Privacy Policy

Controller: Nadya Koseva, operating under the name The Growth Check, Bulgaria.

Contact for privacy matters: info@thegrowthcheck.com.

No Data Protection Officer has been appointed, because there is no legal requirement to appoint one for an activity of this size and nature. Privacy enquiries are handled directly by Nadya Koseva.

The website has one contact form. When you use it, you provide:

• Name (required)
• Email address (required)
• Company or website (optional)
• Message content (required, including anything you choose to write in it)

Please do not include sensitive personal data or confidential third party information in the message field. It is not needed in order to answer an enquiry.

In addition, the hosting infrastructure that serves this website processes standard technical data such as IP address, browser type and time of request. This happens automatically for every website request and is needed to deliver the site and keep it secure.

Contact form data is used for one purpose only: to read, understand and answer your enquiry, and to continue that conversation if it develops into a possible working relationship.

The legal basis is Article 6(1)(b) GDPR, steps taken at your request prior to entering into a contract, when your enquiry concerns possible work together. Where an enquiry is not about a possible engagement, for example a general or professional question, the legal basis is Article 6(1)(f) GDPR, the legitimate interest in responding to messages that were deliberately sent to us.

Consent, Article 6(1)(a) GDPR, is not used as the basis for simply replying to your enquiry. Consent would only apply if you separately and voluntarily agreed to something additional, for example receiving updates. No such option is currently offered on this website.

Technical data processed by the hosting infrastructure is handled on the basis of Article 6(1)(f) GDPR, the legitimate interest in operating a functioning and secure website.

When you submit the form, the content is sent by email to info@thegrowthcheck.com and is read by Nadya Koseva. There is no automated decision making and no profiling.

Submitting the contact form does not subscribe you to any newsletter or marketing list, and your details are not added to any marketing database.

No personal data is sold, rented or traded. Access is limited to Nadya Koseva and to service providers that are technically required to operate the website and deliver email. These providers act as processors and may only process the data on documented instructions.

• Website hosting and application infrastructure, which serves the pages and receives the form submission
• Email infrastructure, which transmits and stores the notification message and any reply
• Google Analytics 4, used only if you accept analytics, which measures aggregated website usage. It does not receive your name, email address, company or message content, and it is switched off entirely if you reject or withdraw consent. See the Cookie Policy for details.
• Where relevant, professional advisers or authorities, if disclosure is required by law

The providers used may process or store data on servers located outside the European Economic Area, for example in the United States. Where that happens, the transfer must be covered by an appropriate GDPR safeguard, normally the European Commission's Standard Contractual Clauses or an adequacy decision, together with the technical and organisational measures applied by the provider.

If you would like to know which safeguard applies to a specific provider, write to info@thegrowthcheck.com and you will receive the information available.

Enquiries that do not lead to any working relationship are kept for up to 12 months from the last message exchanged, so that context is available if you get back in touch, and are then deleted.

Enquiries that lead to a working relationship are kept for the duration of that relationship and afterwards only for as long as required by applicable accounting, tax or limitation periods.

You can ask for earlier deletion at any time, and the request will be honoured unless there is a legal obligation to keep the record.

Subject to the conditions set out in the GDPR, you have the right to:

• Access the personal data held about you and receive a copy of it
• Have inaccurate or incomplete data corrected
• Have your data erased
• Restrict processing in certain circumstances
• Object to processing that is based on legitimate interests
• Receive the data you provided in a structured, commonly used and machine readable format and have it transmitted to another controller, where the processing is based on contract or consent and is carried out by automated means
• Withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before the withdrawal

To exercise any of these rights, write to info@thegrowthcheck.com. You will receive a response within one month, as required by Article 12 GDPR. Additional information may be requested if it is genuinely necessary to confirm your identity.

If you believe your data has been handled incorrectly, please raise it directly first, at info@thegrowthcheck.com, so it can be resolved quickly.

You also have the right to lodge a complaint with a supervisory authority. In Bulgaria this is the Commission for Personal Data Protection (CPDP).

Commission for Personal Data Protection (cpdp.bg)

The website is served over an encrypted HTTPS connection, and access to the mailbox that receives enquiries is protected by authentication. No system can be guaranteed to be completely secure, but the measures applied are appropriate to the limited amount of data involved.

This policy may be updated if the website or the way enquiries are handled changes. The date at the top of the page always shows the current version.