Last updated: 14 September 2026

1. Controller

The controller responsible for processing personal data on this website is:

Brand Creators Group LLC
Tbilisi, Georgia
Email: [email protected]
Website: https://startkap.com

2. Scope and Legal Bases

This Privacy Policy explains how we process personal data when you visit our website, contact us or use our services.

Where the European Union General Data Protection Regulation (GDPR) applies, we process personal data in particular on the following legal bases:

• Article 6(1)(a) GDPR – consent;

• Article 6(1)(b) GDPR – taking steps prior to entering into a contract or performing a contract;

• Article 6(1)(c) GDPR – compliance with legal obligations;

• Article 6(1)(f) GDPR – pursuit of legitimate interests, provided that these interests are not overridden by the interests or fundamental rights and freedoms of the data subject.

Applicable Georgian data protection legislation may also apply.

3. Representative in the European Union

Where we are required to appoint a representative in the European Union under Article 27 GDPR, the representative can be contacted at:

[email protected]

4. Accessing the Website and Server Log Files

When you access this website, the hosting provider may automatically process technical access data. This may include:

• the IP address of the device used;

• the date and time of access;

• the page or file accessed;

• the volume of data transferred;

• the referring URL;

• browser type and version;

• operating system;

• hostname of the accessing device;

• messages regarding successful or failed access attempts.

This processing is carried out to provide the website securely and without technical errors and to detect and prevent misuse. The legal basis is Article 6(1)(f) GDPR. Our legitimate interest is the secure, stable and efficient operation of our website.

Hosting provider: [INSERT NAME, ADDRESS AND PRIVACY POLICY LINK OF THE HOSTING PROVIDER]

Server log files are generally retained only for as long as necessary for the purposes described above. The specific retention period is [INSERT THE HOSTING PROVIDER’S RETENTION PERIOD]. Data may be retained for longer where necessary to investigate a security incident or comply with legal obligations.

5. Contact and Contact Form

When you contact us by email or through the contact form, we process the information you provide. This may include your name, email address, telephone number, the content of your message and any other information you provide voluntarily.

The data is processed to respond to your enquiry. Where the enquiry concerns a contract or steps prior to entering into a contract, the legal basis is Article 6(1)(b) GDPR. In other cases, processing is based on our legitimate interest in appropriately managing communications under Article 6(1)(f) GDPR. Where you have expressly given consent, processing is based on Article 6(1)(a) GDPR.

We delete the data once your enquiry has been fully dealt with and no statutory retention requirements or legitimate reasons for further storage apply. Communications relevant to contracts or billing may be retained for longer in accordance with applicable statutory retention periods.

6. Customer, Contract and Company-Formation Data

When you enquire about or commission our services, we may process in particular the following data:

• identity and contact details;

• passport and identity-verification data;

• powers of attorney and company-formation documents;

• information about the proposed business activity;

• tax-related and company-related information;

• payment and billing data;

• communication and contract data;

• data required by banks, public authorities, notaries, translators or other parties involved in providing the service.

Processing is carried out to take steps prior to entering into a contract and to perform a contract under Article 6(1)(b) GDPR, and to comply with legal obligations under Article 6(1)(c) GDPR. Depending on the service, additional verification and documentation requirements may apply, including identity, due-diligence and anti-money-laundering checks.

We disclose personal data only to recipients whose involvement is required to provide the requested or commissioned service. These may include Georgian public authorities, banks, notaries, translators, legal and tax advisers, payment service providers and technical service providers. The opening of a bank account or any other decision by a third party is not guaranteed and remains solely the responsibility of the respective institution.

7. Cookies and Consent Management

Our website uses cookies and similar technologies. Strictly necessary cookies may be used to provide the website and the functions you have expressly requested. To that extent, storage or access is necessary for operating the website and, where the GDPR applies, is based on Article 6(1)(f) GDPR.

Non-essential cookies and services, particularly those used for analytics, external media or marketing, are activated only after you have given prior consent. The legal basis is Article 6(1)(a) GDPR. You may withdraw or change your consent at any time with effect for the future through the cookie settings.

When you first visit the website, you are shown a consent selection. Your settings are stored so that we can respect your decision. Current providers, purposes, durations and cookie names can be found in the cookie settings, which are accessible at any time.

8. Google Analytics 4

Where you have given consent, we use Google Analytics 4 to analyse website usage statistically. The provider for users in the European Economic Area is generally:

Google Ireland Limited
Gordon House, Barrow Street
Dublin 4, Ireland

Google Analytics may process information concerning page views, sessions, approximate location, technical device and browser data, interactions and online identifiers. Data may be transferred to Google LLC and other Google companies in the United States or other third countries.

