Privacy Policy

At Aionys-Bulgaria LTD, accessible at https://www.aionys.com/, one of our main priorities is the privacy of our visitors. This document is intended to inform you about all aspects of the processing of your personal data by Aionys-Bulgaria LTD (referred to as “we” or “the Company”) and the rights you have in relation to such processing, in accordance with the General Data Protection Regulation (GDPR) — Regulation (EU) 2016/679 — and applicable Bulgarian legislation.

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us via email at alexey.grebennikov@aionys.com or ivan.korytin@aionys.com

Who Are We?

Aionys-Bulgaria LTD is a company registered and operating under Bulgarian law, with the following details:

• Registered address: Arch. Nikola Lazarov No. 4D, Floor 3, Apt. 12, Vitosha Residential Area, 1756 Sofia, Bulgaria

• Office address: Residential Complex Mladost 4 Business Park Sofia Street, Building No. 2 Sofia, 1715, Bulgaria

• Company Registration (UIC): 206989644, entered in the Commercial Register of the Registry Agency

We act as a Data Controller (i.e., the person or legal entity that determines the purposes and means of the processing of personal data) for the personal data we collect, in accordance with the GDPR. We fully comply with both European and Bulgarian data protection legislation.

When we use the terms “personal information” or “Personal Information,” we refer to information related to you that can be used to identify you, either directly or indirectly. This includes, but is not limited to, your name, email address, company name, mailing address, phone number, CV or résumé, and other details about yourself or your business.
Personal Information may also include data about you that is publicly available online (e.g., from platforms such as Facebook, LinkedIn, Twitter, or Google) or information obtained from third-party service providers.

​Information about Children

The Website is not intended for or targeted at children under 16 years old, and we do not knowingly or intentionally collect or maintain information about children under 16 years old. If you believe that we have collected information about a child under 16 years old, please contact us at any of the emails provided, so that we may delete the information. In addition, we kindly ask any child under the age of 16 not to submit any personal information to us or use the Website.

Why and how we collect and use your personal information

The types of information that we may collect from you, depending on how you use our Website or contact us, include:

• your names;
• your email address;
• your company details;
• your CV, motivation letter or additional supporting documentation (portfolio, projects description, related pictures, etc.). You elect to provide, where you apply for a role at our company on our Website or via email;
• any other information that you choose to provide us when filling out a contact form on our Website;
• your IP addresses.

How do we collect information and how we use your Personal Information

Visitors to our Website

When entering one of our Website, we will collect information necessary for the operation of the Website and for us to comply with security and legal requirements in relation to operating our Website. We also collect information about your activities during your visit such as date and time of visits, the pages viewed, time spent at our Website, and the Website visited just before our own, as well as your IP address and your browser so that we can better address your queries and to collect statistics to help us improve your browsing experience in the future.

​Information from the “Contact Form” section of our Website

​We may collect your Personal Information, which you choose to provide when you fill in contact forms on our Website, including your name and e-mail. We may use this Personal Information to respond to your queries, and/or provide the services and/or information that you have requested.

Information from requests via e-mail

​When you contact us via e-mail in connection with a request such as request for information, to order a product or service, to provide you with support, to offer us a proposal we collect information necessary to respond to your request and to be able to contact you. For instance, we collect your name and contact information and details about your request. We may use this Personal Information to respond to your queries, and/or provide the services and/or information that you have requested.

We use Transport Layer Security (TLS) to encrypt and protect web and email traffic. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

Recruitment

​In connection with a job application, inquiry, registration for and/or participation in a Тraining, whether advertised on our Website or otherwise, you may provide us with Personal Information about yourself, including your name, family name, e-mail, CV, motivation letter or additional supporting documentation (portfolio, projects description, related pictures, etc.) you elect to provide, where you apply for a role at our company on our Website or via email, social media sites or other sites as well as any other information that you choose to provide to us when filling out a contact form on our Website or by contacting us via e-mail. We may use this information in order to address your inquiry or consider you for employment purposes. All of the information you provide during the process will only be used for the purpose of recruiting for the relevant currently vacant position that you have applied for and shall be kept for a period of no more than 6 months. If you have explicitly consented – your information will be also used for the purpose of recruiting of personnel for future vacant positions for a period of 2 years, which positions according to us are appropriate for you in view of your education, professional qualification and experience.

