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Privacy Policy

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KUGAR EOOD (“KUGAR,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how KUGAR EOOD collects, uses, stores, discloses, and otherwise processes personal data when you visit www.kugaragency.com (the “Website”), contact us, submit an enquiry, or interact with our digital marketing and advertising activities.

We process personal data in accordance with applicable data-protection legislation, including Regulation (EU) 2016/679 (“GDPR”) and applicable Bulgarian data-protection laws.

1. Data Controller

The data controller responsible for the processing described in this Privacy Policy is:

KUGAR EOOD
Todor Kableshkov 1
1618 Sofia, Bulgaria
Company registration number (EIK): 101661297

KUGAR determines the purposes and means of processing personal data covered by this Privacy Policy.

For privacy-related enquiries or requests, please use the contact details made available on www.kugaragency.com.

Where KUGAR has appointed a Data Protection Officer (“DPO”), the relevant DPO contact details will be provided through the Website.

2. Personal Data We Collect

Depending on how you interact with the Website, we may collect the following categories of personal data.

2.1 Information You Provide to Us

When you contact us or submit an enquiry, we may collect information such as:

  • your name;

  • email address;

  • telephone number, where provided;

  • company or organisation name;

  • job title or role, where provided;

  • information contained in your enquiry or message;

  • details concerning the services you are interested in; and

  • any other information you voluntarily provide to us.

You should avoid submitting sensitive personal information through general enquiry forms unless we specifically request it.

2.2 Technical and Usage Information

When you visit the Website, certain technical information may be collected automatically, depending on your browser, device, hosting environment, and the technologies implemented on the Website.

This may include:

  • IP address;

  • browser type and version;

  • device type;

  • operating system;

  • approximate geographic location derived from technical information;

  • pages visited;

  • date and time of visits;

  • referring website or source;

  • interactions with the Website; and

  • other technical or usage information generated through cookies, pixels, tags, or similar technologies.

2.3 Analytics and Advertising Information

Where permitted by applicable law and, where required, subject to your consent, we may use analytics and advertising technologies to understand how visitors use our Website and to measure, optimise, and improve our advertising activities.

These technologies may collect information about:

  • visits and interactions with our Website;

  • advertising campaigns through which you reached our Website;

  • pages or content viewed;

  • interactions with advertisements;

  • conversion or campaign events; and

  • information associated with your browser, device, or online identifiers.

Depending on the technologies actually implemented on the Website, such processing may involve third-party analytics, advertising, social-media, or remarketing providers.

3. How We Use Personal Data

We may process personal data for the following purposes:

3.1 Responding to Enquiries

We use information submitted through contact forms and other communication channels to:

  • respond to your enquiry;

  • communicate with you about requested services;

  • provide proposals or information;

  • arrange meetings or consultations;

  • understand your requirements; and

  • maintain records of business communications.

The legal basis may be the taking of steps at your request prior to entering into a contract, performance of a contract, or our legitimate interests in managing business enquiries and communications, depending on the circumstances.

3.2 Providing and Managing Services

Where you become a Client, we may process personal data necessary to:

  • provide contracted services;

  • communicate with you;

  • administer the business relationship;

  • manage projects and deliverables;

  • process payments and invoices;

  • maintain business records; and

  • comply with contractual and legal obligations.

3.3 Website Analytics

We may use analytics technologies to understand Website traffic and user behaviour, identify technical problems, improve Website performance, and understand which content is useful to visitors.

Where consent is required for the relevant analytics technology, we will request consent before activating it.

3.4 Advertising and Remarketing

We may use advertising and remarketing technologies to:

  • measure advertising performance;

  • understand how users interact with our advertisements;

  • measure conversions;

  • create or use advertising audiences;

  • display relevant advertisements on third-party platforms; and

  • improve the effectiveness of our marketing campaigns.

Where required by applicable law, non-essential advertising and remarketing technologies will only be activated after obtaining the required consent.

You may withdraw or change your consent through the Website's cookie settings, where such functionality is available.

