Privacy

This policy explains what personal data the official website of Lora Hristova processes, why, on what legal basis, who receives it and what rights you have. It is drafted under Articles 13 and 14 of Regulation (EU) 2016/679, referred to below as the Regulation or GDPR.

Who processes your data

The controller of personal data within the meaning of the Regulation is Lora Hristova, a natural person, correspondence address 1 Vazrazhdane Square, Troyan 5600, Bulgaria, e-mail contact@lora-hristova.com.

No data protection officer has been appointed. The activity of this website does not fall within the cases under Article 37 of the Regulation in which an appointment is mandatory. For any question concerning your personal data, please write directly to the address given above.

What this policy covers

This policy covers this website only. It does not cover other websites reached through links from here, nor the official social media profiles. The policy of the respective platform or website applies there.

What data is processed

a) Data you give us yourself. When you send an enquiry through the form on the “For partners” page, we process your name, e-mail address, company or organisation if you have entered one, and the text of your message, together with anything else you have chosen to write in it.

b) Data that arises from the visit itself. The hosting provider records in its server logs what is usual for any website: the address the request comes from, that is an IP address, the time of the request, the page requested, the type of browser and the operating system. These records are created by the technical infrastructure, not by us, and are not used to track or profile a visitor.

c) One entry in your browser’s storage that remembers the language you chose. It contains no personal data and cannot be used to identify you. There is more about it below.

The site keeps no visitor statistics. It carries no traffic analytics tool, no counter and no third party tracking pixel.

On what basis and for what purpose

a) Replying to an enquiry sent through the form. The purpose is to answer you and to maintain the correspondence on the matter you wrote about. Where the enquiry concerns a possible partnership or other arrangement, the basis is Article 6(1)(b) of the Regulation, that is steps taken at your request prior to entering into a contract. Where the enquiry is of a general nature, the basis is Article 6(1)(f), that is the legitimate interest in replying to a person who has approached us.

b) Operation and security of the site. The hosting server logs exist so that the site works, so that faults can be found and so that abuse can be repelled. The basis is Article 6(1)(f), legitimate interest.

c) Compliance with legal obligations. Where a law, a court order or an order of a competent authority requires us to retain or disclose data, the basis is Article 6(1)(c).

d) Defence of rights. In the event of a dispute or a claim, data may be processed in order to establish, exercise or defend legal rights. The basis is Article 6(1)(f).

Data from the form is not used for automated marketing, is not added to any mailing list and is not sold.

Are you required to provide data

No. Filling in the form is voluntary. The fields marked with an asterisk are needed only so that we can reply to you; if they are left empty, the message is not sent. You may also write directly to contact@lora-hristova.com without using the form at all.

Cookies and browser storage

This site sets no cookies. That is why there is no consent banner either: there is nothing to ask consent for.

One single thing is kept in your browser’s storage: the language you chose, so that you do not have to choose it again each time. The entry appears only after you press the language button yourself, stays on your device alone, is sent nowhere and cannot be used to identify you. It is removed when you clear the site data in your browser. No consent is required for it, because it serves a service you have expressly requested.

The typefaces the site is set in are served by the site itself. It does not fetch them from a third party server, and when you open it your browser makes no connection to Google.

Video

The home page carries a film, and the page “My initiative” carries a report by the Bulgarian News Agency. Both play from YouTube. It does not load on its own. Until you press the play button, the page makes no connection to YouTube and sets no cookies on their behalf. Only after you press it does the video load through youtube-nocookie.com, that is YouTube’s reduced tracking mode, and from that moment Google’s terms and privacy policy apply to the playback.

The film belongs to the International Biathlon Union and the report to the Bulgarian News Agency. Both are shown embedded from their official channels. No copies of them are stored on this site.

Who receives the data

a) Formspree, Inc., United States of America. It receives the message from the form and forwards it by e-mail. The service is used under its general terms. As at the date of this version no separate data processing agreement has been concluded, and we are working to settle this.

b) Netlify, Inc., United States of America. The hosting of the site. It maintains the server logs described above and acts as a processor under a data processing agreement incorporated by reference into the service’s terms.

c) Google Ireland Limited and Google LLC, only if you press a video play button. In that case Google is an independent controller for the playback and its own policy applies.

d) Legal, accounting and other professional advisers, as well as competent authorities where the law so requires.

Partners and sponsors receive no personal data of visitors or followers. Where audience information is provided to them, it is aggregated and does not allow any individual to be identified.

Transfers outside the European Union

Formspree and Netlify are companies in the United States of America, and the data they process for us is processed there. This is a transfer to a third country within the meaning of Chapter V of the Regulation. For Netlify it is governed by the data processing agreement incorporated by reference into the service’s terms. For Formspree, as at the date of this version, we have no separate agreement and the service is used under its general terms. We are working to settle this.

If you would rather your data did not pass through a service outside the European Union, write directly to contact@lora-hristova.com instead of using the form. You may also request a copy of the applicable safeguards at that address.

How long the data is kept

a) Enquiries sent through the form and the correspondence about them are kept for twelve months from the last message on the matter, after which they are deleted. If the enquiry leads to a contract or another arrangement, the correspondence is kept for its duration and for five years thereafter, so that legal obligations can be met and rights defended in the event of a dispute.

b) The hosting server logs are kept for the period set by the hosting provider, which is short and serves technical maintenance and security.

c) The language entry in your browser storage remains until you clear the site data yourself.

Your rights

As a person whose data is processed, you have the right of access to it and to a copy of it under Article 15; to rectification of inaccurate or incomplete data under Article 16; to erasure under Article 17; to restriction of processing under Article 18; to portability, that is to receive your data in a machine readable form or to have it transmitted to another controller, under Article 20; and to object to processing based on legitimate interest, under Article 21.

Where processing is based on your consent, you have the right to withdraw it at any time. Withdrawal does not affect the lawfulness of processing before it.

To exercise these rights, write to contact@lora-hristova.com. You are not required to use the contact form. We reply within one month of receiving the request; for complex or numerous requests the period may be extended by a further two months, of which you will be informed. Exercising your rights is free of charge.

Right to lodge a complaint

If you consider that your rights have been infringed, you have the right to lodge a complaint with the supervisory authority. In Bulgaria this is the Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd, Sofia 1592, telephone +359 2 91 53 519, e-mail kzld@cpdp.bg, www.cpdp.bg. You may also lodge a complaint with the supervisory authority of your habitual residence or place of work.

Children

The site is not directed at children and the contact form is not intended for them. Under Bulgarian law a child’s consent for information society services is valid from the age of fourteen; below that age, consent is given by a parent or guardian.

For initiatives and events involving children, the consent of a parent or guardian is obtained before the event and before any filming or processing of data. For the images from the “Troyan Does Sport” festival, consents were collected by the organisers before the event itself.

If a parent or guardian believes that a child has provided data through this site, please write to contact@lora-hristova.com and the data will be deleted.

Security

The site is served over a secure connection only. Access to messages from the form is limited to the people who answer enquiries. No measure gives a full guarantee for transmission over the internet, so please do not send sensitive data through the form, for example health information or identity documents.

Automated decisions and profiling

No automated decision making, including profiling, within the meaning of Article 22 of the Regulation takes place.

Rights in the photographs and the image

Copyright in the photographs and the rights in the name and image of Lora Hristova are not the subject of this policy. They are set out on the “Image rights” page.

Changes to this policy

This policy may be amended when the way the site works changes, or when the law requires it. The date of the version in force is shown at the top of the page. A material change takes effect from the day it is published here.