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Privacy Policy

Effective Date: January 2025

1. Data Controller

"BRILLIANT FLUX" EOOD
UIC: 208566194
VAT: BG208566194
Sveti Vlas, 8256, Bulgaria

Contact:
Email: [email protected]
Phone: +359 882 597 932

2. What Data We Collect

We collect and process the following personal data:

Information You Provide:

  • Contact Information: Name, email address, phone number, company name
  • Communication Records: Correspondence via email, contact forms, or meetings
  • Professional Information: Job title, industry, business requirements
  • Meeting Data: Calendar bookings, meeting preferences (when applicable)

Automatically Collected Technical Data:

Our website uses Cloudflare for security and performance. Cloudflare automatically collects:

  • IP Address: For security, DDoS protection, and content delivery
  • Browser Information: User agent, browser type, device type
  • Technical Data: Request headers, page accessed, time of access

This data is necessary for the technical operation and security of our website and is retained by Cloudflare according to their data retention policies.

3. How We Use Your Data

We use your personal data for the following purposes:

  • Service Provision: To respond to inquiries and provide requested AI automation services
  • Communication: To send information about our services and project updates
  • Meeting Coordination: To schedule and manage consultations and project meetings
  • Security & Performance: To protect our website from threats and ensure optimal performance (via Cloudflare)
  • Legal Compliance: To comply with applicable laws and regulations

Legal Basis for Processing:

We process your data based on:

  • Consent (when you submit contact forms or request information)
  • Contractual Necessity (to provide services you request)
  • Legitimate Business Interests (to manage client relationships and website security)
  • Legal Obligations (to comply with Bulgarian and EU laws)

4. How We Share Your Data

We do not sell, rent, or trade your personal data to third parties.

We may share your information with:

  • Service Providers: Third-party vendors who assist in:
    • Website hosting and security (Cloudflare)
    • Email delivery and communication tools
    • Calendar and scheduling services (if applicable)
  • Legal Requirements: When required by law, court order, or to:
    • Comply with legal obligations
    • Protect our legal rights and property
    • Prevent fraud or security threats
    • Protect the safety of our users or the public
  • Business Transfers: In connection with mergers, acquisitions, reorganization, or asset sales, your data may be transferred as part of business assets

All third-party service providers are contractually required to protect your data and use it only for specified purposes.

Cloudflare: Our website uses Cloudflare for content delivery and security. Cloudflare may process technical data (IP addresses, request data) according to their privacy policy: https://www.cloudflare.com/privacypolicy/

5. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including for the use of cloud services and analytics tools.

When we transfer data internationally, we ensure appropriate safeguards are in place, such as:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Adequacy Decisions confirming sufficient data protection in the recipient country
  • Binding Corporate Rules for transfers within corporate groups

6. Data Security

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, use, or disclosure, accidental loss, destruction, or damage, and unlawful processing.

Security measures include:

  • Encryption of data in transit and at rest
  • Access controls and authentication
  • Regular security audits and updates
  • Staff training on data protection

However, no internet transmission or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

7. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this policy or as required by law.

Retention periods:

  • Contact Inquiries: 3 years after last contact
  • Client Data: Duration of business relationship + 7 years (for legal and accounting purposes)
  • Technical Logs (Cloudflare): Managed by Cloudflare according to their retention policy

After retention periods expire, we securely delete or anonymize your data.

8. Your Rights (GDPR)

Under the General Data Protection Regulation (GDPR) and Bulgarian Law on Personal Data Protection, you have the following rights:

  • Right to Access: Request a copy of your personal data we hold
  • Right to Rectification: Correct inaccurate or incomplete data
  • Right to Erasure ("Right to be Forgotten"): Request deletion of your data in certain circumstances
  • Right to Restrict Processing: Limit how we use your data
  • Right to Data Portability: Receive your data in a structured, machine-readable format
  • Right to Object: Object to processing based on legitimate interests or for direct marketing
  • Right to Withdraw Consent: Withdraw consent for marketing communications or cookies at any time
  • Right to Lodge a Complaint: File a complaint with a supervisory authority if you believe your rights have been violated

To exercise your rights, contact us at:
Email: [email protected]
Phone: +359 882 597 932

We will respond to your request within 30 days.

9. Technical Data Collection

Our website currently does not use cookies for tracking or analytics purposes.

Cloudflare Technical Data:

We use Cloudflare as our content delivery network (CDN) and security service. Cloudflare automatically processes certain technical data to:

  • Protect against DDoS attacks and malicious traffic
  • Deliver website content efficiently
  • Ensure website security and performance

This processing is necessary for the technical operation of our website. For more information, see Cloudflare's privacy policy at https://www.cloudflare.com/privacypolicy/

Future Use of Cookies:

If we implement analytics or other tools that use cookies in the future, we will update this Privacy Policy and may implement a cookie consent mechanism as required by law.

10. Third-Party Services

We use the following third-party services that may process personal data:

  • Cloudflare: Website security, content delivery, and DDoS protection
  • Email Services: Email delivery and communication tools
  • Hosting Providers: Website hosting and infrastructure

Each service has its own privacy policy:

  • Cloudflare Privacy Policy: https://www.cloudflare.com/privacypolicy/

We ensure that all third-party providers comply with GDPR and implement appropriate data protection measures.

11. Children's Privacy

Our services are not directed at individuals under 16 years of age. We do not knowingly collect personal data from children.

If we become aware that we have collected data from a child under 16, we will delete it promptly.

12. Marketing Communications

We may send you service-related communications and updates about our AI automation services.

Types of Communications:

  • Responses to your inquiries
  • Service updates and project information
  • Relevant industry insights (with your consent)

Unsubscribe: You can opt-out of non-essential communications at any time by:

  • Contacting us at [email protected]
  • Clicking "unsubscribe" in emails (when implemented)

We will always honor opt-out requests promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal or regulatory requirements, or new features or services.

We will notify you of material changes by posting the updated policy on this page with a new effective date, sending an email notification (for significant changes), or displaying a notice on our website.

We encourage you to review this policy periodically.

14. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or your personal data:

Email: [email protected]
Phone: +359 882 597 932
Mail: BrilliantFlux EOOD, Sveti Vlas, 8256, Bulgaria

15. Supervisory Authority

If you believe we have not adequately addressed your concerns, you have the right to lodge a complaint with the Bulgarian data protection authority:

Commission for Personal Data Protection (CPDP)
Website: https://www.cpdp.bg
Email: [email protected]
Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
Phone: +359 2 915 3518

You may also contact the data protection authority in your country of residence.


Last updated: January 2025

Policy Version: 1.0