Privacy Policy
BORCROC EOOD · Last updated: September 2026
1. Who we are - the data controller
This website (startup-kin.com) is operated by BORCROC EOOD, a company registered in Bulgaria, European Union. BORCROC EOOD is the data controller responsible for your personal data under the EU General Data Protection Regulation (GDPR) - the entity that decides why and how your data is processed. You can reach us at [email protected].
2. What data we process, why, and on what basis
We process a limited set of data, each tied to a specific purpose. We do not collect anything beyond what that purpose requires.
| Data | Why we process it | Legal basis |
|---|---|---|
| Application data Startup and founder name, website or LinkedIn, what you do / stage / sector, requested benefits, your email address |
Reviewing membership applications | Steps taken at your request, prior to a contract (Art. 6(1)(b)) |
| Member contact information Startup and founder name, logo, one-line description, website, a contact route for the founder |
Operating the member network - listing members and relaying cooperation requests between them | Performance of the membership arrangement (Art. 6(1)(b)) |
| Exchange information What each side requested and offered, the agreed completion date, whether it was completed |
Facilitating and measuring Startup Kin cooperation exchanges, including tracking commitments under our accountability rule | Our legitimate interest in keeping exchanges fair and reliable (Art. 6(1)(f)) |
| Analytics data Pages visited, session duration, approximate country, device type |
Understanding how the site is used, so we can improve it | Your consent, given via the cookie banner (Art. 6(1)(a)) |
We do not use advertising cookies, retargeting, or any third-party tracking beyond Google Analytics.
3. Cookies set by Google Analytics
We only activate Google Analytics after you give explicit consent via the cookie banner shown on your first visit. You may withdraw consent at any time - see section 7 below.
| Cookie | Purpose | Retention |
|---|---|---|
| _ga | Distinguishes unique users | 2 years |
| _ga_<container-id> | Session state for this property | 2 years |
We also store your consent choice in localStorage
under the key startupkin_ga_consent
so we do not ask you again. This is not a cookie and never leaves your browser.
4. Who receives your data
Member directory - if your application is accepted, your startup name, logo, a one-line description, and your company website may be featured on this website. We do not publish your name, email address, or any other personal contact details.
When you request a cooperation exchange, we relay the details of that specific request - what you are offering and asking for - to the matched member. We do not hand out member contact information directly; Startup Kin stays the point of contact until both sides agree to the exchange.
We share a limited amount of data with the following service providers, strictly to run this website and the club. None of them are permitted to use your data for their own purposes:
- Google LLC (Google Analytics) - anonymized usage statistics, only if you consent.
- Cloudflare, Inc. - hosting and content delivery for this website.
- Our email provider - to send and receive messages at [email protected].
We do not sell your data, and we do not share it with third parties for marketing.
5. International data transfers
Google Analytics may transfer and process data in the United States. Google LLC participates in the EU-US Data Privacy Framework, which provides an adequate level of protection recognised by the European Commission.
6. How long we keep your data
We keep data only for as long as the purpose it was collected for realistically requires, plus a reasonable buffer to handle late-arriving disputes or re-applications:
- Application data - kept while we review your application. If you are not accepted, it is deleted within 12 months, unless you ask us to keep it on file for a future application.
- Member contact information - kept for as long as you are an active member, and for up to 12 months afterward for continuity and accountability record-keeping, then deleted.
- Exchange information - kept for as long as needed to track commitments under our accountability rule, and for up to 24 months after a member leaves, to resolve any outstanding disputes.
- Analytics data - retained by Google Analytics for 26 months by default. Aggregated reports have no expiry but contain no personal identifiers.
7. Your rights under GDPR
You have the right to:
- Access the personal data we hold about you
- Correct inaccurate or incomplete data
- Delete your data, where it is no longer needed for the purposes in section 2
- Restrict or object to certain processing
- Receive a copy of your data in a portable format, where applicable
- Withdraw consent at any time, for processing based on consent (Google Analytics)
To exercise any of these rights, email [email protected]. We will respond within 30 days, as required by GDPR.
Withdraw analytics consent on this site - click below to clear your choice. The banner will reappear on your next page load and Google Analytics will stop loading until you accept again.
Opt out across all websites - install the Google Analytics Opt-out Browser Add-on.
Google's privacy policy - policies.google.com/privacy.
Not satisfied with our response? You have the right to lodge a complaint with your local data protection authority. For BORCROC EOOD, this is the Bulgarian Commission for Personal Data Protection.
8. Changes to this policy
If we change how we use data in a material way we will update this page and revise the "Last updated" date above.
9. Contact
Questions about this policy or your privacy rights? Email us at [email protected].