This document discloses the Privacy Policy collected by users of the Site at (URL)

The site is owned by LUMINESENS Ltd.

This Privacy Policy aims to inform you about how the owner of treats your personal data as an administrator, as well as how you can control your preferences and settings in connection with this treatment.

This Privacy Policy is designed to help you understand your privacy choices when you visit our site, access our mobile application, or use our services. It does not apply to other websites or services that we do not control, including websites or services of other users of the Provider.

Please read this Privacy and Privacy Policy carefully before accessing the Site and
its services. If you do not agree to any of the terms, you should not visit the Site and do not use in any way the services it offers.

This Privacy Policy is an integral part of the General Terms of Use of the Site. All
definitions given in the General Terms and Conditions are also applicable in this
Privacy Policy. This Privacy Policy is effective as of 01.11.2023.


  1. Name: LUMINESENS Ltd., commercial company registered, according to the
    legislation of the Republic of Bulgaria, with UIC: 207354911;
  2. Official email for communication with clients:
    [email protected]
    Commission for Personal Data Protection
    Address: Bulgaria, Sofia, Prof. Tsvetan Lazarov ”2
    Contact details: 02/915 35 18; 02/915 35 19; [email protected]
    In this regard, the owner is an Administrator of personal data.
    The Administrator collects and processes all personal data in accordance with the data protection laws applicable in Bulgaria and the European Union.

When processing personal data, the Administrator observes the following principles:

  1. collects personal data only if there is a legal basis, processes them in good faith
    and in a transparent manner in relation to the data subject - principle of legality, good faith and transparency;
  2. collects personal data for specific, explicitly indicated and legitimate purposes and does not process these personal data in a way that is incompatible with the original purposes - principle of limitation of purposes;
  3. processes only such volume and type of personal data related to and limited to
    what is necessary in relation to the purposes for which they are processed -
    principle of minimization of personal data;
  4. keep personal data accurate and up-to-date - principle of accuracy;
  5. store the personal data in a form that allows the identification of the data subject for a period no longer than is necessary for the purposes for which the personal data are processed - principle of storage limitation;
  6. complies with the principles of data protection by design and data protection by default, taking into account the achievements of technical progress, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks arising from the processing with varying probability and burden on the rights and freedom of individuals, and introduces appropriate measures to protect personal data and achieve compliance with Regulation (EU) 2016/679.
  7. guarantees an appropriate level of personal data security, including protection
    against unauthorized or illegal processing and against accidental loss, destruction or damage, by applying appropriate technical or organizational measures - principle of integrity and confidentiality.

The administrator collects and processes your personal data based on the following grounds:
• Explicit consent received from you as a customer/user. The consent obtained for
the processing of personal data is voluntary and is given on a case-by-case basis.
The consent you have given to the processing of personal data can be withdrawn at
any time by sending a request in free text to withdraw consent by email to the
Administrator. The withdrawn consent is effective going forward, as it does not affect the lawfulness of the processing of the personal data known to you before the request for withdrawal of consent was submitted;
• Processing is necessary for the performance of the contract to which the data
subject is a party, or to take steps at the request of the data subject prior to the
conclusion of the contract;
• The processing is necessary for compliance with a legal obligation of the Company;
• The processing is necessary for the purposes of the legitimate interests of the
Administrator or the third party.


  1. The Administrator shall not collect or store "sensitive" categories of personal data such as political beliefs, ethnic origin, sexual orientation, data on the subject's health, religious or philosophical beliefs, etc. If the Administrator receives "sensitive data", he undertakes to delete it immediately. Please do not send such data to the Administrator.
  2. Personal data collected by the data subject when the persons contact the
    Administrator through the contact form on the site.
    When the person sends a message to the Administrator using email, the
    Administrator collects and stores the person's name, e-mail address, and the
    information provided in the message. The administrator collects and stores the
    specified information for the purposes of communication with the individual.
    Purpose for which the data is collected: The administrator collects and stores the
    specified information for the purposes of communication with the individual.
  3. Personal data collected automatically.
    The data collected automatically may include information such as your device's
    Internet Protocol (IP address) address, browser type, browser version, pages of our service you are visiting, time and date of your visit, time spent on these pages, unique device identifiers and other diagnostic data. We may also collect information that your browser sends when you visit our Service or when you access the Service from or through a mobile device. Purpose for which the data is collected: Improving the security of the services provided by the Provider and preventing misuse of the user account by third parties.
  4. Personal data collected from consumers when paying for a subscription:
    • name and surname;
    • email;
    • address;
    • phone;
    • Payment data such as IBAN, SWIFT code, user's bank account number and similar, Payment date, Payment amount; Place of payment; Method of payment (by bank transfer), etc. Purpose for which data is collected: to fulfill obligations under a service contract, for tax and accounting purposes, to confirm your identity, to provide support such as debugging, troubleshooting, automated decision-making such as fraudulent detection create an account when registering for our service, for advertising and marketing, billing, to resolve incidents related to the use of our website and services, to improve and personalize our services.
  5. Personal data collected during registration for receiving a newsletter:
  • name;
  • email.

