Privacy Policy

Last edited / effective date: 11 April 2025

1. Introduction and Organizational Information

I am Dobromir Todorov, the individual owner and operator of prodigytal.net (“I,” “me,” or “my”).
As a personal blogger, I value the privacy of my visitors and am committed to protecting the personal information collected through my website.
In accordance with the General Data Protection Regulation (GDPR), I act as the Data Controller with respect to any personal data collected through this website. This means that I determine the purposes and means of processing your personal information.
This Privacy Policy explains:
- How I collect, use, store, and disclose your personal information.
- Your rights under applicable privacy laws.
While this policy is primarily designed to comply with the GDPR, as I reside within the European Union, I also strive to adhere to other international privacy standards to the best of my ability.
I recognize that my audience is global, and I am committed to handling your personal information responsibly and securely, regardless of your location.
If you have any questions or concerns about how your information is processed or how specific privacy laws may apply to you, please feel free to contact me. I am dedicated to resolving your concerns promptly and transparently.

2. Contact Information

Email: info@prodigytal.net
Phone: +359 895318463
Physical Address: Sliven, Bulgaria (Full street address available upon request for privacy reasons. Please use the contacts above.)
I do not have a designated Data Protection Officer (DPO), but I am fully prepared to address your privacy-related inquiries directly.

3. Scope and Application

This Privacy Policy applies to:
- All users of my website, including visitors, subscribers, and individuals submitting inquiries via my contact form.
- Personal data collected through phone or email interactions with me.

4. Data Collection and Use

I collect personal information for specific purposes, divided into two categories: data you provide voluntarily and data collected automatically.

4.1 Data You Submit Voluntarily

Contact Form Submissions
- Data Collected: Name, email address, and message content.
- Purpose: Responding to your inquiries.
- Data Retention: Stored securely and not shared with third parties except when legally required. Retained for up to 12 months after resolving your inquiry, unless longer retention is required by law.
- Note: Please do not submit sensitive personal data. If such data is submitted, it will be deleted upon discovery unless legally required to retain it.
- Legal Basis for Processing:
  - Consent (Art. 6(1)(a) GDPR): You have voluntarily provided your data, thereby giving explicit consent to its processing for the specified purpose.
Newsletter Subscriptions
- Data Collected: Email address.
- Purpose: Sending newsletters and service updates.
- Opt-out: You can unsubscribe at any time via the link provided in the newsletter.
- Data Retention: Retained until you unsubscribe, plus 30 days for analytics purposes.
- Legal Basis for Processing:
  - Consent (Art. 6(1)(a) GDPR): You have voluntarily provided your data, thereby giving explicit consent to its processing for the specified purpose.
Comment Submissions
- Data Collected: Name and email address.
- Purpose: Allowing you to comment and enabling moderation and response.
- Data Retention:
  - Your name may appear publicly with your comment.
  - Your email address is stored securely and not shared unless legally required.
  - Comments are retained for up to 5 years unless you request deletion or legal obligations require removal.
  - To request deletion, contact info@prodigytal.net. Requests are processed within 30 days, unless needed for legal compliance.
- Legal Basis for Processing:
  - Consent (Art. 6(1)(a) GDPR): You have voluntarily provided your data, thereby giving explicit consent to its processing for the specified purpose.

4.2 Data Collected Automatically

This includes information gathered through automated tools as you interact with my website.

Third-Party Tools, Analytics, Advertising, and Hosting Services
- Data Collected: IP address, server logs, device ID, browser type, OS, screen resolution, time stamps, approximate location (city or region), traffic sources (referrer URLs, campaigns), and user behavior (clicks, scrolls, session duration, recordings).
- Purpose: To support site performance and security, analyze site usage, improve content, understand visitor behavior (via aggregated metrics, heatmaps, session replays), and serve personalized ads (where applicable).
- Main Third-Party Service Providers:
  - Google (Analytics, Ads, Tag Manager, Search Console): Data may be retained up to 24 months, unless configured otherwise.
  - Hostinger (Hosting): Server logs and related data are retained for the duration of the hosting contract plus 30 days post-termination, unless required longer by law.
  - Microsoft (Clarity, Microsoft Ads, Bing Tools): Data may be retained up to 13 months per default policy.
- Note: Google and Microsoft may use some of this data for their own purposes in accordance with their privacy policies, acting as separate Data Controllers where applicable.
- Legal Basis for Processing:
  - Consent (Art. 6(1)(a) GDPR): Applied to analytics, advertising, and other non-essential tracking services. No data is collected for these unless you have given explicit consent via the cookie banner or consent tool.
  - Legitimate Interest (Art. 6(1)(f) GDPR): Applied to essential technical and infrastructure services (e.g., hosting, performance, security). Data is processed to ensure the website operates effectively and securely, with minimal impact on your privacy rights.

