Privacy policy

1. Data controller

The controller under Regulation (EU) 2016/679 (GDPR) and the Bulgarian Personal Data Protection Act is:

• Name: Black Swan Social Ltd (Блек Суон Соушъл ЕООД)
• Company ID: 208310145
• VAT number: BG208310145
• Registered address: Shumen 9700, Slavyanski district, bl. 5, entr. 3, fl. 1, apt. 39, Bulgaria
• Email: hello@blackswan.social
• Phone: +359 899 197 263

2. What data we collect

• Contact form data: name, email, phone, business name, message.
• Technical data: IP address, browser type, operating system, pages and visit time - usually aggregated via analytics tools.
• Cookies: with consent - for analytics and ad measurement. See Cookie policy.

3. Purposes and legal grounds

• Responding to inquiries - ground: pre-contractual steps (Art. 6(1)(b) GDPR).
• Contract performance - ground: performance of a contract with the client (Art. 6(1)(b)).
• Analytics and marketing - ground: explicit consent (Art. 6(1)(a)), which you can withdraw at any time.
• Legal obligations - e.g. accounting and tax law (Art. 6(1)(c)).

4. Retention period

Form inquiries are kept for up to 24 months to track communication. Accounting documents are kept for 10 years under the Accounting Act. Marketing data - until consent is withdrawn or a maximum of 24 months.

5. Who we share data with

We share data only with processors needed to run the service:

• Hosting and infrastructure (Cloudflare, Supabase).
• Email provider for transactional messages.
• Google (Google Tag Manager, Google Ads, Google Analytics - only with consent).
• Meta Platforms (Facebook/Instagram ads - only with consent).

Some of these providers are established outside the EU/EEA. Transfers are based on standard contractual clauses approved by the European Commission.

6. Your rights

As a data subject you have the right to:

• access your data;
• request correction of inaccurate data;
• request erasure ('right to be forgotten');
• restrict or object to processing;
• withdraw consent at any time;
• data portability;
• lodge a complaint with the Bulgarian Commission for Personal Data Protection (CPDP), Sofia, www.cpdp.bg.

To exercise your rights, write to hello@blackswan.social.

7. Security

We apply technical and organizational measures (encryption in transit, restricted access, logs) to protect personal data from unauthorized access, loss or alteration.

8. Changes to this policy

We reserve the right to update this policy. The current version is always available on this page.