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Privacy policy

Last edit 22-02-2023

This "Privacy Policy" governs the processing of your personal data by the processing manager: Brangels ltd (brand-building agency), registered at Hadzhi Dimitar 148, 1510, Sofia, Bulgaria with VAT: BG207.218.911(hereinafter: "BRANGELS").

Read this Privacy Policy carefully, as it contains essential information about how your personal data is processed and which cookies are used. By providing your personal data on the website, you declare that you have taken note of this Privacy Policy and confirm your express agreement, including for processing.

Article 1 – General

1.1. With this Privacy Policy, BRANGELS takes its responsibility for the processing of personal data in accordance with the European Directive 2016/679 of 27 April 2016 on the protection of personal data.

Article 2 – Personal data

2.1. Personal data given to us by you:

Category 1: when visiting our website: your IP address, browser, surfing behaviour on our website, keywords you used to find us;

Category 2: when registering on our newsletter: your first name, last name, e-mail address, company, function;

Category 3: when applying to join #BrangelsClub on our website: your first name, last name, e-mail address, password, function, company information such as size, revenue.

Category 4: when ordering online: your first name, last name, e-mail address, phone number, company, function;

Category 5: following the use of our website with your account: your files and documents, your login sessions.


2.2. BRANGELS may collect your (personal) data in different ways:

using cookies;

received directly from you;

received from external Identity Management software.

Article 3 – Processing Purposes

3.1. General purposes:

BRANGELS shall use the personal data collected from you exclusively for the following purposes:

Category 1: for the provision and improvement of our website and the inclusion of personal data in anonymous statistics, from which the identity of specific persons or companies cannot be traced, on the grounds of BRANGEL’s legitimate interests in continuously improving its website and services;

Category 2: to send you direct marketing, newsletters, activities and promotions, based on your explicit and prior consent;

Category 3: to analyze your brand on the grounds of implementing an agreement requested by you and, if indicated by you, also transmitting strategy and marketing activities, based on your explicit and prior consent where necessary or if required in our legitimate interest;

Category 4: for the delivery and invoicing of products ordered by you, on the grounds of providing a service requested by you;

Category 5: for the delivery of BRANGELS services within the website in accordance with our terms of use and the technical and practical descriptions on our website and in the user manual.

You are not obliged to provide your personal data, but do be aware that the provision of certain services becomes impossible if you refuse processing.

3.2. Direct marketing:

Your personal data may be used for direct marketing, provided that you have given additional and express consent ("opt-in") or provided that you are an existing customer, to whom we only advertise related goods or services, in which case we have a legitimate interest.

If you are already included on our distribution list for the receipt of marketing material on paper and/or electronically, KAN may use your data to send marketing and other material related to KAN, its products and/or services. BRANGELS may use the information you provide to update documents stored by BRANGELS.

This consent may be revoked at any time, without justification and free of charge by, for example, by clicking on the unsubscribe link provided for this purpose at the bottom of every promotional e-mail message.

3.3. Transfer to third parties:

In certain cases, BRANGELS shall be required to pass on your data to third parties. In such cases, BRANGELS shall make reasonable efforts to inform you in advance of its plans to disclose your data to the aforementioned third party, but you also acknowledge that this is not always technically or commercially feasible. In any case, BRANGELS may share your data with our technical services provider BRANGELS Communication Design, as well as with our accountant, lawyer and other administrative partners.

Should one of our partners be outside the EU or if for some reason your data must leave the EU, BRANGELS shall ensure that these data exports are only carried out in accordance with the relevant European and Bulgarian legislation and, in particular, shall make use of the European Commission's Standard Contracts Clauses on export data security where necessary.

BRANGELS shall not sell, rent, distribute or make your personal data commercially available to third parties in any other way, except as described above or with your prior consent.

In the event of the complete or partial reorganisation or transfer of BRANGEL’s activities, involving the reorganisation, transfer, or termination of its activities, or in the event of bankruptcy, your data may need to be transferred to new entities or third parties charged with carrying out BRANGEL’s business activities or to whom BRANGEL’s business activities are transferred, either in whole or in part.

3.4. Legal requirements:

Very occasionally, BRANGELS may be forced to disclose your personal data under a court order or to comply with other mandatory laws or regulations. BRANGELS shall make reasonable efforts to inform you in advance, unless restricted from doing so by law.

Article 4 – Processing period

The personal data shall be stored and processed by us for a period that is necessary to achieve the purposes of the processing and depending on your contractual relationship with BRANGELS.

