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Privacy Policy

PLANA Digital Ltd. · Effective date: 12 April 2026 · Version 1.0

Contents

  1. 1. Data Controller
  2. 2. What We Collect
  3. 3. Purposes & Legal Basis
  4. 4. Data Retention
  5. 5. Sharing & Transfers
  6. 6. Cookies
  7. 7. Your Rights
  8. 8. Security
  9. 9. Children
  10. 10. Changes
  11. 11. Contact

This Privacy Policy explains how PLANA Digital Ltd. ("PLANA Pulse", "we", "us", or "our") collects, uses, and protects personal data when you visit planapulse.ai or use the PLANA Pulse Business Operating System ("Service"). We are committed to processing personal data in accordance with Regulation (EU) 2016/679 (GDPR) and applicable Bulgarian data-protection law.

1. Data Controller

CompanyPLANA Digital Ltd.
VATBG206624296
Address95-99 Tsar Asen str., 1463 Sofia, Bulgaria
Liable personChudomir Monevski
E-mailcontact@planapulse.ai

For questions about this policy or to exercise your rights, contact us at the e-mail above or by post at the address above, marked "Data Protection".

2. What We Collect

2.1 Website visitors

  • Usage data — pages visited, referrer URL, browser type, device type, and approximate country (via anonymised IP). Collected via first-party analytics only; no cross-site tracking.
  • Contact-form submissions — name, business e-mail, company name, phone (optional), and message content.

2.2 Service (BOS) users

  • Account data — name, work e-mail, job title, company name.
  • Usage & audit logs — actions taken inside the platform, timestamps, and IP addresses, for security and support purposes.
  • Business data — financial, operational, and CRM data that your organisation loads into the Service. This data is processed as a data processor on your behalf under a Data Processing Agreement (DPA) — it is yours, not ours.

2.3 Data we do not collect

We do not collect payment card data (handled by certified PSPs), national ID numbers, biometric data, or data about children under 16.

3. Purposes & Legal Basis

PurposeLegal basis (GDPR Art. 6)
Responding to contact-form enquiries and sales conversationsArt. 6(1)(b) — pre-contractual steps at your request
Providing, operating, and improving the ServiceArt. 6(1)(b) — performance of contract
Sending product updates, security notices, and invoicesArt. 6(1)(b) — performance of contract
Sending marketing e-mails about PLANA Pulse featuresArt. 6(1)(f) — legitimate interest (existing customers only); Art. 6(1)(a) — consent (prospects)
Complying with legal obligations (tax, accounting)Art. 6(1)(c) — legal obligation
Security monitoring and fraud preventionArt. 6(1)(f) — legitimate interest
Website analytics (anonymised, aggregate)Art. 6(1)(f) — legitimate interest

4. Data Retention

  • Contact-form submissions — retained for up to 3 years or until you request deletion, whichever is sooner.
  • Account data — retained for the duration of your contract plus 5 years (Bulgarian accounting-law requirement).
  • Audit logs — retained for 12 months for security purposes, then automatically deleted.
  • Business data you load into the Service — retained while your subscription is active; deleted within 30 days of contract termination unless you export it first or law requires longer retention.
  • Cookies — session cookies expire when you close the browser; persistent cookies expire as stated in our Cookie Policy.

5. Sharing & Transfers

We do not sell personal data. We share data only with:

  • Service providers acting as data processors on our behalf (cloud infrastructure, e-mail delivery, error monitoring). All processors are bound by a DPA and may not use your data for their own purposes.
  • Your organisation's administrators who have permission to access user accounts and audit logs within your own BOS workspace.
  • Competent authorities where required by EU or Bulgarian law.

Our infrastructure is hosted in the European Union (Exoscale, Sofia data centre). If any sub-processor is located outside the EEA, we ensure appropriate safeguards — Standard Contractual Clauses or an EU adequacy decision — are in place.

6. Cookies

We use strictly necessary cookies for session management and optional analytics cookies. Full details, opt-out options, and the cookie list are in our Cookie Policy.

7. Your Rights

As a data subject under GDPR you have the right to:

  • Access — obtain a copy of the personal data we hold about you.
  • Rectification — correct inaccurate or incomplete data.
  • Erasure ("right to be forgotten") — request deletion where no legal basis for continued processing exists.
  • Restriction — ask us to pause processing while a dispute is resolved.
  • Portability — receive your data in a structured, machine-readable format.
  • Object — opt out of processing based on legitimate interest, including direct marketing.
  • Withdraw consent — at any time, without affecting the lawfulness of processing before withdrawal.

To exercise any right, e-mail contact@planapulse.ai. We will respond within 30 days. You also have the right to lodge a complaint with the Commission for Personal Data Protection (CPDP), 2 Prof. Tsvetan Lazarov blvd., Sofia 1592, Bulgaria — www.cpdp.bg.

8. Security

We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or destruction. Measures include TLS encryption in transit, encryption at rest, role-based access controls, audit logging, and regular security reviews. In the event of a data breach affecting your rights and freedoms, we will notify the CPDP within 72 hours and inform affected individuals without undue delay.

9. Children

The Service is designed for business use by adults. We do not knowingly collect personal data from individuals under 16. If you believe a child has submitted data to us, please contact us and we will delete it promptly.

10. Changes to This Policy

We may update this policy as our practices evolve or legal requirements change. Material changes will be notified by e-mail (to active Service users) and by posting a notice on this page at least 14 days before taking effect. The "Effective date" at the top of this page always reflects the current version.

11. Contact

Questions, requests, or complaints about this policy:

PLANA Digital Ltd.
Attn: Data Protection
95-99 Tsar Asen str., 1463 Sofia, Bulgaria
contact@planapulse.ai
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