Personal Data Protection Policy

This Policy governs the processing of personal data of visitors and users of the website www.lenex.technology/chillbill/ and the “Chill Bill” mobile application available on Google Play and the Apple App Store, in accordance with Regulation (EU) 2016/679 (GDPR).

Version: 1.0 Jurisdiction: Bulgaria (EU) Last updated:
Acceptance of this Policy is linked to the General Terms and Conditions of Use of the Website. Providing certain personal data is voluntary but may be necessary to use the services. Refusal to provide required data may prevent the use of the Chill Bill application.

In some cases, processing may be based on legal obligations or contract necessity and may not require your explicit consent. The Controller may update this Policy periodically; please review the Website regularly for changes.

1. Personal Data Controller

Tetris Logistic Ltd.
Commercial Register Unique ID Code: 202666316
VAT Number: BG202666316
Manager: Mihail Ninov
Registered office and place of business: Sofia, Lyulin Residential Complex, Block 984, Entrance G, Floor 7, Apartment 100, Bulgaria
E-mail: info@tetrislogistic.com

The Controller determines the purposes and means of processing and processes personal data in line with the principles of lawfulness, fairness, and transparency.

2. Types of Personal Data, Purposes of Processing, and Retention

The Controller distinguishes between visitors and users. Depending on the category, different data may be processed for the purposes and on the legal bases described below, and retained for the indicated periods.

2.1 Data Automatically Collected (all categories)

  • IP address — automatically recognized by the server; not directly identifying by itself.
  • Summary information — browser type (e.g., Chrome, Safari, Firefox), time spent, and pages visited.
  • Cookies — used to provide personalized service and remember preferences. See our Cookies Policy for details.

2.2 Data by Category (Visitors and Users)

  • Location data (if provided by the visitor/user)
  • Country/City inferred from IP address
  • Information about actions taken on the Website/App
  • Browser/device type

Purpose of processing: to provide basic and additional functions necessary for proper operation of the Website/App.

Retention: information about visitors (unregistered users) is temporarily retained until the content is loaded on their devices.

Legal basis: information automatically provided by the device necessary for browsing.

3. Access to Your Personal Data and Protection

Your personal data may be accessed by:

  • Employees and contractors engaged in the operation of the Website/App;
  • Hosting and technical maintenance service providers (and their employees/subcontractors) under processor agreements compliant with applicable law;
  • Professional advisers (lawyers, accountants, etc.) to the extent necessary to fulfil and protect our rights and legitimate interests;
  • Government authorities, upon lawful request and as required by Bulgarian law, and for the protection of our rights and legitimate interests.

We apply appropriate technical and organizational measures, including system resilience, the ability to promptly restore access to personal data in case of physical or technical incidents, and staff training in personal data protection.

Even after the use of your personal information ceases (e.g., account deletion), we may retain an archive to protect our rights and legitimate interests until applicable limitation periods expire. Generally up to 5 years, subject to shorter or longer statutory periods.

4. Rights of Data Subjects

  • Right of access – request confirmation whether we process your data and obtain a copy with related information.
  • Right to rectification – request correction or completion of inaccurate or incomplete data.
  • Right to erasure ("right to be forgotten") – request deletion of personal data in the cases provided by law.
  • Right to restriction – request restriction of processing in certain circumstances (e.g., accuracy contested, objection pending).
  • Right to data portability – when processing is based on consent or contract and performed by automated means, receive your data in a structured, commonly used, machine‑readable format or request transfer to another controller.
  • Right to object – object to processing based on legitimate interests or performance of a task in the public interest, on grounds relating to your particular situation.

To exercise your rights or for assistance, contact the Controller at info@tetrislogistic.com. If you believe your rights are violated, you may lodge a complaint with the Commission for Personal Data Protection (Bulgaria) or the courts.

5. Final Provisions

Any matters not covered by this Policy are governed by Regulation (EU) 2016/679, the Bulgarian Personal Data Protection Act, and other applicable regulations.