Version 1.

0, July 31st, 2021

PRIVACY POLICY

1. WHO WE ARE

The controller i.e. an entity that determines means and purposes of processing of
your personal data is ST Development Limited (hereinafter “we”, “us”, “StarTerra”), a
company existing and incorporated under the laws of the British Virgin Islands,
whose registered address is 2nd Floor, Ellen L. Skelton Building, Fishers Lane, Road
Town, Tortola, British Virgin Islands.

We are a blockchain technology company that operates a launchpad platform which

enables its users to obtain tokens at early stages of development of the crypto
projects.

We are devoted to protecting the privacy and personal data of all of our users and
business partners. This Privacy Policy sets out the basis on which any personal data
we collect from you, or that you provide to us, will be processed by us. We will
process your data in accordance with the data protection laws of British Virgin
Islands (Data Protection Act, 2021) as well as the Regulation (EU) 2016/679 of the
European Parliament and of the Council of 27 April 2016 on the protection of natural
persons with regard to the processing of personal data and on the free movement of
such data, and repealing Directive 95/46/EC (General Data Protection Regulation,
hereinafter “GDPR”) to the extent it is applicable to our activities.

2. HOW DO WE COLLECT AND PROCESS YOUR PERSONAL

DATA?

Depending on how you will interact with us, we may process different categories of
your personal data for different purposes. We may collect data from you directly on
this website (e.g. newsletter submission) or outside this digital property (e.g. via
forms, surveys, mailbox).

We may process your personal data in the following situations:

SELECTION FOR PUBLIC SALE OF $STT TOKENS

If you choose to take part in the process of selection of users who take part in the
public sale of $STT tokens, we will collect personal data about you via a dedicated
form available on ​sweepwidget.com.
We will process the following categories of personal data: your name, email address
and information about your progress with regard to the tasks enlisted in the form.

PURPOSE OF PROCESSING AND LEGAL BASIS FOR PROCESSING

We will process your data in order to select persons who will qualify for the chance to
take part in the public sale of $STT Tokens.

The legal basis for the processing of personal data is your consent. You have the
right to withdraw your consent at any time. Withdrawal of consent does not affect the
lawfulness of the processing which was carried out on the basis of consent before its
withdrawal.

RECIPIENTS OF YOUR PERSONAL DATA

Your data will be processed only by authorized staff. Your personal data may be
processed by or shared with data processors engaged by StarTerra, i.e., IT service
providers, cloud computing service providers and social media contest tool
providers.

Your personal data may be processed in the EEA and may be transferred to
countries from outside European Economic Area (“third countries”), in particular the
US. In case of data transfer to third countries, we will take measures to ensure the
transfer is in compliance with applicable laws (such as transferring the personal data
to a recipient that entered into data protection clauses referred to in article the
46(2)(c) GDPR or other measures provided by the GDPR.)

RETENTION PERIOD
Your personal data that you provided us with via sweepwidget will be processed by
us for no longer than 6 months since the day of its collection.

SELECTION FOR “AIRDROP” OF $STT TOKENS

If you choose to take part in the process of selection of users who acquire $STT in
the course of the “airdrop” distribution, we will collect personal data about you via a
dedicated form available on ​sweepwidget.com.

We will process the following categories of personal data: your name, email address
and information about your progress with regard to the tasks enlisted in the form.

PURPOSE OF PROCESSING AND LEGAL BASIS FOR PROCESSING

We will process your data in order to select persons who will qualify for “airdrop”
distribution of $STT tokens.

The legal basis for the processing of personal data is your consent. You have the
right to withdraw your consent at any time. Withdrawal of consent does not affect the
lawfulness of the processing which was carried out on the basis of consent before its
withdrawal.

RECIPIENTS OF YOUR PERSONAL DATA

Your data will be processed only by authorized staff. Your personal data may be
processed by or shared with data processors engaged by StarTerra, i.e., IT service
providers, cloud computing service providers and social media contest tool
providers.

Your personal data may be processed in the EEA and may be transferred to
countries from outside European Economic Area (“third countries”), in particular the
US. In case of data transfer to third countries, we will take measures to ensure the
transfer is in compliance with applicable laws (such as transferring the personal data
to a recipient that entered into data protection clauses referred to in article the
46(2)(c) GDPR or other measures provided by the GDPR.)

RETENTION PERIOD
Your personal data that you provided us with via sweepwidget will be processed by
us for no longer than 6 months since the day of its collection.

“KNOW YOUR CUSTOMER” PROCEDURE

In order to allow you to take part in the public sale of $STT Token, we will need to get
to know your identity to reduce the risk of fraud and other illegal intentions such as
identity theft, money laundering or financing of terrorism.

We will process the following categories of personal data: your name, your image,
date of birth, place of birth, place of residence, any other personal data included in
the picture of your document ID, proof of residence, your terra wallet address, results
of KYC procedure.

PURPOSE OF PROCESSING AND LEGAL BASIS FOR PROCESSING

We will process your personal data in order to conduct a KYC procedure for you to
reduce the risk of fraud and other illegal intentions such as identity theft, money
laundering or financing of terrorism

The legal basis for the processing of personal data is your consent. You have the
right to withdraw your consent at any time. Withdrawal of consent does not affect the
lawfulness of the processing which was carried out on the basis of consent before its
withdrawal.

