Privacy Policy

Last updated: 27.07.2026

This Privacy Policy applies to all users of this website and of the interactive property-selection module (the “Website”) for the EMERALD RESIDENCE residential complex, including users in the EU/EEA, in accordance with the General Data Protection Regulation (GDPR) and applicable Bulgarian law.


1. Who We Are (Data Controller)

The controller is “BALKAN ATLAS GROUP” OOD, UIC 207709216, registered office: Varna 9000, Primorski district, 3 Nikola Yonkov Vaptsarov Str., ent. G, fl. 4, office 6, Bulgaria.

Contacts: email emeraldresidence.core@gmail.com; phone +359 875 313 161; correspondence (sales office): Varna, 18 Dimitar Hadzhiyanev Str. We have not appointed a DPO; please use these contacts.


2. What Data We Collect

  • Identity & contact data via our forms, the selection module or Meta lead forms (Facebook/Instagram): name, phone, email (optional), purchase intent, inquiry content. By submitting a form you confirm you are over 18.
  • Call data: calls to/from our sales numbers may be recorded for quality control; we notify you in advance.
  • Usage data: IP address, device/browser, cookie identifiers, pages and actions in the Website and module.
  • Marketing identifiers (Meta Pixel, Google, TikTok) — only with consent via the cookie banner (Section 7).

We do not collect special-category data (Art. 9) and do not knowingly collect data from persons under 18.


3. Legal Basis (Art. 6)

  • Consent — Art. 6(1)(a): forms, direct marketing, analytics/marketing cookies (withdrawable anytime).
  • Pre-contractual steps at your request — Art. 6(1)(b).
  • Legitimate interests — Art. 6(1)(f): security, statistics, handling inquiries.
  • Legal obligation — Art. 6(1)(c): accounting/tax.

4. How We Use Your Data

  • Process your inquiry/reservation and contact you from Sales.
  • Prepare individual offers, price lists and consultations at your request.
  • Direct marketing — newsletters, offers, news (only with consent; unsubscribe anytime).
  • Analytics and improvement of the Website.
  • Advertising and remarketing via Meta, Google and TikTok (only with consent).

We do not perform automated decision-making with legal or similarly significant effects.


5. Data Sharing and Third Parties

We share data only with trusted providers acting on our behalf under a data processing agreement (Art. 28):

  • “TVORZI Architecture, Design” OOD (UIC 208326822) — marketing, advertising and sales management (our processor);
  • Rossery — Website development and hosting;
  • DOMIO — the selection module and inquiry-form platform;
  • EstOffice — CRM (data stored on servers in the EU — Germany);
  • Ringostat — telephony and call recording;
  • HAPP — automated (AI) assistant for chat and voice, including via Instagram, Telegram, WhatsApp, Messenger and Viber;
  • Meta Platforms Ireland Ltd. (Pixel, CAPI, lead forms), Google Ireland Ltd. (Ads, Analytics, YouTube), TikTok Technology Ltd. (Pixel, advertising) — independent controllers under their own terms;
  • Email-newsletter provider [to be added].

We may disclose data to authorities where required by law. We do not sell your personal data.


6. International Data Transfers

Core lead and CRM data is stored on servers in the EU (Germany). Some advertising/analytics providers (Meta, Google, TikTok) may process data outside the EEA, including the USA, under the EU–US Data Privacy Framework and/or the European Commission’s Standard Contractual Clauses (SCCs). Where any other provider processes data outside the EEA, we apply appropriate safeguards, including SCCs.


7. Cookies and Tracking

  • Essential cookies — required for the Website/module; no consent needed.
  • Analytics cookies (e.g. Google Analytics 4) — only with prior consent.
  • Marketing cookies/pixels — Meta Pixel, Google Ads, TikTok Pixel — only with prior consent.

A cookie banner lets you accept or decline non-essential cookies; you can change your choice anytime via the footer settings. Google Consent Mode v2 applies to Google tags. We also use server-side tracking (Meta Conversions API), transmitting hashed event data to Meta only where marketing consent is given. Withdrawal does not affect prior processing.


8. Data Retention

  • Lead/contact data: up to 36 months from last contact or until deletion request.
  • Call recordings: up to 6 months. Cookies: up to 12 months. Analytics: up to 14 months.
  • If a contract is concluded, contractual/accounting data is kept per Bulgarian law (up to 10 years).

9. Your Rights

You have the rights of access, rectification, erasure, restriction, portability, objection (incl. to direct marketing) and withdrawal of consent anytime. Requests: emeraldresidence.core@gmail.com. We respond within 30 days (up to 90 for complex cases).

You may complain to the Bulgarian Commission for Personal Data Protection (CPDP), Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd, cpdp.bg — or your local supervisory authority.


10. Security and Breaches

We apply appropriate technical and organisational measures (incl. encryption). We notify the CPDP within 72 hours of a breach likely to risk your rights (Art. 33) and, where high-risk, notify you directly (Art. 34).


11. Children’s Privacy

Our services are not directed to persons under 18; we do not knowingly collect their data.


12. Changes

We may update this Policy; the current version is always on this page.


13. Contact

“BALKAN ATLAS GROUP” OOD, UIC 207709216, 3 Nikola Yonkov Vaptsarov Str., Varna; sales office: 18 Dimitar Hadzhiyanev Str.; emeraldresidence.core@gmail.com; +359 875 313 161.