Legal
Privacy Policy
How Iskrena Technologies collects, uses, and protects your personal data — fully compliant with the EU General Data Protection Regulation (GDPR).
This Privacy Policy explains how Iskrena Technologies LLC (“Iskrena”, “we”, “us”, or “our”) processes personal data in connection with our website iskrenatech.com and our services. We are established in Bulgaria and operate within the European Union. This policy is governed by the EU General Data Protection Regulation (GDPR) (EU) 2016/679.
1. Data Controller
The data controller responsible for personal data processed through this website and our services is:
Iskrena Technologies LLC
European Trade Centre, Sofia 1784, Bulgaria
Email: info@iskrenatech.com
Phone: +359 897 980 391
Registered and operating under Bulgarian commercial law.
2. Data We Collect
2.1 Data you provide directly
When you use our contact form, we collect: Full nameEmail addressCompany name (optional)Message content. When you book a strategy call via Calendly, Calendly collects your name, email address, and scheduling preferences under their own privacy policy.
2.2 Data collected automatically
When you visit our website, we may collect: IP addressBrowser type and versionDevice type and operating systemPages visited and time spentReferring URLGeneral geographic location (country/city level). This data is collected through server logs and any analytics tools we operate.
2.3 Data collected through client projects
When you engage us for a project (Website, Webshop, or WebApp), we may process business contact data, project briefs, brand materials, and other information you share to fulfil the engagement. This data is processed under our contract with you (see Section 4).
We do not collect sensitive personal data (special categories under GDPR Article 9) and we do not use automated decision-making or profiling.
3. How We Use Your Data
Responding to contact form enquiries
Legitimate interest / Pre-contractual stepsScheduling and conducting strategy calls
Pre-contractual steps / Contract performanceDelivering project services (design, development, deployment)
Contract performanceSending project updates, invoices, and deliverables
Contract performanceWebsite analytics and performance monitoring
Legitimate interestLegal compliance and record-keeping
Legal obligationProtecting our rights in case of disputes
Legitimate interestWe do not sell, rent, or otherwise commercially exploit personal data to third parties.
4. Legal Basis for Processing (GDPR Article 6)
We process your personal data on the following legal grounds:
6(1)(a) — Consent
Where you have freely given consent, for example by submitting a contact form or opting into communications.
6(1)(b) — Contract performance
Processing necessary to perform a contract with you, or to take pre-contractual steps at your request (e.g. preparing a project proposal).
6(1)(c) — Legal obligation
Processing necessary to comply with applicable Bulgarian and EU law (e.g. accounting records, tax obligations).
6(1)(f) — Legitimate interests
Processing for our legitimate business interests where these do not override your rights and freedoms (e.g. website security, analytics, direct follow-up to an enquiry).
5. Data Retention
To follow up on potential projects and maintain a record of communications.
Bulgarian accounting law requires retention of business records for 7 years from contract completion.
Standard analytics retention window for trend analysis and performance monitoring.
To maintain a record of project discussions, scope agreements, and deliverable confirmations.
After the applicable retention period, personal data is securely deleted or anonymised.
7. International Data Transfers
Some of our sub-processors (Calendly, Vercel, Stripe) are based in the United States. Where personal data is transferred outside the European Economic Area (EEA), we ensure adequate safeguards are in place, including:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- The EU-U.S. Data Privacy Framework (DPF), where the recipient is certified
- Binding Corporate Rules or other approved transfer mechanisms
You may request a copy of the transfer safeguards applicable to your data by contacting us at info@iskrenatech.com.
9. Your Rights Under GDPR
As a data subject under the GDPR, you have the following rights. You may exercise any of them at any time by contacting us at info@iskrenatech.com. We will respond within 30 days of receipt.
Right of Access (Art. 15)
Obtain confirmation of whether we process your data, and receive a copy of that data.
Right to Rectification (Art. 16)
Request correction of inaccurate or incomplete personal data we hold about you.
Right to Erasure (Art. 17)
Request deletion of your personal data ("right to be forgotten") where no overriding legal ground exists.
Right to Restrict Processing (Art. 18)
Request that we limit how we use your data while a dispute is resolved.
Right to Data Portability (Art. 20)
Receive your data in a structured, machine-readable format to transfer to another controller.
Right to Object (Art. 21)
Object to processing based on legitimate interests. We will cease unless we demonstrate compelling grounds.
Right to Withdraw Consent (Art. 7)
Where processing is based on consent, withdraw it at any time without affecting prior processing.
Right to Lodge a Complaint
File a complaint with the Bulgarian Commission for Personal Data Protection (CPDP) at cpdp.bg or your local supervisory authority.
We will not charge a fee for exercising your rights unless requests are manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee or decline the request with justification.
10. Minors
Our website and services are directed solely at businesses and professionals. We do not knowingly collect personal data from individuals under the age of 16. If you believe we have inadvertently collected data from a minor, please contact us immediately at info@iskrenatech.com and we will delete it promptly.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or the services we offer. When we make material changes, we will update the “Last Updated” date at the top of this page. We encourage you to review this policy periodically.
Continued use of our website or services after an updated policy has been posted constitutes acceptance of the updated terms, to the extent permitted by applicable law.
12. Contact Us
For any questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact us:
Iskrena Technologies LLC
European Trade Centre, Sofia 1784, Bulgaria
Email: info@iskrenatech.com
Phone: +359 897 980 391
If your complaint is not resolved to your satisfaction, you have the right to lodge a complaint with the Bulgarian Commission for Personal Data Protection (CPDP): cpdp.bg, or with the data protection authority of your EU member state.