Privacy Policy & Cookie Policy (GDPR)

Last updated: 2025-12-17

1. Controller Information

The data controller within the meaning of Article 4(7) GDPR is:

2. Scope of This Legal Pack

This Legal Pack explains how GAUDENS LTD collects, processes, stores, and protects personal data when users:

• Visit our website
• Use our services or platforms
• Communicate with us
• Enter into contractual or pre-contractual relationships

Processing is carried out in accordance with Regulation (EU) 2016/679 (GDPR), applicable Bulgarian data-protection law, and the ePrivacy Directive.

3. Categories of Personal Data Processed

Depending on usage, we may process:

3.1 Identification & Contact Data

• Name
• Email address
• Telephone number
• Company name

3.2 Technical & Usage Data

• IP address
• Browser type and version
• Device and operating system
• Date and time of access
• Referring URLs

3.3 Contractual & Billing Data

• Invoicing details
• VAT number
• Payment status (no raw card data stored)

3.4 Communication Data

• Contact form submissions
• Email correspondence
• Support communications

4. Legal Bases for Processing (Article 6 GDPR)

Personal data is processed only where lawful, based on:

• Consent (Art. 6(1)(a))
• Contractual necessity (Art. 6(1)(b))
• Legal obligations (Art. 6(1)(c))
• Legitimate interests (Art. 6(1)(f)), including:
  • Website security
  • Fraud prevention
  • Service optimisation

Consent may be withdrawn at any time.

5. Purposes of Processing

Personal data is processed for:

• Providing and operating services
• Handling inquiries and communications
• Contract management and billing
• Compliance with legal obligations
• IT security and abuse prevention
• Improving website functionality

No automated decision-making or profiling within the meaning of Article 22 GDPR is carried out.

6. Data Retention

Personal data is stored only as long as necessary for:

• Contractual purposes
• Legal retention requirements (e.g. tax law)
• Legitimate interests or legal defense

After expiry, data is securely deleted or anonymised.

7. Data Sharing & Processors

Personal data may be shared with:

• Hosting and IT providers
• Accounting and legal advisors
• Payment service providers
• Public authorities where legally required

All processors are bound by Article 28 GDPR Data Processing Agreements.

Personal data is never sold.

8. International Data Transfers

If data is transferred outside the EEA, this occurs only with:

• Adequacy decisions, or
• Standard Contractual Clauses (SCCs), or
• Other safeguards under Chapter V GDPR

9. Data Subject Rights

You have the right to:

• Access (Art. 15)
• Rectification (Art. 16)
• Erasure (Art. 17)
• Restriction (Art. 18)
• Data portability (Art. 20)
• Objection (Art. 21)
• Withdraw consent at any time

Requests can be sent to contact@gaudens.ltd

Response time: within one month.

10. Right to Lodge a Complaint

You may lodge a complaint with a supervisory authority, in particular in your EU Member State of residence or work.

For Bulgaria: Commission for Personal Data Protection (CPDP).

11. Security Measures

GAUDENS LTD applies appropriate technical and organisational measures (TOMs) including:

• Access controls and authentication
• Secure hosting environments
• Data minimisation
• Regular monitoring and updates

12. What Are Cookies?

Cookies are small text files stored on your device when visiting a website. They help ensure functionality, security, and user experience.

13. Types of Cookies We Use

13.1 Strictly Necessary Cookies

Required for basic website functionality and security.

13.2 Functional Cookies

Remember user preferences and settings.

13.3 Analytics Cookies

Help understand website usage and performance.

13.4 Marketing / Tracking Cookies

Used for advertising or tracking across websites (if applicable).

14. Cookie Consent Management

On first visit, users are presented with a cookie banner allowing them to:

• Accept all cookies
• Reject non-essential cookies
• Manage individual preferences

Consent is logged and can be withdrawn at any time via cookie settings.

15. Cookie Retention Periods

Cookies are stored for varying durations depending on their purpose, and are automatically deleted after expiry or when manually removed by the user.

16. Managing Cookies

Users can manage or delete cookies via:

• Browser settings
• Website cookie preference tools

Disabling cookies may affect website functionality.

17. Changes to This Legal Pack

GAUDENS LTD reserves the right to update this Legal Pack to reflect legal, technical, or business changes. The current version is always published on the website.