Privacy Policy

 

1.   Purpose

The purpose of this Privacy Policy is to define the principles, responsibilities, and procedures that govern how TransformWave® Ltd. collects, processes, uses, stores, shares, and protects the personal data of individuals who access or interact with our official website and digital platforms.

This Policy reflects our commitment to:

  • Ensuring full compliance with applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 (GDPR) and the Bulgarian Personal Data Protection Act (PDPA).
  • Promoting transparency and accountability in all personal data processing activities.
  • Informing data subjects about the nature of the personal data we collect, the legal basis for processing it, the purposes for which it is used, and the rights they have in relation to their data.
  • Providing a clear framework for how we protect data confidentiality, integrity, and availability.
  • Establishing trust with all website visitors, clients, and partners by demonstrating responsible data handling practices.

This Policy applies to all personal data collected through:

  • Direct interactions via our website (e.g., contact forms, newsletter subscriptions).
  • Passive collection methods such as cookies, tracking pixels, and analytics tools.
  • Third-party services integrated into our digital platforms.

Ultimately, the goal of this Policy is to protect the personal data and privacy of individuals while enabling TransformWave® Ltd. to deliver a seamless, informative, and user-centric digital experience. It ensures a balance between our legitimate business interests and the rights and freedoms of individuals whose data we process.

2.   Scope

This Privacy Policy applies to all personal data collected, processed, and stored by TransformWave® Ltd. through its official website (https://www.transformwave.com) and any associated digital platforms, including but not limited to web applications, mobile interfaces, and online services managed or operated by TransformWave® Ltd.

The scope of this Policy covers:

  • Data Subjects: All individuals who visit, use, or interact with our website and digital services, including prospective and current clients, partners, suppliers, employees, and general visitors.
  • Personal Data: Any information relating to an identified or identifiable natural person (“data subject”), including but not limited to names, contact information (email addresses, phone numbers), IP addresses, cookie identifiers, user behavior data, and any other data voluntarily provided through forms, registrations, or communications.
  • Processing Activities: All operations performed on personal data, whether automated or manual, including collection, recording, organization, storage, adaptation, retrieval, use, disclosure, erasure, or destruction.
  • Data Collection Channels:
    • Direct data collection through user interactions such as contact forms, subscriptions, feedback submissions, and account registrations.
    • Indirect data collection through cookies, analytics, and tracking technologies.
    • Data received from third parties where applicable and in compliance with data protection laws.
  • Geographical Scope: This Policy applies to personal data collected from individuals located within the European Union and Bulgaria, as well as users accessing the website globally, subject to applicable local data protection regulations.
  • Third-Party Processors: The Policy extends to all third-party service providers and processors engaged by TransformWave® for hosting, analytics, marketing, customer relationship management, and other related functions, where personal data may be transferred or processed on our behalf.

We are committed to ensuring that all personal data handling within the defined scope is conducted lawfully, transparently, and with respect for data subject rights, in alignment with the principles set forth in this Privacy Policy.

3.   Policy Statements
3.1. Lawful, Fair, and Transparent Processing

TransformWave® Ltd. processes personal data lawfully, fairly, and in a transparent manner. We collect only the personal data necessary for specified, explicit, and legitimate purposes and inform data subjects clearly about how their data will be used before or at the point of collection.

3.2. Purpose Limitation

Personal data is collected and processed solely for legitimate business purposes, including but not limited to:

  • Responding to inquiries and providing requested services
  • Managing client relationships and communications
  • Marketing and promotional activities (with consent where required)
  • Website analytics and improvement
  • Compliance with legal and regulatory obligations
3.3. Data Minimization

We limit the collection of personal data to what is adequate, relevant, and necessary for the intended purposes. Unnecessary or excessive data collection is avoided.

3.4. Accuracy

TransformWave® Ltd. strives to keep personal data accurate, complete, and up to date. Data subjects are encouraged to inform us of any changes or inaccuracies in their personal information.

3.5. Storage Limitation

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal requirements. Once the retention period expires, data is securely deleted or anonymized.

3.6. Integrity and Confidentiality

We implement appropriate technical and organizational security measures to protect personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. Access to personal data is limited strictly to authorized personnel with a legitimate need to know.

3.7. Data Subject Rights

Individuals whose personal data is processed by TransformWave® Ltd. have the following rights, subject to applicable legal limitations:

  • Right of Access: To request confirmation and access to their personal data.
  • Right to Rectification: To request correction of inaccurate or incomplete data.
  • Right to Erasure (“Right to be Forgotten”): To request deletion of personal data where applicable.
  • Right to Restrict Processing: To limit how personal data is processed in certain circumstances.
  • Right to Data Portability: To receive their data in a structured, commonly used, and machine-readable format.
  • Right to Object: To object to processing based on legitimate interests or direct marketing.
  • Rights related to Automated Decision-Making: Where applicable, the right not to be subject to decisions based solely on automated processing.

Requests to exercise any of these rights can be submitted via the contact details provided in Section 6 of this Policy. We commit to responding promptly and transparently.

3.8. Consent Management

Where processing is based on consent (e.g., marketing communications, non-essential cookies), TransformWave® Ltd. obtains freely given, specific, informed, and unambiguous consent. Users are given clear options to accept or decline and may withdraw consent at any time without affecting the lawfulness of prior processing.

3.9. Third-Party Sharing and Transfers

Personal data may be shared with trusted third-party service providers who assist with our operations (e.g., hosting, CRM, marketing). Such transfers are conducted under strict agreements ensuring compliance with data protection standards. Where data is transferred outside the European Economic Area (EEA), appropriate safeguards are implemented to ensure adequate protection.

3.10. Data Breach Management

In the event of a personal data breach, TransformWave® Ltd. follows documented procedures to assess risks, contain impacts, notify supervisory authorities and affected data subjects as required by law, and implement corrective actions.

4. Data Retention

TransformWave® Ltd. retains personal data only if necessary to fulfill the purposes outlined in this Policy or to comply with applicable legal, regulatory, or contractual requirements. Retention periods vary depending on the nature of the data and the purpose of processing. Once personal data is no longer needed, it will be securely deleted or anonymized to prevent identification of individuals.

5. Security Measures

TransformWave® Ltd. is committed to protecting personal data through appropriate technical and organizational measures, including but not limited to:

  • Use of secure servers and encrypted communication protocols (e.g., HTTPS)
  • Access controls and role-based permissions limiting data access to authorized personnel only
  • Regular staff training on data protection and privacy best practices
  • Regular reviews and updates to security procedures to address emerging threats
  • Incident response planning for timely identification and management of data breaches
6. Children’s Privacy

TransformWave® Ltd.’s website and services are not intended for children under the age of 16. We do not knowingly collect or process personal data of minors without appropriate parental consent. If we become aware that personal data of a child under 16 has been collected without consent, we will take prompt steps to delete such data.

7. Contact Information

For any questions, requests, or concerns regarding this Privacy Policy or your personal data, please contact TransformWave® Ltd.’s Chief Operational Officer (COO) at:

Email: office@transformwave.com
Address: ул. Ген. Йосиф Гурко 62А, ет. 4, ап. 14, гр. София, България

You have the right to lodge a complaint with the relevant data protection supervisory authority if you believe your rights under data protection laws have been violated.