, alteration, disclosure, or misuse.

Security controls may include:

Access Controls

  • Role-based access control
  • Least privilege principles
  • Multi-factor authentication
  • Access reviews

Encryption

  • Encryption in transit
  • Encryption at rest where appropriate

Monitoring

  • Audit logs
  • Security monitoring
  • Threat detection

Infrastructure Security

  • Network protections
  • Cloud security controls
  • Secure configuration management

Operational Security

  • Incident response procedures
  • Backup processes
  • Business continuity planning

No system can guarantee absolute security.

10. DATA RETENTION SCHEDULE

Unless a longer retention period is required by law, contractual obligations, litigation holds, fraud investigations, or regulatory requirements, information may be retained as follows:

  • Account Records: Duration of account plus reasonable retention period.
  • Billing Records: Up to seven (7) years.
  • Tax Records: Up to seven (7) years.
  • Security Logs: Up to twelve (12) months.
  • Audit Logs: Up to twenty-four (24) months.
  • Customer Support Records: Up to twenty-four (24) months.
  • Marketing Records: Until consent is withdrawn or records become inactive.
  • AI Processing Logs: Only for operational, security, quality assurance, or legal purposes and retained for the minimum reasonable period.
  • Deleted Accounts: Generally removed within thirty (30) days following verification and processing of deletion requests, except where retention is legally required.

11. DATA DELETION

Users may request deletion of eligible personal information by contacting: privacy@startdotcom.com

To protect users, identity verification may be required.

Deletion requests may be denied or partially fulfilled where retention is required for:

  • Legal obligations
  • Tax obligations
  • Fraud prevention
  • Security investigations
  • Contract enforcement
  • Litigation
  • Regulatory requirements

Where deletion is approved, StartDotCom will take reasonable steps to remove or anonymise eligible information.

12. SOCIAL MEDIA DATA DELETION

Users may disconnect connected social media accounts through: Settings → Connected Accounts

To request deletion of social integration information, users may contact: privacy@startdotcom.com

Upon successful verification, StartDotCom will delete eligible social connection data, associated access tokens, and related records within thirty (30) days unless retention is required by law or legitimate security obligations.

13. DATA SUBJECT RIGHTS

Where applicable law grants such rights, individuals may request:

  • Access
  • Rectification
  • Erasure
  • Restriction
  • Objection
  • Portability
  • Withdrawal of consent

Requests should be submitted to: privacy@startdotcom.com. Additional information may be requested to verify identity.

14. DATA BREACH MANAGEMENT

StartDotCom maintains procedures designed to identify, assess, investigate, contain, and remediate security incidents.

Where required by law, affected parties and regulators may be notified in accordance with applicable legal obligations.

Not every security event constitutes a reportable data breach.

15. CUSTOMER RESPONSIBILITIES

Customers remain responsible for:

  • Obtaining lawful consent where required.
  • Providing privacy notices where required.
  • Maintaining lawful processing activities.
  • Managing access permissions.
  • Configuring retention settings where available.
  • Ensuring information uploaded to the Services is lawfully obtained.

StartDotCom does not assume responsibility for unlawful customer data collection practices.

16. ENTERPRISE DATA PROCESSING AGREEMENTS

Enterprise customers may request a separate Data Processing Agreement (DPA).

Where executed, the DPA shall govern processing activities and prevail over this Data Policy where conflicts arise.

17. COMPLIANCE, AUDITS AND INVESTIGATIONS

StartDotCom reserves the right to investigate:

  • Security incidents
  • Fraud
  • Abuse
  • Unauthorised access
  • Platform misuse
  • Regulatory concerns

Relevant information may be retained, disclosed, preserved, or reviewed where legally required or reasonably necessary to protect the Services, users, partners, or the public.

18. CHANGES TO THIS POLICY

This Data Policy may be updated periodically.

Material changes may be communicated through the platform, email notifications, account notices, or website updates.

Continued use of the Services following updates constitutes acceptance of the revised version.

19. CONTACT DETAILS

TechDotAI Ltd

United Kingdom

All rights reserved.