I. Personal data controller
The controller of personal data is Avigentis EOOD, ЕИК 208742849, e-mail sale@avigentis.eu, tel. +359 89 861 3378.
This policy applies when you visit the website avigentis.eu, use the contact forms or the AI chat agent, and receive consultancy services.
II. What personal data we collect
2.1. Data provided by you
- Names, e-mail address, telephone – when filling in a contact or enquiry form
- Name of organisation, job title – for professional enquiries
- Content of messages and correspondence
- Data entered into the AI chat agent (please do not enter personal data)
2.2. Automatically collected data
- IP address, browser type and operating system
- Date and time of visit, pages visited
- Cookie data – see the Cookie Policy
2.3. Data within the framework of a service contract
- Client identification data (UIC, name, address)
- Data on the client’s contact persons
- Technical data on the IT infrastructure (within the scope of an audit)
III. Purposes and legal basis
| Purpose | Legal basis | Retention period |
|---|---|---|
| Responding to enquiries via the contact form/e-mail | Legitimate interest (Art. 6(1)(f) GDPR) | 12 months after the last communication |
| Performance of a service contract (audit, consultancy, training) | Performance of a contract (Art. 6(1)(b) GDPR) | 5 years after the contract ends |
| Accounting and tax obligations | Legal obligation (Art. 6(1)(c) GDPR) | 10 years (Accountancy Act) |
| Analytics of visits to the Website | Consent (Art. 6(1)(a) GDPR) | Until consent is withdrawn / 26 months |
| AI chat agent – conversation logs | Legitimate interest (Art. 6(1)(f) GDPR) | 6 months |
IV. Recipients of personal data
Personal data may be disclosed to:
- Hosting service providers (processor under Art. 28 GDPR)
- AI service providers (processor under Art. 28 GDPR, with a data protection agreement)
- Accountant/lawyer – where necessary
- Competent public authorities – where required by law
Agreements under Art. 28 GDPR have been concluded with all processors.
V. Transfer of data outside the EEA
Some of our providers (e.g. the AI service provider) may process data outside the European Economic Area. In such cases the transfer takes place on the basis of:
- A European Commission adequacy decision (Art. 45 GDPR), or
- Standard contractual clauses (Art. 46(2)(c) GDPR)
VI. Your rights
As a data subject, you have the right to:
- Access – to obtain a copy of the data processed (Art. 15 GDPR)
- Rectification – to request the correction of inaccurate data (Art. 16 GDPR)
- Erasure (“right to be forgotten”) – Art. 17 GDPR
- Restriction of processing – Art. 18 GDPR
- Data portability – Art. 20 GDPR
- Objection to processing – Art. 21 GDPR
- Withdraw consent at any time (where processing is based on consent)
To exercise your rights, please contact us at sale@avigentis.eu. We respond within 1 month.
VII. Supervisory authority
You have the right to lodge a complaint with the Commission for Personal Data Protection (CPDP):
Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592
E-mail: kzld@cpdp.bg
Website: https://www.cpdp.bg
VIII. Data security
The Company applies appropriate technical and organisational measures to protect personal data in accordance with Art. 32 GDPR, including:
- Encryption of communications (TLS/SSL)
- Access control and authentication
- Regular security assessments
- Staff training in cyber hygiene
IX. AI chat agent and personal data
The AI chat agent on the Website is intended for general consultations on the Cybersecurity Act (ZKS)/NIS2 and does not require the provision of personal data. Please do not enter personal, classified or sensitive data.
Logs of conversations with the AI agent are retained for 6 months for the purpose of improving the service. The processing is carried out by the AI service provider as a processor under Art. 28 GDPR.
X. Changes to the policy
The Company may update this Policy periodically. The current version is always available on the Website. In the event of material changes, you will be informed by means of a notice on the Website.
XI. Contacts
Avigentis EOOD | ЕИК 208742849
E-mail: info@avigentis.eu
Telephone: +359 89 861 3378