​We may also obtain information about job applicants from other sources, to the extent permitted by applicable law, such as through your contact with us, including your interactions with us, or from third parties such as employment agencies and other Website on the Internet. For example, you may choose to provide us with access to certain personal data stored by third parties such as social media sites like LinkedIn. By authorizing us to have access to this information, you agree we may collect, store and use this information in accordance with this Policy.

Our business purposes

We may also use your Personal Information for our business purposes such as:

• record keeping, statistical analysis, internal reporting and research purposes;
• to ensure network and information security;
• to notify you about changes to our services;
• to investigate any complaint, you make;
• to provide evidence in any dispute or anticipated dispute between you and us;
• to customise various aspects of our Website to improve your experience;
• to host, maintain and otherwise support the operation of our Website;
• for the detection and prevention of fraud and other criminal offences and for risk management purposes;
• for business and disaster recovery (e.g. to create back-ups);
• for document retention/storage;
• for database management;
• to protect our rights, property, and/or safety, our personnel and others; 
• to ensure the quality of the services we provide to our users.

Use of third-party services and Cookies

We collect the information relating to your use of our Website through the use of various technologies.

​When someone visits one of our Website, we use our own as well as third party services and technologies to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the Website. This information is only processed in a way which does not identify anyone.

​Our Website utilizes a standard technology called ‘cookies’ and server logs to collect information about how our Website is used and to remember your preferences. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our Website, and the Website visited just before our own, as well as your IP address and browser.

​A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to our Website or browse from one page to another.

​We also use the third-party service Google Analytics – a web analytics service provided by Google, Inc. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our Website. Google Analytics uses cookies to help us analyze how visitors use our Website. The information generated by the cookie about your use of the Website includes your IP address and will be transmitted to and stored by Google, on its servers. Google will use this information for the purpose of evaluating your use of the Website, creating reports on website activity and providing other services relating to Internet usage. Google may also pass this information on to third parties when required to do so by law, or when such third parties process the information on Google’s behalf. By using our Website, you consent to the processing of data about your visit by Google in the manner and for the purposes set out above. If you so choose, you can opt out by turning off cookies in the preferences settings in your browser, or by downloading and installing the Google Analytics Opt-out Browser.

We use a third party service to help maintain the security and performance of our Website. To deliver this service it processes the IP addresses of visitors to our Website.

In addition, we may use your Personal Information for further specific purposes made clear at the point of collection on particular pages of our Website.

​If you choose not to provide Personal Information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information. Aside from this, your visit to our Website will remain unaffected.

Legal Basis for the Collection and Use of Personal Information

We process your personal information in connection with the use of the contact form on our website and, in some cases, for recruitment purposes, where we have obtained your consent. In other instances, we process your personal information when it is necessary:
• to comply with our legal and regulatory obligations;
• for our legitimate interests, provided these are not overridden by your data protection interests or fundamental rights and freedoms, such as:
 – responding to your queries;
 – providing services and/or information to you; 
 – for our internal business purposes, as outlined in Section 2.8 above.

Retention of Personal Information

It is our policy to retain your personal information only for as long as necessary to fulfill the specific purpose(s) for which it was collected, which shall not exceed five years. However, we may be required to store certain personal information for a longer period, taking into account factors such as:
• legal obligations under applicable laws requiring data retention for a specific period;
• statutes of limitations under applicable law(s);
• potential or ongoing disputes; 
• guidelines issued by relevant data protection authorities.

We will securely delete your information once it is no longer needed.

Should the data retention period need to be extended to fulfill a legal obligation or based on the legitimate interests of the data controller, we will inform you accordingly.

​​How and when do we share information with third parties

Some of the services we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your personal information is adequately protected. Details about how we share personal information with third parties are set out below:

Google Analytics
Our website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics operates using cookies.
These cookies collect your IP address. We use the information collected by Google Analytics cookies to understand how visitors interact with our website.
The IP address transmitted by your browser in connection with Google Analytics will not be merged by Google with other data.

If you wish, you can opt out by disabling cookies in your browser settings, or by downloading and installing the Google Analytics Opt-out Browser Add-on, available at: http://tools.google.com/dlpage/gaoptout.
Please note, however, that if you disable cookies, you may not be able to fully use all functions of the website.