3.5 Legal and Security Purposes

We may process personal data where necessary to:

  • comply with legal obligations;

  • establish, exercise, or defend legal claims;

  • prevent fraud or misuse;

  • protect the security and integrity of our Website and systems;

  • enforce our Terms & Conditions; and

  • protect our legitimate business interests and rights.

4. Legal Bases for Processing

Depending on the circumstances, KUGAR relies on one or more of the following legal bases under Article 6 of the GDPR:

Consent — where you have given consent to a specific processing activity, such as certain non-essential cookies, analytics, or advertising technologies.

Contract or pre-contractual measures — where processing is necessary to provide services, respond to a request for services, or take steps at your request before entering into a contract.

Legal obligation — where processing is necessary for KUGAR to comply with an applicable legal or regulatory obligation.

Legitimate interests — where processing is necessary for KUGAR's legitimate interests, provided those interests are not overridden by your rights and freedoms. Such interests may include operating and improving our business, managing client relationships, maintaining security, preventing fraud, and protecting our legal rights.

Where we rely on legitimate interests, we consider the relevant interests and balance them against the rights and freedoms of individuals.

5. Cookies and Similar Technologies

The Website may use cookies and similar technologies.

Cookies are small files or identifiers placed on your device that allow a website to recognise your browser and remember certain information.

We may use different categories of cookies, including:

Strictly Necessary Cookies

These cookies are necessary for the Website to function properly and cannot normally be disabled through standard cookie settings.

Analytics Cookies

These cookies help us understand how visitors use the Website and allow us to measure and improve its performance.

Advertising and Remarketing Cookies

These technologies may be used to measure advertising effectiveness, build advertising audiences, and provide or measure remarketing campaigns on third-party platforms.

Non-essential cookies will be used only in accordance with applicable law and, where required, after obtaining your consent.

You can manage your cookie preferences through the cookie consent mechanism provided on the Website, where available. You may also control cookies through your browser settings.

6. Third-Party Services

KUGAR may use third-party service providers to operate the Website, analyse Website usage, manage communications, measure advertising performance, and provide digital marketing functionality.

Depending on the Website's configuration, these may include providers of:

  • website hosting and infrastructure;

  • analytics services;

  • advertising and remarketing services;

  • social-media advertising services;

  • customer relationship management systems;

  • email and communication services;

  • security services; and

  • other technology or business services.

Third-party providers may process personal data on our behalf as data processors or may process certain data independently as separate controllers, depending on their role and the applicable service.

We seek to use reputable providers and implement appropriate contractual and technical safeguards where required by applicable law.

7. International Data Transfers

Some of our service providers or advertising and technology partners may process personal data outside the European Economic Area (“EEA”).

Where personal data is transferred outside the EEA, we will take appropriate measures required by applicable data-protection law.

Depending on the circumstances, these measures may include:

  • a European Commission adequacy decision;

  • Standard Contractual Clauses approved by the European Commission;

  • appropriate supplementary safeguards; or

  • another lawful transfer mechanism permitted under the GDPR.

You may contact us using the details provided on the Website if you require further information regarding applicable safeguards.

8. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, unless a longer retention period is required or permitted by law.

Retention periods may depend on the nature of the information and the purpose for which it is processed.

For example:

  • enquiry and communication data may be retained for as long as reasonably necessary to respond to and manage the enquiry and any resulting business relationship;

  • Client information may be retained for the duration of the contractual relationship and thereafter for as long as necessary to comply with legal, accounting, tax, or dispute-resolution obligations;

  • technical and analytics information may be retained according to the applicable configuration and retention settings of the relevant technology; and

  • information processed on the basis of consent may be processed until consent is withdrawn, subject to any other lawful basis that may apply.

When personal data is no longer required, we will delete it, anonymise it, or otherwise securely dispose of it, subject to applicable legal obligations.

