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Privacy policy

PRIVACY POLICY OF “EXECUTIVE CONTENT” LTD

This Privacy Policy is adopted in accordance with the requirements of REGULATION (EU) 2016/679 of the European Parliament and of the Council (General Data Protection Regulation – GDPR) and aims to inform you about your rights regarding the processing of your personal data. Please read this document carefully, as it is intended to explain the main rules that “Executive Content” Ltd (hereinafter referred to as “the Company”) applies when collecting and processing your personal data.

I. DATA CONTROLLER:

“Executive Content” Ltd is a Bulgarian company offering consulting services in the field of communications, public relations, training in communication strategies, intellectual property trading and know-how, and more. Detailed information is available at executivecontent.bg or by contacting us directly.

Contact details of “Executive Content” Ltd, UIC 208044214:
Registered office: 6 Vincent van Gogh Street, 1407 Sofia, Bulgaria
Legal representative: Magdalena Ivanova
Data Protection Officer: Magdalena Ivanova
Email: info@executivecontent.bg

II. DEFINITIONS

All terms used in this document are defined according to Article 4 of the General Data Protection Regulation (EU) 2016/679.

Additional terms not included in the GDPR:

  • B2B (business-to-business) – refers to the Company’s business relations with other businesses;

  • B2C (business-to-consumer) – refers to the Company’s relations with individual consumers of its services.

III. CATEGORIES OF DATA SUBJECTS

The Company interacts with the following categories of data subjects, as required by its business:

  • Individuals – clients who have used the services offered on the website (B2C);

  • Legal entity representatives – publicly listed individuals in the Commercial Register (B2B).

This policy is intended to protect the data of natural persons.

These policies apply alongside the General Terms of Use of the website executivecontent.bg and the Cookie Policy, both of which are integral parts of this Privacy Policy.

IV. PERSONAL DATA

The personal data we collect and process from you as our client may include:

  • When purchasing a service – email and service-specific details. Depending on the communication channel you use, you may also voluntarily provide additional data (e.g. phone number, company name, etc.).

  • When submitting a contact form inquiry – name and surname, in addition to the above.

  • For invoice issuance – full name, address, and other billing details.

  • When paying via bank transfer – bank account information, account holder’s name, and payment details.

  • In case of order cancellation and refund request – full name, email, bank account, and service details.

The Company does not collect or process special categories of personal data as defined in the GDPR.

We do not intentionally collect data from minors and do not offer services to them. Minors should not submit personal data without the consent of a parent or guardian.

V. LEGAL GROUNDS AND PURPOSES FOR DATA PROCESSING

1. For contract performance:

Personal data provided when purchasing a service or requesting a consultation is processed for contract conclusion and execution under our General Terms.
Legal basis: Article 6(1)(b) GDPR

2. Based on consent:

When submitting a general inquiry not tied to a specific service, we process your data based on your explicit consent.
You can withdraw your consent at any time by emailing: info@executivecontent.bg
Legal basis: Article 6(1)(a) GDPR

3. Legal obligation:

Data used for invoicing and tax compliance is processed according to Bulgarian tax laws and the Consumer Protection Act.
Legal basis: Article 6(1)(c) GDPR

VI. HOW WE COLLECT YOUR DATA

All personal data is voluntarily submitted by you through our website or communication channels (social media, email, etc.) and only after you choose to interact with us.

VII. DATA STORAGE

We have implemented appropriate technical and organizational measures to protect your data, including password protection and restricted access.

VIII. DATA RETENTION PERIOD

  • Contractual data – up to 5 years after contract fulfillment or termination.

  • Data processed based on consent – deleted upon consent withdrawal.

  • Accounting/tax data – up to 10 years after the last payment. If subject to audits or inspections, the period may be extended.

IX. DATA DESTRUCTION

Upon expiration of the data retention period, personal data is securely destroyed to prevent unauthorized access or use.

X. DATA SHARING

Personal data may be shared with:

  • An accounting firm (for tax purposes)

  • An IT services company (for website maintenance)

All third parties are bound by confidentiality and data protection agreements.

XI. DATA SUBJECT RIGHTS

You have the right to:

  • Access your personal data and receive information about its processing;

  • Correct inaccurate or outdated data;

  • Restrict processing or request deletion of your data when it’s no longer needed;

  • Data portability – receive your data in a structured format or request its transfer to another controller;

  • Object to processing based on public interest or legitimate interests;

  • File a complaint with the Bulgarian Data Protection Commission.

We do not use automated decision-making or profiling.

XII. RISK ASSESSMENT

We assess the risks associated with personal data processing and take appropriate measures to minimize potential harm. If a high risk is identified, we consult with the relevant supervisory authority.

XIII. SECURITY MEASURES

We have implemented both technical and organizational security measures to ensure the confidentiality and integrity of personal data. No third party may access your data unless a written confidentiality agreement is in place.

XIV. CHANGES TO THIS POLICY

Any changes to this policy will be published on our website.

Effective date: January 1, 2025