Privacy Policy & Cookies

DRAFT — confirm the marked analytics retention setting before publication.

Last updated: 4 October 2026

1. Who we are

Spagiria LTD operates the SPAGIRIAᴮ website at https://www.spagiriabrand.com and is the controller of the personal data described in this policy.

Registered address: 25 Vitosha Blvd., fl. 2, Sofia 1000, Bulgaria.

For privacy questions or requests, contact info@spagiriabrand.com.

This website presents our services and enables enquiries and newsletter subscriptions. It does not accept online payments.

2. Information we collect and why

Enquiries and correspondence. When you contact us, we receive the information you provide, such as your name, email address, telephone number, company details and project information. We use it to answer your enquiry, discuss your project and prepare proposals. Where you request services for yourself, processing is necessary to take steps at your request before entering a contract. For other business correspondence, including enquiries made on behalf of a company, we rely on our legitimate interest in responding to enquiries and managing business relationships.

Newsletter subscriptions. We collect your email address and subscription information when you choose to subscribe. We use your consent to send the updates you requested. Contacting us about a project does not automatically subscribe you to marketing emails. You can unsubscribe through the link in a newsletter or by emailing us.

Website operation and security. Our website and service providers may process technical information, including IP addresses, browser and device information, access times and pages requested. We use this information to operate the website, identify faults and prevent misuse, relying on our legitimate interest in maintaining a secure, functioning website.

Website analytics. We use Google Analytics to understand visits, traffic sources and interactions with our content. Depending on your consent and the service configuration, this can include page views, device and browser information, approximate location and cookie identifiers. We rely on your consent for non-essential analytics cookies and associated analytics processing.

Spam prevention. Our forms use Google reCAPTCHA. Google processes technical and interaction information to help distinguish legitimate visitors from automated submissions. Our purpose is to prevent spam and protect our forms, based on our legitimate interest in website security. Google's Privacy Policy and Terms apply to its service: https://policies.google.com/privacy and https://policies.google.com/terms.

Providing enquiry and subscription information is voluntary. Without the relevant contact details, we may be unable to respond or send requested updates. Please do not include sensitive personal information in your enquiry.

3. Cookies and your choices

Cookies are small files stored on your device. Our website uses technologies for essential functions, security, remembering cookie choices and, with your consent, analytics.

Necessary cookies support website functionality and security. Google reCAPTCHA also uses a security cookie for its risk analysis. These functions are separate from optional analytics.

Our cookie banner provides Accept all, Decline all and Manage cookies choices. Non-essential cookies are restricted until you accept the relevant category. Declining optional cookies does not prevent you from browsing the website or contacting us.

You can revisit Cookie Preferences on the website to change your choices or withdraw consent. You can also remove cookies through your browser settings; blocking necessary cookies may affect some functions.

Cookie lifetimes vary by cookie and provider. Squarespace describes its cookies at https://support.squarespace.com/hc/en-us/articles/360001264507-The-cookies-Squarespace-uses. Google's cookie information is available at https://policies.google.com/technologies/cookies.

4. Who receives information

We use service providers to operate the website and handle communications:

  • Squarespace: website hosting, forms, form submissions and subscriber contact storage.

  • Google: Google Analytics and reCAPTCHA.

  • Hostinger: our business email service.

Access is limited to people and providers who need the information for the relevant purpose. We may also disclose information when legally required or when necessary to establish, exercise or defend legal claims.

5. International transfers

Some providers process information outside the European Economic Area, including in the United States. Applicable transfer arrangements may include an adequacy decision, such as the EU–US Data Privacy Framework for certified recipients, or the European Commission's Standard Contractual Clauses. The relevant provider's terms describe its arrangements. You can contact us for information about the safeguards applicable to your data.

6. How long we keep information

  • Enquiries that do not lead to a client relationship: 12 months after our last communication, unless a legal obligation or an identifiable legal claim requires longer retention.

  • Client records: for the duration of the relationship and afterwards as required by applicable accounting obligations or relevant legal claim periods.

  • Newsletter records: while your subscription remains active. Following withdrawal, we retain only the limited records necessary to respect your unsubscribe choice or demonstrate consent where needed.

  • Google Analytics user and event data: [BEFORE PUBLICATION: insert the actual retention period and whether new activity resets the period, as shown in your GA4 settings. Aggregated reports are subject to different retention rules.]

  • Operational and security records: for the period needed to investigate faults or abuse and meet relevant obligations, according to the applicable service's retention arrangements.

7. Your rights

Subject to the conditions and exceptions in applicable law, you may request access, correction, deletion, restriction of processing or portability of your personal data. You may object to processing based on legitimate interests, and you may object to direct marketing at any time.

Where processing relies on consent, you may withdraw it at any time without affecting the lawfulness of earlier processing. To exercise your rights, email info@spagiriabrand.com. We may need reasonable information to verify your identity.

You may complain to the Bulgarian Commission for Personal Data Protection: https://cpdp.bg/en/. You may also contact the supervisory authority in the EU country where you live or work, or where an alleged infringement occurred.

8. Updates

We may update this policy when our website, services or data practices change. The date above identifies the latest revision.