9. Disclosure of Personal Data

We may disclose personal data to the following categories of recipients where necessary and lawful:

  • employees and authorised personnel of KUGAR;

  • professional advisers, accountants, lawyers, auditors, and insurers;

  • hosting and IT service providers;

  • analytics providers;

  • advertising and remarketing platforms;

  • communication and email service providers;

  • other contractors or service providers assisting us in operating our business;

  • payment and financial service providers, where applicable;

  • courts, regulators, government authorities, or law-enforcement bodies where required or permitted by law; and

  • potential buyers, investors, or successors in connection with a corporate transaction, subject to applicable law.

We do not sell personal data to third parties.

10. Your Data Protection Rights

Subject to the conditions and limitations established by applicable law, you may have the following rights:

Right of Access

You may request confirmation as to whether we process your personal data and, where applicable, request access to that data and certain information concerning its processing.

Right to Rectification

You may request correction of inaccurate or incomplete personal data.

Right to Erasure

You may request deletion of your personal data in circumstances provided by law.

Right to Restriction

You may request that processing of your personal data be restricted in circumstances provided by law.

Right to Data Portability

Where applicable, you may request to receive personal data you have provided to us in a structured, commonly used, and machine-readable format and request its transmission to another controller.

Right to Object

You may object to certain processing based on our legitimate interests.

You have an absolute right to object to the processing of your personal data for direct marketing purposes.

Right to Withdraw Consent

Where processing is based on your consent, you may withdraw your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Right to Lodge a Complaint

You have the right to lodge a complaint with a competent data-protection supervisory authority if you believe that the processing of your personal data infringes applicable data-protection law.

In Bulgaria, the competent supervisory authority is the Commission for Personal Data Protection (CPDP).

These rights are not absolute and may be subject to statutory conditions and exceptions.

11. How to Exercise Your Rights

You may submit a privacy-related request to KUGAR using the contact details made available on www.kugaragency.com.

When making a request, we may need to verify your identity to protect personal data from unauthorised disclosure.

We will respond to valid requests within the timeframe required by applicable data-protection law.

In general, requests under the GDPR should be handled without undue delay and, in principle, within one month, subject to the applicable rules concerning complexity and the number of requests.

12. Data Security

We take reasonable technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, destruction, alteration, disclosure, or other unlawful processing.

However, no method of transmission over the internet or electronic storage system can be guaranteed to be completely secure.

Accordingly, while we take appropriate measures to protect personal data, we cannot guarantee absolute security.

13. Children's Privacy

The Website and KUGAR's services are intended for business and general audiences and are not specifically directed at children.

We do not knowingly collect personal data from children where prohibited by applicable law.

If you believe that a child has provided personal data to us without appropriate consent, please contact us so that we can assess and, where appropriate, delete the information.

14. Automated Decision-Making and Profiling

We do not intend to make decisions producing legal or similarly significant effects on individuals solely through automated decision-making based on personal data collected through this Website.

Advertising and remarketing technologies may involve automated audience selection, measurement, or profiling by third-party advertising platforms. Such activities are governed in part by the relevant third party's privacy practices and settings.

Where applicable law requires additional information or safeguards concerning automated decision-making or profiling, we will provide such information.

15. Third-Party Websites

The Website may contain links to third-party websites, social-media platforms, or other online services.

KUGAR is not responsible for the privacy practices, security, content, or policies of third-party websites.

We encourage you to review the privacy policies of any third-party service before providing personal data to it.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to:

  • our services or business practices;

  • the technologies used on the Website;

  • applicable laws or regulatory requirements; or

  • our data-processing activities.

The updated version will be published on this page with a revised “Last updated” date.

Where required by law, we will provide additional notice or obtain consent for material changes to processing activities.

17. Contact Us

If you have questions about this Privacy Policy, our processing of personal data, or your data-protection rights, please contact:

KUGAR EOOD
Todor Kableshkov 1
1618 Sofia, Bulgaria
Company registration number (EIK): 101661297
Website: www.kugaragency.com

Please use the contact details provided on the Website for privacy-related enquiries and requests.

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