PRIVACY POLICY

ETÉRA CREATIVE

Last updated: October 2026

1. Introduction

ETÉRA (“we”, “us”, or “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, and protect personal information when you visit our website, https://www.eteracreative.com (the “Website”), contact us, or interact with us through the Website.

We process personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, or “GDPR”), the applicable Bulgarian Personal Data Protection Act, and other relevant data protection legislation.

This Privacy Policy applies to visitors of our Website and individuals who communicate with us through its available contact channels.

2. Data Controller

The controller responsible for the processing of your personal data is:

ETERA CREATIVE LTD
UIC: 208933587
Registered address: 5 Prof. Mihail Andreev St., Floor 1, Apt. 3, Lozenets District, Sofia, Bulgaria
Email: hello@eteracreative.com
Website: https://www.eteracreative.com

For questions relating to this Privacy Policy or the processing of personal data, please contact us using the details above.

3. Personal Data We Collect

Depending on how you interact with the Website, we may process the following categories of personal data:

3.1. Information you provide directly

When you contact us through email, a contact form (where available), or other communication channels linked to the Website, we may collect:

  • Your name and surname;
  • Your email address;
  • Your telephone number, if provided;
  • Your company name or professional affiliation, if provided;
  • The content of your enquiry or message;
  • Any additional information you voluntarily share with us.

3.2. Technical and usage information

When you access the Website, certain technical information may be processed automatically by the hosting infrastructure and other services used to operate the Website, including:

  • IP address;
  • Browser type and version;
  • Device type and operating system;
  • Date and time of access;
  • Requested pages and technical access logs;
  • Information necessary to maintain Website functionality and security.

3.3. Cookies and similar technologies

The Website may use cookies and similar technologies to support its functionality, remember applicable preferences, and, where implemented, analyse Website performance or support marketing activities.

Further details are provided in our Cookie Policy.

4. Purposes and Legal Bases for Processing

We process personal data only where a valid legal basis applies under Article 6 of the GDPR.

4.1. Responding to enquiries and communications

We process the personal data you provide when contacting ETÉRA to:

  • Respond to your questions and requests;
  • Discuss potential projects, collaborations, or business opportunities;
  • Provide information about our services;
  • Continue communication initiated by you.

Legal basis: Article 6(1)(f) GDPR — our legitimate interest in maintaining professional communication and responding to enquiries. Where processing is necessary to take steps at your request before entering into a contract with you personally, Article 6(1)(b) GDPR may apply.

4.2. Operation, administration and security of the Website

Technical data may be processed to:

  • Ensure the Website functions correctly;
  • Maintain its security and availability;
  • Diagnose technical issues;
  • Prevent unauthorised access, misuse, or malicious activity.

Legal basis: Article 6(1)(f) GDPR — our legitimate interest in maintaining a secure and functional Website.

4.3. Website analytics and performance

Where analytics services are implemented, we may process information about Website interactions to understand traffic, evaluate performance, and improve the visitor experience.

Legal basis: Article 6(1)(a) GDPR — consent, where required for the relevant tracking or processing.

4.4. Marketing and communications

If we introduce optional marketing subscriptions, promotional communications, or advertising technologies, any related personal data will be processed under the applicable legal basis and subject to the consent or other requirements established by law.

Consent may be withdrawn at any time where processing is based on consent.

4.5. Compliance with legal obligations

Where applicable, personal data may be processed to comply with legal requirements or lawful requests from competent authorities.

Legal basis: Article 6(1)(c) GDPR — compliance with a legal obligation.

5. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer period is required or permitted by applicable law.

Retention periods depend on the nature of the information and the purpose of processing.

  • Enquiries and correspondence: retained for as long as reasonably necessary to respond, manage any resulting professional relationship, and address potential follow-up matters or legal claims.
  • Technical and security information: retained for a limited period determined by operational and security requirements.
  • Analytics information: retained according to the settings and applicable retention periods of the analytics services used, where implemented.
  • Information subject to statutory requirements: retained for the period required under applicable legislation.

When personal data is no longer required, it will be deleted, anonymised, or otherwise securely disposed of, as appropriate.

6. Sharing of Personal Data

We do not sell personal data.

Where necessary for the operation of the Website and our business communications, personal data may be accessible to authorised service providers, including:

  • Website hosting and infrastructure providers;
  • Website developers and technical support providers;
  • Business email and communication service providers;
  • Website analytics providers, where implemented;
  • Other professional service providers assisting with Website maintenance, security, or legal compliance.

Such access is limited to what is necessary for the relevant service.

Where third parties process personal data on our behalf, appropriate contractual and organisational safeguards are applied as required by GDPR.

We may also disclose personal data where required by applicable law or lawful requests from competent public authorities.

7. International Data Transfers

Some external service providers may process or access personal data from countries outside the European Economic Area (EEA).

Where such transfers occur, ETÉRA will ensure that an appropriate legal mechanism is in place, as required by GDPR. Depending on the circumstances, this may include:

  • An adequacy decision adopted by the European Commission;
  • Standard Contractual Clauses approved by the European Commission;
  • Other appropriate safeguards or lawful transfer mechanisms.

Information about applicable safeguards may be requested using the contact details provided in this Privacy Policy.

8. Your Rights Under GDPR

Subject to the conditions and limitations established by applicable legislation, you have the right to:

  • Access: request confirmation of whether we process your personal data and obtain access to that information.
  • Rectification: request correction of inaccurate or incomplete personal data.
  • Erasure: request deletion of your personal data in circumstances provided by GDPR.
  • Restriction: request limitation of the processing of your personal data under applicable conditions.
  • Data portability: receive certain personal data in a structured, commonly used and machine-readable format where the relevant legal requirements are met.
  • Object: object to processing based on legitimate interests, including the right to object at any time to processing for direct marketing.
  • Withdraw consent: withdraw your consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.
  • Lodge a complaint: submit a complaint to a competent data protection supervisory authority.

To exercise your rights, please contact us at hello@eteracreative.com.

We will respond within the time limits established by applicable data protection legislation.

9. Supervisory Authority

If you believe that your personal data has been processed in violation of applicable data protection legislation, you have the right to lodge a complaint with the Bulgarian Commission for Personal Data Protection (CPDP), without prejudice to other administrative or judicial remedies available to you.

Commission for Personal Data Protection (CPDP)

Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
Email: kzld@cpdp.bg
Website: https://www.cpdp.bg

You may also contact another competent supervisory authority in accordance with GDPR.

10. Data Security

ETÉRA takes appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, unlawful processing, alteration, or disclosure.

These measures are selected according to the nature of the information processed and the risks associated with the processing activities.

Although we take reasonable precautions to protect personal information, no method of electronic transmission or storage can be guaranteed to be completely secure.

11. Third-Party Websites and Platforms

The Website may contain links to third-party websites, social media platforms, or external services.

These third parties operate independently and may process personal data under their own privacy policies.

ETÉRA is not responsible for the privacy practices of external websites or platforms outside our control.

We encourage visitors to review the relevant privacy information before providing personal data to third parties.

12. Automated Decision-Making

ETÉRA does not use personal data collected through the Website to make decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant effects on individuals.

13. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in the Website, our processing activities, the services we use, or applicable legal requirements.

The latest version will be published on this page with an updated revision date.

Where legally required, additional notice or consent will be provided before implementing relevant changes.

14. Contact

For questions, requests, or concerns regarding the processing of personal data, please contact:

ETÉRA CREATIVE
Email: hello@eteracreative.com
Website: https://www.eteracreative.com

Effective as of October 2026.