Processing is carried out exclusively on the basis of your consent under Article 6(1)(a) GDPR. You may withdraw your consent at any time through the cookie settings. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

We have agreed to the data protection terms provided for use of the service. According to Google, where data is transferred to third countries, such transfers are based on applicable safeguards, such as adequacy decisions or Standard Contractual Clauses.

Further information: https://policies.google.com/privacy?hl=en

Specific Google Analytics data-retention period: [INSERT THE DATA-RETENTION PERIOD CONFIGURED IN GOOGLE ANALYTICS]

9. Google Fonts

We recommend hosting the fonts used on this website locally on our server. Where fonts are hosted exclusively locally, no connection to Google is established when the fonts are loaded.

[CHECK TECHNICALLY BEFORE PUBLICATION:] If Google Fonts are loaded from Google’s servers instead, your device’s IP address may be transmitted to Google. Such external integration may be used only after prior consent and must be listed as an external service in the cookie banner.

10. Google Maps

Individual pages may include maps provided by Google Maps. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Maps is loaded only after you have given consent or expressly activated the map. Your IP address, device information, location data and information about your use of the map may then be transmitted to Google. Processing by Google LLC in the United States cannot be ruled out.

The legal basis is your consent under Article 6(1)(a) GDPR. You may withdraw your consent at any time through the cookie settings.

Further information: https://policies.google.com/privacy?hl=en

11. YouTube

Individual pages may include videos from the YouTube platform. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Embedded videos are loaded only after you have given consent or expressly activated the video. When a video is loaded or played, Google may process information including your IP address, device and browser data, the page visited and other usage data. If you are signed in to YouTube or Google, Google may associate your use of the video with your account.

The legal basis is your consent under Article 6(1)(a) GDPR. You may withdraw your consent at any time through the cookie settings.

Further information: https://policies.google.com/privacy?hl=en

12. Recipients and Processors

We may engage external service providers to assist us with website operation, communications, hosting, analytics, document management, payment processing or the provision of our services. Where these service providers process personal data on our behalf, they are engaged in accordance with applicable data protection requirements.

Personal data is disclosed only where necessary to perform a contract, comply with a legal obligation, act on your consent, or pursue a legitimate interest that is not overridden by your interests or fundamental rights and freedoms.

13. Transfers to Third Countries

The controller is established in Georgia. If you are located in the European Union or European Economic Area, your data may therefore be transferred to and processed in Georgia. The use of certain technical service providers may also involve processing outside the EU or EEA.

Where no adequacy decision applies to the relevant third country, transfers are made, where required, on the basis of appropriate safeguards, particularly Standard Contractual Clauses, or a statutory derogation under Article 49 GDPR. Where Georgian services are commissioned, the transfer may also be necessary to take steps prior to entering into a contract or to perform a contract.

Please note that the level of data protection in a third country may differ from that in the EU or EEA.

14. Retention Period

We retain personal data only for as long as necessary for the relevant purpose. We may retain data for longer where and for as long as statutory retention periods, the establishment, exercise or defence of legal claims, or other permissible reasons require it.

Once the purpose of processing no longer applies and all relevant periods have expired, the data is deleted or anonymised. Where deletion is temporarily impossible, processing is restricted to the necessary extent.

15. Data Security

We use appropriate technical and organisational security measures to protect personal data against loss, manipulation, unauthorised access and other risks. Data transmitted between your browser and our website is encrypted using HTTPS/TLS.

However, complete protection during data transmission over the internet cannot be guaranteed.

16. Your Rights

Where the GDPR applies and the relevant legal requirements are met, you have in particular the right to:

• obtain information about the processing of your personal data;

• have inaccurate data corrected or incomplete data completed;

• request deletion of your personal data;

• request restriction of processing;

• data portability;

• object to processing based on legitimate interests;

• withdraw consent with effect for the future;

• lodge a complaint with a competent data protection supervisory authority.

To exercise your rights, please contact [email protected]. We may request additional information where necessary to verify the identity of the person making the request.

17. Objection to Direct Marketing

Where we process personal data for direct marketing purposes, you may object to such processing at any time. Following your objection, we will no longer use your data for this purpose.

18. No Automated Decision-Making

As part of operating this website, we generally do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.

Decisions made by banks, public authorities or other independent institutions remain their sole responsibility.

19. Amendments to this Privacy Policy

We may amend this Privacy Policy if legal requirements, the services we use or our data-processing activities change. The version published on this website at the relevant time applies.

20. Privacy Contact

If you have questions about privacy or wish to exercise your rights, please contact:

Brand Creators Group LLC
Email: [email protected]

If no Data Protection Officer has been appointed, this address is the general privacy contact. It does not identify a formally appointed Data Protection Officer.