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Privacy Policy

Version 1.0 · Effective from [DATE]

WORKING TEMPLATE. This document is a draft for adaptation and does not constitute legal advice. All fields in square brackets must be filled in. Review and approve the final text with a lawyer before publishing.

If the Bulgarian and English versions differ, the Bulgarian version prevails.

1. Controller

The data controller is Code Cave Co Ltd., UIC 208340284, with registered office at [ADDRESS]. Contact: office@merka.bg and 0883 307 573.

2. What data we collect

With a configurator request: name, email, phone, preferred contact channel (if provided) and the project information you enter yourself: selected design, package, features and business details if you choose to share them.

With a partner application: name, email, phone, company and the chosen participation model.

With cookie management: a record of your choice with date, time, policy version and a service consent id. The record is stored in your browser and evidences your choice.

Technical data for form protection: IP address and service logs limiting abuse (for example many requests in a short time). With Google reCAPTCHA protection enabled, an interaction score is sent to Google; see section 6.

3. Purposes and legal bases

Reviewing your request, preparing an offer and contacting you: steps at your request prior to entering into a contract (Art. 6(1)(b) GDPR).

Protecting the forms from abuse and technical security: legitimate interest (Art. 6(1)(f) GDPR).

Analytics and marketing measurement: only with your explicit consent through the cookie banner (Art. 6(1)(a) GDPR). Consent can be withdrawn at any time from „Cookie Settings“.

We do not sell personal data and we do not make automated decisions with legal effects.

4. Recipients and processors

Hosting and technical infrastructure: [HOSTING PROVIDER].

Email delivery of confirmations and notifications: [EMAIL PROVIDER].

With consent for analytics cookies: Google Ireland Ltd. (Google Analytics 4) and Microsoft Ireland Operations Ltd. (Microsoft Clarity).

With consent for marketing cookies: Meta Platforms Ireland Ltd. (Meta Pixel and Conversions API). When a request is submitted, a server-side confirmation of the event is also sent to Meta, in which the email and phone are transmitted only in hashed (irreversibly encoded) form, together with the pixel's technical identifiers.

Access to the data is limited to authorized team members and processors under Art. 28 GDPR agreements. Some of the listed providers may process data outside the EEA under the safeguards of the standard contractual clauses.

5. Retention

Requests and the related correspondence: up to [24] months from the last contact, unless a contract follows.

Accounting documents: per the statutory periods.

The cookie consent record: 12 months in your browser, after which we ask again.

The form protection service logs: up to [30] days.

6. Cookies and measurement

Details about the cookies used, their lifetimes and consent management are described in the Cookie Policy at merka.bg/en/pravni/politika-za-biskvitki.

With form protection enabled, Google reCAPTCHA v3 is used. Technical data about the interaction with the page is sent to Google to distinguish real visitors from automated abuse.

7. Your rights

You have the right of access, rectification, erasure, restriction of processing, portability, objection and withdrawal of consent at any time, without affecting the lawfulness of processing before the withdrawal.

Requests are submitted to office@merka.bg. We respond within one month.

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

8. Changes

The current version of this policy is published on this page with an effective date. On a substantial change of the measurement tools in use, cookie consent is requested anew.

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