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Privacy Policy

This Privacy Policy applies to all users, including residents of the European Union (subject to the General Data Protection Regulation — GDPR) and residents of Israel (subject to the Israeli Protection of Privacy Law, 5741-1981 and its regulations). Where applicable, both frameworks are addressed explicitly.

1. Who We Are

Company (Controller): "ТВОРЦИ Архитектура, Проектиране, Дизайн" ООД

Address: Република България, гр. Варна, бул. Цар Освободител № 44, ет. 2, ап. 4

Email: emeraldresidence.core@gmail.com

Website: https://emeraldresidence.bg

We are the data controller responsible for your personal data collected through this website and through our advertising forms on Meta platforms (Facebook and Instagram).

2. What Data We Collect

We collect the following categories of personal data:

  • Identity data: first name and last name
  • Contact data: email address, phone number
  • Usage data: IP address, browser type, pages visited, time and date of visit, device identifiers
  • Cookie data: see Section 8 below

We do not collect sensitive personal data (special categories under GDPR Article 9) and do not knowingly collect data from individuals under 16 years of age.

3. Legal Basis for Processing (GDPR — EU Users)

For users in the European Union and EEA, we process personal data on the following legal bases under GDPR Article 6:

  • Consent (Art. 6(1)(a)): When you submit a registration form or consent to cookies, you provide explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
  • Legitimate interests (Art. 6(1)(f)): To communicate project updates to people who have expressed interest in Emerald Residence, where such interests are not overridden by your rights.
  • Legal obligation (Art. 6(1)(c)): Where processing is required to comply with applicable law.

4. Legal Basis for Processing (Israeli Law — Israeli Users)

For users in Israel, we process personal data in accordance with the Protection of Privacy Law, 5741-1981 and the Privacy Protection Regulations (Data Security), 5777-2017.

  • Data is collected with your knowledge and consent when you submit a registration form.
  • You have the right to review the personal data we hold about you and to request correction of inaccurate data, in accordance with Section 13 of the Protection of Privacy Law.
  • We do not sell or transfer your personal data to third parties for their own marketing purposes without your explicit consent.
  • The Israeli Privacy Protection Authority (PPA) oversees compliance with Israeli privacy law. You may contact the PPA at gov.il/en/departments/the_privacy_protection_authority.

5. How We Use Your Data

We use your personal data for the following purposes:

  • To contact you with information about Emerald Residence pre-sales and reservation openings
  • To respond to your inquiries
  • To manage and improve our website and services
  • To comply with legal obligations
  • To send marketing communications (only with your consent, which you may withdraw at any time)

We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects.

6. Data Sharing and Third Parties

We may share your personal data with:

  • Meta Platforms (Facebook/Instagram): when you submit a lead form via a Meta advertisement. Meta's own privacy policy applies: facebook.com/privacy/policy
  • Service providers: technical or marketing partners acting as data processors on our behalf, bound by data processing agreements
  • Legal authorities: where required by applicable law or court order

We do not sell your personal data to third parties.

7. International Data Transfers

Your data may be processed in countries outside the European Economic Area (EEA). Where this occurs, we ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Transfer to countries with an EU adequacy decision (Israel holds an EU adequacy decision under GDPR)

8. Cookies

Our website uses cookies and similar tracking technologies. We use:

  • Essential cookies: required for the website to function. No consent needed.
  • Analytics cookies: to understand how visitors use our site. Used only with your consent.
  • Marketing cookies: to track advertising effectiveness. Used only with your consent.

You can manage your cookie preferences at any time through your browser settings or our cookie consent tool. Withdrawing consent does not affect the lawfulness of prior cookie-based processing.

9. Data Retention

We retain your personal data only as long as necessary:

  • Lead/registration data: up to 24 months from the date of collection, or until you request deletion
  • Usage and analytics data: up to 24 months
  • Legal compliance data: as required by applicable law

After retention periods expire, data is securely deleted or anonymised.

10. Your Rights

EU/EEA Users — Rights under GDPR

You have the following rights, exercisable free of charge:

  • Right of access (Art. 15): obtain a copy of the personal data we hold about you
  • Right to rectification (Art. 16): correct inaccurate or incomplete data
  • Right to erasure / "right to be forgotten" (Art. 17): request deletion of your data where there is no overriding legal basis for retention
  • Right to restriction of processing (Art. 18): request that we limit how we use your data
  • Right to data portability (Art. 20): receive your data in a structured, machine-readable format
  • Right to object (Art. 21): object to processing based on legitimate interests or for direct marketing
  • Right to withdraw consent (Art. 7(3)): where processing is based on consent, you may withdraw at any time
  • Right to lodge a complaint: with your national data protection supervisory authority. In Bulgaria: cpdp.bg. You may also complain to the authority in your country of residence.

We will respond to all requests within 30 days (extendable to 90 days for complex cases, with notice).

Israeli Users — Rights under the Protection of Privacy Law

  • Right to access: request to review personal data we hold about you (Section 13, Protection of Privacy Law)
  • Right to correction: request correction of inaccurate personal data
  • Right to deletion: request deletion where there is no legal obligation to retain
  • Right to object: object to use of your data for direct marketing

To exercise any of these rights, contact us at: emeraldresidence.core@gmail.com

11. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or alteration. However, no method of internet transmission is 100% secure.

12. Children's Privacy

Our services are not directed to individuals under 16. We do not knowingly collect data from minors. If you believe a minor has submitted data to us, please contact us and we will delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy periodically. We will notify you of material changes by posting the updated policy on this page and updating the "Last updated" date. We encourage you to review this page regularly.

14. Contact Us

For any questions, requests, or complaints regarding this Privacy Policy or our data practices:

Emerald Residence

Email: emeraldresidence.core@gmail.com

Website: https://emeraldresidence.bg