Privacy Policy

Last updated: October 2025

Introduction

Astrara (“we,” “us,” or “our”) is a trademark of Start Learn LLC, and respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, process, and protect your information when you use our wellness and personal development app and services, and outlines your privacy rights and how the law protects you.

Who We Are

Start Learn LLC is a company registered in U.S.A, with its registered office at 3402, 1603 Capitol Avenue, Suite 413A, Cheyenne, WY, 82001. We act as the data controller for the personal data collected through our app and services.

Information We Collect

We collect, use, store, and transfer different kinds of personal data about you, which we have grouped as follows:

• Identity Data: Includes first name, last name, username, date of birth, and gender.
• Contact Data: Includes email address, billing address, and telephone numbers.
• Technical Data: Includes IP address, device type, operating system, app version, unique device identifiers, and time zone.
• Profile Data: Includes account preferences, subscription status, wellness settings, and personal development goals.
• Usage Data: Includes app interactions, feature usage, session duration, and content views.
• Communication Data: Includes customer support interactions, feedback, and survey responses.

We do not collect special categories of personal data (such as details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, health data beyond basic wellness information) unless specifically required for personalized wellness recommendations, nor do we collect any information about criminal convictions and offences.

How We Collect Your Personal Data

We use different methods to collect data from and about you, including through:

• Direct Interactions: You may provide us with your Identity and Contact Data by using our app features or by corresponding with us. This includes personal data you provide when you:

• • Register for our services;

• • Subscribe to premium features;

• • Set personal development goals;

• • Subscribe to our newsletter;

• • Give us feedback or contact us.

• Automated Technologies or Interactions: As you interact with our app, we may automatically collect Technical Data about your device, app usage patterns, and behaviors. We collect this personal data by using analytics, crash reports, and other similar technologies.
• Third-Party Services: We may receive data from app stores, payment processors, analytics providers, and advertising networks.

Legal Basis for Processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of Contract: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Legal or Regulatory Obligations: Where we need to comply with a legal or regulatory obligation.
• Consent: Where you have given your explicit consent for specific processing activities.

Purposes for Which We Will Use Your Personal Data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so:

• To register you as a new user: Performance of a contract with you.
• To provide personalized wellness content and insights: Performance of a contract with you.
• To generate personal development reports and recommendations: Performance of a contract with you.
• To process payments and manage subscriptions: Performance of a contract with you; Necessary to comply with a legal obligation.
• To manage our relationship with you: Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated and to study how users use our app).
• To improve our services through analytics: Necessary for our legitimate interests (to develop our app, to grow our business, and to inform our strategy).
• To send newsletters and updates: Consent.
• To provide customer support: Performance of a contract with you; Necessary for our legitimate interests (to provide customer service).
• To administer and protect our business and app: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) and to comply with a legal obligation.
• To deliver relevant content and measure effectiveness: Necessary for our legitimate interests (to study how users use our app, to develop it, to grow our business, and to inform our marketing strategy).

Data Sharing and Third Parties

We may share your data with:

• Affiliated apps within our brand family: With your explicit consent for enhanced wellness services, social connections, or personal development matching.
• Service providers: Payment processors, cloud storage providers, customer support platforms.
• Analytics partners: Google Analytics, Facebook/Meta Pixel, TikTok Pixel, Pinterest Analytics, Google Ads.
• App stores: Apple App Store, Google Play Store.
• Legal authorities: When required by law or to protect our rights.

We never sell your personal data to third parties for marketing purposes.

Cookies and Tracking Technologies

Our app uses cookies and similar tracking technologies to distinguish you from other users and to provide you with a good experience. This helps us improve our app and provide personalized content. For detailed information on the tracking technologies we use and the purposes for which we use them, see our Cookie Policy.

Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal data to employees, agents, contractors, and third parties who have a business need to know. Our security measures include data encryption in transit and at rest, secure authentication systems, regular security audits, access controls and monitoring, secure cloud infrastructure with AWS/Google Cloud, regular encrypted backups, and staff training on data protection.

Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Account data is retained while your account is active. After account deletion, most personal data is removed within 30 days, though some information may be retained longer for legal compliance, fraud prevention, or legitimate business purposes. Backup data may persist for up to 90 days before complete deletion.

Your Legal Rights

Under data protection laws (including GDPR), you have rights in relation to your personal data, including the right to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
• File a complaint with a supervisory authority.

If you wish to exercise any of the rights set out above, contact [email protected]

Children’s Privacy

Our service is not intended for children under 13 years of age (or 16 in the EU). We do not knowingly collect personal information from children under the applicable age. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at [email protected], and we will delete such information promptly.

International Data Transfers

Your information may be transferred to and processed in countries other than your own, including the United States where our servers are located. We ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission, Adequacy decisions by the European Commission, and other legal mechanisms recognized under applicable data protection laws.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy in the app with a new effective date, sending a push notification or email notification, and requiring acceptance of updated terms for continued service use. Your continued use of our services after changes take effect constitutes acceptance of the updated policy.

Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or need to contact our Data Protection Officer, please reach us at:

Email: [email protected]

Postal Address: Start Learn LLC 3402, 1603 Capitol Avenue, Suite 413A Cheyenne, WY, 82001 USA

We will respond to your inquiries within 30 days (or sooner as required by applicable law).

This Privacy Policy was last updated on October 2025