Most web browsers are set to accept cookies by default. If you prefer, you can
usually choose to set your browser to remove cookies and reject cookies. If you
choose to remove cookies or decline cookies, this may affect certain features or
services on our sites. You can learn more about how the Administrator uses cookies
by reading the Cookie Policy.

The Administrator collects and processes the personal data of individuals, which are provided directly by them or are collected automatically only for the following
• For the normal functioning of all services on the Site;
• To make contact with the person;
• To provide services offered on the Site;
• For the fulfillment of the rights and obligations of the parties under the concluded agreement;
• To improve the efficiency and functionality of the Site;
• For accounting purposes;
• For statistical purposes and analyzes to improve our services;
• To protect information security;
• To send a newsletter if you wish;
• To make sure our customers are real and prevent fraud;
We also use your data:
• To send you administrative information (for business, legal and/or possibly
contractual purposes). We may use your personal information to send you
information about products, services and new features and/or information about
changes to our terms and policies.
• To communicate with you (for our business purposes and/or with your consent). We may use your information to solicit feedback and contact you about your use of our site.

• For other business purposes. We may use your information for other business
purposes, such as analyzing data, identifying usage trends, determining the
effectiveness of our promotional campaigns, and to evaluate and improve our sites,
products, services, marketing, and your experience.
If the purposes change, we will inform you and ask for your express consent to
process your personal data in accordance with the new purposes.

We use and store your personal data for and as long as necessary for the purpose
for which it was provided, including all purposes set out in this Privacy Policy (e.g. for services, products or interactions you have requested or initiated; to communicate with you; for billing, advertising and marketing; to improve the user experience, such as troubleshooting, optimization and personalization; and to comply with legal, contractual and regulatory obligations). We may also use and store information for other purposes where you have consented, such as in response to a pricing or hiring inquiry, or where a legitimate business interest exists. We will not store your data for longer than is necessary to achieve the purposes for which we process it. If the reason on which we store your personal data ceases to exist (for example, if we cease to have a legitimate interest in storing your personal data, if the statutory period for storing your personal data has expired or if you have withdrawn your consent to store your personal data) we will delete or destroy them safely.
The storage of data continues as long as we have a reason for their storage.
We apply the following terms for storing the different types of personal data according to their purpose, namely:

  1. Regarding personal data of the persons who have made an inquiry, through the
    contact form on the Site:
  • up to 12 months from sending the request, if the user has not become a client of the
  1. Regarding personal data collected during registration for receiving a newsletter:
  • Until you want your registration to be deleted or while the site is active.
  1. Regarding the data in connection with the contractual relations between the
    Administrator and the User of the Site, they are stored for five years after the
    expiration of the limitation period for repayment of the public obligation to which they
    are related, unless the mandatory rules of law require the Provider to keep the data
    for your partners for a longer period (eg. for the categories of documents that we are
    obliged to keep according to the Accounting Act and / or the Tax and Social Security
    Procedure Code).


The Administrator has taken a wide range of technical and organizational measures to protect your personal data against loss or other forms of illegal processing. We maintain administrative, technical and physical security measures designed to provide reasonable protection of personal data against unauthorized access, disclosure, alteration, loss and misuse. Unfortunately, no method of Internet use, data transmission or electronic storage is completely secure, so we cannot guarantee the absolute security of personal data.

Although we are dedicated to protecting our website and services, you are
responsible for ensuring and maintaining the confidentiality of your passwords and account information. Access to personal data is limited to individually authorized and instructed staff. We will keep you informed at all times of changes in data protection and security processes, including practices and policies, through up-to-date information in this section.