5. Legal Basis for Processing – Summary

I process your personal data based on the following legal grounds:
- Consent: When you voluntarily provide data (e.g., submitting a form, subscribing, accepting cookies).
- Legitimate Interest: Improving website performance, analytics, or maintaining site security – where this does not override your rights, as balanced against the necessity of providing a functional and secure site.
- Legal Obligation: Where data must be retained or disclosed by law.
You may withdraw your consent at any time as outlined under User Rights and Choices below.

6. Data Storage and Protection

Storage Location:
- Voluntarily submitted data is stored on Hostinger servers located in Germany.
- Automatically collected data (e.g., via Google or Microsoft) may be stored outside the EU.
Security Measures:
- Industry-standard encryption and infrastructure security.
- Password-protected systems and regularly updated platforms.
International Transfers:
- Data transferred outside the EU (e.g., by Google or Microsoft) is protected via safeguards such as the EU-U.S. Data Privacy Framework or Standard Contractual Clauses (SCCs) in compliance with GDPR.
Data Breach Notification:
- If a data breach affects your personal information and poses a risk to your rights and freedoms, I will notify you and applicable authorities within 72 hours of becoming aware of the breach, as required by law.

7. Data Sharing and Disclosure

I do not sell your personal data. Data sharing is strictly limited to trusted third-party service providers, including but not limited to:
- Google (Google Ireland Limited) – Google Privacy Policy
- Microsoft (Microsoft Corporation) – Microsoft Privacy Statement
- Hostinger (Hosting provider)
These providers assist with site hosting, analytics, performance, advertising, or infrastructure. They are contractually obligated to process your data in accordance with applicable laws, though Google and Microsoft may also act as separate Data Controllers for their own purposes (e.g., ad personalization), as outlined in their privacy policies.
Legal Requirements:
- Your data may be disclosed only when required by law (e.g., tax, legal process, government requests).
CCPA Clarification:
- As a personal blogger, I do not meet the definition of a “business” under the California Consumer Privacy Act (CCPA). However, I confirm that I have not sold or shared personal information for monetary gain in the past 12 months.

8. User Rights and Choices

Under the GDPR, CCPA, and other privacy laws, you have the right to:
- Access: Request a copy of your personal data.
- Rectification: Request correction of inaccurate or incomplete data.
- Deletion: Request erasure of your data.
- Restriction: Limit how your data is processed.
- Portability: Receive your data in a structured, commonly used, machine-readable format.
- Objection: Object to certain types of processing, such as direct marketing.
- Complaint: File a complaint with a data protection authority (e.g., EU authority or the California Privacy Protection Agency). In Bulgaria, my supervisory authority is the Commission for Personal Data Protection (https://www.cpdp.bg/).
To exercise your rights, contact me at:
- 📧 Email: info@prodigytal.net
- 📞 Phone: +359 895318463
I will verify your identity (e.g., via email confirmation) and respond within legal timeframes:
- GDPR: 30 days
- CCPA: 45 days

9. Automated Decision-Making

I may use automated tools (e.g., Google Analytics, Microsoft Clarity) to analyze user behavior, which may involve profiling for analytics or advertising purposes (e.g., to personalize ads). These tools do not involve automated decision-making that has legal or similarly significant effects on you, though they may influence the ads you see.
You may object to such processing at any time by contacting me at info@prodigytal.net.

10. Cookies and Tracking

Please refer to my Cookies Policy for details on cookie types, durations, and purposes.
Consent: Non-essential cookies (e.g., analytics, advertising) are only set after you explicitly consent via my cookie banner/tool.
Essential Cookies: These do not require consent and are necessary for the website’s basic operation.
Do Not Track (DNT):
- My website does not currently respond to DNT signals. You can manage tracking preferences through your browser or cookie settings as explained in the Cookies Policy.

11. Children’s Privacy

This website is not intended for children under 16. I do not knowingly collect personal data from minors.
If such data is collected, please contact me at info@prodigytal.net for prompt removal.

12. Changes to this Privacy Policy

I may update this Privacy Policy from time to time. Significant changes will be announced on my website or via email.
Your continued use of the site indicates acceptance of the current Privacy Policy.

13. Language Accessibility

This Privacy Policy is provided in English. If you need assistance in another language, please contact me at info@prodigytal.net. I’ll do my best to assist via translation tools or external support, but responses may be in English.

14. Additional Policies and Legal Information

For more information about how data is collected, stored, and used on this website, you may also review the following pages:
- 📄 Cookies Policy – Detailed information about the types of cookies used, their purposes, durations, and how you can manage or withdraw your consent.
- 📜 Terms and Conditions – The legal terms that govern your use of this website and its content.
- ⚠️ Disclaimer – Disclosures regarding liability, content accuracy, professional advice, and affiliate links (if applicable).
These documents complement this Privacy Policy and provide additional transparency about your rights and my responsibilities as the website owner.