Privacy Policy

Welcome to the Project Fresh Start website (hereunder, "Project Fresh Start", "we", "us" or "our").

Project Fresh Start is committed to protecting your privacy and developing technology that gives you a safe and secure online experience. This Privacy Policy applies to the Project Fresh Start website and governs collection, retention and usage of personal information and cookies. By using the Project Fresh Start website, you consent to our privacy policy as described in this statement.

This policy is effective as of April 1, 2023.

Last updated: October 26, 2025.

Application of the privacy policy

This privacy policy applies to all users (account holders and site visitors) and all personal information that is posted or collected on the websites, applications, and platforms where this policy is posted.

User-generated content

We consider “user-generated content” to be materials (text, image and/or PDF) voluntarily supplied to us by our users for the purpose of processing, and/or usage on our platform. All user-generated content is associated with the account or email address used to submit the materials.

Transaction data

Transaction data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.

Children's privacy

Our products or services are not aimed directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.

Collection of your personal information

Registration Data: When you register for a service with us, we ask you to provide certain information, which includes your full name, email address, physical address including zip code, telephone number as well as a password for your account.

Payment Information: When you register for a service with us, we ask you to provide your name and credit card information to pay for the services provided.

In addition, Project Fresh Start collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests and favorites.

There is also information about your computer hardware and software that is automatically collected by Project Fresh Start. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by Project Fresh Start for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Project Fresh Start website.

Use of your personal information

Project Fresh Start collects and uses your personal information to operate the Project Fresh Start website and deliver the services you have requested. Project Fresh Start also uses your personally identifiable information to inform you of other products or services available from Project Fresh Start and its affiliates. Project Fresh Start may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

Project Fresh Start does not sell, rent or lease its customer lists to third parties. Project Fresh Start may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, Project Fresh Start may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Project Fresh Start, and they are required to maintain the confidentiality of your information.

Project Fresh Start keeps track of the websites and pages our customers visit within Project Fresh Start, in order to determine what Project Fresh Start services are the most popular. This data is used to deliver customized content and advertising within Project Fresh Start to customers whose behavior indicates that they are interested in a particular subject area.

Project Fresh Start websites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Project Fresh Start or the site; (b) protect and defend the rights or property of Project Fresh Start; and, (c) act under exigent circumstances to protect the personal safety of users of Project Fresh Start, or the public.

Security of your personal information

We shall take reasonable steps to protect the personal data from loss, misuse and unauthorised access, disclosure, alteration and destruction. We have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the personal data from loss, misuse and unauthorised access, disclosure, alteration and destruction. However, our company cannot guarantee the security of personal data on or transmitted via the internet.

Disclosure of personal information to third parties

We may disclose personal information to: a parent, subsidiary, or affiliate of our company; third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators; our employees, contractors, and/or related entities; our existing or potential agents or business partners; credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you; courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights; third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you; third parties to collect and process data; an entity that buys, or to which we transfer all or substantially all of our assets and business.

These are the third parties we are currently using: Contabo, platform provider; Ultahost, platform provider; Google Cloud, platform provider; Raisely, online payment processor; SMTP2GO, email delivery provider.

Data retention

We will not keep your personal data longer than we need to. These factors may determine the length of data retention period:

Whether there is a legal/regulatory/compliance (accounting, reporting obligation) requirement for us to keep it;
Whether we need to retain the data to protect us or you from any legal claims.

Use of cookies

The Project Fresh Start website uses "cookies" to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

Authentication: If you're signed in to Project Fresh Start, cookies help us provide right information to you and personlise your browsing experience on our website.

Preferences, features and services: The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize Project Fresh Start pages, or register with Project Fresh Start site or services, a cookie helps Project Fresh Start to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Project Fresh Start website, the information you previously provided can be retrieved, so you can easily use the Project Fresh Start features that you customized.

Manage your cookie and other preferences: Many web browsers allow you to manage your cookie preferences. You can set your browser to refuse cookies or delete certain cookies. Please note that If you choose to block cookies, you may not be able to fully experience the interactive features of the Project Fresh Start services or websites you visit.

Notification of data breaches

We will comply with laws applicable to us in respect of any data breach.

Unsubscribe

To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to our privacy policy

Project Fresh Start may update this Privacy Policy from time to time by posting an updated Privacy Policy on the website. Your continued use of our services constitues your agreement to the updated Privacy Policy on a prospective basis.

Complaints

If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.

For any questions or concerns regarding your privacy, you may contact us here.