You can request information at any time where and how your data is stored,
protected and used. In the event that your data is compromised, we will notify you and the competent supervisory authority within 72 hours by email with information on the extent of the breach, the data affected, any impact on the service and the action plan, measures to limit any possible harmful effects on data subjects. "Violation of personal data" means a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to personal data transmitted, stored or otherwise processed in connection with the provision of the Service. In case you want to receive detailed information about the technical and organizational measures, please do not hesitate to contact us.

We process and use only data that you have provided to us voluntarily, and we rely
on the fact that this data is owned and provided by you lawfully.
Therefore, each person bears unlimited personal liability if he provides us with data to a third party without his knowledge or without his consent in accordance with the requirements of applicable data protection law, regardless of the type of data or the reasons for which provide: names, phone, email address, and any other. MINORS We do not wish to collect or process data of minors or minors under the age of 18. If we become aware that we have collected personal data from/on a person under the age of 18, we will immediately delete it, unless we are legally required to retain such data.
Please contact us if you believe that we have mistakenly or unknowingly collected
information from/on a person under the age of 18.

The Administrator does not sell, trade or otherwise transfer to third parties any
personal information. This does not include trusted third parties or subcontractors who assist us in the operation of our website, the conduct of our business or your service. Such trusted parties may have access to personal information based on the need to know it and will be required by contract to keep your information.
Your personal data will not be transferred to third parties unless:
● provide us with your explicit, informed and freely given consent;
● the third parties in question provide us with contractual support in order to provide our products or services;
● this is required by law or by virtue of an act of authority of a public body;
● there is a justified need to protect the rights, property or security of the users of the Site or other defensible public interest;

  • for business transfers. We may share or transfer your personal information in
    connection with or during negotiations to merge, sell the Company's assets, finance or acquire all or part of our business to another company.
  • with partners. We may share your information with our affiliates, in which case we will require those affiliates to comply with this Privacy Policy. Partners include Our parent company and any other subsidiaries, partners in joint ventures or other companies that we control or that are under common control with Us.
  • With business partners. We may share your information with our business partners to offer you specific products, services or promotions.
  • With other users. When you share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly disseminated to the outside world. If you interact with other users or register through a third-party social media service, your third-party social media service contacts may see your name, profile, photos, and a description of your business. In the same way, other users will be able to view descriptions of your business, communicate with you, and view your profile.
    We need statistical information about the use of our website to make it more
    accessible, to measure reach and to do market research.
    For this purpose, we use the web analysis tools described in this section.
    Google Analytics
    Google Analytics is offered by GoogleInc., 1600 AmphitheaterParkway,
    MountainView, CA 94043, USA ("Google"). We use GoogleAnalytics with the
    additional function offered by Google to anonymize IP addresses. Google abbreviates the IP address already within the EU and only in exceptional cases in the USA, in both cases only abbreviated IP addresses are recorded.
    Our website uses the services provided by Google Analytics to analyze and regularly improve the use of our website. An analysis of your user activity on the site is carried out with the help of "cookies", which are stored on your computer, generate information about your user behavior and transmit it to Google. Under normal circumstances, a shortened version of your IP address is sent to Google's servers, but in exceptional cases the full IP address may also be sent. Google uses this information on our behalf to create a report on the user's activity on our website. The IP address identified by Google Analytics is not combined with other Google data.
    If you activate the anonymous mode on this website, your IP address will be
    intercepted in the member states of the European Union or in other countries that have signed the agreement on the European Economic Area. In exceptional cases, the full IP address may be transferred to a Google server in the USA and truncated there. Google uses this information on behalf of the operator of this website to analyze your use of the website, to compile reports on website activities and to provide other services for the website operator in connection with the use of the website and the Internet.
    You can refuse the use of cookies by selecting the appropriate settings on your
    browser, but please note that if you do this, you may not be able to use the full
    functionality of this website Terms of use for users:,
    The data privacy statement:
    Facebook pixel to create custom audiences.
    If a user clicks on an ad placed by us that plays on Facebook, the URL of our linked page will be added by the Facebook Pixel. If our site allows data sharing with Facebook via pixels, this URL parameter is saved in the user's browser via a cookie that our linked site sets itself. This cookie is then read by the Facebook Pixel and allows the data to be forwarded to Facebook.
    Accordingly, we only use the Facebook pixel to display the Facebook advertisements placed by us to Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products that are based on the visited websites) that we transmit to Facebook (so-called "Custom Audiences"). The collected data is anonymous to us, so it does not allow us to draw any conclusions about the user's identity. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with Facebook's data usage guidelines ( The data may allow Facebook and its partners to place advertisements on and off
    Facebook. Data processing related to the use of the Facebook pixel is carried out on the basis of our primarily legitimate interest in the evaluation, optimization and economic functioning of our online offer as well as our advertising measures in accordance with
    Article 6 (1) GDPR.