Third-Party Service Providers

We also share your personal information with our third-party service providers based in the European Economic Area (“EEA”), whom we engage to provide support services related to our website. These services include: hosting and maintaining our website, providing data storage, assisting with database management, and supporting us with related tasks or processes.

We may also share your personal information with other third parties if we are under a legal obligation to disclose or share such information, or if it is necessary to protect the rights, property, and/or safety of Aionys-Bulgaria LTD, our personnel, or others. This may also include sharing information in order to comply with requirements from a court, regulatory authority, or government agency — for example, complying with a search warrant, court order, or applicable law or regulation.

International Transfers

Some of the third parties described in this Privacy Policy that provide services to us may be located in countries outside the European Economic Area (“EEA”). If we are required to transfer personal information outside the EEA, we take all necessary and reasonable steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy. We apply an adequate level of protection, in particular by implementing the European Commission-approved Standard Contractual Clauses, binding corporate rules for transfers to data processors, or other appropriate legal mechanisms to safeguard such transfers.

Your Rights in the Collection, Processing, and Storage of Your Personal Data

Withdrawal of Consent to the Processing of Your Personal Data

If you no longer wish for the personal data you have provided to be processed, you may withdraw your consent at any time by sending a free-text request via email.
Please note that the withdrawal of consent does not affect the lawfulness of any data processing carried out by the Data Controller prior to the withdrawal.

Right of Access

You have the right to request confirmation from the Company regarding whether personal data concerning you is being processed. To do so, please send a free-text request via email.
After receiving your request, we will carry out a verification process to confirm your identity as the data subject.
Once verified, we will provide you with a copy of the personal data we process, in electronic or another appropriate format.

Right to Rectification or Completion

You may correct or complete any inaccurate or incomplete personal data concerning you at any time by sending a free-text request via email.

Right to Erasure ("Right to Be Forgotten")

You have the right to request the deletion of some or all of your personal data. We will delete it without undue delay where any of the following grounds apply:

• The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;

• You withdraw your consent on which the processing is based and there is no other legal basis for the processing;

• You object to the processing of your personal data, including for direct marketing purposes, and there are no overriding legitimate grounds for the processing;

• The personal data have been processed unlawfully;

• The personal data must be deleted to comply with a legal obligation under EU law or the law of a Member State applicable to the Data Controller;

• The personal data were collected in connection with the provision of information society services.

The Data Controller is not obligated to delete personal data if it is necessary:

• For exercising the right to freedom of expression and information;

• To comply with a legal obligation under EU or Member State law applicable to the Data Controller, or to perform a task carried out in the public interest or in the exercise of official authority;

• For reasons of public interest in the area of public health;

• For archiving purposes in the public interest, scientific or historical research, or statistical purposes;

• For the establishment, exercise, or defense of legal claims.

To exercise your right to erasure, please send a deletion request via email or in free-text format.

Right to Restriction of Processing

You have the right to request the restriction of processing of your personal data by sending a free-text request via email.

Right to Data Portability

You have the right to request your personal data in a structured, commonly used, and machine-readable format. You may also request that we transfer your data to another Data Controller, or directly to a specified Data Controller, where technically feasible.

Right to Receive Information

You may request information about all recipients to whom your personal data have been disclosed, particularly when you have requested rectification, erasure, or restriction of processing. We may decline this request if providing such information proves impossible or would involve a disproportionate effort.

Right to Object

You have the right to object at any time to the processing of your personal data, including processing for profiling or direct marketing purposes.

Breach of Your Rights

In the event of a data breach, the Data Controller will notify the competent authorities within 72 hours, in accordance with Article 33 of the GDPR.

If your rights under this policy or applicable data protection laws are violated, you have the right to lodge a complaint with the Bulgarian Commission for Personal Data Protection:

Name: Personal Data Protection Commission
Headquarters and Address: Sofia 1592, Prof. Tsvetan Lazarov No. 2
Mailing Address: Sofia 1592, Prof. Tsvetan Lazarov No. 2
Phone: +359 2 915 3 518
Website: www.cpdp.bg

This policy was adopted on March 27, 2025.