Privacy Policy

Demo version — the site is not engaging in commercial activity at this time.

Last updated: 30 September 2026.

This policy explains how Shturko (shturko.com / test.shturko.com) processes personal data under the GDPR and Bulgarian PDPA (ЗЗЛД).

1. Controller

While the site is in demo mode and not engaging in commercial activity, full trader details (legal name, company ID, registered address) will be published here after a legal entity is registered.

Privacy contact: shturko.info@gmail.com.

Supervisory authority in Bulgaria: Commission for Personal Data Protection (CPDP), cpdp.bg.

2. Children

Shturko products are designed for children roughly aged 2–8, but accounts, orders and consent are for a parent/guardian or other adult. In Bulgaria the digital age of consent for information society services is 14. We do not create accounts for children under 14.

3. Data we process

  • Email — one-time login codes (OTP), linking to an order/demo profile.
  • Order data (if/when commerce is active) — name, address, phone for delivery; no commercial activity at present.
  • Game progress — levels/unlocks tied to an account or a service cookie.
  • Waitlist — email, language, consent date and a personal 20% discount code; to send you the code and write when the shop opens (consent; unsubscribe link in every email).
  • Feedback — message, role, optional child age/gender and reply email.
  • Technical logs — limited IP (security/rate limits), user agent for login devices.
  • Analytics (consent only) — pageviews, clicks, time on page; no typed form values.
  • Teachers’ code access — after entering a code on the teachers’ page we record pages opened, clicks, IP address and device type to improve Shturko (legitimate interest). No typed form values.

4. Purposes and legal bases

  • Contract / steps at your request (Art. 6(1)(b)) — login, games, QR unlock.
  • Legitimate interests (Art. 6(1)(f)) — security, abuse prevention, improving the demo.
  • Consent (Art. 6(1)(a)) — marketing emails; non-essential cookies/analytics.
  • Legal obligation — when applicable (e.g. accounting once sales start).

5. Recipients / processors

  • SuperHosting — website and database hosting.
  • ipinfo.io — approximate place (city, provider) for IP addresses of teachers’ code access; used only when the admin opens the statistics.
  • Google (Gmail) — OTP and correspondence via shturko.info@gmail.com.
  • Couriers and payment providers — not used while there is no commercial activity.

6. Retention

  • Account/identity — while you use the service or until deletion (unless law requires longer).
  • OTP codes — minutes.
  • Analytics events — about 90 days.
  • Teachers’ code access statistics — up to 180 days.
  • Waitlist — up to 12 months after the shop opens, or until you unsubscribe.
  • Feedback — until handled plus a reasonable follow-up period.
  • Consent cookie — up to 12 months or until you change it.

7. Your rights

You may access, rectify, erase, restrict, port (where applicable), object, and withdraw consent at any time. You may complain to the CPDP. Contact: shturko.info@gmail.com.

8. Cookies

See the Cookie Policy. Change choices via “Cookie settings” in the site footer.

9. Changes

We will update this page when material changes occur. When commercial activity starts, trader, delivery, payment and withdrawal details will be added.

Optional emails

Shturko sends promotions, useful information, new PDF worksheets for your chosen decks, new games and content, and new deck announcements only for the topics you separately choose. Boxes are unchecked by default. Declining does not affect your purchase or included access. We keep your choices, date, source and notice version as evidence of consent. Change topics or unsubscribe using the link in every subscription email. Order emails and included materials are separate from subscriptions.