Specifically, this means that your data shall be kept as follows:

Category 1, for the duration of your surfing session and up to 12 months thereafter;

Category 2: for the duration of your account and up to a maximum of 5 years thereafter;

Category 3: for the duration of your account and up to a maximum of 5 years thereafter;

Category 4: for the duration of your account and up to a maximum of 5 years thereafter;

Category 5: for the duration of your account and up to a maximum of 5 years thereafter.

Article 5 - Your rights

5.1. Right of access and inspection:

You have the right to inspect your personal data free of charge at any time, as well as to view the use we make of your personal data.

5.2. Right to rectify, remove and restrict:

You are free to choose whether or not to disclose your personal data to BRANGELS. In addition, you always have the right to ask us to rectify, complete or delete your personal data. You acknowledge that by refusing to communicate or requesting the removal of personal data, certain services and products shall not be available.

You may also ask to restrict the processing of your personal data.

5.3. Right to object:

You also have a right to object to the processing of your personal data for serious and legitimate reasons.

In addition, you always have the right to object to the use of personal data for direct marketing purposes. In this case, you are not required to give a reason.

5.4. Right of free data transfer:

You have the right to receive your personal data that we process in a structured, common and machine-readable form and/or to transfer it to other responsible parties.

5.5. Right to withdraw your consent:

You are entitled to revoke your consent to the extent that the processing is based on such prior consent.


5.6. Exercising your rights:

You may exercise your rights by contacting us, either by e-mail to our Data Protection Officer on, by post to BRANGELS at the address shown at the top of this Privacy Policy or by using the "Contact Us" section on the website, provided you include a copy of your identity card.

5.7. Automatic decisions and profiling:

Our processing of your personal data does not include profiling and nor will you be subject to automated decisions.

5.8. Right to complain:

You have the right to file a complaint with the Bulgarian Data Protection Authority:

2 Prof. Tsvetan Lazarov Blvd., Sofia 1592

Tel: +359 (0)2 91 53 519

This shall have no impact on civil-court proceedings.

Should you suffer damages as a result of the processing of your personal data, you may claim for damages.



Article 6 – Safety and confidentiality

6.1. We have developed security measures adapted at both technical and organisational level to avoid the destruction, loss, falsification, modification, unauthorised access or accidental communication to third parties of personal data, as well as any other unauthorised processing of such data.

6.2. Under no circumstances shall BRANGELS be considered liable for any direct or indirect damage resulting from improper or unlawful use of personal data by a third party.

6.3. You must comply with safety regulations at all times, including by preventing any unauthorised access to your login and code. This means that you alone have full responsibility for the use made of the website from your computer, IP address and your identification details, as well as its confidentiality.

Article 7 – Third-party access

7.1. In order to be able to process your personal data, we give our employees access to your personal data.

7.2. We guarantee an identical level of protection by making contractual obligations with these employees and appointees, similar to this Privacy Policy.

Article 8 - Cookies

8.1. What are cookies?

A "cookie" is a small file sent by BRANGEL’s server and placed on your computer's hard drive. The information stored in these cookies can only be read by us and only during the period you visit the website.

8.2. Why do we use cookies?

Our website uses cookies and similar technologies to distinguish your usage preferences from those of other users on our website. This helps us to provide you with a better user experience when you visit our website and also allows us to optimise our website.

Following recent changes in legislation, all websites targeting certain parts of the European Union are now required to ask your consent for the use or storage of cookies and similar technologies on your computers or mobile devices. This cookie policy gives you clear and complete information about the cookies we use and their purpose.

8.3. Types of cookies:

Although there are different types of cookies, with a different functionality, origin or retention period, the legislation mainly distinguishes between cookies that are functional or required for technical reasons on the one hand, and all other cookies on the other.

The website only uses cookies linked to your login sessions with your account.

For cookies placed by third parties (e.g. Google Analytics) we refer you to the statements given by these parties on their respective websites. Please note that we have no control whatsoever over the content of these statements, nor on the content of these third-party cookies.

8.4. Your consent:

When you first visit our website you will be asked to accept our different types of cookies. You can accept or reject cookies category by category. You can change the cookie settings for our website at any time via the hyperlink at the bottom of our website and thus withdraw your consent.

You can refuse to install these cookies by choosing "Reject cookies" the first time you use the website in the relevant pop-up screen.

You can also reject or block cookies by changing the configuration parameters in your navigation system. Disabling cookies may mean that you cannot use certain functionalities of the website.

More information about cookies can also be found on: More information about online behavioural advertising and online privacy can be found here:

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