PRIVACY POLICY

Last Updated: October 06, 2025

ORLANDO HOLDING EOOD (registration number 208159800), with its registered office at 30, BACHO KIRO, ,Fl.: 1st, SOFIA, OBORISTE, 1000, Bulgaria (hereinafter referred to as "we", "us", "our company"), respects your privacy and is committed to protecting your personal data.

This Privacy Policy describes how we collect, use, disclose, and protect your information when you visit our website (the "Site") or use our IT solutions and services (the "Services").

Please read this policy carefully. By using our Site or Services, you agree to the terms set forth below.

1. INFORMATION WE COLLECT

1.1 Identity Information

Full name, job title, company name
Identity document data for verification purposes (when required)

1.2 Contact Information

Email address
Telephone number
Postal address
Company details and business registration information

1.3 Technical and Usage Information

IP address
Browser type and version
Operating system
Device identifiers
Pages visited
Date and time stamps
Referral and exit pages
Click-stream data
Error logs and system performance data

1.4 Cookies and Tracking Technologies

We use cookies, web beacons, pixels, local storage, and similar technologies to recognize your device and collect information about your browser activity.

1.5 Communication Data

Messages, inquiries, feedback, and other content sent through contact forms
Email correspondence
Data from chat systems and social media interactions

1.6 Transaction Data

Payment details and billing information
Billing address
Transaction dates and amounts
Information about IT services provided

2. HOW WE COLLECT DATA

2.1 Direct Collection

When you complete forms, register an account, place an order for IT solutions, subscribe to newsletters, or otherwise interact with our Site or Services.

2.2 Automatic Collection

Through cookies and similar technologies when browsing our Site. Most browsers allow you to reject cookies or alert you when cookies are being sent.

2.3 External Sources

We may receive information about you from trusted partners and publicly available sources (such as social media, professional directories, business registries).

3. PURPOSES OF DATA PROCESSING

We use personal data for:

Providing, operating, and maintaining the Site and Services
Processing orders, invoices, returns, and technical support requests
Communicating important updates, security notifications, and administrative messages
Personalizing content, recommendations, and advertising
Conducting internal research, analytics, and reporting to improve functionality
Marketing activities (only with your consent)
Detecting, preventing, and addressing technical issues and fraud
Complying with legal obligations and regulatory requirements

4. LEGAL BASIS FOR PROCESSING

We rely on the following legal bases in accordance with Bulgarian and European legislation:

Contract Performance: to fulfill our obligations when you purchase IT products or services
Consent: when you agree to receive marketing communications or optional cookies
Legitimate Interests: for business administration, network security, and fraud prevention
Legal Obligations: to comply with legislative and regulatory requirements

5. COOKIES AND TRACKING

5.1 Types of Cookies

Strictly Necessary: required for the Site to function properly
Performance and Analytics: collect anonymous data about Site usage
Functional: remember preferences and settings
Targeting and Advertising: deliver relevant advertising and measure campaign effectiveness

5.2 Managing Cookies

You can configure your browser to reject all or some cookies, or to alert you when cookies are being sent. Disabling certain cookies may affect Site functionality.

6. DATA SHARING AND DISCLOSURE

We do not sell, rent, or trade your personal data. We may share data with:

6.1 Service Providers

Hosting providers
Payment processors
Email service providers
Analytics services
Marketing automation platforms
IT partners for solution implementation

6.2 Professional Advisors

Legal counsel, auditors, and financial advisors to ensure compliance and risk management.

6.3 Affiliates and Subsidiaries

Within our corporate group for operational and administrative purposes.

6.4 Business Transactions

In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the acquiring party.

6.5 Government Authorities

To comply with court orders, subpoenas, or lawful requests from government authorities.

All third parties are contractually obligated to maintain appropriate safeguards and confidentiality.

7. INTERNATIONAL DATA TRANSFERS

Your data may be transferred, processed, and stored in Bulgaria and countries outside the EU. When making transfers, we implement Standard Contractual Clauses or other approved mechanisms to ensure an adequate level of protection.

8. DATA RETENTION

We retain personal data only as long as necessary for the stated purposes or to fulfill legal, regulatory, or accounting requirements. When data is no longer needed, we securely delete or anonymize it.

9. YOUR RIGHTS

Under applicable law, you have the right to:

Access your personal data and obtain a copy
Request correction or completion of inaccurate or incomplete data
Request deletion of your personal data ("right to be forgotten")
Restrict or object to processing based on legitimate interests
Data portability to another controller in a structured, machine-readable format
Withdraw consent at any time without affecting the lawfulness of prior processing

To exercise these rights, contact us at info@orlandoholding.bg. Verification may be required to process your request.

10. SECURITY MEASURES

We implement technical and organizational measures to protect data from unauthorized access, disclosure, alteration, or destruction. Measures include:

Data encryption
Firewalls and security systems
Multi-factor authentication
Regular security assessments
Staff training programs
IT infrastructure monitoring
Data backup and recovery procedures

11. CHILDREN'S PRIVACY

Our Site and Services are not intended for children under 16 years of age. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a child, please contact us to request deletion.

12. THIRD-PARTY LINKS

Our Site may contain links to third-party websites. We are not responsible for the privacy practices or content of such sites. We recommend reviewing their privacy policies before providing personal data.

13. CHANGES TO THE PRIVACY POLICY

We may update this policy to reflect changes in our practices, technology, legal requirements, or business operations. The revised policy will be posted with a new effective date. Continued use of our Site or Services constitutes acceptance of the updated policy.

14. SPECIAL PROVISIONS FOR IT SOLUTIONS

As part of providing IT solutions and services, we may:

Process technical data for system configuration and optimization
Collect system logs for monitoring and diagnostics
Analyze performance of implemented solutions
Provide technical support with potential remote access (only with explicit client permission)
Ensure integration with existing client IT systems
Maintain solution documentation and update records

15. CLIENT DATA PROTECTION IN IT SERVICES

When providing IT services, we act as both data controller and processor:

As Data Controller: for client contact information, billing data, and service usage analytics
As Data Processor: when handling client data through implemented IT solutions
We maintain separate Data Processing Agreements (DPAs) with clients
Client data is processed only according to documented instructions
We implement appropriate technical and organizational measures for client data
Data breach notification procedures are established for both controller and processor roles

CONTACT INFORMATION
ORLANDO HOLDING EOOD
Registration Number: 208159800
Address: BULGARIA, Sofia, Oborishte district, Bacho Kiro street, 30, floor 1
Email: info@orlandoholdingltd.com

Note: This Privacy Policy has been prepared in accordance with EU Regulation 2016/679 (GDPR), the Bulgarian Personal Data Protection Act, and applicable national legislation.

Compliance Statement: Orlando Holding EOOD is committed to maintaining the highest standards of data protection and regularly reviews its practices to ensure ongoing compliance with evolving privacy regulations.