The website may contain buttons, tools or content that connect to other companies, such as Facebook, Instagram, Viber and others. The administrator assumes no responsibility for damages and losses incurred as a result of the use of these sites. Individuals are solely responsible for their use of these sites and should read their Privacy Policy.

Sometimes, at our discretion, we may include or offer third party products or services on our website. These third-party sites have separate independent privacy policies. Therefore, we are not responsible or liable for the content and activities of these linked websites. However, we strive to protect the integrity of our website and welcome any feedback on these websites.

Right of access to your personal data
. You have the right to request and receive confirmation from the Administrator as to whether personal data relating to you is being processed by sending a request in free text by e-mail.
Right to rectification of personal data: if you find that the personal data we
process about you is inaccurate, you have the right to have us correct that personal
data. You may at any time correct or complete inaccurate or incomplete personal
data relating to you by sending a request to the Administrator by email in free text.
Right to erasure of personal data (the right to be “forgotten”)
You have the right to request from the Administrator the deletion of part or all of your personal data, and the Administrator has the obligation to delete them without undue delay when any of the following grounds are present:
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 data processing is based and there is no
other legal basis for the processing;
• You object to the processing of your personal data and there are no overriding legal grounds for the processing;
• personal data were processed illegally;
• personal data must be deleted in order to comply with a legal obligation under EU law or the law of a Member State that applies to the Administrator;

The administrator is not obliged to delete the personal data if it stores and processes them:
• to exercise the right to freedom of expression and the right to information;
• to comply with a legal obligation that requires processing provided for in EU law or Member State law that applies to the Administrator or for the performance of a task in the public interest or in the exercise of official powers granted to him;
• for reasons of public interest in the field of public health;
• for the purposes of archiving in the public interest, for scientific or historical
research or for statistical purposes;
• for the establishment, exercise or defense of legal claims.
In order to exercise your right to be forgotten, it is necessary to send by email a
request for the deletion of your personal data that the Administrator processes
through a free text request.

Right to restriction of processing: in certain circumstances, such as if you doubt the accuracy of your personal data or you have objected to our legitimate purpose for processing your personal data, you have the right to request that we restrict the processing of your personal data until a solution is found. You have the right to request the Administrator to restrict the processing of data related to you by sending us a free text request by email when:
• dispute the accuracy of the personal data, for a period that allows the Administrator to verify the accuracy of the personal data;
• the processing is illegal, but you do not want the personal data to be deleted, but
only to have its use restricted;
• The administrator no longer needs the personal data for the purposes of
processing, but you require them to establish, exercise or defend your legal claims;
• You have objected to the processing pending verification of whether the legal
grounds of the Administrator take precedence over your interests.

Right to data portability. If you have consented to the processing of your personal data or the processing is necessary for the performance of the contract with the Administrator, or if your data is processed in an automated manner, you can:
• to ask the Administrator to provide you with your personal data in a readable format and to transfer them to another Administrator;
• to ask the Administrator to directly transfer your personal data to an administrator specified by you, when this is technically feasible.
Right to lodge a complaint with a supervisory authority: you have the right to lodge a complaint regarding the processing of your personal data by us with the relevant supervisory authority.

The data subject also has the right not to be subject to a decision based solely on automated processing, including profiling, which gives rise to legal
consequences for the data subject or similarly significantly affects him;
Right to judicial or administrative protection in the event that the data subject's rights have been violated.

Changes to our Privacy Policy
If we decide to change our Privacy Policy, we will post those changes on this page
and / or update the date of the Privacy Policy change below.

You can exercise all rights by contacting us by email:
[email protected]. We will contact you and introduce you in detail to
the procedure for exercising your rights.