This document outlines how the SelfStartGlobal mobile application (the "App"), operated by SelfStartGlobal, a sole proprietorship (Eenmanszaak) registered in the Netherlands with its business address at Kennemerplein 6, 2011MJ Haarlem ("we," "us," or "our"), complies with the Children’s Online Privacy Protection Act ("COPPA") and relevant international age-related data protection regulations, including those under the GDPR.

Please note: this COPPA and Age Rating Disclosure is intended to supplement our Privacy Policy and Terms of Use. Please consult those documents for further details on our data practices.


1. General Audience and Intended Users

The App is primarily intended for teenage users aged 15 and older who are engaged in preparing for admission to international universities. These users may access our services independently or with support from their parents or legal guardians. While users under 18 are permitted to use the App, our onboarding process includes appropriate parental involvement to ensure lawful data processing and supervision. In jurisdictions where a higher age threshold applies (such as 16 under the GDPR for EEA users), we require verifiable parental consent before collecting or processing personal data. We remain attentive to evolving legal standards in each jurisdiction where our users reside.

The App is not designed for or marketed to children under the age of 13, and we do not knowingly collect personal information from users in this age group. In the ordinary course of business, we do not engage with users under 13 years old. However, if a situation arises in which we become aware that a child under 13 is attempting to access or has accessed our services, we will promptly implement all necessary measures in accordance with COPPA, including obtaining verifiable parental consent or deleting the child’s personal data where consent is not provided.


2. Age Verification and Parental Consent

To ensure compliance with data protection laws and the safe use of the App by minors, we implement robust age verification procedures and require parental or legal guardian consent in applicable cases as part of our onboarding process.

• For users under the age of 16 residing in the European Economic Area (EEA), we require verifiable parental consent in accordance with Article 8 of the GDPR. This consent must be freely given, specific, informed, and unambiguous, and must be obtained prior to any data processing;
• For users under the age of 13 (globally), we comply with the Children’s Online Privacy Protection Act (COPPA) by requiring verifiable parental consent before any personal information is collected or processed. While we generally do not serve users in this age group, if such a case arises, we will apply COPPA-compliant procedures without exception.

To facilitate the consent process, for all users, including those under the age of 18, registration and, therefore, proper access to the App are only permitted after the conclusion of a written service agreement. In the case of minors, such agreements are entered into directly by their parents or legal guardians on the minor’s behalf. This process ensures that identity, age, and legal responsibility are appropriately verified before any data is collected or processed;

We reserve the right to deny or suspend access if proper documentation or confirmation is not provided or cannot be validated.


3. Types of Data Collected from Minors

We collect only the data necessary to deliver educational consulting services and ensure effective communication between the user and their assigned SelfStartGlobal consultant. We do not use such data for profiling, marketing to minors, or automated decision-making.

Where permitted by applicable law and with valid parental or legal guardian consent, we may collect and process the following categories of personal data from users under the age of 18:

• Identity and demographic information, contact details: аull name, date of birth, age, nationality, and gender (if provided), email address and residential location (city and country); in some cases, parent or guardian contact details for verification and communication purposes.
• Educational data: academic history, school or university attended, test scores, transcripts, extracurricular activities, achievements, and intended academic programs.
• Application-related content: documents required for university admissions such as personal statements, CVs, letters of recommendation, certificates, or writing samples.
• Usage and communication data: in-app chat messages, voice notes, shared files, task progress, and other activity records generated through use of the App’s communication features.
• Technical data: device type, operating system, app version, and usage logs (used to ensure safe and functional access).

All data collected from minors is handled with heightened safeguards and is not shared with third parties except as strictly necessary to fulfill our services or comply with legal obligations.


4. Parental Rights

Parents or legal guardians of minor users have the following rights regarding the personal data we collect and process:

• Right to access: you may request to review the categories and specific pieces of personal data we have collected from your child, as well as how this data is used and shared;
• Right to rectification: you may request correction of any inaccurate or incomplete personal data relating to your child;
• Right to erasure: you may request deletion of your child's personal data, subject to applicable legal obligations that may require limited retention;
• Right to withdraw consent: you may withdraw your previously provided consent to our processing of your child’s data. If consent is withdrawn, we will disable the child’s account and cease further processing of their data unless otherwise required by law;
• Right to object or restrict processing: in certain circumstances, you may object to or request a restriction on how your child's data is being processed.

All such requests may be submitted at any time to hello@selfstartglobal.com. We will take reasonable steps to verify the identity and authority of the requester (e.g., confirmation of relationship to the child) before fulfilling the request. We aim to respond promptly and in accordance with applicable data protection timelines (e.g., within one month under the GDPR or 45 days under the CCPA, where applicable).


5. Age Rating for App Stores

For Apple App Store submission, the App is designated as suitable for users aged 12 and older. While the App does not contain objectionable content, its functionality involves collection of educational data and personal communication, which requires a moderate level of maturity and parental involvement.

We recommend that minors use the App only under the supervision of a responsible adult.


6. Updates to This Statement

We may update this document from time to time to reflect changes in legal requirements or app functionality. The most recent version will be made available in the App and on our website.