Last updated: 6 October 2025

1. Who We Are (Data Controller)

Belayer OOD (“Belayer”, “we”) is the controller of personal data processed in connection with our newsletters (Weekly Recap, Deep Dives and Quarterly Brief) and resource pages.

Company registration number (EIK): 204792388
Country: Bulgaria
Address: 7 Industrialna Street, Sofia, Bulgaria
Contact email: team@belayer.bg
Data Protection Officer (DPO): anastas.mateev@belayer.bg

2. Scope

This Policy applies to website visitors, newsletter subscribers, people who download materials (such as PDFs or “lead magnets”), participants in webinars or referral campaigns, and people who contact us by email.

3. Personal Data We Process

• Contact details: email address (required) and name (optional).

• Preferences: selected publications or topics, level of knowledge and language.

• Marketing activity: double opt-in confirmation, email opens and clicks, unsubscribes and frequency preferences.

• Technical data: IP address, device, browser and operating system type, approximate location derived from IP address, cookies and consent identifiers.

• Communications: enquiries, correspondence and requests to exercise data protection rights.

We do not request or process special categories of personal data under Article 9 of the GDPR.

4. Purposes and Legal Bases for Processing

• Sending and managing newsletters, including segmentation by selected topics: consent under Article 6(1)(a) of the GDPR.

• Analytics and improvements, including aggregated metrics and A/B testing: our legitimate interest in maintaining the quality of our content under Article 6(1)(f) of the GDPR.

• Security and compliance with the law: legitimate interests under Article 6(1)(f) and/or compliance with a legal obligation under Article 6(1)(c) of the GDPR.

If we wish to expand these purposes, we will request new consent.

5. Cookies and Consent Management

The website uses cookies for functionality, analytics and marketing. Non-essential cookies and scripts are used only after consent has been given. Visitors can manage their preferences through the consent banner or panel, and we keep records of consent in the website dashboard.

How to manage your preferences: use the “Manage Cookies” banner on the website and select “Settings”, or clear the cookies in your browser and make a new choice on your next visit.

6. Where We Obtain Data

We obtain data mainly from you directly, through subscription forms and email correspondence. Technical data is generated automatically when you visit the website or interact with our emails.

7. Sharing Data with Processors

We work with providers that help us deliver our services, subject to applicable data processing agreements (DPAs) and processing instructions:

• Wix.com Ltd.: website hosting and infrastructure, cookie banner, consent records and web forms. Wix provides a DPA for its users and publishes a list of its subprocessors and their locations. Its infrastructure uses multiple cloud providers (AWS and GCP), with data centres in the United States and Europe.

• Email delivery: we use our own email domain and tools within Wix (or a compatible email service provider). If we integrate an external email service provider, we will add it to Annex A (DPA/SCC).

• Analytics and measurement: we use Wix’s built-in tools or an external service that operates only after consent has been given, as described in Annex A.

We do not sell personal data.

8. International Transfers

When data is processed outside the European Economic Area (EEA), for example by a Wix subprocessor, we rely on Standard Contractual Clauses (SCCs) and supplementary measures in accordance with Wix’s policies and DPA.

9. Retention Periods

• Subscription data: until consent is withdrawn or after 24 months of inactivity, following which we anonymise or delete the data.

• Consent and security records: for up to 12 months, or as required by law.

• Campaign and referral data: for up to 24 months after the campaign ends, or as required by law.

10. Your Rights (Exercising Them Through Wix/Wix Studio)

Under the GDPR, you have the rights of access, rectification, erasure, restriction of processing, objection and data portability, as well as the right to withdraw your consent. We provide the following practical ways to exercise these rights using the features available through Wix:

• Withdraw consent to receive emails: use the “Unsubscribe” link in any email. This immediately stops marketing messages.

• Manage cookies and identifiers: use the cookie banner or panel available on the website.

• Request access or a copy of your data, rectification, erasure, restriction or portability: email team@belayer.bg. We may ask you to verify your identity. We handle requests using available features, exports and relevant providers. We will respond within one month. Where a request is complex, this period may be extended and we will inform you.

• Object to processing based on legitimate interests: email us and specify the processing you are objecting to. We will reassess it and restrict it where applicable.

11. Security

We apply technical and organisational measures, including TLS, access controls, data minimisation, consent records and regular reviews of our providers.

12. Minors

Our services are not intended for anyone under 18. If we learn that we have processed a minor’s personal data without the consent of a parent or guardian, we will delete it.

13. Changes to This Policy

We may update this Policy. We will announce significant changes on the website and/or by email. Continued use of the website after the effective date means that you accept the changes.

14. Contact

Privacy email: team@belayer.bg
Data Protection Officer (DPO): anastas.mateev@belayer.bg
Postal address: Belayer OOD, 7 Industrialna Street, Sofia, Bulgaria