BGEN

Privacy Policy (GDPR)

Last updated: November 2026

1. General

This Privacy Policy aims to inform users of this website about how personal data is collected, used, stored and protected, in accordance with Regulation (EU) 2016/679 (GDPR).

Data Controller: Stanimir Yasenov Koruev, trading as UpZora
Email: [email protected]

2. Data We Collect

Depending on how you use the site, we may collect the following data:

3. Purposes of Processing

Collected personal data is used to:

4. Legal Basis

Processing is carried out on the following legal bases:

5. Retention

Personal data is kept only for as long as necessary to fulfil the purposes for which it was collected. Booking data is retained for up to 24 months after the booking date. Registration data is retained until deletion is requested or 12 months of inactivity have elapsed.

6. Data Sharing

Personal data is never sold or rented. We share data only with the providers the site needs in order to run, and where the law requires it (e.g. by court or prosecutorial order). The processors we use are:

All of them act as data processors and are bound by GDPR. Google and Meta are established outside the EEA - transfers are made on the basis of the European Commission's adequacy decision (EU-US Data Privacy Framework) and standard contractual clauses.

7. Cookies and tracking

Google Analytics and the Meta pixel start only if you click "Allow" in the cookie notice. Until you answer, or if you click "Decline", they are not loaded at all. You can change your choice at any time:

7.1 Strictly necessary

These need no consent - without them the site or the portal does not work, or cannot remember your choice.

7.2 Analytics - with consent only

Google Analytics (_ga, _ga_* cookies) - aggregated statistics on how many people visit the site and which pages they read. It is not used for advertising. The legal basis is your consent.

7.3 Marketing - with consent only

Meta Pixel (_fbp, _fbc cookies) - on the home page and on the pages of our ad campaigns. Its purpose is to tell us which ads lead to real enquiries.

When you submit a request from a campaign page, Meta is told that a request was made, together with your email address and phone number in hashed form (an irreversible SHA-256 fingerprint), so that Meta can match the request to the ad you were shown. The same is also sent from our server - again only if you allowed it. Your email and phone are never transmitted in readable form, and Meta does not receive the content of your message. The legal basis is your consent.

On "Decline" we delete the Google Analytics and Meta cookies already stored in your browser. Declining does not limit your use of the site.

7.4 Our own visit statistics - no cookies

Separately from Google Analytics, our server counts which page was opened and where the visitor came from (e.g. a search engine, a social network, a link with utm_source), along with the device type and country. We do not store IP addresses and set no cookie for this; a visitor can only be told apart within the same day, after which that is no longer possible. The data is kept for up to 24 months and used only in aggregate, to see which channels bring visitors and enquiries. The legal basis is our legitimate interest in improving the site.

You have the right to object. Click the button and we stop counting your visits from this browser:

8. Data Security

We apply appropriate technical and organisational measures to protect personal data against:

We use encrypted HTTPS connections, hashed passwords and restricted access to the production database. However, 100% security of data transmission over the internet cannot be guaranteed.

9. Your Rights

Every user has the right to:

To exercise any of the above rights, send an email to [email protected]. We will respond within 30 days.

You have the right to lodge a complaint with the Commission for Personal Data Protection (CPDP): www.cpdp.bg, 2 Prof. Tsvetan Lazarov Blvd, 1592 Sofia.

10. Contact

Questions or requests regarding your personal data?

Write to us at [email protected] - we respond within 30 days.

11. Changes to This Policy

This policy may be updated periodically. Changes will be published on this page with a new date.