RECIPIENTS OF PERSONAL DATA

Your data will be processed only by authorized staff. Your personal data may
processed by or shared with data processors engaged by StarTerra, i.e. IT service
providers, computing cloud service providers and KYC solution providers.
Your personal data may be processed in the EEA and may be transferred to
countries from outside European Economic Area (“third countries”). In case of data
transfer to third countries, we will take measures to ensure the transfer is in
compliance with applicable laws (such as transferring the personal data to a recipient
that entered into data protection clauses referred to in article the 46(2)(c) GDPR or
other measures provided by the GDPR.)

RETENTION PERIOD
Your data will be stored for no longer than is necessary for the above indicated
purpose and/or as long as required by applicable laws.

SUBMISSION FOR OUR NEWSLETTER AND OTHER COMMERCIAL

INFORMATION
If you would like to receive commercial information from StarTerra, in particular our
newsletter you may submit your email in a dedicated text input field on our website
or in a dedicated form on a third party’s digital property (e.g. sweepwidget).

We will process the following categories of personal data: your email.

PURPOSE OF PROCESSING AND LEGAL BASIS FOR PROCESSING

We will process your data for our marketing purposes i.e. to send you our
commercial information and promote our platform.

The legal basis for the processing of personal data is your consent for receiving
commercial information from us, in particular StarTerra newsletters. You have the
right to withdraw your consent at any time. Withdrawal of consent does not affect the
lawfulness of the processing which was carried out on the basis of consent before its
withdrawal.

RECIPIENTS OF YOUR PERSONAL DATA

Your data will be processed only by authorized staff. Your personal data may be
processed by or shared with data processors i.e. IT service providers, cloud
computing service providers and online marketing service providers.

Your personal data may be processed in the EEA and may be transferred to
countries from outside European Economic Area (“third countries”), in particular the
US. In case of data transfer to third countries, we will take measures to ensure the
transfer is in compliance with applicable laws (such as transferring the personal data
to a recipient that entered into data protection clauses referred to in article the
46(2)(c) GDPR or other measures provided by the GDPR.)

RETENTION PERIOD
Your data will be processed for 3 year since the day of its collection.

3. DATA SECURITY MEASURES

We have implemented organizational and technical measures to assure an

appropriate level of security of your data as required by Article 32 of the GDPR. We
have deployed procedures regarding every aspect of data processing, and we
carefully select technologies used for such processing and any data recipients.

Your data is protected against human interactions, equipment malfunctions, internal

or external attacks, losses, or misuses. To maintain data integrity we have designed
our systems and internal procedures to keep at all times consistency, accuracy, and
trustworthiness of data over its entire life cycle. Furthermore, our information
systems are developed and maintained to ensure data availability at high level,
making it consistently accessible to authorized end users and applications, when and
where they need it. Our systems and procedures also comply with the principles of
personal data processing established by GDPR, i.e. data minimization, limited
retention, purpose limitation, data accuracy, lawfulness and transparency.

We make sure that all our contractors maintain high standards in relation to data
security.

4. CHILDREN’S PRIVACY

We do not knowingly collect or solicit any information from anyone under the age of
18. This website is not directed at children under the age of 18. In the event that we
learn that we have collected personal information from a child under age 16 without
verification of parental consent, we will delete that information as quickly as possible.

5. EXERCISING YOUR PRIVACY RIGHTS

To the extent provided by the applicable data protection laws you have the right to:

● Right to express and withdraw your consent

If we ask for consent to process your personal data, you can always choose to give it
or not. We inform you about the right to withdraw your consent before giving
consent. If the processing is based on your consent, you may withdraw your consent
by contacting us at [email protected] or in case a commercial email from us by
clicking “unsubscribe” in the email you received.

● Right of access
You have the right to obtain confirmation if we process your Personal Data. If we do,
you have the right to access your personal data and receive a copy of your Data.

The first copy of your personal data is free of charge. For any further copies you
request, we may charge you a reasonable fee based on the administrative costs
resulting from preparing this information.

● Right to rectification
You have the right to rectify and complete the personal data you provide.

● Right to erasure (“right to be forgotten”)

To the extent permitted by the applicable laws you have the right to have us erase
your personal data.

We will keep some of your personal data despite the demand to erase it if it’s
necessary for performing our legal duties or establishing, pursuing, or defending a
claim.

● Right to restriction of processing

You have the right to have us restrict the processing of your personal data when one
of the following applies: you contest the accuracy of your personal data; the
processing of your personal data is unlawful, and you request the restriction of its
use instead of erasing it; we no longer need your personal data to process it, but you
require it to establish, exercise, or defend legal claims; you object to the processing
of your personal data.

● Right to object
You have the right to object, on grounds relating to your specific situation, at any
time, to the processing of your personal data, providing that we are processing your
personal data based on our legitimate interests.

Regarding the processing for legitimate interests as pointed out above, if your
objection turns out to be legitimate and we don’t have any other legal grounds for
processing your Data, we will remove the Data you don’t want us to process.

● Right to lodge a complaint with a supervisory authority

You have right to lodge a complaint with a competent supervisory authority in the
country you reside.

To find out more about your rights concerning processing of your personal data and
how to exercise them, please contact us at: [email protected]

6. COOKIES
On our website we do not use cookies or any other similar tracking technologies.

7. PRIVACY POLICY CHANGES

In order to develop the privacy protection, we may deem it fit or necessary to update
this Privacy Policy at any time. Please follow our website where we will inform you
about any material changes to our Privacy Policy.

8. CONTACT DETAILS

If you have any further questions related to your privacy, please do not hesitate to
contact [email protected]

Last updated July 31st, 2021