PRIVACY AND DATA PROTECTION POLICY
Company: PolarModa
Version: 1.1
Effective Date: 26.02.2026
1. GENERAL PROVISIONS AND IDENTIFICATION
This Privacy Policy (the “Policy”) outlines how PolarModa (“the Company,” “we,” “us,” or “our”) collects, processes, and protects personal data in its capacity as a Data Controller.
This Policy is drafted in strict compliance with:
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Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR).
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The Bulgarian Personal Data Protection Act (ЗЗЛД).
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The relevant ordinances of the Commission for Personal Data Protection (CPDP).
Data Controller Information:
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Legal Entity: PolarModa OOD
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UIC (EIK): 175422714
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Registered Office: БЪЛГАРИЯ, гр. София (1799), р-н Младост, жк. Младост 2, ул.Свети Киприян, бл. 280А, вх. 2, ет. 1, ап. 1
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Representative: Vasil Yordanov
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Email: info@polarmoda.bg
2. DATA COLLECTION: CATEGORIES AND SOURCES
While PolarModa operates primarily as a wholesale landing page, we collect data through two primary channels: Direct Interactions (Forms) and Automated Technologies (Cookies/Logs).
A. Information You Provide (Intake Forms)
When you navigate to our two ClickUp-powered intake forms, we collect:
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Identity Data: Full name, job title, and company position.
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Business/Contact Data: Registered business name, VAT number (EIK), business address, email address, and telephone number.
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Inquiry Data: Specific requirements, wholesale volume interests, and any free-text information provided in the “Message” or “Notes” section of the intake form.
B. Technical and Usage Data
When you visit the landing page, we may automatically collect:
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Log Data: IP address (masked/anonymized where possible), browser type, time zone settings, and operating system.
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Interaction Data: How you reached our site (referral URL) and which intake form you clicked.
3. PURPOSES AND LEGAL GROUNDS FOR PROCESSING
We do not process data “just because.” Every action has a legal justification under Article 6 of the GDPR:
| Purpose of Processing | Category of Data | Legal Basis |
| Lead Management: Responding to wholesale inquiries via intake forms. | Contact, Identity, Inquiry | Art. 6(1)(b): Steps taken at the request of the data subject prior to entering into a contract. |
| System Integration: Transferring form data into our ClickUp task management system. | All provided data | Art. 6(1)(f): Our legitimate interest in organized, efficient business operations. |
| Site Security: Protecting our landing page from DDoS attacks or bot spam. | Technical Data (IP) | Art. 6(1)(f): Legitimate interest in maintaining IT security. |
| Legal Compliance: Maintaining records for Bulgarian tax/customs audits. | Transactional/Identity | Art. 6(1)(c): Compliance with a legal obligation (Bulgarian Accountancy Act). |
4. THE ROLE OF CLICKUP (DATA PROCESSOR)
Our intake forms are hosted by ClickUp (Mango Technologies, Inc.).
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The Flow: When you click “Submit,” your data is transmitted directly to ClickUp’s cloud environment.
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Security: ClickUp maintains SOC 2 Type II compliance and uses encryption (AES-256) for data at rest.
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Data Transfer: As ClickUp is a US-based provider, we ensure that Standard Contractual Clauses (SCCs) are in place to provide the same level of protection as required within the EU.
5. DATA RETENTION PERIODS
We adhere to the principle of “storage limitation.”
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Unsuccessful Leads: If an inquiry does not result in a wholesale partnership, we delete the data within 12 months of the last communication.
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Active Business Partners: Data is kept for the duration of the commercial relationship.
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Tax/Audit Records: Under Bulgarian law, documents related to commercial transactions must be kept for 10 years.
6. DISCLOSURE TO THIRD PARTIES
PolarModa does not sell, rent, or trade your personal data. We only share data with:
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IT/SaaS Providers: ClickUp (Task Management), Google Workspace (Email), and our Web Hosting provider.
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Public Authorities: Only when mandated by Bulgarian law (e.g., NRA/NAP, Customs).
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Logistics Partners: If a sample or order is requested, your contact data is shared with couriers (e.g., Econt, Speedy, DHL).
7. DATA SECURITY MEASURES
We have implemented technical and organizational measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way:
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SSL/TLS Encryption: All traffic to and from the PolarModa landing page and ClickUp forms is encrypted.
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Access Control: Access to our internal ClickUp workspace is restricted via Two-Factor Authentication (2FA).
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Anonymization: Technical logs are periodically scrubbed of identifying information.
8. YOUR STATUTORY RIGHTS
Under GDPR and Bulgarian law, you possess the following rights:
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Right to Information: To know exactly what we are doing with your data (this policy).
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Right of Access: To request a copy of the data we hold about you.
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Right to Rectification: To have us correct any inaccurate or incomplete data.
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Right to Erasure: To ask us to delete your data when it is no longer needed.
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Right to Object: To object to processing based on “legitimate interest” if you feel it impacts your fundamental rights.
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Right to Data Portability: To receive your data in a structured, machine-readable format.
To exercise these rights, please contact our Data Protection Coordinator at info@polarmoda.bg. We will respond within 30 days.
9. COMPLAINTS TO THE REGULATOR
If you are dissatisfied with our response, you have the right to contact the Bulgarian Supervisory Authority:
Commission for Personal Data Protection (CPDP / КЗЛД)
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Address: 2 Prof. Tsvetan Lazarov Blvd., Sofia 1592, Bulgaria
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Email: kzld@cpdp.bg
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Website: www.cpdp.bg
10. AMENDMENTS
PolarModa reserves the right to update this Policy as our business tools evolve. Any changes will be posted on this page with an updated “Effective Date.”